How Sweden's deposit limits and duty of care rules work

On October 8, 2026 the Court of Appeal in Jönköping left a warning and a SEK 40 million penalty fee against Hillside (Sports) ENC, and a warning and a SEK 4 million penalty fee against Hillside (Gaming) ENC. Spelinspektionen, Sweden's gambling authority, licensed the sports company for betting under P1811 and the gaming company for commercial online gambling under P1812, both granted on November 27, 2018. The companies offer play on bet365.com.

Between January 1, 2019 and April 18, 2022 those customers could still choose "ingen gräns", no limit. Sweden deposit limits are a number the player has to specify under Chapter 14, section 7 of the Gambling Act (2018:1138). Section 1 of that chapter is the duty of care. A hidden ceiling of SEK 500 million was not the number the section requires.

What the player has to set before the first deposit

Chapter 11, section 3 of the Gambling Ordinance (2018:1475) says the limits are stated per day, per week and per month. A reduction applies at once. A rise applies no earlier than 72 hours later. Section 5 tells the licensee to stop deposits from passing a limit the player has set, and to make contact if the player raises a limit or sets monthly deposits above SEK 10,000. That contact is how the duty of care in Chapter 14, section 1 is supposed to start.

Login time works differently, which is why the deposit rule is easy to miss. Under section 4 the player must say whether session time should be limited and, if so, for how long. Declining a time limit is allowed. Declining a deposit limit is not.

Ordinary online play has no statutory maximum on the figure itself. A player who types a very large number has still set a limit. A player offered "no limit" has not.

Why Sweden deposit limits reject a hidden ceiling

Hillside's account, in Spelinspektionen's decisions of April 24, 2023, was that no limit had been available from the day the licences started. Where a customer picked it, the system held a technical ceiling of SEK 500 million the customer could not see. The option came off on April 19, 2022. Supervision had opened on December 21, 2021. Diary numbers 21Si2726 and 21Si2727. The decisions were to be communicated on April 27, 2023.

Six of the 10 Hillside Sports customers who lost the most between October 17 and December 17, 2021 lacked a limit on at least one of the day, week or month fields. Four lacked limits entirely. Of the five files read in full, two had none and one lacked them for part of the period.

"Att tolka en lagregel som stadgar att kunderna ska ha en insättningsgräns på så sätt att den utgör en öppning för att tillåta kunden att göra valet ”ingen gräns” är inte bara felaktigt, det är också uppseendeväckande och nonchalant mot de självklara skyldigheter ett spelbolag har att följa regelverket och skydda kunderna."

Spelinspektionen, decision of April 24, 2023, diary 21Si2726, against Hillside (Sports) ENC (Spelinspektionen)

Read plainly, that passage is not a complaint about a high number. A duty to have a deposit limit is not permission to offer a way around it.

Sweden deposit limits are a maximum the player specifies, not a ceiling hidden in the software. Chapter 14, section 7 of the Gambling Act requires that maximum for online gambling. Chapter 11, section 3 of the Gambling Ordinance (2018:1475) says the player states it for the day, the week and the month. A lower figure applies at once. A higher figure waits at least 72 hours. Section 5 tells the licensee to block deposits past the figure, and to make contact if the player raises a limit or sets monthly deposits above SEK 10,000. Spelinspektionen's decision of April 24, 2023 records that Hillside customers could choose no limit from January 1, 2019 through April 18, 2022, with a technical ceiling of SEK 500 million the customer could not see. On June 13, 2024 the Administrative Court in Linköping held that the ceiling did not cure the breach, because the limits had not been obligatory. The Court of Appeal left that finding in place on October 8, 2026.

Counsel for Hillside told the Administrative Court the opposite. A customer can type an enormous figure, so a forced number changes little, and SEK 500 million was a figure anyway. Government bill 2017/18:220 treats the limit as the player's own decision about their play. A back-end cap the player never chooses does not stand in for it. The judgments do not support the claim that an invisible ceiling is a limit the player has set.

