Regulated
The Swedish Gambling Act (2018:1138) allows any gambling operator satisfying the suitability criteria set out in the Gambling Act to apply for and be granted licences to offer online commercial gambling and/or betting to Swedish consumers.

Included in the product scope for online commercial gambling is online bingo, online casino (including roulette, baccarat, punto banco, blackjack, poker and dice games) and computer simulated gambling machines (slots). Betting, both online and land-based betting, are included in the licence scope.

Changes to the Gambling Act mean that as from 1 July 2023, B2B operators manufacturing, amending, installing or supplying gambling software to Swedish B2C online licence holders also require a software permit.

Land-based bingo, casino, lottery, poker, skilled games are – with few exceptions – reserved for the state monopoly and/or charity organisations.

For gambling operations, the relevant regulator is the Swedish Gambling Authority (SGA). Within gambling, the SGA is also the regulatory authority when it comes to compliance with AML-legislation.

Market size
In 2023, the total net turnover for the gambling market amounted to SEK 27,1400 billion (approximately EUR 2,402 billion), of which online commercial gambling and betting represented a total of SEK 17,031 billion (approximately EUR 1,510 billion).

Competitive landscape
As of 18th March 2024, 57 companies held licences to offer commercial online gambling and 45 companies held licences to offer betting to Swedish consumers. 181 companies hold B2B software permits.

Furthermore, 14 companies held licences to offer casino products in amusement parks, hotels or restaurants, 4 to offer land-based goods gambling machines, 2 to offer land-based card games, 2 to offer gambling on ships in international traffic.

Statistics from the Tax Agency on the reported Net Revenue and Gross Gaming Revenue shows that the market is dominated by a few major companies and that the ten biggest licenced operators represents 75% of the turnover in the market.

Localisation
Main payment method used is direct debit and cards. Some online licence holders offer so called Pay N Play which means that players use bank login both to verify their identity and deposit. Some of the bigger online licence holders have been able to open Swedish bank accounts, which means they are able to offer the mobile payment method Swish, enabling players to deposit and withdraw with their mobile phones and phone numbers. Due to the supposed AML risk connected with gambling, banks are however generally unwilling to service the industry meaning this payment method is not available to a majority of operators.

Marketing shall be made in moderation and generally in accordance with the Marketing Act and Gambling Act but there are no limitations in terms of marketing channels.

Top Key Attractions and Challenges
Attractions

• Relatively competitive product scope
• Relatively easy market entry (licence process is not too onerous)
• Acceptable tax rate at 22% (as from 1st July 2024) on Gross Gaming Revenue
• No local presence required (the licence holder’s gambling system shall be placed in Sweden but exemptions are normally granted)
• No limit on number of issued licences

Challenges

• Market concentrated to top 5 online licence holders
• Big leakage to unlicensed market (the SGA calculates that SEK2.400M was spent with operators without a Swedish licence in 2021)
• Only welcome bonus (no retention bonus) permitted
• Harsh sanctions from the SGA in case of violations
• Unequal access of popular payment methods