BOS calls for balanced Swedish gambling reform

The Swedish Trade Association for Online Gambling (BOS) has released a detailed comparative report examining how Sweden and Denmark regulate their gambling markets. Conducted by the independent law firm Nordic Legal, the study provides an in-depth analysis of both countries’ approaches to regulation, compliance, and consumer protection. It also includes 19 policy recommendations directed at the Swedish government and the Swedish Gambling Authority (SGA).

According to the findings, Denmark’s regulatory framework has historically achieved greater success in fulfilling national gambling policy objectives. The report emphasizes that Denmark has maintained a higher and more stable level of channelisation—the proportion of gambling conducted through licensed operators—than Sweden. However, it warns that even Denmark’s market stability faces emerging challenges due to evolving consumer behaviour and technological developments.

Understanding the purpose of the study

The BOS-commissioned study aims to evaluate how well Sweden’s gambling regulation meets its intended goals, particularly regarding market channelisation, responsible gambling, and effective supervision. Since Sweden re-regulated its gambling market in 2019, policymakers have sought to achieve a 90 percent channelisation target, meaning that the vast majority of gambling should occur through licensed operators rather than unlicensed or offshore platforms.

However, the report concludes that Sweden is unlikely to meet this ambitious target under its current framework. Nordic Legal’s analysis suggests that only a major reform—addressing both regulatory culture and market competitiveness—could enable Sweden to significantly improve its channelisation rate.

The report’s recommendations therefore serve as a roadmap for reform, offering practical and cultural lessons from Denmark’s more collaborative regulatory model.

Channelisation as a key performance indicator

The concept of channelisation is central to the study. It measures how effectively a country directs its gambling activity into the licensed market. A high level of channelisation indicates that players are choosing legal, regulated operators—ensuring stronger consumer protection, fair taxation, and reduced risks of problem gambling.

The report stresses that channelisation must remain a critical benchmark of a well-functioning gambling market. It rejects the notion, increasingly discussed among some Swedish policymakers, that channelisation should be downplayed due to difficulties in meeting high targets. According to the authors, doing so would undermine the very objectives of regulation: ensuring player safety, promoting responsible gaming, and keeping gambling revenues within a controlled environment.

Denmark’s success and Sweden’s challenges

The comparative study finds that Denmark’s approach to gambling regulation has been more effective and flexible. Denmark liberalised its gambling market earlier than Sweden, implementing a framework that balances control with commercial viability. The Danish Gambling Authority maintains an open dialogue with licensed operators, encouraging compliance through education and gradual enforcement rather than punitive measures.

By contrast, the report suggests that Sweden’s regulatory environment has developed a punitive culture. Licensees interviewed for the report described the SGA’s approach as characterized by “a culture of fear”, with enforcement actions often perceived as severe and immediate rather than proportionate.

In Denmark, regulators typically use an escalation ladder—a step-by-step system of corrective measures—when dealing with rule violations. This system encourages cooperation and improvement before resorting to harsher sanctions. Sweden, according to the study, tends to apply the strictest penalties upfront, creating an atmosphere of uncertainty and apprehension among licensed operators.

The importance of attractive legal offerings

A key finding of the BOS report is that restrictive regulations alone cannot achieve higher channelisation. The authors argue that repressive measures such as ISP or payment blocking will not drive players toward licensed operators if the legal market fails to provide competitive and appealing products.

Instead, the study recommends making the licensed market more attractive by revising some of Sweden’s rigid regulations, particularly those concerning bonuses and loyalty programs. According to the authors, allowing a moderate degree of flexibility in such areas could make licensed operators more competitive with unlicensed counterparts, thereby improving channelisation without compromising player protection.

This reasoning reflects Denmark’s experience, where balance—rather than restriction—has proven more effective in guiding consumers toward regulated options.

Regulatory culture and policymaker attitudes

Beyond specific rules, the report highlights the stark contrast in regulatory culture between Sweden and Denmark. Denmark’s gambling authority is portrayed as dialogue-driven, fostering constructive relationships with licensees. This collaborative approach helps ensure compliance while supporting industry growth within legal boundaries.

Sweden, on the other hand, is perceived by stakeholders as operating within a more punitive and fear-based environment, where communication between operators and regulators is limited. According to the study, this adversarial dynamic discourages transparency and innovation.

Gustaf Hoffstedt, Secretary General of BOS, commented on this cultural divide, stating:

“We hope that the report will be a useful tool and encourage Sweden to find inspiration in several of the measures and approaches that have been so successfully implemented in Denmark. Some of them are strictly rule-based, such as how loyalty programs are regulated. Some are more difficult to approach and of a cultural nature, but just as important, and are connected to the policymaker’s attitude to the industry it is supervising.”

Lessons from Denmark’s dialogue-oriented model

The report identifies several specific mechanisms within Denmark’s system that could serve as models for Sweden. These include:

• Progressive enforcement: Regulators in Denmark prioritize guidance and correction before imposing penalties.
• Constructive dialogue: Ongoing communication between the regulator and licensees builds mutual trust and reduces compliance risks.
• Proportionate penalties: Sanctions are scaled according to the severity and frequency of violations.
• Balanced promotional rules: Operators can offer moderate bonuses and loyalty incentives under clear consumer protection rules.
• Transparent monitoring: Data-sharing mechanisms promote accountability without stifling innovation.

