Spelinspektionen fines ImpactWin Partner for telephone sales rule breach

The Swedish gambling regulator Spelinspektionen has issued a formal warning and financial penalty against ImpactWin Partner Ltd after determining that the company’s procedures for telephone sales did not comply with legal requirements under the Swedish Gambling Act. The regulator concluded that the operator failed to follow specific rules governing how gambling contracts must be concluded when consumers are contacted by phone.

The enforcement action includes a fine of SEK 400,000, equivalent to approximately €37,500. The decision concerns ImpactWin Partner Ltd, which operates several gambling related brands including ImpactWin, Lotto Experten and Superlottoclub.

According to the regulator, the company’s method of confirming gaming subscriptions and consumer approvals after telephone contact did not meet the legal standards required for distance gambling agreements in Sweden. As a result the authority determined that the operator had violated provisions contained in Chapter 14 Section 19 of the Swedish Gambling Act.

Regulatory oversight of gambling marketing and contracts

Sweden maintains a structured regulatory framework for gambling services that focuses on consumer protection, responsible marketing practices and transparency in contractual agreements. Spelinspektionen serves as the national authority responsible for supervising licensed operators and ensuring that companies offering gambling services follow the law.

The Swedish Gambling Act contains detailed provisions on how gambling operators may interact with consumers. This includes specific requirements for distance contracts, which are agreements concluded without physical presence between the company and the consumer. Telephone marketing of gambling services falls under these rules.

When a gambling operator contacts a consumer by phone with the intention of concluding a gambling contract the law requires that the offer be confirmed in a clear and durable format that the consumer can access. This confirmation must be legible and must allow the consumer to review the terms of the offer before accepting it.

The contract is considered valid only after the consumer accepts the offer in writing following the telephone conversation.

Regulators emphasize that these procedures exist to ensure that consumers fully understand the services they are agreeing to and that they have time to review the conditions without pressure during a phone call.

Details of the enforcement decision

Spelinspektionen’s investigation found that ImpactWin Partner Ltd had confirmed subscriptions and consumer approvals in a manner that did not satisfy these requirements.

The regulator stated that the company contacted consumers by telephone and subsequently confirmed agreements through procedures that did not provide the type of written confirmation required by law. Because the process did not meet the standard of a durable and accessible written confirmation prior to the consumer’s acceptance the regulator determined that the contracts were not concluded according to the rules.

As a result the authority issued a warning alongside a financial sanction.

ImpactWin Partner Ltd was previously known as More Tech Group Ltd. The regulator’s decision notes that the company holds a licence to operate in Sweden and therefore must comply with the full set of obligations established under Swedish gambling legislation.

Regulatory actions such as warnings and administrative fines are part of Spelinspektionen’s enforcement framework. These measures are intended to encourage compliance and ensure that licensed operators follow consumer protection standards.

Importance of written confirmation in distance gambling contracts

Distance selling rules play an important role in consumer protection across many regulated industries including gambling. Swedish legislation requires that consumers receive clear documentation before they are bound by a contract that has been discussed by telephone.

In the context of gambling services the law places particular emphasis on transparency. Operators must provide information about the service being offered along with relevant terms and conditions.

Written confirmation allows the consumer to examine these details after the phone conversation. It also provides a record of the agreement and the terms that were presented.

Authorities consider these safeguards essential because telephone marketing can involve complex offers that may be difficult for consumers to fully evaluate during a call.

By requiring written acceptance the law ensures that consumers have an opportunity to reflect on the offer before committing to a subscription or gambling service.

Administrative Court supports orders against illegal gambling advertising

In a separate development related to Sweden’s gambling regulatory environment two companies have lost their appeals against enforcement orders issued by Spelinspektionen.

The Administrative Court ruled that the regulator had legal grounds to order both Sinovum Media AB and Flashback Media Group AB to stop marketing gambling services that did not hold a Swedish licence.

Spelinspektionen issued these orders in late 2025. The authority determined that advertising appearing on two websites promoted gambling platforms that were not licensed to operate in Sweden.

The advertising involved banner placements on the websites synonymer.se and flashback.org.

According to the regulator the banners directed users to websites offering gambling services without a Swedish licence. Swedish law prohibits the promotion of such services to consumers within the country.

Court findings on marketing of unlicensed gambling

The Administrative Court reviewed the regulator’s orders and ultimately concluded that Spelinspektionen had sufficient grounds for its enforcement actions.

The court found that both Sinovum Media AB and Flashback Media Group AB had promoted illegal gambling through the advertising displayed on their websites.

