COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Sweden Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2020 Rule of Law Report The rule of law situation in the European Union
Date: 2020-09-30
Institutions: European Commission, Secretariat-General
Subjects: Sweden, administrative transparency, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.9.2020  SWD(2020) 326 final  COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Sweden Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  2020 Rule of Law Report      The rule of law situation in the European Union {COM(2020) 580 final} - {SWD(2020) 300 final} - {SWD(2020) 301 final} - {SWD(2020) 302 final} - {SWD(2020) 303 final} - {SWD(2020) 304 final} - {SWD(2020) 305 final} - {SWD(2020) 306 final} - {SWD(2020) 307 final} - {SWD(2020) 308 final} - {SWD(2020) 309 final} - {SWD(2020) 310 final} - {SWD(2020) 311 final} - {SWD(2020) 312 final} - {SWD(2020) 313 final} - {SWD(2020) 314 final} - {SWD(2020) 315 final} - {SWD(2020) 316 final} - {SWD(2020) 317 final} - {SWD(2020) 318 final} - {SWD(2020) 319 final} - {SWD(2020) 320 final} - {SWD(2020) 321 final} - {SWD(2020) 322 final} - {SWD(2020) 323 final} - {SWD(2020) 324 final} - {SWD(2020) 325 final}  
 
 
ABSTRACT 

The  Swedish  justice  system  is  characterised  by  a  high  level  of  perceived  judicial 
independence. To further foster judicial independence, Sweden has, in a cross-party inquiry, 
launched  a  parliamentary  process  to  examine  certain  elements  of  the  constitutional 
framework relating to the judiciary. Additionally, a recent amendment to the Code of Judicial 
Procedure  has  codified  the  rules  that  govern  the  allocation  of  cases.  The  Government 
launched  a  legislative  initiative  to  address  challenges  relating  to  the  digitalisation  of  the 
justice system. In particular, the possibility to complete certain steps of the judicial procedure 
online is partially available, both as concerns submitting a case and transmitting summons. 

According to surveys, Sweden is perceived as one of the least corrupt countries in the EU and 
the world. The Penal  Code criminalises most forms  of public  and private corruption. While 
there  is  no  codified  comprehensive  anti-corruption  strategy  in  place,  the  Government  has 
announced  its  initiative  to  develop  a  National  Action  Plan  on  anti-corruption.  The  public 
institutions have built a reputation for transparent administration and a reliable and functional 
corruption  prevention  framework.  Lobbying  is  not  regulated  by  law.  A  broad  right  to 
information  is  a  core  element  of  the  Swedish  approach  to  corruption  prevention  and  public 
officials  are  entitled  to  disclose  information  to  the  media.  Measures  are  in  place  to  ensure 
whistle-blower protection and a review is ongoing to assess the need for amendments in view 
of  the  EU  Directive  (EU)  2019/1937  on  the  protection  of  persons  who  report  breaches  of 
Union law. Foreign bribery remains an area of risk. 

Sweden has a long regulatory tradition of media freedom and pluralism. Its legal safeguards 
concerning  media  freedom  and  pluralism  stem  from  both  constitutional  and  legislative 
framework  and  appear  to  be  fully  implemented  in  practice.  The  Swedish  media  regulator 
possesses  strong  guarantees  of  its  independence,  enshrined  in  the  constitutional  provisions. 
No  major  issues  are  reported  in  the  area  of  media  ownership  transparency,  despite  the  fact 
that  there  are  no  specific  rules  for  media  companies.  Sweden  also  proves  to  have  a  robust 
system  concerning  journalists’  protection.  The  conditions  in  which  Swedish  journalists 
operate are estimated as one of the most favourable in the world. Nevertheless, some physical 
and online threats to journalists were reported in 2020.   

A particular characteristic of the system of checks and balances is the inclusive and structured 
process  for  preparing  legislation.  This  process  is  being  used  for  the  above-mentioned 
examination  of  the  constitutional  framework  relating  to  the  judiciary.  In  this  process,  a 
reform of the procedure for amending the constitution will also be considered as a means to 
enhance the protection of the basic structures of the democratic system. Several independent 
authorities play a role in safeguarding fundamental rights, and a reform process to extend the 
mandate of the National Human Rights Institution is ongoing. Furthermore, the Government 
has implemented specific instruments for dialogue with civil society. 

1 

 
 
 
 
I.  JUSTICE SYSTEM  

The  Swedish  justice  system  has  two  branches:  the  general  courts,  consisting  of  48  district 
courts, six courts of appeal and the Supreme Court; and the general administrative courts with 
twelve  administrative  courts,  four  administrative  courts  of  appeal  and  the  Supreme 
two  special  courts1.  The  National  Courts 
Administrative  Court.  There  are  also 
Administration,  an  agency  operating  under  the  Ministry  of  Justice,  is  responsible  for  the 
overall  management  of  the  Courts,  including  allocation  of  resources,  staffing  levels  and 
equipment.  The  independent  Judges’  Proposal  Board2  prepares  proposals  for  all  judicial 
appointments3,  based  on  which  judges  are  appointed  by  the  Government4.  The  Swedish 
Prosecution  Service5  is  independent  and  separate  from  the  Government.  The  Swedish  Bar 
Association is an independent and self-governing association established by law.6 

Independence 

The level  of perceived  independence of the judiciary is  consistently very high. Overall, 
80% of both the general public and companies consider that the independence of the courts 
and  judges  in  Sweden  is  either  ‘very  good’  or  ‘fairly  good’7.  This  high  level  of  perceived 
judicial  independence  has  been  stable  overall,  and  has  slightly  increased  for  the  general 
public, since 2016.  

A  reform  process  to  further  strengthen  judicial  independence  has  been  initiated.  A 
Commission of Inquiry8 on ‘Strengthening the protection of democracy and the independence 
of the judiciary’ was set up by the Government in February 2020, following a request by the 
Parliament  from  2018.  The  cross-party  inquiry  is  chaired  by  the  President  of  the  Supreme 
Court and has a mandate to  examine several  aspects  of the Swedish  framework for judicial 
independence,  in  order  to  bring  forward  proposals  for  legislative  and  constitutional 
amendments9.  The  committee  will  examine  whether  the  number  and  retirement  age  of 
Supreme Court Judges and Supreme Administrative Court Judges should be regulated in the 

1   The Labour Court and the Defence Intelligence Court. For a description of the judicial structure, see CEPEJ 

(2020), Study on the functioning of judicial systems in the EU Member States. 

