Sweden’s Administrative Court of Appeal in Jönköping (Kammarrätten) has upheld a decision by the gambling regulator, the Swedish gambling authority Spelinspektionen, to refuse a licence for non-temporary electronic bingo terminals placed outside traditional bingo halls. The ruling, published Tuesday, confirms the regulator’s power to control where bingo can lawfully be offered under the Gaming Act (2018:1138). It overturns a lower court decision from November 2024 that had sided with the operator. For Sweden’s charitable gaming sector, the stakes are concrete: the proposal would have multiplied bingo’s physical footprint roughly sixfold.
What the Ruling Means for Sweden’s Bingo Operators
The case turns on a narrow but consequential question — where bingo belongs. The court read the Gaming Act as deliberately restrictive towards self-service gambling terminals, and that reading now stands as the operative interpretation. Below are the practical implications for licence-holders and the wider charitable gaming market.
- Regulatory authority reaffirmed: Spelinspektionen retains discretion to deny licences on suitability grounds even where the statute does not name a specific prohibited location.
- Retail expansion stalled: Plans to install terminals in kiosks and small shops are effectively closed off, at least under the current legal framework.
- The roughly 50 existing traditional bingo premises remain the lawful venue, rather than the proposed 297 retail sites.
- Funding pressure for associations: Charitable operators who rely on bingo revenue now face a narrower distribution model, and the operator behind the case has warned of consequences for sustainability.
- Precedent value: The appeals court has handed the regulator a template for resisting venue expansion arguments grounded in “market flexibility.”
A Dispute That Began in 2023
In June 2023, the operator Föreningen Idrottens Spel i Sverige applied for a licence to run charitable bingo through electronic terminals in approximately 297 retail outlets across the country, mostly small shops and kiosks. The association wanted to operate these machines entirely outside the structure of traditional bingo halls.
Spelinspektionen rejected the application on 21 March 2024. Its reasoning leaned on chapter 3, section 1 of the Gaming Act, which sets out a statutory “suitability” test. The regulator argued that bingo conducted on a permanent basis in retail environments could not meet it.
The four pillars of that test, as cited by the regulator, require:
- that the gambling activity is very safe;
- a high level of consumer protection;
- that the negative effects of gambling are limited;
- and that gambling is not used to support criminal activity.
The regulator’s central worry was exposure. Kiosks and convenience outlets sit closer to children and young people, and they lack the social control of a dedicated bingo hall (a distinction the legislature treated as more than incidental).
How the Lower Court Saw It Differently
In November 2024, the Administrative Court in Linköping disagreed with the regulator. Its judges found that the Gaming Act did not explicitly confine non-temporary bingo to traditional halls, and they emphasised the need to adapt to a changing gaming market. The court sent the matter back for fresh consideration, which in practice invalidated the original denial.
That gave the operator a window. It did not stay open long.
Why the Appeals Court Reversed the Decision
Spelinspektionen appealed, and Kammarrätten has now reinstated the original refusal. The appeals court stressed that the Gaming Act was shaped by a restrictive posture towards self-service gambling terminals, with explicit limits on where gaming machines may be placed. Bingo enjoys certain exceptions, but those exceptions, the court reasoned, exist precisely because bingo has traditionally been confined to settings with strong social control — bingo halls and licensed restaurants among them.
Move the terminals into kiosks, and that protective context evaporates. The court accepted the regulator’s framing that the operator’s model amounted to a “total change” of the existing system, lifting the count from around 50 supervised premises to nearly 300 scattered retail points. On the statutory suitability criteria, the judges found sufficient grounds to deny the licence.
The operator countered that the ruling could threaten the long-term viability of bingo in Sweden and choke off funding streams that charitable causes depend on. Whether that warning materialises is a separate question, and one the court did not weigh.
The Wider Regulatory Signal
This decision lands at a moment when European regulators are tightening their grip on accessibility — where gambling products sit, who can reach them, and under what supervision. Sweden’s approach has long favoured controlled environments over convenience. The Jönköping ruling reinforces that philosophy and arguably sharpens it.
For operators, the message is direct: statutory silence on a specific location does not equal permission. The regulator can still invoke the suitability test to fill the gap, and now an appeals court has confirmed it may do so. That shift matters because it narrows the room for creative expansion arguments built on the idea that the law must “keep pace” with commercial models.
There is also a structural tension here that the ruling exposes without resolving. Charitable gaming associations rely on revenue that flows back into community and sports funding, yet the safest delivery model — the supervised hall — is also the least scalable. Squeeze accessibility, and you protect consumers; squeeze it too hard, and you may erode the funding base the model was built to support. The court chose protection. The funding consequences fall outside its remit, and so they remain unanswered for now.
Frequently Asked Questions
What did the court actually decide?
Kammarrätten in Jönköping upheld Spelinspektionen’s refusal to license non-temporary electronic bingo terminals in retail outlets, reversing a 2024 lower court ruling that had favoured the operator.
Which law governs the decision?
The Gaming Act (2018:1138), specifically the suitability requirement set out in chapter 3, section 1. That provision demands safety, consumer protection, limited harm, and no link to criminal activity.
How many locations were at stake?
The operator sought to place terminals in roughly 297 retail outlets, against the existing base of about 50 traditional bingo premises.
Can the operator still offer bingo?
Yes, but within the traditional framework. The ruling blocks the retail-terminal model, not bingo itself.
Does this set a precedent for other operators?
In practice, it strengthens the regulator’s hand. Operators arguing for venue expansion on flexibility grounds now face a confirmed appeals-level interpretation working against them.
