Sweden proposes licence requirement wherever players in Sweden can take part
Ds 2025:23 proposes that online gambling counts as offered in Sweden whenever people in Sweden can play, with a proposed start of 1 January 2027.
By Oliwer Brewitz, Head of Marketing
Key changes
- Proposed removal of the targeting criterion for online gambling
- Licence needed if people in Sweden can take part, unless participation is effectively blocked
- Promotion ban proposed to cover payment and similar services
- Proposed entry into force 1 January 2027
What changed
In February 2025 the government appointed an inquiry to review the scope of the Gambling Act. Its memorandum, Spellagens tillämpningsområde (Ds 2025:23), dated 17 September 2025 and published by the government on 24 September 2025, proposes removing the current targeting criterion. Online gambling would instead be treated as offered in Sweden if people in Sweden can take part, unless the operator takes effective steps to prevent participation from Sweden. The ban on promoting unlawful gambling would extend to payment solutions and similar services supplied to gambling operators, whether or not they are built for the sector. Payment intermediaries would have to presume that a person resident in Sweden is playing from Sweden. The memorandum proposes entry into force on 1 January 2027. It is a proposal, not adopted law.
What it means for advertising
Sweden's promotion ban already covers marketing of unlicensed gambling to Swedish consumers. If adopted, a wider definition of what counts as gambling offered in Sweden is likely to widen the set of brands that Swedish media owners, ad networks and affiliates cannot promote. Brand-safety and advertiser checks for display, video/CTV and DOOH would then need to follow the new participation-based test rather than the targeting test.
What operators should do
Licensed operators should follow the legislative process and expect stronger enforcement against unlicensed competitors once any new rules apply. Media owners and agencies should review advertiser verification so that only brands on Spelinspektionen's licence register are accepted for Swedish inventory. Payment and service providers working with gambling companies should assess how the proposed presumption rule would affect their onboarding checks.
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