What the duty of care requires after the first message

Spelinspektionen's English text of the Act puts the duty in working language. Social and health considerations have to be taken in the operation, so as to protect players from excessive gambling and help them reduce it when that is called for. Continuous monitoring is part of the duty. An action plan has to say how it will be done.

Case 2341-24, the sports judgment we read, treats delay itself as the failure. Broader measures, including restrictions on access, cannot wait once they are necessary. They have to keep pace with the gambling.

"Det innebär att om en spelare uppvisar ett omfattande riskbeteende och ett första meddelande inte har någon effekt måste licenshavaren skyndsamt eskalera sina åtgärder."

Kammarrätten i Jönköping, judgment of October 8, 2026, case 2341-24, Hillside (Sports) ENC (Court of Appeal)

Case 2342-24, the gaming judgment of the same day, uses that sentence too. Initial contact with most of the customers was not the fight. Continued play after it was.

Limits on those five sports files were high or absent. Pop-ups went out around large deposits, and the wording on the screen did get firmer. Manual review and suspension came later, too long after the first warning about losses on a short clock.

Customer 1, born in 2001 and so inside the 18 to 24 group, was scored medium risk by the company. Spelinspektionen called the risk high, citing age, daily deposits and night-time play. Between the first pop-up and the follow-up, that customer deposited SEK 486,376 and customer 2 deposited SEK 135,000. The authority lacked data for the whole of customer 1's gap, and it said so. On the interval it could see, the follow-up was already late. Customers 2, 4 and 5, on the sports file, did not receive those two messages in the window at all.

Effect is the test the authority used. A note on responsible play, a pointer to Spelpaus and a spending prompt do not finish the duty if the pattern does not change. Tighter restrictions have to follow. On these files they mostly arrived late.

Both companies use bet365.com. Deposit limits and the login-time choice are set once, and deposits land in a single account that funds betting and casino. One broken tool is two licensed businesses. That is why both supervisions opened on December 21, 2021, and why the courts heard the cases as a pair. At the joint hearing on March 4, 2024, Robert Joseph Munro presented Hillside's early risk detection system, ERDS.

Fees follow each book's turnover, not a shared pot. The sports company is the larger licensed business, so the same configuration produced the larger fee. The April 24, 2023 decisions record Hillside Sports' 2021 gross gaming revenue at SEK 724.6 million and Hillside Gaming's at SEK 69,042,354. Original penalties were SEK 65 million and SEK 14 million. Those sums did not survive, for a reason in the turnover rules that has nothing to do with a fresh look at the play.

What a player can still do when the number is high

A real gap sits in the middle of this rule, and short accounts skip it. Nothing in ordinary online play stops a player typing a limit so high that it will never bind a session. Hillside was right about that fact and wrong about the legal consequence. The Administrative Court took the point of the rule from the bill: an active choice, not a cap chosen by the regulator. Once a number exists, the contact duty on a rise, and above SEK 10,000 a month, has something to attach to. "No limit" left Chapter 11, section 5 with nothing to bite on.

What the law still gives a player, and still requires of a licensee, is a short list.

Three deposit figures. The player sets a day limit, a week limit and a month limit before online play, under Chapter 14, section 7 of the Act and Chapter 11, section 3 of the ordinance.
No opt-out. A "no limit" choice fails, and so does a hidden ceiling of the SEK 500 million kind recorded in the decisions of April 24, 2023.
Speed of a change. A lower limit applies immediately. A higher limit waits at least 72 hours.
Contact above SEK 10,000. Raising a limit, or setting monthly deposits above that sum, requires the licensee to make contact.
Escalation. If a first message has no effect on extensive risky play, the licensee must escalate promptly. That is the Court of Appeal's holding of October 8, 2026.
Named higher-risk groups. The action plan has to cover players aged 18 to 24 and players returning from self-exclusion. Hillside Sports' original plan named neither.
Spelpaus. Chapter 14, section 12 lets a player self-exclude from all register-based gambling, at every licensee, for a set period or indefinitely. An indefinite exclusion cannot be lifted for 12 months. Online casino also carries a 24-hour break under section 11.