2   The  Judges’ Proposal Board is composed of nine  members: five current or former judges proposed by the 
courts, two law  graduates  working outside the court system (one lawyer proposed by the Bar Association, 
the other proposed by the Swedish Association of Local Authorities and regions and the Swedish Agency for 
Government Employers) and two representatives of the public. The members of the public are appointed by 
the Parliament (and are usually members of Parliament), while the seven other members are appointed by the 
Government.  

3   The Judges’ Proposal Board, following an assessment of the applicants’ qualifications, submits a motivated 
proposal  (ranked  list,  in  general  three  candidates)  to  the  government,  which  appoints  the  judge.  If  the 
government  intends  to  select  a  candidate  not  included  in  the  proposal  of  the  Judges’  Proposal  Board,  the 
Board  is  to  have  an  opportunity  to  submit  an  opinion  on  the  candidate.  In  practice,  since  2011,  when  the 
current system came into force, the government has always followed the proposal.  

4   Act on the Appointment of Permanent Judges (2010:1390).  
5   Instrument of Government, Chapter 12, Section 2.  
6   Code of Judicial Procedure, Chapter 8.  
7   Figures 44 and 46, 2020 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as  follows:  very  low  (below  30%  of  respondents  perceive  judicial  independence  as  fairly  good  and  very 
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

8   Setting up a Commission of Inquiry is often part of the legislative process in Sweden; see section IV.  
9   The  commission  will  also  examine  the  way  constitutional  amendments  are  adopted  (see  section  IV)  and 
possible  restrictions  to  the  freedom  of  association  for  terrorist  associations.  Swedish  Government, 
Committee terms: Strengthening the protection of democracy and the independence of the judiciary.  

2 

 
                                                 
Constitution10. The mandate of the commission sets out that this reflection takes place  inter 
alia in view of the recent case law of the Court of Justice11. According to  the mandate, the 
objective  would  be  to  protect  judges  against  possible  interference  due  to  a  lowering  of  the 
retirement  age  by  ordinary  law.  The  question  of  regulating  the  number  of  judges  in  both 
Supreme  Courts  will  be  assessed  in  view  of  the  legal  academic  debate  in  Sweden,  in  the 
context of which it has been suggested that an increase or decrease in the number of judges 
could  be  used  as  a  means  of  political  influence.  In  addition,  the  commission  will  examine 
whether the independence of the National Courts Administration should be strengthened12. If 
the  commission  finds  that  such  a  strengthening  is  warranted,  it  is  within  its  mandate  to 
propose the establishment of a Council for the Judiciary or of a Board of the National Courts 
Administration13,  composed  mainly  of  judges,  which  would  be  consistent  with  Council  of 
Europe recommendations14. The work of the commission is at an early stage and will include 
a  review  of  existing  systems  in  other  EU  Member  States.  Its  results  will  be  presented  in 
February 2023. The inclusive method for preparing such a reform, including the cross-party 
process  and  the  attention  given  to  recent  case  law  of  the  Court  of  Justice  are  particularly 
noteworthy. 

The rules for the allocation of cases have been codified. The amendment  to  the Code of 
Judicial Procedure stipulates that the allocation of cases must be based on objective criteria 
established  by  the  court  in  advance  and  must  not  be  capable  of  affecting  the  outcome  or 
progression  of  the  case15.  This  codifies  the  already  existing  practice  and  ensures  that  the 
standards  for  allocation  of  cases  are  set  out  in  law,  which  is  consistent  with  Council  of 
Europe  recommendations16.  The  concrete  details  for  the  allocation  of  cases  continue  to  be 
specified in rules of procedure or similar standards of the courts17.  

Quality 

The National Courts Administration has requested additional resources, to cope with an 
increased  caseload.  Following  an  increase  in  the  resources  of  both  the  police  and  the 
prosecution service to strengthen their investigative capacities18, there has been a significant 
rise  in  the  number  of  incoming  criminal  cases  in  first  instance  courts.  To  handle  this 
increased caseload, the National Courts Administration has requested to increase the courts’ 
budget  for  2021-202319  in  order  to  cover  additional  court  personnel,  training  and  reforms 
aiming at improving the efficiency of courts20.  

10   Currently the general rules for retirement under the employment protection act apply to judges.  
11   Judgment  of  the  Court  of  Justice  of  24  June  2019,  Commission  vs  Poland,  C-619/18.  See  p.  7  of  the 

committee terms.   

12   The  commission of  inquiry  will also address  whether it should be  possible for the Supreme Court and the 

Supreme Administrative court to meet in a special joint forum for certain cases.   

13   The National Courts Administration is currently led by a Director-General appointed by the Government.  
14   Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe, para. 26-27. 
15   Code of Judicial Procedure, Chapter 4, Section 11a.   
16   The  Council  of  Europe  recommends  that  the  allocation  of  cases  within  a  court  follow  objective  pre-
established criteria in order to safeguard the  right to an independent and impartial judge. See in particular 
Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe, para. 24; CCJE 
Opinion N19 (2016) – The Role of Court Presidents; ENCJ Minimum Judicial Standards IV – Allocation of 
Cases: ENCJ Report 2013-2014. 

17   Contribution from the Swedish Supreme Court for the 2020 Rule of Law Report, p. 5.  
18   In 2018-19, about 90 new posts were created in the Prosecution Service, including 40 new prosecutors.  
19   Around EUR 60 million (SEK 628 million) were requested for the courts, with additional requests for legal 

aid and migration courts.  

20   National Courts Administration, More and more cases before the country's courts.  

3 

 
                                                 
Efforts are ongoing to address challenges concerning the use of digital communication 
in the Swedish judiciary. The possibility to complete certain steps of the judicial procedure 
online  remains  only  partially  available  in  Sweden,  both  as  concerns  submitting  a  case  and 
transmitting  summons,  and  no  possibility  exists  to  monitor  stages  of  a  proceeding  online21. 
There  is  also  no  online  access  to  first  instance  court  judgments22.  To  enable  and  facilitate 
digital  communication  in  court  proceedings  and  improve  the  service  to  citizens,  the 
Government  has  proposed  a  bill,  first  presented  in  August  2019,  which  aims  inter  alia  to 
make it possible to submit documents to initiate civil and certain other claims online, submit 
a power of attorney in digital form, and remove unnecessary requirements for hard copies23. 
The  proposal  was  submitted  to  Parliament  in  June  2020.  If  adopted,  most  provisions  are 
foreseen to enter into force in January 2021.   

