Swedish Court Upholds Spelinspektionen's Bingo Licence Denial
Jacob Mitchell 
Key Takeaways:
- Swedish Administrative Court of Appeal upheld Spelinspektionen's bingo licence denial.
- Operator Föreningen Idrottens Spel sought a licence for 297 retail terminals.
- Regulator cited suitability concerns for non-traditional bingo locations.
- Court reversed a previous ruling that favoured the operator.
- Ruling could impact bingo's sustainability and funding in Sweden.
The Administrative Court of Appeal in Jönköping, Sweden, has upheld Spelinspektionen's decision to deny a licence for operating non-temporary electronic bingo terminals outside traditional bingo halls. This ruling confirmed the gambling regulator's authority to restrict where bingo can be offered under Sweden's Gaming Act. The decision overturned a previous ruling by an Administrative Court in Linköping, which would have permitted the retail bingo operation.
Background to the Bingo Licence Dispute
Operator Föreningen Idrottens Spel i Sverige applied in June 2023 for a licence to provide charitable bingo via electronic terminals. These terminals were intended for approximately 297 retail outlets across Sweden, primarily in small shops and kiosks. The association aimed to operate these terminals outside the established framework of traditional bingo halls.
Spelinspektionen declined the application on 21 March 2024, citing concerns that non-temporary bingo outside traditional halls would not meet the statutory “suitability” requirement under chapter 3, section 1 of the Gaming Act (2018:1138). The regulator highlighted public interest concerns, specifically that kiosks increased accessibility for children and young people due to lower social control in retail environments.
The suitability requirements included ensuring the gambling activity is very safe, has a high level of consumer protection, limits negative impacts, and is not used to support criminal activities. In November 2024, the Administrative Court in Linköping initially disagreed with Spelinspektionen, ruling that the Gaming Act did not explicitly confine non-temporary bingo to traditional bingo halls. This court emphasised flexibility for market changes and remitted the matter, effectively invalidating the regulator's denial.
Appeals Court Ruling and Industry Impact
Spelinspektionen subsequently appealed the Linköping court's decision. The Administrative Court of Appeal (Kammarrätten) has now reversed the November 2024 ruling, reinstating the regulator’s original refusal to approve the licence. The appeals court stressed that the Gaming Act reflects a restrictive attitude towards self-service gambling terminals.
The court noted that the law contains explicit limits on permissible locations for gaming machines, with certain exceptions for bingo traditionally confined to environments with strong social control, such as bingo halls or licensed restaurants. It endorsed the regulator’s view that placing bingo terminals in retail kiosks and outlets would undermine the protective context envisioned by the legislature.
The operator's proposed model represented a “total change” of the current system, potentially increasing the approximately 50 traditional bingo premises to nearly 300 dispersed retail locations. The appeals court concluded there were sufficient grounds under the statutory suitability criteria to deny the licence.
Implications for Swedish Bingo Operations
The operator warned that this ruling could threaten online gambling in Sweden. Furthermore, it suggested that the decision might reduce crucial funding streams associated with charitable bingo operations. This outcome reinforces the regulator's interpretation of the Gaming Act regarding the appropriate environments for certain gambling activities and the importance of maintaining social control in gambling settings.
