Main Developments in Competition Law and Policy 2025 – Sweden

Introduction and summary

With 2025 now concluded, it is an opportune moment to reflect on the main developments of the past year in Swedish competition law. Several trends from recent years have continued, including further litigative setbacks for the Swedish Competition Authority (the “SCA”) and the ongoing expansion of the Authority’s toolbox through new competition instruments and revised merger guidance.

The year saw Sweden’s first Towercast-style investigation, alongside several other concentration investigations, none of which ultimately resulted in a prohibition. A broader reform of the merger control framework is underway, with several regulatory initiatives published during the year. At the same time, the Patent and Market Court has experienced a noticeable increase in private enforcement actions, including both follow-on damages claims and applications for private injunctions.

Set out below are some of the key developments from 2025.

Proposed amendments to the Swedish merger control rules, new regulations and updated guidelines

On 24 February 2025, the SCA submitted an official letter to the Swedish Government proposing significant amendments to the Swedish merger control regime. The proposals aim to strengthen the Authority’s ability to intervene against anti-competitive concentrations.

Key proposals include removing the requirement that a concentration must affect a “substantial part of Sweden” in order to be prohibited, thereby enabling intervention in smaller and more local markets. The SCA also proposed extending the Phase II investigation deadline from three calendar months to 90 business days, as well as lengthening the time limits for court review.

The proposals follow a 2023 inquiry into new competition tools and reflect broader trends in EU competition law. The extended timelines are particularly noteworthy in light of a 2023 case in which the SCA was forced to clear a merger despite competition concerns due to statutory time constraints. Overall, the proposals seek to address perceived gaps in the current framework, particularly with respect to local market effects. Whether the Parliament will adopt the proposals remains to be seen.

On 26 May 2025, the SCA’s new Regulations and General Guidance on Merger Notifications (KKVFS 2025:1) entered into force. The regulations primarily require more detailed information on relevant markets at an earlier stage of the notification process.

The following day, on 27 May 2025, the SCA published updated non-binding Guidelines for Notification and Review of Mergers. These guidelines clarify, inter alia, the conditions for the SCA’s use of its call-in powers, how the Authority interprets the concept of a concentration, and what information it requires for its substantive assessment.

Public inquiry proposes a new competition tool for proactive market interventions

On 7 March 2025, a public inquiry (SOU 2025:22) proposed a new competition tool that would allow the SCA to impose pro-competitive remedies on one or several companies where it perceives that competition is not working properly.

The inquiry also addressed potentially anti-competitive mergers and acquisitions falling below the current notification thresholds. In such cases, including so-called “killer acquisitions” where larger firms acquire small or nascent competitors to prevent future competition, the inquiry proposed extending the SCA’s call-in powers. Much suggests that the a new competition tool will be available to the SCA by the end of this summer.

Patent and Market Court confirms SEK 16.9 million fine against Tapwell for RPM

On 21 March 2025, the Patent and Market Court upheld the SCA’s decision to fine Tapwell AB, a Swedish importer and wholesaler of premium kitchen and bathroom plumbing products, SEK 16.9 million (approximately EUR 1.5 million) for resale price maintenance (“RPM”). This is both the highest fine imposed by the SCA since it obtained fining powers in 2021 and the highest fine ever imposed in Sweden for a vertical restraint.

The SCA found that Tapwell had fixed minimum online resale prices for its kitchen and bathroom products with resellers Home Online and Hemgallerian. The resellers were required not to price products more than ten per cent below Tapwell’s recommended retail prices. Compliance was monitored through price comparison tools, and Tapwell directly contacted resellers to enforce adherence.

The Court confirmed that the conduct constituted a restriction of competition by object, referring to recent CJEU case law, including Super Bock (Case C-211/22). Tapwell’s argument that the pricing policy was intended to prevent free-riding by online retailers was rejected due to a lack of supporting evidence.

The judgment confirms the SCA’s strict approach to RPM and provides important guidance on the assessment of vertical restraints under Swedish law. The judgment has been appealed to the Patent and Market Court of Appeal.

SCA opens investigation into Bank-ID for restrictive agreements and abuse of dominance

In mid-2024, the Norwegian digital payment service Vipps MobilePay entered the Swedish market, initially using Bank-ID, Sweden’s largest electronic identification service, to verify users at first log-in, after which Vipps’ own authentication procedures were applied. Shortly after Vipps’ market entry, Bank-ID required its identification service to be used for every log-in and payment.

Bank-ID is jointly owned by several of Sweden’s largest banks. Vipps argued that, since Bank-ID connects all major Swedish banks, operating in the Swedish market is in practice impossible without an agreement with Bank-ID. Vipps therefore notified the practice to the SCA, which subsequently opened investigations into potential restrictive agreements and abuse of dominance.

The outcome of the investigation may have implications for several adjacent markets. It is also worth noting that the Swedish Government is developing a public electronic identification service, scheduled to be launched in 2026.

