Fintech & payments regulation in Sweden (2026)
Fintech and digital payments in Sweden: licensing regime.
Sweden operates a mature, fully articulated licensing regime for payment institutions and e-money institutions supervised by Finansinspektionen, implementing EU PSD2 and EMD2 through national statute. Open banking is live under PSD2, but instant payment coverage remains limited, the Riksbank publicly criticised Swedish banks in March 2026 for failing to offer interoperable instant payments and set a March 2027 compliance target. The EU PSD3/PSR package reached provisional political agreement in November 2025, with direct application of the PSR expected approximately 18 months after entry into force, requiring Sweden to update its Payment Services Act accordingly.
Legal framework
Payment Services Act (SFS 2010:751, last amended SFS 2025:253), Electronic Money Act (SFS 2011:755), Consumer Credit Act (2010:1846) implementing EU PSD2/EMD2; competent authority: Finansinspektionen (FI); Riksbank oversees payments infrastructure and statistics
How to get an EMI license in Sweden
To provide electronic-money or payment services in Sweden you need authorisation as an Electronic Money Institution (EMI), supervised by Finansinspektionen (FI), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- Finansinspektionen (FI)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Sweden covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
Step by step: getting an EMI license in Sweden
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
Deposit and evidence the €350,000 initial capital.
Submit the application to the national competent authority.
The authority has three months from a complete application to grant or refuse.
On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Sweden
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
Ongoing obligations in Sweden
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
Key points: digital payments & fintech in Sweden
Payment Institution Licensing
Payment services above EUR 3 million/month turnover require full authorisation from Finansinspektionen under the Payment Services Act (SFS 2010:751, amended SFS 2025:253). Application fee is SEK 405,000; annual supervision fee SEK 150,000. Smaller operators may seek registered (exempt) status below that threshold.
E-Money Institution (EMI) Licensing
Issuance of electronic money requires authorisation under the Electronic Money Act (SFS 2011:755). Minimum initial capital is EUR 350,000; application fee SEK 378,000; processing typically takes 3-6 months. Sweden-authorised EMIs appear in the EBA's central PSD2 register.
Open Banking & Instant Payments
Open banking account-information and payment-initiation services operate under PSD2 rules. Swish, the dominant mobile rail, was historically a bank-only system; in September 2025 Zimpler became the first non-bank payment institution to connect directly. The EU Instant Payments Regulation entered into force October 2025, and the Riksbank's Payments Report (March 2026) set a March 2027 deadline for banks to offer interoperable instant payment services.
BNPL & Consumer Credit Rules
BNPL is regulated under the Consumer Credit Act (2010:1846). Following repeal of the Act on Certain Consumer Credit Activities (effective 1 July 2025), consumer credit may only be granted or brokered by licensed banks, credit market companies, or payment institutions operating strictly within their payment-transaction credit scope. Finansinspektionen supervises creditworthiness assessment and disclosure obligations.
Payments Reporting (RBFS 2025:1)
The Riksbank introduced regulation RBFS 2025:1 requiring payment service providers and payment system operators to submit regular, detailed payment-statistics data, strengthening the Riksbank's statutory monitoring of the payments market.
PSD3/PSR Transition
The EU's PSD3 and Payment Services Regulation (PSR) reached provisional political agreement on 27 November 2025; Official Journal publication is expected around mid-2026. The PSR will be directly applicable 18 months after entry into force, with conduct-of-business rules moving from directive-level (discretionary) to regulation-level (uniform); Sweden must transpose PSD3 and amend the Payment Services Act within the implementation window.
EMI license in Sweden: FAQ
Do you need a license to run an e-money business in Sweden?
Yes. To provide electronic-money or payment services in Sweden you need authorisation as an Electronic Money Institution (EMI), supervised by Finansinspektionen (FI), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
Which authority issues EMI licenses in Sweden?
Finansinspektionen (FI).
How much does an EMI license cost in Sweden?
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
How long does it take to get an EMI license in Sweden?
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
What documents do you need for an EMI license in Sweden?
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
What is the application process for an EMI license in Sweden?
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Does an Sweden EMI license work in other EU/EEA countries?
Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Timeline of decisions
- Enforcement · officialFinansinspektionen Issues Klarna Bank SEK 500 Million Fine for AML Violations
FI issued Klarna Bank AB a formal remark and a SEK 500 million (~€43 million) administrative fine after finding its general risk assessment lacked analysis of how products could be misused for money laundering, and its customer due-diligence procedures were incomplete. This is Sweden's largest AML sanction against a payment firm.
Finansinspektionen
- Decision · officialAll RIX-INST Banks Mandated to Accept Instant Payments Under Nordic NCT-INST Rules
From November 2024, every bank connected to the Riksbank's RIX-INST settlement platform became obligated to receive instant credit-transfer payments according to the Nordic Payments Council's NCT-INST rule set, opening the instant payment market to non-Swish competitors and increasing interoperability.
