Too Early: Sweden Authority Passes on Tiered Risk Assessment for Advertising Restrictions

Lee R. - December 2, 2022
Sweden Flag

The emerging jurisdiction of Sweden is still experiencing growing pains.

Sweden’s authority has rejected proposals for stricter gambling advertisements. 

Grounds for Refusal

The proposal to tighten advertising rules was rejected by the Swedish Riksdag’s Culture Committee, due to ambiguities in categorical risk assessment for the still-emerging jurisdiction.

No Rush

The Culture Committee disapproved of bringing in a tiered system of regulation“by the back door” as the Riksdag called it. The decision speaks to the lingering greater issue of restrictions applicable only to some forms of gambling that would require a system of classifying types of iGaming. 

Committee Unsatisfied

The gambling reform bill originally targeted harm reduction and channelisation improvement, with the rejection decision handed down in the committee report.


The proposed bill called for tiered sanctions such as a ban on so-called “high-risk” gambling ads between 6 AM and 9 PM.


The legislation was ultimately updated merely to require “adjusted moderation” for gambling ads. 

Hurting Not Helping

The government’s rejection of the 6-9 ban was based on the grounds that channeling and media revenues could be adversely impacted by a daytime ban, without significantly preventing at-risk people from being exposed to ads. In other words, the government did not believe that the proposed 6-9 ban would do its job, 

Problematic Clauses

Potentially problematic vagaries in language cropped up further when the Swedish government distinguished the standard of adjusted moderation from the “special moderation” requirement currently in place in Sweden and which was proposed for gambling guidelines in 2021 as well.  

The Challenge of Adjusted Moderation

The government called “adjusted moderation” problematic because said moderation on advertisements would have to be adapted to each type of gambling involved.

Trade Association Concerns

Trade association Branschföreningen för Onlinespel (BOS) understandably expressed concerns about the ambiguity of the rule and the lack of extant examples or concrete guidelines. 

Market Erosion Risk

The Culture Committee took issue with the entire procedure for generating the guidelines as a rushed approach which could prevent many licenced operators from marketing their products “to a wider extent.”

Too Early

The Culture Committee also was not comfortable with making major changes to marketing rules for a major jurisdiction in a still embryonic stage of existence less than three years old. 

More Risks to Be Identified

The Culture Committee decided that too many factors need to be identified and taken into consideration at this point to apply across-the-board categorical restrictions and that products still need to be assessed on a case-by-case basis. 


The full spectrum of risk factors has yet to be revealed. Fuller data with enough examples to base Parliamentary decisions on could take a couple more years. 

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