
BOS urges Swedish government to close black market loophole
Trade body argues Sweden’s Gambling Act has been applied incorrectly, making it too easy for Swedish players to access unlicensed operators

The Swedish Trade Organisation for Online Gambling (BOS) has called on the government to change Sweden’s gambling legislation, which it claims is allowing black-market operators to continue to flourish.
A letter sent to the Ministry of Finance by BOS secretary general Gustaf Hoffstedt argues it is too easy for Swedish players to access unlicensed sites.
The trade body believes the issue stems from a misapplication of Sweden’s Gambling Act, which came into effect when the market re-regulated in 2019.
BOS suggests that the current application of the law focuses on whether offshore operators are specifically targeting Swedes and that widespread English proficiency and understanding of foreign currencies leaves the rule somewhat redundant.
BOS argues that the law was originally designed to apply to any games that are accessible by Swedish players, regardless of whether they have been specifically designed for the market, thus providing players with more protection.
Hoffstedt wrote: “The decisive factor is whether the gaming site has text in Swedish or offers deposits and winnings in Swedish currency and that this must be determined by an overall assessment on a case-by-case basis.”
Hoffstedt added that the current interpretation of the law means that the government, or the regulator, the Swedish Gambling Authority, can’t provide any effective regulation for the market.
He continued: “It is [therefore] permitted for gambling companies all over the world and their service providers to enable games from Swedish customers as long as it is done in a language other than Swedish and in a currency other than SEK [Swedish krona].”
“Most Swedes understand English and understand the value of commonly used foreign currencies, such as the euro.
“There is therefore no real possibility for the government to initiate any effective measure […] to make it more difficult for Swedish gambling customers to freely choose to play at gambling companies that are not licensed in Sweden.”
The letter concluded with a call to action for the government to change how the Gambling Act is applied in order to better tackle unlicensed operators infiltrating the Swedish market.
“We would like the government to take the initiative to change the scope of application of the Gambling Act so that it also becomes illegal to passively receive Swedish gambling consumers,” Hoffstedt continued.
“Such a change in law would make it possible to counteract the existence of unlicensed gambling companies as well as payment intermediaries and other subcontractors who currently avoid being hit by the law by using the euro as currency and English as language.”
The trade body argued that the loophole was playing a role in the channelisation rate in Sweden falling below the 90% target set by the government when the market re-regulated.
A report published by Swedish horseracing operator ATG in December 2024 estimated that the market’s channelisation rate sat between 70% and 82% by Q3 2024, falling way below the government’s target.