As a result the court upheld the injunctions requiring the companies to cease the marketing activities.

The ruling confirms the authority’s ability to intervene when websites or media companies promote gambling services that operate outside the Swedish licensing system.

Regulators in Sweden have consistently stated that the licensed market framework depends on ensuring that consumers are directed toward operators that follow Swedish law.

Marketing channels that promote unlicensed platforms are therefore considered a potential risk to the integrity of the regulated market.

Sweden’s broader approach to gambling compliance

The recent enforcement actions highlight the active role played by Swedish authorities in supervising the gambling sector.

Since the introduction of Sweden’s modern gambling licensing system the regulator has pursued a strategy that combines licensing oversight with enforcement measures against companies that fail to comply with regulatory obligations.

This includes actions against operators whose marketing practices breach consumer protection rules as well as interventions targeting the promotion of unlicensed gambling services.

Spelinspektionen regularly reviews marketing practices used by operators and affiliates to ensure they align with the legal framework.

Companies that operate within the Swedish market are expected to maintain procedures that comply with both advertising regulations and consumer protection requirements for contracts and communications.

Industry observers note that enforcement decisions such as the fine issued to ImpactWin Partner Ltd serve as reminders to operators that compliance with procedural requirements is an essential part of maintaining a gambling licence.

Compliance expectations for licensed operators

Licensed gambling operators in Sweden must implement systems that ensure all customer interactions comply with the law. This includes internal procedures governing marketing activities, contract formation and customer communication.

Telephone marketing can be a sensitive area because of the potential for misunderstandings or incomplete information during calls.

Regulators therefore expect operators to follow strict protocols when contacting consumers. Written confirmation, transparent contract terms and documented acceptance procedures form part of these compliance standards.

Companies that fail to follow these procedures may face regulatory scrutiny and potential sanctions.

For operators active in Sweden maintaining robust compliance systems is therefore a key element of their business operations.

Conclusion

The enforcement actions taken by Spelinspektionen illustrate the regulator’s continued commitment to enforcing the standards established by the Swedish Gambling Act. The warning and SEK 400,000 fine issued to ImpactWin Partner Ltd highlight the importance of following precise legal procedures when concluding gambling contracts through telephone sales.

Swedish law requires that consumers receive written confirmation of offers and that contracts be accepted in writing after a phone call. These requirements are designed to protect consumers by ensuring transparency and giving them the opportunity to review agreements carefully.

At the same time the Administrative Court’s decision regarding Sinovum Media AB and Flashback Media Group AB reinforces the regulatory stance against the promotion of unlicensed gambling services.

Together these developments underline a broader message within Sweden’s regulated gambling market. Operators, affiliates and media platforms are expected to adhere strictly to the legal framework that governs marketing practices and contractual agreements. Authorities have indicated that they will continue to monitor compliance and take action when necessary to protect consumers and maintain the integrity of the licensed market.

FAQs

What action did Spelinspektionen take against ImpactWin Partner Ltd?
Spelinspektionen issued a formal warning and imposed a fine of SEK 400,000 after determining that the company’s telephone sales procedures did not comply with Swedish gambling law.

Why was ImpactWin Partner Ltd fined by the regulator?
The regulator concluded that the company did not properly confirm gambling contracts in a durable written format before consumers accepted them.

What brands are operated by ImpactWin Partner Ltd?
The company operates several brands including ImpactWin, Lotto Experten and Superlottoclub.

What rule under the Swedish Gambling Act was involved in the case?
The decision concerns provisions in Chapter 14 Section 19 of the Swedish Gambling Act which regulates how gambling contracts may be concluded through telephone sales.

What is required when a gambling operator contacts a consumer by phone?
The operator must provide a clear written confirmation of the offer in a durable format that the consumer can review before accepting the agreement in writing.

Did the regulator take action against other companies?
Yes. Spelinspektionen also issued orders against Sinovum Media AB and Flashback Media Group AB related to the marketing of unlicensed gambling services.

What did the Administrative Court decide in the appeal cases?
The court upheld the regulator’s orders and ruled that the companies had promoted illegal gambling through online advertising.

Why is advertising for unlicensed gambling restricted in Sweden?
Swedish law aims to ensure that consumers engage with licensed operators that comply with national regulations and consumer protection standards.

What role does Spelinspektionen play in the gambling market?
Spelinspektionen supervises licensed operators and enforces Swedish gambling laws to ensure consumer protection and market integrity.

How can operators avoid similar regulatory penalties?
Operators can avoid penalties by implementing clear compliance procedures that ensure all marketing activities and contract agreements follow the requirements of Swedish gambling legislation.