Swedish Appeal Court Upholds SEK44 Million in bet365 Penalties Over a No-Limit Deposit Option

Sweden's Administrative Court of Appeal has upheld two warnings and SEK44 million in sanction fees against bet365 for letting players choose "no limit" as their mandatory deposit limit for more than three years. The fees are lower than Spelinspektionen first set in 2023, mostly because of a ruling on how the cap is calculated, but the regulator's reading of the law has held.

• Sweden's Administrative Court of Appeal on 8 October rejected appeals by bet365's two Swedish licensees, leaving warnings and fees of SEK40 million and SEK4 million in place
• From 1 January 2019 to 18 April 2022 bet365 let customers choose "no limit" for the deposit limit the Gambling Act requires, backed by a hidden SEK500 million technical ceiling
• Spelinspektionen imposed SEK65 million and SEK14 million in April 2023; a lower court cut them in 2024 after a ruling that the 10% cap is measured on net turnover
• The regulator called the breach serious and systematic but chose warnings over revocation because bet365 removed the option and tightened its duty of care plan
• It is a win for Spelinspektionen after courts quashed its duty of care fines against Svenska Spel Sport & Casino and LeoVegas's Roar Vegas

A Court in Jönköping Rejects Both bet365 Appeals

The Administrative Court of Appeal in Jönköping (Kammarrätten i Jönköping) rejected both appeals on 8 October 2026, in case 2341-24 for Hillside (Sports) ENC, bet365's Swedish betting licensee, and case 2342-24 for Hillside (Gaming) ENC, its online casino licensee. It agreed with the Administrative Court in Linköping that both had breached the duty of care in chapter 14, section 1 of the Gambling Act (Spellagen, 2018:1138) and the deposit limit rules, and that warnings with fees of SEK40 million (approximately $4.0 million) and SEK4 million (approximately $401,000) were proportionate. Spelinspektionen published them on 14 October; a further appeal needs leave from the Supreme Administrative Court. No public statement from bet365 on the rulings was found.

The two companies share the bet365.com site and one player account. Their licences took effect on 1 January 2019, when Sweden's re-regulated market opened, and supervision began on 21 December 2021. Chapter 14, section 7 says that for online gambling "the player shall state an upper limit for their deposits" (quotations from Swedish documents are our translations), and the Gambling Ordinance requires that limit per day, week and month.

According to the regulator's April 2023 decisions, bet365 offered a "no limit" choice from 1 January 2019 to 18 April 2022, backed by a SEK500 million (approximately $50.2 million) technical limit the customer could not see. bet365 argued the law did not clearly require a figure and cited a pre-launch conversation with the regulator. Spelinspektionen replied that it gives no binding advance rulings, had no record of the conversation, and that without a numeric limit bet365 could not meet the rule requiring contact with players who raise their limit above SEK10,000 a month. It called the interpretation "not only incorrect" but "remarkable and nonchalant", and the breach serious and systematic.

The regulator also examined five of the 10 biggest losers at each company between 17 October and 17 December 2021. At the betting licensee those five lost between about SEK259,000 and SEK386,000 each in two months, according to the Linköping judgment; one, born in 2001, had a SEK5 million monthly limit and deposited on 53 of 62 days. Spelinspektionen found bet365 escalated too late. The Court of Appeal held that necessary measures must be taken "at the same pace as the gambling takes place": if a first message has no effect, the licensee must escalate promptly. bet365's arguments that five customers were a tiny fraction of its base and that the missing limits had no real consequences did not persuade it.

Why the Fees Fell From SEK79 Million to SEK44 Million

Under chapter 18, section 12 a serious breach leads to revocation unless a warning is sufficient. The regulator chose warnings because bet365 removed the option and changed its duty of care plan, including closer review of customers losing more than SEK10,000 a month and lower risk thresholds for 18 to 24 year olds and returning self-excluded players, while doubting it had "the necessary will" to comply.

Chapter 19, section 13 caps the fee at 10% of the previous year's turnover. In 2023 Spelinspektionen used the betting company's gross turnover of SEK8.85 billion, a cap of SEK884.6 million, and set SEK65 million, plus SEK14 million for the casino company, against 2021 GGR of SEK724.6 million (approximately $72.7 million) and SEK69.0 million. After the Supreme Administrative Court ruled in HFD 2023 ref. 25 that turnover means net turnover, the caps fell to SEK72 million and SEK6.9 million. Spelinspektionen proposed SEK52 million and SEK5 million; bet365 argued for about SEK5.3 million on the betting side. On 13 June 2024 the Linköping court set SEK40 million and SEK4 million, weighing in part that duty of care guidance had not been entirely clear at the time.

A Mandatory Limit Has to Be a Number

The durable part of this case is the interpretation, not the fee. Two courts have now held that a limit the player can set to "none" is not a limit, hidden ceiling or not. The rule exists to make the player actively decide. That matters as Spelinspektionen consults on replacing guidance with binding duty of care rules, which BOS, the licensed operators' trade body, says would add friction that weakens the licensed market against offshore sites.

Spelinspektionen Needed a Win on the Duty of Care

Its court record on the duty of care has been uneven. The Linköping court quashed a SEK100 million fee against Svenska Spel Sport & Casino in June 2025, a ruling Spelinspektionen appealed, and an SEK8 million fine against Roar Vegas in June 2026. The "same pace" test gives the regulator a firmer standard than the open-ended timing the Roar Vegas court accepted. The fees remain modest, about 5.5% of the betting company's 2021 GGR. bet365 has a record elsewhere: Britain's Gambling Commission settled with its two British licensees for £582,120 in April 2024, partly because an Early Risk Detection System, the name the Swedish decisions also give bet365's monitoring, was not demonstrably effective, and North Carolina fined bet365 $75,000 last month over a push notification to self-excluded players.

The money is small for bet365 and the conduct ended in April 2022. What lasts is an appeal court reading that a mandatory limit must be a number, and a test that interventions must keep pace with the play.