These elements collectively help Denmark maintain a more sustainable gambling market with high consumer trust and strong regulatory oversight.

Recommendations for Sweden’s reform

Nordic Legal’s report puts forward 19 recommendations for improving Sweden’s gambling regulation. While the full list is not disclosed in the summary, key proposals include:

• Revising bonus and loyalty program restrictions to align with consumer preferences and competitive realities.
• Enhancing collaboration and communication between SGA and licensees.
• Implementing proportional sanctions to replace automatic severe penalties.
• Developing a transparent framework for continuous dialogue between policymakers and industry stakeholders.
• Maintaining channelisation as a central measure of market health and consumer protection.

By adopting these reforms, Sweden could move closer to achieving its channelisation target while maintaining robust safeguards against gambling-related harm.

BOS calls for balanced regulation

The BOS emphasizes that the ultimate goal of reform should be to strengthen the licensed market rather than punish it. A thriving regulated market protects players, ensures tax revenues, and minimizes illegal gambling activities.

In his concluding remarks, Gustaf Hoffstedt expressed optimism that policymakers will heed the report’s findings:

“Hopefully, this report can inspire policymakers in Sweden to choose the path of regulation that strengthens the licensed gambling market and as a consequence strengthen consumer protection, as neighbouring Denmark has successfully proven is possible.”

Hoffstedt’s statement underscores BOS’s commitment to constructive reform—seeking to build a Swedish gambling landscape that is fair, competitive, and consumer-focused.

The broader implications for Europe

The study’s findings extend beyond Sweden and Denmark. As many European countries continue to revise their gambling laws, the balance between consumer protection and market competitiveness remains a universal challenge.

Denmark’s success story demonstrates that responsible regulation and commercial flexibility can coexist. For Sweden, embracing a more cooperative regulatory culture could help attract more players to the legal market while maintaining high ethical standards.

Ultimately, the BOS report contributes to an ongoing European dialogue about how to regulate gambling effectively in an increasingly digital age—where borders blur, competition intensifies, and consumer expectations evolve.

Conclusion

The BOS-commissioned study presents a compelling case for reforming Sweden’s gambling regulations by drawing inspiration from Denmark’s more balanced and collaborative approach. Through its detailed comparative analysis, the report underscores that effective gambling regulation depends not solely on enforcement but on cultivating trust, dialogue, and fairness between regulators and operators.

Denmark’s success demonstrates that a regulatory model grounded in cooperation, proportionality, and commercial realism can achieve higher levels of compliance and consumer protection. In contrast, Sweden’s current framework, marked by stringent restrictions and a punitive enforcement culture, risks driving players toward unlicensed operators—undermining both state objectives and consumer safety.

The recommendations outlined by Nordic Legal and BOS provide a constructive roadmap toward a more sustainable and transparent gambling environment in Sweden. By embracing reform, policymakers have the opportunity to enhance market competitiveness, restore trust among operators, and ultimately protect players through a robust, well-regulated system.

In an increasingly interconnected and digitalized gambling landscape, Sweden’s willingness to evolve will determine its ability to maintain a safe, attractive, and responsible market. As Gustaf Hoffstedt aptly stated, the path forward lies not in repression, but in regulation that empowers the licensed market to thrive while upholding the highest standards of consumer protection.

FAQs

What is the main finding of the BOS report?
The report concludes that Denmark’s gambling regulation has been more successful in achieving its policy goals compared to Sweden, particularly in maintaining higher channelisation rates.

What does channelisation mean in gambling regulation?
Channelisation refers to the proportion of gambling activity conducted through licensed, legal operators as opposed to unlicensed or offshore sites.

Why is Sweden struggling to reach its 90 percent channelisation goal?
The report attributes Sweden’s struggle to overly restrictive regulations, limited operator flexibility, and a punitive regulatory culture that discourages innovation.

How does Denmark’s regulatory model differ from Sweden’s?
Denmark’s system emphasizes dialogue and progressive enforcement, while Sweden’s approach is perceived as more rigid and punitive.

Who conducted the comparative study?
The report was prepared by the independent law firm Nordic Legal on behalf of the Swedish Trade Association for Online Gambling (BOS).

What are some of the key recommendations in the report?
Recommendations include relaxing bonus restrictions, improving regulator-operator dialogue, and implementing proportionate sanctions.

Why is channelisation important for consumers?
High channelisation ensures that most gambling takes place in a regulated environment, which enhances consumer protection and reduces exposure to unregulated operators.

What is BOS’s role in Sweden’s gambling industry?
BOS represents licensed gambling operators in Sweden and advocates for fair, balanced, and responsible regulation.

Does the report suggest eliminating strict rules entirely?
No, it advocates balance—retaining strong consumer protections while allowing enough flexibility to make licensed operators competitive.

What outcome does BOS hope to achieve from this study?
BOS hopes the findings will inspire Swedish policymakers to adopt a regulatory approach that strengthens the licensed market and improves consumer safety.