Sweden's Trade Body Tells the Regulator to Rethink Its Safer Gambling Rules

Spelinspektionen wants to replace guidance with binding duty-of-care requirements. BOS says the regulator has not asked what the cumulative friction does to the licensed market it is trying to protect.

• Spelinspektionen opened a consultation in June on proposed responsible gambling regulations spanning 12 chapters, with responses due by 10 August 2026
• The reforms would replace the existing LIFS 2018:2 regulations and general guidance with a more prescriptive set of binding requirements
• BOS, the trade association for licensed online operators, has told the regulator to return to the drawing board rather than proceed as drafted
• Central to the BOS response is that Spelinspektionen has not assessed how the combined reforms would affect the appeal of the licensed market
• The measures BOS cites include electronic identification at every login, repeated messages and confirmations, automatic logout, loss notifications and restrictions on game functions

The Objection Is About the Sum, Not the Parts

Spelinspektionen opened its consultation in June on a package of responsible gambling regulations running to 12 chapters, with stakeholders asked to respond by 10 August. The proposals would replace LIFS 2018:2 and its accompanying general guidance with a set of binding requirements, moving the regime from guidance operators interpret to rules they must follow precisely.

BOS, which represents licensed online operators in Sweden, has argued the package should go back for reconsideration. Its central point is not that any individual measure is wrong. It is that the regulator has not assessed what the measures do together.

The list BOS points to is cumulative by nature: electronic identification at every login, repeated messages and confirmations during play, automatic logout, loss notifications, and restrictions on game functions. Taken one at a time each is defensible. Taken together, BOS argues, they create significant friction for every customer, including those showing no signs of harmful gambling.

That is the argument in one line. A duty of care aimed at a minority is being delivered through the experience of the majority, and nobody has modelled what that does to the licensed market's attractiveness relative to the unlicensed alternative.

Channelisation Is the Only Number That Settles This

Sweden's regulator reports online channelisation at around 84%, down about a point on the previous year and from 86% in 2023. That figure is the whole argument between the two sides, and it is the reason a friction debate in Stockholm is not merely a trade body complaining about compliance costs. Every unit of friction added to the licensed product is a reason for a player to use one that has none, and the unlicensed alternative imposes no logins, no confirmations and no loss notifications at all. The regulator's own trend line has been drifting the wrong way for two years. BOS is asking it to run the numbers before adding more.

Prescription Buys Enforceability and Costs Judgement

There is a real case for what Spelinspektionen is doing. General guidance is hard to enforce, produces inconsistent practice across licensees and gives an operator room to argue that its interpretation was reasonable. Binding requirements remove that argument and make supervision straightforward. The cost is that prescriptive rules apply identically to a customer depositing SEK 50 a month and one showing every marker of harm, because a rule cannot exercise judgement. Regulators that have gone down this road elsewhere have generally ended up reintroducing risk-based flexibility later, having discovered that uniform friction is an expensive way to reach a small group.

A Consultation Response Is Not a Defeat

It is worth keeping the stage in proportion. This is a trade body responding to a consultation, which is what consultations are for, and Spelinspektionen is under no obligation to agree. The question is whether the final rules show evidence that the cumulative effect was assessed. If the package emerges unchanged with no channelisation analysis attached, BOS will have a stronger argument in twelve months than it has today, and it will have the regulator's own statistics to make it with.

Sweden has spent seven years arguing about whether its licensed market is attractive enough to hold players. This consultation is that argument again, in a different register.