Europe

The government of Sweden has appointed Erik Eldhagen as new State Secretary for Gambling, reporting to Minister for Financial Markets Niklas Wykman to lead one of Sweden’s most closely scrutinised policy portfolios.

Eldhagen’s responsibilities will extend across gambling regulation, financial markets, state-owned properties, and the financing of new nuclear power projects. His appointment takes effect on 1 December 2025.

A seasoned public official, Eldhagen joins from the Riksbank, where he served as Head of the International Secretariat. He previously held senior positions within the Ministry of Finance and acted as an advisor to the World Bank.

The appointment comes ahead of the government’s anticipated amendments to the 2018 Gambling Act, which opened Sweden’s online gambling market.

The forthcoming reforms, developed under the guidance of Inspector Marcus Isgren and Niklas Wykman, to strengthen Swedish gambling consumer safeguards and protections against unlicensed gambling.

2025 has seen Sweden change its leadership of Swedish gambling as Gambling Inspectorate Spelinspektionen has undertaken its own transition. Announced in October Johan Röhr has begun his tenure as Acting Director General following the departure of Camilla Rosenberg after eight years at the helm.

Prelude to sweeping 2026 reforms

In the final months of 2025, Spelinspektionen has advised all Swedish licensees to prepare for a transformative 2026, as the government finalises a package of sweeping regulatory reforms.

Amendments to the Gambling Act will tighten definitions of illegal gambling activity and expand the law’s jurisdiction to offshore operators that make their services available to Swedish players, even without explicit targeting.

The Ministry of Finance has endorsed a proposal to remove the “directional criterion” — a long-standing clause that excluded non-Swedish-facing games from domestic law. Its removal will empower authorities to pursue any operator accepting Swedish players, regardless of language, payment method, or marketing approach.

Additionally, the government plans to bolster regulatory oversight through new enforcement powers and an enhanced penalty framework, granting Spelinspektionen the authority to impose heavier sanctions, revoke licences, and expand compliance investigations.

A landmark element of the 2026 reforms will see Sweden become the first EU nation to impose a complete ban on gambling with credit. From 1 April 2026, operators will be prohibited from processing any payments funded through credit cards, overdrafts, personal loans, or buy-now-pay-later services.

Hailed by the government as a key consumer protection measure, the ban aims to curb gambling-related indebtedness and reinforce the country’s responsible gambling framework.

The implementation of these measures will fall under the leadership of Acting Director General Johan Röhr, who succeeded Camilla Rosenberg on 1 November 2025, marking a new chapter for Spelinspektionen’s direction and enforcement strategy.

Optdeck Service Ltd, operator of Unibet in the Netherlands, has been fined €4m over duty of care failures.

The Dutch gambling commission, Kansspelautoriteit (KSA), confirmed that the failures occurred between 14 July 2022 and 1 July 2024, and that they were related to insufficient player protection measures.

“Gambling companies must protect players as much as possible from excessive participation and gambling addiction,” the regulator said.

Within the files requested and examined by the KSA, it was revealed that Optdeck continuously failed to intervene in cases where problem gambling indicators were present.

Several incidents involved gamblers spending “thousands of Euros” per day but information about their income was requested only weeks after. Also present in the documents reviewed by the KSA was an instance where money from a business account was used to gamble – a prohibited practice under Dutch law.

Michel Groothuizen, KSA Chairman, commented: “When there are signs of immoderate gambling behavior and someone bets a huge amount of money in a short time, a provider must investigate the origin of the money.

“It is essential that providers carry out this analysis adequately, because not all financial resources may simply be included. The KSA takes violations of the duty of care very seriously and will continue to act hard against them.”

Unibet, is everything alright?
This is not the first time Optdeck has landed in trouble with the Dutch regulator. Earlier in September, the operator was charged an additional €450,000 for offering Unibet customers bets on prohibited markets – corner kicks, yellow cards, and under-21 games.

The violations went on from October 2022 to May 2025 – overlapping with the time period when the player protection failures occurred.

Similar duty of care breaches are not limited just to Optdeck, however. Earlier this year, Unibet received a penalty of AU$1m (£481,000) in Australia for failure to restrict the access of hundreds of self-excluded accounts.