SCA finds that digital healthcare providers restricted competition through online advertising agreements

In April 2025, the SCA fined three digital healthcare providers—MinDoktor, Doktor.se and Doktor24—approximately SEK 26 million (around EUR 2.6 million) for anticompetitive agreements with their competitor Kry concerning Google Ads advertising.

The case originated in 2020, when Kry proposed separate bilateral agreements under which the parties would refrain from bidding on each other’s brand names in Google Search advertisements. All three competitors accepted the arrangements, with the result that consumers searching for a specific provider were no longer shown advertisements from competing services.

The SCA found that online advertising, and Google Ads in particular, plays a critical role in competition in the digital healthcare sector, as visibility in search results strongly influences consumer choice. The agreements were therefore considered restrictions of competition by object.

Kry received full immunity after submitting a leniency application. The decisions underscore the importance of online advertising for competition and consumer choice in digital markets. The SCA has also announced that it is investigating similar conduct in the pharmacy sector.

Strålfors’ acquisition of 21 Grams approved subject to extensive commitments

On 30 May 2025, the SCA approved Strålfors’ acquisition of 21 Grams, subject to extensive commitments. Both companies act as intermediaries for digital and physical customer communications, and Strålfors is a subsidiary of PostNord.

In its decision, the SCA identified significant competition concerns arising from the parties’ close links to PostNord, which holds a strong position in postal distribution with a market share exceeding 60 per cent. According to the SCA, the transaction could have enabled Strålfors to raise rivals’ costs, divert volumes to PostNord, and foreclose competitors such as CityMail. The Authority also expressed concerns related to the combination of the two largest intermediary service providers, particularly in light of its assessment that 21 Grams’ software solutions (iSort and PostSort) are regarded as indispensable by many customers.

To address these concerns, Strålfors offered a package of remedies that the SCA considered sufficient, including functional separation from PostNord’s distribution activities, access to postal optimisation services on FRAND terms, and strict information barriers. The commitments will apply until 2038 and are backed by substantial conditional fines ranging from SEK 300 to 450 million, as well as independent monitoring. The decision reflects the SCA’s approach to approving transactions involving dominant players where it considers that comprehensive remedies adequately address identified competition concerns.

SCA closes investigation into alleged abuse of dominance by Lupin GmbH

In 2023 and 2024, the SCA conducted a preliminary study into high prices for repurposed orphan drugs—medicinal products originally developed for a different indication and later granted orphan designation, thereby extending market exclusivity after patent expiry.

In May 2024, the SCA opened a formal investigation into the pricing of the orphan drug Namuscla, for which Lupin had obtained market exclusivity through repurposing. The investigation examined whether the pricing constituted an abuse of dominance. The case was closed on 15 October 2025 without a finding of infringement.

Sweden’s first Towercast-style investigation is closed

In June 2024, the two Nordic media monitoring services, Infomedia and Retriever, announced plans to merge. As the transaction did not meet Swedish notification thresholds, it was neither notifiable nor subject to the SCA’s call-in powers.

Due to concerns regarding the parties’ combined market power, the SCA nonetheless initiated an investigation into potential abuse of dominance, following the Towercast judgment (Case C-449/21), in which the CJEU clarified that merger control rules do not preclude the application of abuse of dominance provisions.

On 21 November 2025, the SCA closed the investigation. In Norway, the same transaction was reviewed under the merger control framework and was approved only subject to the divestment of Infomedia Norway.

Continued growth in private enforcement before the Patent and Market Court

Private competition enforcement in Sweden continues to gain momentum. The Patent and Market Court is currently handling several high-value damages claims and injunction proceedings across a range of sectors. Notable pending damages actions include PriceRunner’s follow-on claim against Google arising from the European Commission’s 2017 Google Shopping decision, which was heard in late 2025 and for which a ruling is expected in spring 2026.

Volvo Cars’ claim against ZF arising from the OSS cartel remains ongoing following Volvo’s withdrawal of its claim against Autoliv in October 2025. In addition, a damages claim by the Dutch collective redress foundation STCC against Scania relating to the Trucks cartel has been reported, though proceedings in Sweden are progressing in the context of parallel litigation stemming from the confirmed cartel liability of Scania under EU competition law.

Two private injunction-type disputes previously progressing in Sweden have since concluded: Sweetspot’s competition complaint against the Swedish Golf Association (SGF) was discontinued after the parties agreed a commercial cooperation in late 2025, and a separate excessive pricing claim against district heating provider Nevel was dismissed by the Patent and Market Court in early 2026.

Together, these matters reflect an increasingly active private enforcement landscape alongside public enforcement, in line with the objectives of the EU Competition Damages Directive.

Reflections on the year

Overall, 2025 has been a year of transition in Sweden. Legislative reform initiatives and the growing number of private enforcement cases suggest that the Swedish competition law landscape is evolving. At the same time, merger activity has remained relatively subdued, resulting in fewer merger reviews than in previous years.

Economic forecasts for 2026 are cautiously optimistic, and with the potential introduction of a new competition tool and expanded call-in powers, the SCA appears likely to face an increasingly demanding enforcement agenda in the years ahead.