Efficiency  

The  Swedish  justice  system  is  not  facing  particular  challenges  regarding  efficiency, 
despite  a  particularly  high  number  of  incoming  administrative  cases.  The  Swedish 
system performs at an average level regarding the disposition time for both litigious civil and 
commercial  cases  as  well  as  administrative  cases.  The  number  of  incoming  administrative 
cases  is  particularly  high  and  the  number  of  pending  administrative  cases  has  continued  to 
increase slightly since 2016. The clearance rate for administrative cases has in result dropped 
in 2016 and 2017, but shows a positive trend in 2018, moving back closer to 100%, with the 
average time to resolve administrative cases still remaining relatively low.24 As there was no 
general  lockdown,  courts  have  mostly  continued  to  operate  normally  in  the  COVID-19 
pandemic,  with  some  cancellations  and  postponements  of  hearings  for  public  health 
reasons25.  

II.  ANTI-CORRUPTION FRAMEWORK  

Sweden  has  the  legislative  and  institutional  framework  to  combat  and  prevent  corruption 
broadly  in  place.  While  Sweden  has  no  comprehensive  anti-corruption  strategy  in  place 
codified  in  writing,  the  Government  envisages  to  develop  a  National  Action  Plan  on  anti-
corruption.  The  preventive  and  repressive  dimensions  of  corruption  are  dealt  with  through 
several legal and other regulatory provisions, through specific rules concerning government 
agencies,  as  well  as  through  law  enforcement  and  judicial  authorities.  The  National  Anti-
Corruption Unit is the specialised prosecution agency within the Prosecution responsible for 
all  criminal  investigations  related  to  corruption  and  foreign  bribery.  The  National  Anti-
Corruption Police Unit, as part of the Swedish Police Authority, has tasks to both investigate 
corruption  crimes  and  ensure  a  preventive  role  by  supporting  different  public  authorities  in 
drafting  anti-corruption  policies.  Further  agencies  such  as  the  National  Audit  Office,  the 
National Competition Authority, the National Council for Crime Prevention and the Financial 
police (the Swedish FIU and a part of the Police Authority) are in charge with the prevention, 
forensic and auditing competence and investigation of corruption. 

Sweden scores  85/100  in the Transparency International  Corruption  Perception  Index 
and ranks 3rd in the European Union and 4th globally. The 2020 Special Eurobarometer on 

21   Figure 27, 2020 EU Justice Scoreboard.  
22   Figure 28, 2020 EU Justice Scoreboard.  
23   Swedish government, Digital communication in court proceedings.  
24   Figures 2-15, 2020 EU Justice Scoreboard.  
25   E.g. National Courts Administration, Statistics due to coronavirus.  

4 

 
                                                 
Corruption shows that 40% of respondents perceive corruption as widespread (EU average: 
71%)  and  9%  of  people  feel  personally  affected  by  corruption  in  their  daily  lives  (EU 
average:  26%)26.  As  regards  businesses,  30%  of  companies  consider  corruption  to  be 
widespread (EU average: 63%) and 12% of companies consider that corruption is a problem 
when doing business (EU average: 37%). 55% of people find that there are enough successful 
prosecutions  to  deter  people  from  corrupt  practices  (EU  average:  36%)  while  48%  of 
companies  believe  that  people  and  businesses  caught  for  bribing  a  senior  official  are 
appropriately punished (EU average: 31%).27 

Sweden has the legal framework to criminalise corruption broadly in place. The Swedish 
Criminal Code28  regulates criminal offences such as receiving and  giving of a bribe, trading 
in  influence and negligent  financing of bribery.  The penalty  for taking or  giving of  a bribe 
can be either fines or imprisonment for a maximum of two years (statute of limitation of five 
years). The penalty for gross giving/taking of a bribe ranges from six months to six years in 
prison  (statute  of  limitation  of  ten  years).  Moreover,  criminal  offences  such  as  official 
misconduct  or  breach  of  the  duty  of  confidentiality  are  regulated  in  the  Criminal  Code.  In 
addition,  the Public Employment Act  adopted in  1994 provides for disciplinary liability  for 
neglect of duty in the form of warnings or wage reduction. The law also prohibits employees’ 
involvement  in  activities  that  may  adversely  affect  confidence  in  their  impartiality  in  their 
work or that may harm the reputation of the authority.29 

While  there  is  no  comprehensively  codified  national  anticorruption  strategy  in  place, 
the Government has announced its initiative to develop a National Action Plan on anti-
corruption. The Action Plan is set to be presented at the end of 2020 and discussions with 
relevant authorities are at an early stage. The intention is to review existing preventive work 
and  identify  needs  for  new  measures  against  corruption,  for  example  by  enabling  more 
effective and efficient coordination and collaboration between key authorities.   

The  responsibility  to  fight  and  prevent  corruption  is  distributed  across  several 
authorities.  The  Agency  for  Public  Management  manages  a  national  network  against 
corruption  since  2017  and  conducts  research  and  policy  coordination,  supporting  good 
governance  and  anti-corruption.  30  The  National  Audit  Office,  whose  competences  include 
forensic and auditing expertise, covers both financial and non-financial controls within public 
the 
sector  organisations.  The  National  Council  for  Crime  Prevention functions  as 
Government's  body  of  expertise  within  the  judicial  system31.  The  Swedish  Association  of 
Local  Authorities  and  Regions  (SALAR)32   has  coordinated  a  series  of  workshops  on 
corruption  prevention.  In  addition,  the  Financial  Police  serves  as  Sweden’s  Financial 
Intelligence  Unit  (FIU)  and  takes  part  in  investigations  within  the  Police  Authority. 

26   Eurobarometer 502 (2020). 
27   Eurobarometer 482 (2019).   
28   Chapter  10,  Section  5c  of  the  Criminal  Code  https://www.government.se/press-releases/2020/01/an-up-to-

date-english-translation-of-the-swedish-criminal-code/. 

29   If  a  bribery  is  committed  in  the  exercise  of  the  business  activities  of  a  company  a  corporate  fine  ranging 

from SEK 5000 to SEK 500 000 000 can be imposed on the company. 

30   For  more 

information 

http://www.statskontoret.se/var-verksamhet/myndighetsnatverket-mot-
korruption/.  The  Agency  organises   4  -  6  network  meetings  per  year.  During  2019,  a  total  of  150  public 
authorities participated in meetings arranged by the network.  

see: 

31   BRÅ experts are currently taking part in a government working group on the culture of silence in Swedish 

organisations, notably the use and treatment of e.g. whistleblowers.   

32   SALAR  functions  as  an  employers'  organisation  (including  all  municipalities  and  regions)  and  as  an 

organisation that represents and advocates for local government.  