Sveriges Riksbank
- Law · officialEU Instant Payments Regulation (2024/886) Enters Into Force
Regulation (EU) 2024/886 entered into force on 8 April 2024, requiring banks offering standard euro credit transfers, including Swedish banks with euro-denominated accounts, to also offer instant euro payments at the same fee from January 2025 onward, and to provide Verification of Payee services.
European Commission — DG FISMA
- Decision · officialSwish Payments Fully Migrated to RIX-INST Central-Bank Money Settlement
Since February 2024, all inter-bank Swish transactions are settled in real time through the Riksbank's RIX-INST system in central-bank money, replacing deferred net settlement and aligning Sweden's dominant retail payment service with the European TARGET Instant Payment Settlement (TIPS) infrastructure.
Sveriges Riksbank
- Decision · officialRiksbank Concludes e-Krona Technical Pilot; Platform Shut Down
After four pilot phases, including offline CBDC payments testing, the Riksbank shut down the e-krona technical platform in autumn 2023 and shifted to policy-design research. Any decision to issue an e-krona was declared a political question; future work centres on monitoring EU digital-euro development.
Sveriges Riksbank
- Decision · officialRiksbank Launches RIX-INST: 24/7 Real-Time Interbank Settlement in Central-Bank Money
The Riksbank introduced the RIX-INST service, enabling Swedish banks to settle payments between each other in real time around the clock in central-bank money for the first time. RIX-INST became the foundational infrastructure precondition for broad instant payment adoption, including Swish's subsequent migration.
Sveriges Riksbank
- Decision · officialRiksbank Launches e-Krona Pilot Project on Distributed Ledger Technology
The Riksbank began its multi-phase e-krona pilot in early 2020 to test technical possibilities for a retail central-bank digital currency, initially built on R3's Corda platform. The pilot explored design, access models, programmable payments, and cross-border use, making Sweden one of the first advanced economies to run a hands-on CBDC pilot.
Sveriges Riksbank
- Law · officialPSD2 Strong Customer Authentication Requirements Take Effect in Sweden
The EBA Regulatory Technical Standards on Strong Customer Authentication (Commission Delegated Regulation 2018/389) became enforceable on 14 September 2019, mandating two-factor authentication for online payments. This tightened security across all Swedish online card and account-based payment flows.
Finansinspektionen
- Guidance · officialFinansinspektionen Establishes Innovation Centre for Fintech Firms
Following a government mandate, FI launched a dedicated innovation hub to provide regulatory guidance to companies developing innovative financial services. The centre became the primary first contact for fintech start-ups navigating licensing requirements, helping Sweden maintain its position as one of Europe's most innovation-friendly financial regulatory environments.
Finansinspektionen
- Law · officialSweden Transposes 4th AML Directive; Payment Institutions Brought Fully into AML Regime
The Anti-Money Laundering and Counter-Terrorist Financing Act (2017:630) and Finansinspektionen's regulations FFFS 2017:11 entered into force, transposing EU Directive 2015/849 (AMLD4). Payment institutions and e-money issuers were brought fully within the Swedish AML supervisory perimeter, with mandatory risk assessments, due-diligence obligations and reporting to the Financial Intelligence Unit.
Finansinspektionen
- Decision · officialSwish Mobile Payment Service Launched by Six Major Swedish Banks
Handelsbanken, Nordea, SEB, Swedbank, Länsförsäkringar, and Danske Bank launched Swish in partnership with Bankgirot and the Riksbank, enabling real-time person-to-person transfers via mobile number linked to a bank account. Swish grew to ~9 million users by 2024 (≈86% of the population) and became the de facto national retail payment rail.
Sveriges Riksbank
- Law · officialPayment Services Act (2010:751) Enters Into Force, Implementing EU's First Payment Services Directive
Sweden enacted Lag (2010:751) om betaltjänster, transposing Directive 2007/64/EC (PSD1) and creating the national licensing regime for payment institutions and electronic money institutions for the first time. Finansinspektionen became the supervisory authority; the Act established the foundational legal framework still in force today (as amended).
Sveriges riksdag
Sources
- fi.se/en/payments/apply-for-authorisation/payment-services/
- fi.se/en/payments/apply-for-authorisation/electronic-money/
- riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssamling/lag-2010751
- eba.europa.eu/risk-and-data-analysis/data/registers/payment-institutions-register
- riksbank.se/en-gb/payments--cash/payments-in-sweden/payments-report-2026/developm
- riksbank.se/en-gb/press-and-published/notices-and-press-releases/notices/2025/swe
- twobirds.com/en/insights/2025/sweden/sweden---new-reporting-requirements-for-payme
- twobirds.com/en/trending-topics/buy-now-pay-later-regulatory-tracker/sweden
- schjodt.com/news/new-legislative-proposal-the-swedish-act-on-certain-consumer-cre
- nortonrosefulbright.com/en/knowledge/publications/cedd39c6/psd3-and-psr-from-provisional-agre
- practiceguides.chambers.com/practice-guides/fintech-laws-and-regulations/sweden
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