Another case from just over two months ago saw Platinum Gaming, operator of Unibet in the UK, receive a whopping £10m penalty for social responsibility and AML beaches

All of these instances build up the case for a bigger question – are such significant oversights region-locked or is there something far more bigger going on centrally at Unibet and its parents Kindred Group and FDJ United that requires urgent attention?

The use of Codere’s name in the headline of a recent ruling from Spanish regulators has been criticised as creating “an inaccurate and disproportionate impression”, according to Fernando Martín, Partner at Loyra Abogados.

Codere was among three regulated operators highlighted as the authorities announced sanctions worth €33.5m to 32 gambling operators in Spain. However, $30m of the total fines were attributed to six illegal operators.

The Spanish gambling group argued that its inclusion within the Ministry of Social Rights, Consumer Affairs and Agenda 2030’s headline alongside 888 and Betfair unfairly grouped them in with more serious offenders, given its fine totalled a measly €17,500 of the total figure.

Martín said: “For licensed operators such as Codere, 888 or Betfair, these cases relate to administrative compliance issues. They involve failures in technical controls, internal procedures or reporting obligations. They do not relate to illegal gambling activity.

“By contrast, the €5 million fines issued to offshore operators correspond to very serious infringements and come with website and payment blocking. These are aimed at disrupting unlicensed activity.

“This difference is essential. Mixing both types of operators in a single headline creates confusion and can damage reputations. This episode illustrates why such a distinction is essential, especially at a time when consumer confusion between legal and illegal platforms is growing.”

Black market confusion

Alongside sanctioning each illegal operator €5m, the DGOJ has blocked their websites. However, the sanctions illustrate the strength of Spain’s illicit gambling market.

Recent data from EY and Jdigital revealed that 23.4% of Spanish players have used illegal gambling websites, and the market has grown to be worth €231m in 2024, approximately 16% of the value of the regulated market.

Mirroring similar findings to those in the UK, the research found that the distinction between the legal and illegal remains increasingly blurred for players.

“One of the most striking findings is the level of confusion among consumers. Almost half of the players who believe they only use legal “.es” sites have actually accessed illegal platforms, including domains such as “.com” or “.bet”. This lack of awareness is a major cause of exposure,” explained Martín.

“32.1% of players aged 18 to 24 do not realise they are using illegal operators, making them one of the most exposed demographics.

“Illegal operators exploit these weaknesses with aggressive promotions, unlimited stakes, faster payments and a strong presence on digital channels. Platforms such as YouTube, TikTok, Instagram, Telegram, and payment methods like Bizum and cryptocurrencies are central to their strategy of attracting Spanish players outside the regulated system.”

Regulating the suppliers

The DGOJ is currently considering a raft of significant reforms, including tighter restrictions on advertising and promotions, and the implementation of a regulator-developed risky player behaviour monitoring system.

Alongside this, for the first time in Spain, B2B providers will be required to register with the DGOJ, marking “the beginning of direct supervision over the technological backbone of the industry”.

“The reform introduces a clear obligation for providers to ensure that their systems are not used by unlicensed operators,” concluded Martín.

“They will need to adopt both technical safeguards and contractual controls to prevent their platforms, software or RNGs from ending up in the illegal market. This shifts part of the responsibility for enforcement onto those who develop and supply the technology.

“In addition, a licensed operator will only be allowed to certify or approve a technical system if the supplier is properly registered. This creates a direct link between the regulatory status of B2B providers and the compliance obligations of licensed operators, tightening oversight across the entire chain.”

The Government of Montenegro has rejected appeals demanding a constitutional review of articles authorised under the New Law on Games of Chance.

The challenge was filed by NVO, the national trade association for games-of-chance suppliers, and Lutrija Crne Gore (the Lottery of Montenegro), which has contested the provisions of Article 106.

The Incumbents cite that the “transitional and concession rules” set out in the legislation undermine constitutional rights of gambling licences authorised by the former laws of Montenegro.

According to the two parties, Article 106 of the New Law will breach the constitutional ban on retroactive legislation, create unequal treatment for operators with different contract expiry dates, and will further infringe on what they described as “acquired rights” linked to existing concessions.