5 

 
                                                 
According to the Swedish National Council for Crime Prevention (BRÅ) in 201833, 297 cases 
of taking bribes and 143 cases of offering bribes were reported. Foreign bribery remains an 
area of risk since Sweden has one of the highest  number of multi-national  corporations per 
capita  and  the  prosecution  of  foreign  bribery  is  limited  by  the  dual  criminality  requirement 
and the corporate liability requirement34.  

The  National  Anti-Corruption  Unit  (NACP)  within  the  Prosecution  Authority  is 
responsible  for  all  criminal  investigations  related  to  corruption  and  foreign  bribery. 
Around ten prosecutors and two accountants work at the unit, which focuses solely on anti-
corruption cases. The Agency has faced challenges in terms of available analytical capacity 
and resources in view of the number of cases investigated and prosecuted, with a risk of not 
being  able  to  process  a  case  within  the  statute  of  limitation.  The  National  Anti-Corruption 
Police Unit (NACPU) was created with the aim of bringing together national competences for 
investigating corruption  crimes in  one place  and consists of 27 staff, including 14 police, 6 
civil investigators and 4 forensic accountants. In addition to investigating corruption crimes, 
it  also  has  a  preventive  role  supporting  public  agencies  in  drafting  anti-corruption  policies. 
The NACPU also gives trainings to different authorities and organisations in Sweden on anti-
corruption.  

Some  categories  of  officials  as  well  as  members  of  Parliament  and  Ministers  are 
required  to  submit  asset  declarations.  The  Act  (2018:1625)  on  the  obligation  for  certain 
public  officials  to  report  holdings  of  financial  instruments  contains  provisions  on  the 
obligation for ministers and certain officials in public authorities, municipalities and regions 
to report holdings of financial instruments. Ministers must report their holdings of financial 
instruments  to  the  Government  Offices.  Members  of  a  public  authority’s  management  are 
also  obliged  to  report  in  case  the  authority  holds  insider  information.  The  Government 
decides which public authorities are subject to such an obligation to report. Such authorities 
decide which of its officials outside the management will have to report depending on their 
access  to  insider  information.  Municipalities  and  regions  also  decide  which  of  their  public 
authorities  should  be  subject  to  the  reporting  obligation.  Members  of  the  Parliament  are 
required  to  declare  certain  economic  assets  within  four  weeks  of  the  first  meeting  in  the 
Riksdag after elections.  The information contained in members of Parliaments’ declarations 
is  maintained in  a  public register kept  by the Riksdag Administration. The data is  removed 
from the register after the end of the full parliamentary term. The principle of public access to 
official documents also applies, which means that members of Parliaments’ declarations must 
also be made available if requested. 

Measures are in place to ensure whistle-blower protection  and encourage reporting  of 
corruption.  Under  the  Whistleblowing  Act  2016:749,  an  employer  may  not  subject  an 
employee  or a  temporary  agency  worker  to  reprisals  by  reason  of  him  or  her  blowing  the 
whistle  on  serious  irregularities  in  the  employer’s  operations35.  The  protection  has  several 
components:  the  freedom  to  communicate  information,  to  procure  information  and 
intelligence,  the  right  to  anonymity.  At  the  end  of  May  2019,  the  Government  launched  a 

33   Brå, Handled crimes.  
34   In this sense see also OECD (2017), Sweden’s Laws on Corporate Responsibility for International Bribery 

need Urgent Reform.  

35   Furthermore,  according  to  the  Freedom  of  the  Press  Act  and  the  Fundamental  Law  on  Freedom  of 
Expression, everyone has the right, with impunity, to provide information on any subject for publication. 

6 

 
                                                 
review  to  prepare  implementation  of  the  EU  Whistle-blowing  Directive  and  assess  if  any 
amendments of Swedish law will be required in relation to the Directive.36  

Rules on ‘revolving doors’ have been introduced for high-level officials, while lobbying 
provision remains unregulated. The regulation on ’revolving doors’ was adopted in 201837, 
setting restrictions on ministers, members of the cabinet and department secretaries that move 
to  employment  and assignments in  organizations other than Government/public sector. This 
regulation  is  applicable  to  transitions  to  non-state  activities,  including  when  ministers  and 
state secretaries intend to take up a new assignment or employment in non-state activities, or 
set  up  a  business.  “Non-state  activities”  encompass  all  activities  where  the  state  is  not  the 
responsible  authority.  The  regulation  also  applies  to  companies  that  are  completely  or 
partially state-owned. The special review body, the Committee for Review of the Transitional 
Restrictions of the cabinet and department secretaries examines transfers to all activities for 
which  the  Government  is  not  the  employer.  As  regards  lobbying,  there  is  no  specific 
obligation for registration of lobbyists or reporting of contacts  between  public officials  and 
lobbyists. GRECO has noted the lack of developed rules to regulate the contact with lobbyists 
along the trend of former public officials becoming lobbyists.38  

A broad right to public access to information is a core element of the Swedish approach 
to corruption prevention. Public officials are entitled to disclose information to the media, 
the  public  is  entitled  to  attend  the  meetings  of  decision  making  bodies  (Parliament,  county 
council assemblies) and court hearings. Restrictions to this principle are clearly set out in law 
to safeguard a limited number of important public and private interests39.  

III.  MEDIA PLURALISM 

The  Swedish  legal  framework  concerning  media  pluralism  is  based  on  the  safeguards 
stemming  both  from  the  constitutional  framework40  and  from  secondary  law.  The 
Constitution  guarantees  freedom  of  expression  in  the  Fundamental  Law  on  Freedom  of 
Expression  and  the  Freedom  of  the  Press  Act.  With  regard  to  the  media  regulator  -  the 
Swedish  Press  and  Broadcasting  Authority  (Myndigheten  för  press,  radio  och  tv),  its  status 
and  competences  are  regulated  both  by  the  Constitution41  and  by  the  Radio  and  Television 
Act.42 The Swedish  legal  system does not  envisage any sector specific laws  concerning the 
transparency of media ownership.43  

36   According  to  the  authorities,  certain  provisions  of  the  EU  Directive  (EU)  2019/1937  on  the  protection  of 
persons who report breaches of Union law, lack any equivalent in Swedish law, for instance regarding the 
obligation of companies of a certain size to establish internal channels for reporting violations. Furthermore, 
the Directive protects a broader group of people than the Whistleblowing Act. (Input from Sweden for the 
2020 Rule of Law Report.). 
Karens 

37   Regeringen, 

statssekreterare. 

statsråd 

införs 

och 

för 

https://www.regeringen.se/pressmeddelanden/2018/02/karens-infors-for-statsrad-och-statssekreterare/.  

