BOS Calls for Clarifications in Swedish Gambling Authority’s Responsible Gambling and Tech Proposals

The Swedish Online Gambling Trade Association (BOS) supports the Swedish Gambling Authority’s (Spelinspektionen) drive to modernise responsible gambling and technical regulations, but cautions that the current proposals leave too much ambiguity for licensees and fail to guarantee a clear, uniform application. BOS recommends further clarifications, robust evidence bases for thresholds, and harmonised implementation to accomplish effective, proportionate consumer protection within Sweden’s regulated market.

BOS Welcomes Reform But Points to Persistent Ambiguities

BOS, representing licensed online gambling operators in Sweden, responded formally on 28 August 2026 to Spelinspektionen’s consultation on its updated responsible gambling (21Si540) and technical requirements (25Si946) regulations. BOS acknowledges the importance of a modern, clear regulatory framework, but argues that several key definitions and thresholds within the proposals remain insufficiently precise, perpetuating uncertainties for both operators and the regulator.

"A codification that leaves the decisive assessments open thus writes the ambiguity into the regulation instead of removing it." — BOS submission (28 August 2026)

Neither courts nor Spelinspektionen have established consistent practice on key requirements such as the duty of care, reflecting unresolved legal interpretations even after multiple years of oversight and judicial review. The proposals, in BOS’s view, largely repeat the problematic language underpinning inconsistent enforcement, rather than rectifying it.

Areas Requiring Evidence-Based Clarification

BOS highlights that regulations must be proportionate, technology-neutral, and grounded in evidence, with risk assessments reflecting the player’s context, rather than rigid application of single-risk triggers. Areas of concern include:

• Conceptual Vagueness: Several provisions, such as thresholds for action (e.g., SEK 10,000 monthly deposit, nighttime definitions, and assessment of mental illness) lack transparent knowledge bases.
• Risk of Over-Formalisation: Mandating that a single indicator triggers intervention may result in box-ticking, not a holistic assessment of player behaviour.
• Documentation Asymmetry: Regulations oblige operators to document every intervention, but not when a considered assessment finds action unnecessary, potentially distorting audit outcomes.
• Feedback Confirmation and Sanctions: The proposal that access be restricted solely based on missing feedback from players may drive pre-emptive operator actions, misaligning incentives away from early, proportionate engagement.
• Lack of Justification for Limits: Notably, the restriction of slot autoplay to 60 rounds is not evidence-backed, and similar concerns apply to the one-hour auto-logout rule.

BOS draws on research, including a 2025 review by Marionneau, Ristolainen, and Roukka, stressing that regulators should set out what operators must measure, the thresholds, and ensure these are evidence-based and practical to supervise.

Channelisation, Consumer Protection, and Cumulative Regulatory Impact

Central to BOS’s submission is the principle that Sweden’s responsible gambling regime must support strong channelisation—ensuring customers use licensed providers for regulatory protections to be effective. Citing Spelinspektionen’s own findings (e.g., Online Gambling Habits 2023), BOS notes that up to 16% of 18–29-year-olds and a third of casino players who gamble frequently seek out unlicensed sites, often due to exclusion from Spelpaus.se. Measures that create excessive friction for all players risk driving players to unregulated operators, undermining consumer protections.

Regulations that require recurrent confirmations, automatic logouts, and limits on features such as autoplay should be evaluated for their aggregate effect, not just individually. BOS asserts the cumulative friction created should be assessed against the protective value it delivers, particularly for players not exhibiting risky behaviour.

Proposals for Harmonisation and Practical Implementation

BOS recommends:

1. Harmonised Entry Into Force: Coordinating the start date for responsible gambling and technical regulations so licensees implement compliant systems and processes simultaneously.
2. Joined-up Impact Assessment: Analysing overlapping provisions and combined compliance costs of both sets of regulations to present a complete picture for operators.
3. Documenting Negative Assessments: Requiring operators to record when risk assessments do not trigger intervention, to support proportional supervision.
4. Technology-Neutral Standards: Referencing security levels (as in EU eIDAS and Sweden’s anti-money laundering law) rather than naming specific authentication methods, so the regulations remain future-proof.
5. Clarifying Feedback and Action Thresholds: Defining when feedback has been successfully delivered, how player responses should be considered, and under what circumstances access restrictions are genuinely warranted.
6. Allowing Role-Based Training: Enabling operators to adapt recurrent staff training in responsible gambling according to job function and risk exposure.
7. Evaluating Cumulative Impact: Requiring impact assessments that focus on the overall effect of all measures on player experience and market channelisation, instead of evaluating each requirement in isolation.
8. Proportionate Approach to Player Data: Explicitly weighing the privacy impact of continual data monitoring and collection against its consumer protection benefits.

Specific Regulatory Issues Highlighted

Autoplay and Game Limits

BOS contends that setting a cap of 60 autoplay rounds lacks clear justification and may not address the intended risk. The organisation stresses regulators should provide the evidence base for these figures, assess their aggregate impact, and consider allowing targeted interventions rather than blanket restrictions.

Shortened Training and Communication Windows

The proposals reduce the time for new staff training to three months after start (from previously four months), and extend the requirement for real-time responsible gambling support by two hours (to at least eight hours per day). BOS requests clarity on these reductions and their rationale.

Responsible Gambling and Technical Regulations Overlap

BOS calls for mapped alignment between processes governed by both sets of proposals—such as automatic logouts and identification requirements—to avoid duplicative or contradictory compliance obligations.

"Several provisions regulate the same processes or are based on the same concepts but are not fully harmonised. A more coherent regulatory framework would reduce the risk of conflicting interpretations, facilitate compliance and contribute to more effective supervision." — BOS submission

Player Integrity and Data Use

Operators are required to assess risks based only on data from gambling activity with that licensee. BOS questions the proportionality of the proposed measures in light of this inherent limitation and requests that regulators clarify expected efficacy.

Concluding Recommendations

The Swedish Gambling Authority is urged to:

• Clearly report the knowledge base for every stated limit within the regulations
• Justify any new or revised thresholds through impact assessments with cost and privacy considerations
• Harmonise responsible gambling and technical requirements for simultaneous implementation
• Allow technology-neutral compliance, especially regarding player identification
• Establish a permanent working group including licensees, researchers, and aid organisations for ongoing review and regulatory development

BOS emphasises that regulatory measures should be proportionate, risk-based, and focus on players who actually demonstrate concerning indicators, avoiding unnecessary friction for typical customers. Transition timelines must allow operators to adapt, test, and certify systems to maintain both compliance and a viable, attractive regulated market for Swedish players.