PM Spajić says no…
A written opinion was submitted to the Vlada legislature directly by Prime Minister Milojko Spajić, who stated:

“After examining the submission, the government finds that the law does not have retroactive effect. The mandate on games of chance is an activity of public interest and holds exclusive rights for the state. Organisers therefore do not possess any rights that will be in breach of the New Law.

The government ensures a transitional period of 270 days to allow all organisers to align their business operations with the new requirements, in all fairness to all, regardless of who they might be.

Spajić continued: “The government ultimately decides that this disputed provision is not contrary to constitutional norms or international conventions, and that there is no prospect of bringing proceedings before the Constitutional Court with respect to Article 106 of the Law on Games of Chance.”

The PM’s opinion formed the legal basis upon which the cabinet rejected the petition for constitutional review. Although the constitutional challenge has been rejected, the new framework continues to attract criticism from Montenegro’s gambling licences.

Montenegrobet, the national association of licensed operators, has warned the government that it will introduce “unrealistic compliance obligations, disproportionate criminal-liability triggers, and licence-revocation grounds that could destabilise the legal market and hinder channelisation.”

The association has urged the government to reopen dialogue with gambling licences and revise several contentious provisions that will hinder market stability and suppress investment in domestic operators.

Gambling and Euro ascension
Following the decision, Montenegro’s New Law on Games of Chance passed in August 2023 – will proceed through a phased implementation in which the government will consider minimal changes.The Ministry of Finance has begun issuing secondary regulations covering licensing conditions, AML controls, supervision, and market conduct standards.

The launch of a modernised gambling framework is earmarked by the Spajić “Pro Europa” administration as a critical domestic reform supporting Montenegro’s full accession to the European Union – in which PM Spajić and the government seek to become a full member state by 2028.

Denmark, Finland, Iceland, Norway and Sweden have aligned to launch the joint research project on gambling, gathering comparable knowledge about gambling habits and gambling problems in the region.

It marks a key move from the Nordic countries as they seek to learn lessons from each other in a bid to strengthen each market’s understanding of gambling habits and subsequently bolster player safeguards.

Approximately 30,000 randomly selected people, aged 18 to 80, from each country will participate in the study across the Nordic region, with invitations sent by post and reminders sent via Kivra.

The survey is being conducted in collaboration with the Swedish Gambling Authority (Spelinspektionen), Danish Gambling Authority (Spillemyndigheden), Aalborg University, Finnish Institute for Health and Welfare, University of Iceland, Norwegian Gambling and Foundation Authority (Lotteritilsynet) and the University of Bergen.

Maria Vinberg, Investigator at Spelinspektionen, commented: “The study will provide a basis for assessing gambling and gambling problems in the Nordic countries.

It will be exciting to compare the results with previous Swedish data and with the rest of the Nordic countries, especially since so few similar joint surveys have been conducted in Europe.”

To be answered digitally, the study questions will cover topics such as gambling, computer games and problems related to gambling.

The Pan-Nordic Gambling Study’s results will be published in the spring next year, with a selection of the results reported in the Swedish Public Health Agency’s statistical database, Folkhälsodata, and on the knowledge website spelprevention.

Ombudsman criticism

However, the study comes as Spelinspektionen receives criticism from the Swedish Ombudsman.

On its website, the Swedish authority stated that the Ombudsman criticised Spelinspektionen for not previously being able to exclude individuals from gambling without electronic identification.

In the summer of 2024, a person requested to be banned from gambling without electronic identification, but it took approximately a month for the person’s request to be processed by Spelinspektionen.

The Swedish authority said in a statement that Spelpaus, its self-exclusion service, was built “on the basic idea that the Swedish Gambling Authority would not handle any suspensions manually”, and so the person would go onto the website and confirm their exclusion with an electronic ID.

Spelinspektionen said: “Until the summer of 2024, it was not possible to exclude oneself from gambling without an e-ID. After the court found in the spring of 2024 that there were no formal requirements for reporting, the Swedish Gambling Authority began work on enabling manual handling of suspensions in the system.”

However, the Ombudsman responded that the Swedish authority “cannot escape criticism because there was no alternative to banning” when the request was made and that “the information about why the processing was delayed should have been better”.