38   GRECO Fifth Evaluation Round – Evaluation Report. 
39   Freedom of the Press Act. 
40   The  Swedish  Constitution  consists  of  four  fundamental  laws:  the  Instrument  of  Government,  the  Act  of 
Succession,  the  Freedom  of  the  Press  Act  and,  especially  with  regard  to  the  Swedish  Broadcasting 
Commission, the Fundamental Law on Freedom of Expression.  

41   Relevant parts of the Constitution: the Instrument of Government and the Fundamental Law on Freedom of 

Expression 

42   Radio and Television Act.  
43   Sweden ranks on the 4th position in the 2020 Reporters Without Borders World Press Freedom Index.  

7 

 
                                                 
Sweden has in place effective regulatory safeguards for the independence of the media 
regulator.  The  Swedish  Press  and  Broadcasting  Authority  has  a  status  of  an  independent 
administrative  authority44.  The  Authority  has  a  statutory  obligation  to  support  freedom  of 
expression,  diversity,  independence  and  accessibility.  Within  the  authority,  there  are  two 
independent decision-making bodies: the Swedish Broadcasting Commission and the Media 
Subsidies  Council.  The  latest  edition  of  the  Media  Pluralism  Monitor  (MPM  2020)45,  has 
reported  a  very  low  risk  with  regard  to  the  independence  and  effectiveness  of  the  Swedish 
media  regulatory  authority.  In  2018,  an  inquiry  was  launched  to  examine  Sweden’s 
implementation  of  the  revised  Audio-visual  Media  Services  Directive  (AVMSD),  including 
the  provisions  for  the  independence  and  effectiveness  of  national  media  regulators.46  The 
resulting report47 was presented to the Government in August 2019 with the conclusion that 
the  Swedish  governance  model  provides  a  high  level  of  independence  for  all  Swedish 
authorities,  including  the  media  authority.  According  to  the  report  and  as  confirmed  by  the 
representatives  of  the  Swedish  Press  and  Broadcasting  Authority,  the  most  important 
safeguard  stems  from  Chapter  12,  Article  2  of  the  Instrument  of  Government,  which 
establishes  a  general  principle  of  the  independence  of  Swedish  administrative  authorities.48 
Sweden  is  currently  in  the  process  of  transposing  the  revised  AVMSD.  This  might  include 
further legislative changes aimed at strengthening the independence of the media regulator, in 
particular  in  the  context  of  the  appointment  of  its  members.49  The  representatives  of  the 
Swedish  Press  and  Broadcasting  Authority  also  indicated  that  they  expect  an  increased 
budget attribution.50  

Sweden  has  a  well-established  self-regulatory  framework  in  the  media  sector.  The 
system is entirely voluntary and financed by four press organisations and four broadcasting 
companies51.  The  Media  Ombudsman,  in  charge  of  handling  complaints  on  the  editorial 
content  of  newspapers,  magazines,  broadcast  media  and  their  websites  and  social  media,  is 
appointed by a committee consisting of the Chief Parliamentary Ombudsman, the chairman 
of  the  Swedish  Bar  Association  and  the  chairman  of  the  National  Press  Club.  The  Media 
Ombudsman also  ensures the compliance with  the self-regulatory Code of Ethics  for Press, 
Radio  and  Television.52  Appeals  against  the  decisions  of  the  Media  Ombudsman  are 
examined by the Media Council, which is composed of four judges, 16 representatives of the 
media organisations participating in the self-regulatory scheme and 12 representatives of the 
general public. 

44   Set out in the Instrument of  Government,  the  Fundamental Law on Freedom of Expression and the  Radio 

and Television Act. 

45   2020 Media Pluralism Monitor. 
46   It should be recalled that the revised Audio-visual Media Services Directive (AVMSD) sets out a range of 

specific guarantees for the independence and effectiveness of national media regulators. 

47   2019 report “A modernized radio and television law - implementation of amendments to the AV Directive” 
48   According  to  its  Article  Art.  2.  “no  public  authority,  including  the  Riksdag  (the  Parliament),  or  decision-
making  body  of  any  local  authority,  may  determine  how  an  administrative  authority  shall  decide  in  a 
particular  case  relating  to  the  exercise  of  public  authority  vis-à-vis  an  individual  or  a  local  authority,  or 
relating to the application of law. 

49   Contribution from Sweden for the 2020 Rule of Law Report, points 28-29. 
50   Information received during the virtual country visit to Sweden in the context of the preparation of the 2020 

Rule of Law Report  

51   This  includes  the  Swedish  Media  Publishers’  Association,  the  Magazine  Publishers’  Association,  the 
Swedish  Union  of  Journalists,  the  National  Press  Club,  Swedish  Radio  (SR),  Swedish  Television  (SVT), 
Swedish Educational Broadcasting Company (UR) and TV4. 

52  Available  at:  https://medieombudsmannen.se/about-the-media-ombudsman/code-of-ethics-for-press-radio-

and-television-in-sweden/#. 

8 

 
                                                 
With regard to the transparency of media ownership, the Swedish legal system does not 
provide for any media-specific legislation. As reported by the MPM 202053, all companies 
are required to comply with the general framework based on the Swedish  Law of Financial 
Relations  (the  Transparency  Act)  which  requires  companies  to  be  transparent  about 
ownership structures. They should also comply with the Competition Act, which regulates the 
ownership  concentration.  Under  this  regime,  all  Swedish  companies  are  required  to  inform 
the  Swedish  Competition  Authority  about  their  ownership  structure  and  provide  annual 
reports,  which  also  cover  information  on  ownership.  Such  reports  should  be  publicly 
available  (including  publication  of  their  websites).  Due  to  the  lack  of  a  media  specific 
framework,  the  MPM  2020  reports  however  medium  risk  for  the  transparency  of  media 
ownership.  At  the  same  time,  according  to  the  representatives  of  the  Swedish  Press  and 
Broadcasting  Authority54  there  have  not  been  any  concerns  related  to  the  identification  of 
owners of media services.55 

