Sweden’s Gambling Act is under scrutiny after industry experts highlighted legal loopholes that allow unlicensed gambling operators to continue targeting Swedish consumers.

The Swedish Online Gambling Trade Association (BOS) has urged the government to tighten regulations to prevent the growing presence of black-market gambling.

Swedish Gambling Act 2018

Under Chapter 3, Section 3 of the Gambling Act (2018:1138), all gambling operators offering services in Sweden must obtain a valid licence. The law applies to both domestic and international operators if they enable participation from Swedish residents.

However, as clarified in the Inquiry 2017/18:220, online gambling sites that do not specifically target Swedish players – meaning they do not use Swedish text, customer service, or transactions in SEK – are technically outside the scope of regulation. This allows offshore operators to offer gambling services to Swedish consumers while avoiding compliance with national laws.

BOS has warned that the current legal framework fails to prevent unlicensed gambling websites from reaching Swedish players. The decisive factor in determining whether a site falls under Swedish jurisdiction is whether it caters explicitly to the Swedish market through language or currency use. This means that gambling platforms operating in English and accepting payments in euros can legally bypass Swedish regulations.

Additionally, Chapters 18 and 19 of the Gambling Act, which deal with payment blocking and criminal liability, are considered ineffective. Authorities can only enforce payment blocks if a gambling operator is proven to be targeting Sweden directly, which leaves room for unlicensed platforms to process payments legally.

Calls for the Swedish Ministry of Finance to make changes

BOS has called on the Swedish Ministry of Finance to amend the law and criminalise all unlicensed gambling directed at Swedish consumers, irrespective of language or currency. BOS Secretary General Gustaf Hoffstedt stated:

“Unlicensed gambling should be eliminated in Sweden. It is completely inadequate that around a quarter of all gambling is unlicensed, not least given the total absence of consumer protection on the black gambling market.” (Cited by SBC News.)

To counter illegal gambling, BOS suggests that Sweden should follow Denmark’s example, where strong regulations and high enforcement rates have led to better control over the gambling market. The trade association argues that Sweden must either make licensed gambling more attractive by reducing restrictions or increase enforcement efforts to block unlicensed operators more effectively.

Swedish regulators have recently ramped up enforcement, banning operators such as Versus Odds BV and Cosmogames for offering gambling without a licence. In December 2024, four licensed operators: Snabbare, Hajper, ComeOn Sweden, and Casinostugan were fined SEK 59 million (€5.27 million) for unauthorised bonus offers, as reported by Gambling Insider.

The Swedish Gambling Authority (Spelinspektionen) has also launched an awareness campaign titled “Unnecessarily Exciting” to educate consumers about the risks of unlicensed gambling. However, industry experts believe that without legislative changes, Sweden will continue to struggle with black-market operators exploiting legal loopholes.

With an estimated 25 per cent of all gambling in Sweden taking place on unlicensed sites (SBC News), the government faces mounting pressure to amend the Gambling Act and ensure that at least 90 per cent of gambling occurs within the regulated market.

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