Britain's regime is a different statute, not a stricter copy of this one. The Gambling Commission has been phasing operator deposit-limit tools on its own timetable, covered in the extension of the online deposit-limit deadline. Its staged financial risk assessments ask whether the money is affordable. A Swedish contact at SEK 10,000 a month does not. The Netherlands has moved toward a means test on deposits. Sweden has not. The number here can still be high, provided the player types it.

Why five customer files carried a wider breach

Hillside told the Court of Appeal that five customers were a fraction of a per mille of the base, too thin to prove a duty-of-care failure. It also said the authority had found the duty met for at least half of the customers reviewed. Those points are in the pleadings, as the judgments record them. They did not decide the case.

Excessive gambling, initial contact, then more play. That is the sequence the court found. For the sports company, manual review and access limits took a long time where they happened at all. Hillside's submission, recorded rather than found as fact, was that 60% of the sports sample were later shut off by the company and a further 20% self-excluded. A late closure is not a timely one.

Missing limits, not the wider routines, were what the Administrative Court said justified the warning on their own.

Particular weight, when the appeal court set the fee, went to a deposit-limit breach that was serious and had run for a long time. Five files prove the delay. A configuration that applied across the base for more than three years is what makes the breach systemic. These judgments do not support a story about five unlucky accounts.

How the penalty is capped, and why the first fees fell

Chapter 18, section 12 is a ladder. The authority can order a fix, change conditions, or issue a reprimand. A serious breach means revocation, unless a warning is enough. A negligible breach, or one the licensee has already put right, can mean no intervention. Both courts left the licences in place and kept the warnings.

Stopping at a warning was a narrower call than "the company had improved". In the sports decision of April 24, 2023, Spelinspektionen listed a late removal of "no limit", a free-text field so the customer would type a ceiling, an action-plan change for customers losing more than SEK 10,000 a month, and lower ERDS thresholds for 18 to 24-year-olds and for players back from self-exclusion. Those steps would help if they were actually followed. A company that had treated "no limit" as compliance could still be doubted. The authority stopped anyway. Clarifications in the decision were, for the time being, enough to assume future compliance, so a warning was sufficient. Later, the Administrative Court used the adjustments to cut the fee. It did not use them to drop the warning.

A penalty fee under Chapter 19, section 13 of the Gambling Act runs from a floor of SEK 5,000 to 10% of the previous year's turnover from the licensed activity only. The Supreme Administrative Court, in HFD 2023 ref. 25, read turnover as net turnover. That reading is why the fees of April 24, 2023 did not last. Spelinspektionen had used gross. Hillside Sports' 2021 gross turnover of SEK 8,845,644,242 produced a ceiling of SEK 884,564,424, and the authority set SEK 65 million. Hillside Gaming's decision set SEK 14 million against 2021 gross turnover of SEK 1.97 billion and GGR of SEK 69,042,354. Once net turnover was the base, the Court of Appeal capped the sports fee at SEK 72 million, about 10% of roughly SEK 720 million. The gaming judgment capped that fee at SEK 6.9 million. The sums that survived, SEK 40 million and SEK 4 million, sit inside those caps. Each is one assessment of both breaches, not a price per file.

The Administrative Court in Linköping made that cut on June 13, 2024, to SEK 40 million and SEK 4 million. The appeal court called both proportionate and dismissed the appeals on October 8, 2026. Sweden deposit limits, not the five files, are what that court said should weigh heaviest. A warning left the Swedish offer standing. It did not find the breach small.

Spelpaus, the state self-exclusion register, sits in the same chapter as the deposit-limit rule, and an entry binds every licensee at once. Britain's multi-operator scheme is built differently. How it registers a player, and where it stops, is set out in our explainer of how GAMSTOP self-exclusion works across UK operators.

This article is informational analysis only and is not gambling or financial advice. Figures are as attributed in the text.

18+Gambling carries financial risk and can be addictive. If you or someone you know needs help, visit GamCare (UK), call 1-800-GAMBLER (US), or see our Responsible Gambling page.