Sweden  has  a  robust  framework  for  the  protection  and  activities  of  journalists.  The 
conditions in which Swedish journalists operate are estimated as one of the most favourable 
in the world. The MPM 2020 reported a low risk concerning editorial autonomy in Sweden.56 
In this regard, the Freedom of the Press Act regulates autonomy in appointing and dismissing 
editors-in-chief.  Additionally,  a  large  number  of  media  and  journalist  organisations  have 
developed  self-regulatory  initiatives  related  to  the  editorial  independence.  With  regard  to 
defamation,  imprisonment  is  among  the  envisaged  sanctions  for  defamation  and  insult 
committed through print and audio-visual media, according to the Freedom of the Press Act 
(Chapter  7)  and  the  Fundamental  Law  on  Freedom  of  Expression  (Chapter  5)  read  in 
conjunction  with  the  Swedish  Criminal  Code.57  However,  as  reported  by  the  International 
Press  Institute,58  criminal  prosecutions  for  defamation  involving  the  media  are  rare  in 
Sweden,  due  to  extensive  requirements  for  conducting  such  cases  envisaged  in  the  above 
mentioned acts. Still, some sources, including Reporters without Borders59 and the Swedish 
National  Council  for  Crime  Prevention  (Brå)60,  reported  that  some  journalists  experience 
threats as a result of their professional activity. The number of journalists exposed to abusive 
or derogatory comments online has decreased from 80% in 2013 to about 70% in 2019.61 In 
2019, the Council of Europe Platform to promote the protection of journalism and safety of 
journalists62  did  not  report  any  alerts  concerning  Sweden.  In  2020  three  alerts,  concerning 
both the cases of physical and online attacks on journalists, were published on the platform.63 
The  Swedish  Police  Authority  has  launched  specific  actions  aiming  to  address  the 

53   2020 Media Pluralism Monitor. 
54   Information received during the virtual country visit to Sweden in the context of the preparation of the 2020 

Rule of Law Report 

55   To  be  noted  that  the  revised  AVMSD  encourages  Member  States  to  adopt  legislative  measures  providing 
that media service providers under their jurisdiction make accessible information concerning their ownership 
structure, including the beneficial owners. 

56   2020 Media Pluralism Monitor. 
57   Mapping of decriminalisation of defamation (2020).  
58   International Press Institute, Media Laws Database, available at: http://legaldb.freemedia.at/legal-database/. 
59   Reporters without borders, Sweden. 
60   Brå, Threats and violence. 
61   JMG, Continued hatred and threats against Swedish journalists. 
62   Council of Europe Platform to promote the protection of journalism and safety of journalists – Sweden. 
63   The reported cases concerned: the threats and hate speech on social media (including death threats) towards 
a cartoonist, following a publication of his satirical illustration, the death of the editor-in-chief of the online 
news magazine Balochistan Times (the initial autopsy was inconclusive and a possibility that the death was 
related to his professional activity cannot be excluded) and the attack on a blogger of Chechen origin, most 
likely related to his online activities. 

9 

 
                                                 
fundamental  rights and freedoms, including crimes against journalists. This includes setting 
up national contact points, additional staff to support victims of such crimes, and allocating 
additional  funding64  to  better  investigate  crimes  against  democracy  and  hate  crimes.65  An 
inquiry  chair66,  appointed  by  the  Government  in  May  2020,  is  currently  reviewing,  among 
other  matters,  the  criminal  law  protection  for  certain  vital  functions  in  society,  including 
journalists.  This  process  is  expected  to  examine  if  any  further  legislative  safeguards 
concerning freedom of speech should be considered.67 In addition, journalists benefit from a 
robust  framework  for  access  to  information.  According  to  the  MPM  2020,68  the  legal 
provisions concerning access to information and the restrictions on grounds of protection of 
privacy and confidentiality are clearly defined and stakeholders, such as the Swedish Media 
Ombudsman, considers that this right is fully respected and well implemented in practice.69  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Sweden  has  a  unicameral,  parliamentary  system  of  government,  in  which  a  Council  of 
Legislation  ensures  ex-ante  constitutional  review,  while  courts  can  carry  out  an  ex-post 
constitutional review in concrete cases. Legislative proposals can be submitted by Parliament 
or the Government, with the latter submitting the vast majority of proposals in practice. , The 
Chancellor of Justice, the Parliamentary Ombudsmen and the Equality Ombudsman play an 
important role in the system of checks and balances.  

The  enactment  of  legislation  is  characterised  by  a  particularly  inclusive  process.  The 
process of preparation of laws starts with the inquiry stage, where the matter in question must 
first  be  analysed  and  evaluated,  normally  by  officials  from  the  responsible  ministry,  a 
commission of inquiry, operating independently of the Government, or an inquiry chair (one-
person  inquiry)70.  The  inquiry  draws  up  a  draft  legislative  proposal.  As  required  by  the 
Constitution71, authorities concerned and stakeholders must have an opportunity to express an 
opinion, which happens through the so-called referral process, for a standard period of three 
months. While it is addressed to the authorities and stakeholders concerned, it is open to any 
other organisation or individual as well. The referred proposal and the opinions received are 
both published on the Government website. Based on the outcome of the inquiry and referral 
process,  the  Government  prepares  its  draft  bill.  This  process  includes  the  preparation  of  an 
impact assessment, which for proposals with an impact on companies’ working conditions or 
competitiveness  needs  to  be  submitted  to  the  Swedish  Better  Regulation  Council.72  The 
Commission of Inquiry on ‘Strengthening the protection of democracy and the independence 
of  the  judiciary’  is  a  good  illustration  of  the  importance  of  such  an  inclusive  process  for 

64   Around EUR 970,000 (SEK 10 million).  
65   Contribution from Sweden for the 2020 Rule of Law Report, points 33-36. 
66   Swedish Government, The government is holding talks with the media industry and the police about threats 

and hatred against journalists. 

67   In  that  respect,  it  should  be  recalled  that,  in  line  with  European  standards,  a  comprehensive  legislative 
framework  that  enables  journalists  and  other  media  actors  to  contribute  to  public  debate  effectively  and 
without fear is recommended by the Council of Europe. CM/REC(2016)4 of the Committee of Ministers of 
the Council of Europe. 

68   Media Pluralism Monitor 2020.  
69   Information received during the virtual country visit to Sweden in the context of the preparation of the 2020 

Rule of Law Report.  
70   Riksdag, Making Laws.  
71   Instrument of Government, Chapter 7, Section 2.  
72   A  decision  not  to  carry  out  an  impact  assessment  needs  to  be  justified,  as  set  out  in  the  Ordinance 
(2007:1244)  on  impact  assessment  in  regulations.  On  consultation  of  the  Better  Regulation  Council,  see 
Ordinance (2011: 118) on authorities obtaining an opinion from the Swedish Regulatory Council.  

