In the midst of a spring 2025 marked by promises of reform, Sweden is preparing to make sweeping changes to its legislation on online gambling. The proposed amendment aims to close the loopholes in the current regime, particularly those that allow unauthorised operators to reach Swedish players.
Origin of the project
It all began with the publication of a report by Marcus Isgren, an investigator for the Ministry of Finance. This document, made public at the end of September 2025, scrutinised the Gambling Act framework and identified a central problem: the directional criterion, which defines whether an online operator falls under Swedish jurisdiction, depending on whether it explicitly targets the Swedish market (Swedish language, Swedish krona, local marketing, etc.).
This criterion has enabled many unlicensed operators to exploit a legal loophole by avoiding any visible mark of belonging to Sweden: site in English, payments in euros, absence of national indications.
The main changes proposed
Isgren is proposing to replace this directional criterion with a participation criterion. From now on, it doesn’t matter what language or currency is used: what matters is whether a Swedish resident can play on the site. If so, the site falls under Swedish law, unless the operator can prove that it has put in place appropriate and effective measures to block access to Swedish players.
Other changes include:
- Extension of the ban on the promotion of unlicensed games, not just to advertising, but also to technical providers, financial services, etc.
- A presumption rule for payment processors: if they process transactions linked to an unlicensed operator, they will have to presume that Swedish players are involved, unless there is proof to the contrary.
- Adaptation of criminal provisions to explicitly include unauthorised activity and its promotion.
If these measures are adopted, they will come into force on 1 January 2027.
Expectations and hopes: channelling and consumer protection
One of the stated aims of the reform is to increase channelling, i.e. the proportion of players’ bets that are placed via licensed operators. The government is aiming for a threshold of 90% for legal gambling to dominate the market.
Currently, the Swedish company estimates that this rate is 85%, but it varies depending on the sector: for online casinos, the figure is between 72% and 82%, which is considered catastrophic by some professional organisations.
Although the legal framework will be tightened, several players warn that this will not be enough to solve all the problems. The flaws linked to the attraction of illegal offers are considered to be more structural than technical.
Hoffstedt points out that players are not always able to distinguish a legal operator from an unlicensed one; some sites usurp the appearance and visual identity of authorised platforms. This fuels the flight to the black market. Furthermore, even with new enforcement measures (DNS blocking, payment restrictions, extended liability), without a competitive user experience, the regulations will remain partly circumvented.
Timetable, political issues and outlook
The proposed reform still has to pass through the formal legislative stages before it comes into force on 1 January 2027.
Another factor to watch out for is the general election scheduled for September 2026 in Sweden. Political opposition, interest groups in the gambling industry, and public concerns around freedom and regulation could influence the final version of the law.The amendment of the Gambling Act in Sweden is an important step towards a safer, more transparent and better regulated market. The move from a targeting criterion to a participation criterion could have a major impact on the practices of unauthorised operators.