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In Sweden, the gambling duty of care has come under sharp focus following recent enforcement actions by the Swedish Gambling Authority (SGA) against two operators.
During the spring of 2024, the Swedish Gambling Authority (SGA) intensified its oversight of licensed online gambling operators in Sweden, with a particular focus on compliance with the gambling duty of care outlined in the Swedish Gambling Act (2018:1138). This regulatory action led to two high-profile enforcement cases involving Roar Vegas Ltd and Glitnor Services Limited. The SGA concluded that both companies had violated the duty of care provisions, resulting in substantial financial penalties—SEK 8,000,000 (approx. EUR 730,000) for Roar Vegas and SEK 28,000,000 (approx. EUR 2,600,000) for Glitnor.
Below is the article on the topic from my DLA Piper’s Swedish gambling law colleagues Anna Jussil Broms and Emanuel Sonstrand.
Regulatory Framework: Sweden’s Gambling Duty of Care
Under Chapter 14, Section 1 of the Swedish Gambling Act, all licensed gambling operators in Sweden are required to uphold a strict duty of care. This legal obligation compels operators to prioritize the protection of players by monitoring gambling behavior, intervening when signs of excessive gambling appear, and providing support to help reduce harmful play. The duty of care is central to Sweden’s approach to gambling regulation, which treats gambling as a public health issue with serious social and economic consequences.
Case Study 1: Roar Vegas Ltd
In its supervisory review, the Swedish Gambling Authority found that Roar Vegas Ltd failed to meet its duty of care obligations for three out of twelve audited customers. Although Roar Vegas had monitoring systems and sent automated messages, the SGA determined that the company did not act with sufficient urgency or implement effective measures early enough. This failure to intervene in a timely and meaningful way led to a penalty of SEK 8 million.
Roar Vegas argued that the lack of detailed guidance on the timing and nature of interventions contributed to its non-compliance. However, the SGA reaffirmed that the legal requirements under the Gambling Act had been clear since its implementation.
Case Study 2: Glitnor Services Limited
Similarly, Glitnor Services Limited was penalized for breaches of the gambling duty of care, having failed to assist ten of twelve audited customers in reducing their gambling activity. Despite initiating “care calls” and emails, the SGA found that these actions were insufficient and poorly timed. In response, Glitnor was issued a warning and ordered to pay a penalty of SEK 28 million.
Glitnor maintained that the Gambling Act does not require operators to exclude players without consent, and noted the lack of specific statutory timelines for implementing protective measures. Nonetheless, the Swedish Gambling Authority emphasized that operators must enforce restrictions and access limitations when necessary, based on each customer’s risk profile.
Implications for Online Gambling Operators in Sweden
These enforcement actions highlight the stringent expectations placed on online gambling operators under Sweden’s gambling duty of care framework. The decisions by the Swedish Gambling Authority reflect a commitment to consumer protection and underscore the importance of proactive, effective, and timely interventions to prevent gambling-related harm. Operators failing to comply with these obligations risk significant penalties and reputational damage.
Conclusion
The penalties outlined above stress the relevance of the duty of care under the Swedish Gambling Act is not merely a formality—it is a legally enforceable obligation with serious consequences for non-compliance. As the Swedish regulatory landscape evolves, gambling operators must ensure their responsible gambling frameworks are robust, well-implemented, and aligned with the expectations of the Swedish Gambling Authority.
To learn more on the topic, I will be glad to introduce you to my Swedish gambling law colleagues Anna Jussil Broms and Emanuel Sonstrand. Also, you can have an outline on the Swedish gambling law regime in DLA Piper’s Gambling Laws of the World Guide available HERE and access further gambling law news HERE.