10 

 
                                                 
sensitive  matters  such  as  the  rule  of  law.  It  ensures  the  representation  of  different  political 
parties and the judiciary, with the President of the Supreme Court as its chair. The timetable 
for the commission also avoids carrying out this process under tight deadlines, with its results 
being due in 2023.  

The  Council  on  Legislation  is  responsible  for  ex-ante  constitutionality  review  of  laws. 
Before they are submitted to Parliament, the Council on Legislation, composed of former and 
current  judges  of  the  Supreme  Court  and  Supreme  Administrative  Court73,  examines 
legislative  proposals  by  the  Government  and  submits  a  non-binding  opinion  on  the 
conformity  of the proposal  with  the Constitution and the legal  system  as a whole,  ensuring 
that the principles of rule of law are upheld74. A committee of the Riksdag (Parliament) can 
also  solicit  an  opinion  by  the  Council  on  Legislation.  While  Sweden  does  not  have  a 
Constitutional Court, all courts can review the compatibility of laws with the Constitution or 
with superior statues when adjudicating concrete cases and must disapply any incompatible 
provisions (this is called norm assessment). If a law was adopted in conflict with the opinion 
of  the  Council  of  Legislation,  courts  can  take  this  into  account  in  the  context  of  the  norm 
assessment75.  

Sweden  is  considering  a  reform  of  the  procedure  for  amending  its  Constitution. 
Currently,  constitutional  amendments  can  be  adopted  by  simple  majority,  but  require  two 
consecutive  decisions  by  Parliament  with  a  parliamentary  election  between  them76.  In 
addition  to  the  reform  of  the  judiciary,  the  Commission  of  Inquiry  on  ‘Strengthening  the 
protection of democracy and the independence of the judiciary’ will also examine a number 
of  possible  changes  to  the  way  constitutional  amendments  are  adopted.  According  to  the 
commission’s  mandate,  this  is  under  consideration  in  light  of  recent  developments  in  other 
countries  showing  the  importance  of  robust  protection  of  the  basic  structures  of  the 
democratic  system77.  In  particular,  the  Commission  of  inquiry  will  assess  if  a  qualified 
majority should be required, whether there should be a requirement for a minimum number of 
members of the Parliament to take part in the decision, and if the elections held between the 
two decisions must be an ordinary election. The results of this part of the inquiry will also be 
presented in 2023.  

Several  independent  authorities  play  a  role  in  safeguarding  fundamental  rights.  The 
Equality Ombudsman is the Swedish National Human Rights Institution (NHRI) and equality 
body,  accredited  with  B-Status  in  2011  by  the  Global  Alliance  of  National  Human  Rights 
Institutions as regards its compliance with the UN Paris Principles, as its mandate is limited 
to equality matters and does not cover human rights more broadly78. In 2018, the Government 
appointed an inquiry to prepare a proposal for the establishment of a NHRI with a full human 
rights mandate. The inquiry report was presented in 201979 and has undergone consultation; 
in  its  Government  declaration  in  2019,  Sweden  announced  formally  that  a  NHRI  will  be 

73   Members are usually appointed for one year in accordance with principles established by the courts.  
74   Exceptions  can  be  made  for  legislation  where  an  examination  by  the  Council  would  lack  significance  or 

where it would delay the process in such a way that it would result in serious detriment.  
75   Contribution from the Swedish Supreme Court for the 2020 Rule of Law Report, p.15.  
76   Instrument of Government, Chapter 8, Section 14.  
77   Swedish Government, Committee terms: Strengthening the protection of democracy and the independence of 

the judiciary. pp. 2-5.  

78   Contribution  by  the  European  Network  of  National  Human  Rights  Institutions  for  the  2020  Rule  of  Law 

Report, p. 215.   

79   Swedish Government, Proposal for a national institution for human rights in Sweden.  

11 

 
                                                 
established80. The European Network of National Human Rights Institutions (ENNHRI)81 has 
provided comments  on the inquiry  report, stressing the need to  ensure sufficient  safeguards 
for  the  independence  and  public  accountability  of  the  new  institution.  In  addition,  both  the 
Parliamentary  Ombudsmen  (appointed  by  and  acting  on  behalf  of  Parliament)  and  the 
Chancellor  of  Justice  (appointed  by  and  acting  on  behalf  of  the  Government)  supervise  the 
application of laws and other regulations by public authorities, including courts and judges. 
Both institutions can initiate disciplinary procedures against higher public officials, including 
judges82,  and  can  provide  non-binding  opinions  on  the  handling  of  a  matter  by  a  public 
authority or a court (this concerns only the application of laws and procedures by a court or 
judge but not the substance of a court decision). In February 2020, the Parliament decided to 
appoint a parliamentary inquiry reviewing the constitutional status, remit and activities of the 
Parliamentary Ombudsmen, which is to be submitted in May 202283.   

The  Government  has  implemented  specific  instruments  for  dialogue  with  civil  society. 
Sweden is considered as having an open civil society landscape84. The Government has, since 
2017, implemented a specific method for different forms of dialogue with civil society called 
‘sakråd’  (thematic  consultation  forum)85  and  a  national  body  for  dialogue  and  consultation 
between  the  Government  and  civil  society,  established  in  2018,  provides  a  forum  for 
structured cooperation and joint problem-solving86.  

80   Swedish Government, Government declaration 10 September 2019, p.18.   
81   European  Network  of  National  Human  Rights  Institutions,  Regarding  the  consultation  on  the  proposal  for 

the establishment of a National Human Rights Institution in Sweden (Ds 2019:4).  

82   Except for judges of the Supreme Courts, who are exempted from disciplinary liability but can be subject to 
legal  proceedings  regarding  a  criminal  act  committed  in  the  performance  of  their  appointment.  For  such 
proceedings, a separate system applies, which means that the matters are examined by the Supreme Courts 
after initiation by the Parliamentary Ombudsmen or the Chancellor of Justice.  

83   Riksdag, Inquiry on the review of the Parliamentary Ombudsmen (JO).  
84   Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed.   

85   Swedish Government, Sakrad.  
86   Nationellt organ för dialog och samråd mellan regeringen och det civila samhället. 

12 

 
                                                 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2020 Rule of Law report 
can be found at (COM website). 

Brå,  Threats  and  violence.  https://www.bra.se/publikationer/arkiv/publikationer/2015-04-29-hot-och-

vald.html.   

Brå, Handled crimes. https://www.bra.se/statistik/kriminalstatistik/handlagda-brott.html.   

Brå, Reported crimes. https://www.bra.se/statistik/kriminalstatistik/anmalda-brott.html.  

