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The Swedish trade association for online gambling (BOS) has written a letter to the gambling regulator to express its concern about the lack of umbrella licences for suppliers just days before applications are set to be accepted.

Sweden is set to begin accepting applications for mandatory supplier licensing in the coming days, as it becomes one of the few countries where B2B gambling companies must seek direct regulatory approval, but industry figures say they face a potentially overwhelming volume of paperwork.

BOS states in its letter that it wants the Swedish Gambling Authority (SGA) “to publish guidelines for permits for gambling software, with clearly defined definitions of which businesses are affected by the new law and which are not”.

A spokesperson for the SGA told VIXIO that a “decision regarding [umbrella licences] will be taken shortly”.

Additionally, “information and a Q&A will be published in the near future”.

However, the regulator declined to go into more detail at the time of writing.

The letter was written by BOS secretary general Gustaf Hoffstedt and shared with VIXIO GamblingCompliance.

It starts off by thanking the SGA for involving the trade group “to such a large extent in the development of the upcoming permits for gambling software”.

However, it goes on to say that it sees just one issue remaining: the lack of an umbrella permit that would allow the holder to take sufficient responsibility for its sub-contractors and subsidiaries.

“Without an umbrella permit, it may, in the worst case, require a permit to, for example, provide a game developer with audio files, as well as a permit requirement with all kinds of other subcontractors and subsidiaries of services and products,” the letter states.

The same issue has been flagged separately to VIXIO GamblingCompliance by a gambling supplier, who is concerned that the lack of an umbrella permit would require them to apply for around 20 licences.

The games supplier said: “If we need 20 licences it's a lot of work for us and the SGA. Will be a lot of additional admin on an ongoing basis too. I don't think they have thought this through.”

BOS fears that would also lead to “high costs for the companies” and that it is “beyond reasonable doubt that such a thing is not the desire of the legislature”.

The supplier also shared BOS’ concern that a Q&A on the new licence application has still not been published.

On November 23, 2022, the Riksdag, the Swedish parliament, approved the creation of a gambling software supplier licence, along with proposals for an extended ban on the promotion and advertising of illegal gambling, with the aim to tackle unlicensed gambling in Sweden.

The software's supplier's licence will come into force on July 1, 2023, and the SGA is expected to accept applications for the licence from March 1, 2023.

In other jurisdictions, such as the UK, the Gambling Commission has published information in the past entitled “When can a company operate under another’s licence?”, which provides guidance on the circumstances in which it will issue an “umbrella licence” for a group of companies.