Centre  for  Media  Pluralism  and  Media  Freedom  (2020),  2020  Media  pluralism  monitor. 

https://cmpf.eui.eu/media-pluralism-monitor/mpm-2020.   

CEPEJ (2020), Study on the functioning of the judicial systems in the EU Member States.  

CIVICUS, Monitor tracking civic space: Sweden. https://monitor.civicus.org/country/sweden/.   

Council  of  Europe  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 

Sweden. https://www.coe.int/en/web/media-freedom/sweden.  

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 

Committee of Ministers on judges: independence, efficiency and responsibilities. 

Council of Europe: Committee of Ministers (2016): Recommendation CM/REC(2016)4 Ministers on 

the protection of journalism and safety of journalists and other media actors. 

Council of Europe: Consultative Council of European Judges – CCJE (2016), Opinion No. 19 on the 

role of Court Presidents.  

Court of Justice of the European Union, Judgment of 24 June 2019, Commission v. Poland, C-619/18.  

Directorate-General  for  Communication  (2019),  Flash  Eurobarometer  482:  Businesses’  attitudes 

towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. 

European Commission (2020), EU Justice Scoreboard.   

European Network of Councils for the Judiciary  – ENCJ (2014), Minimum Judicial Standards IV  – 

Allocation of Cases: ENCJ Report 2013-2014. 

European  Network  of  National  Human  Rights  Institutions  (2019),  Re:  Consultation  on  the  proposal 

for the establishment of a National Human Rights Institution in Sweden (Ds 2019:4). 

European  Network  of  National  Human  Rights  Institutions  (2020),  Contribution  to  the  stakeholder 

consultation for the 2020 Rule of Law Report.  

GRECO  (2018),  Fifth  Evaluation  Round  –  Evaluation  Report  on  Sweden  on  preventing  corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies.  

JMG, 

Continued 

Swedish 
and 
https://jmg.gu.se/aktuellt/Nyheter/Nyheter+detalj/fortsatt-hat-och-hot-mot-svenska-
journalister.cid1637975.  

against 

threats 

hatred 

journalists. 

National  Courts  Administration  (2020),  More  and  more  cases  before  the  country's  courts. 

https://www.domstol.se/domstolsverket/nyheter/2020/02/allt-fler-mal-till-landets-domstolar/.  

National  Courts  Administration,  Statistics  due  to  coronavirus.  https://www.domstol.se/om-sveriges-
domstolar/statistik-styrning-och-utveckling/statistik/statistik-med-anledning-av-coronaviruset/.  

OECD  (2017),  Sweden’s  Laws  on  Corporate  Responsibility  for  International  Bribery  need  Urgent 
http://www.oecd.org/corruption/sweden-s-laws-on-corporate-responsibility-for-

Reform. 
international-bribery-need-urgent-reform.htm.  

13 

 
Reporters without Borders, Sweden. https://rsf.org/en/sweden.  

Riksdag 

(2020), 

the  Parliamentary  Ombudsmen 
review  of 
https://www.riksdagen.se/sv/press/pressmeddelanden/2020/feb/21/utredning-om-oversyn-av-
riksdagens-ombudsman-jo/.  

Inquiry  on 

the 

(JO). 

Riksdag,  Making  Laws.  https://www.riksdagen.se/en/how-the-riksdag-works/what-does-the-riksdag-

do/makes-laws/.  

Statskontoret,  The 

against 
verksamhet/myndighetsnatverket-mot-korruption/.  

authority  network 

corruption.  http://www.statskontoret.se/var-

Swedish 

Government 

(2019), 

Government 

declaration 

10 

September 

2019. 

https://www.government.se/speeches/20192/09/statement-of-government-policy-10-september-
2019/.   

Swedish  Government  (2020),  Committee  terms:  Strengthening  the  protection  of  democracy  and  the 
judiciary. 

independence 
https://www.regeringen.se/4915d2/contentassets/2399f42ba83d48f4ad2e5ebb3ddb0e21/forstarkt-
skydd-for-demokratin-och-domstolarnas-oberoende-dir-2020-11.pdf.  

the 

of 

Swedish 

Digital 
https://www.regeringen.se/rattsliga-dokument/proposition/2020/06/prop.-201920189.  

communication 

Government 

(2020), 

court 

in 

proceedings. 

Swedish Government (2020), Input from Sweden for the 2020 Rule of Law Report.  

Swedish  Government  (22  February  2018),  Karens  införs  för  statsråd  och  statssekreterare. 

https://www.regeringen.se/pressmeddelanden/2018/02/karens-infors-for-statsrad-och-
statssekreterare/.   

Swedish Government, Sakråd. https://www.regeringen.se/sakrad/.  

Swedish Government, Proposal for a national institution for human rights in Sweden.  

Swedish Government, The government is holding talks with the media industry and the police about 
journalists. 

threats 
https://www.regeringen.se/pressmeddelanden/2020/02/regeringen-haller-samtal-med-
mediebranschen-och-polisen-om-hot-och-hat-mot-journalister/.  

against 

hatred 

and 

Swedish  Supreme  Court  (2020),  Contribution  to  the  stakeholder  consultation  for  the  2020  Rule  of 

Law Report.  

UN  Office 

on  Drugs 

and 

Crime, 

goAML 

(Anti-money-laundering 

system). 

https://www.unodc.org/unodc/en/global-it-products/goaml.html.  

Virtual country visit to Sweden in the context of the 2020 Rule of Law Report. 

14 

 
 
Annex II: Country visit to Sweden 

The Commission services held virtual meetings in June 2020 with: 

  Agency for Public Management 
  Committee of Inquiry on Independence of Courts 
  Council on Legislation 
  Economic Crime Authority 
  Ministry of Finance 
  Ministry of Justice 
  National Courts Administration 
  Office of the Chancellor of Justice 
  Office of the Prime Minister 
  Press and Broadcasting Authority 
  Press Ombudsman 
  Prosecution Service 
  Supreme Administrative Court 
  Supreme Court 
  Swedish Association of Judges 
  Swedish Bar Association  
  Swedish Journalists’ Association  
  Transparency International Sweden  

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International 
  Civil Liberties Union for Europe 
  Civil Society Europe 
  Conference of European Churches  
  EuroCommerce 
  European Center for Not-for-Profit Law  
  European Centre for Press and Media Freedom 
  European Civic Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
ILGA-Europe 
 
International Commission of Jurists 
 
International Federation for Human Rights  
 
International Press Institute  
  Lifelong learning Platform  
  Open Society Justice Initiative/Open Society European Policy Institute 
  Reporters without Borders  
  Transparency International EU  

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