COMMISSION STAFF WORKING DOCUMENT 2023 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 2023 Rule of Law Report The rule of law situation in the European Union
Date: 2023-07-05
Institutions: European Commission, Secretariat-General
Subjects: Sweden, administrative transparency, corruption, democracy, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.7.2023  SWD(2023) 827 final  COMMISSION STAFF WORKING DOCUMENT 2023 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 2023 Rule of Law Report                        The rule of law situation in the European Union {COM(2023) 800 final} - {SWD(2023) 801-827 final}  
 
 
ABSTRACT 

The level of perceived judicial independence in Sweden continues to be high among the general 
public  and  among  companies.  The  all-party  Committee  of  Inquiry  on  strengthening  the 
protection of democracy and the independence of the judiciary has completed its work. A wider 
societal  discussion  took  place  on  the  nomination  system  of  lay  judges  which  is  done  via 
political  parties  and  therefore  raised  concerns  on  ensuring  their  independence.  Some  of  the 
gaps  regarding  digitalisation  of  justice  are  being  addressed  and  fully  digital  judgments  in 
criminal cases in district courts were introduced. The courts were granted increased financial 
resources for the period 2023-2025. The Swedish justice system performs efficiently. 

The perception among experts and business executives is that Sweden is one of the least corrupt 
countries in the world. As part of the National Anti-Corruption Plan, work is ongoing towards 
a final report in December 2023. There have been no developments following a proposal by a 
committee  of  inquiry  to  extend  the  statute  of  limitations  for  corruption  and  other  serious 
offences. Corruption related to infiltration of organised crime groups into the public service 
remains a concern. Efforts have been made to prosecute foreign bribery cases, but so far, the 
limited legal definitions of foreign bribery remain unchanged. The Government has still not 
updated  the  Ethical  Guidelines  for  civil  servants,  and  independent  advice  and  oversight  for 
ministers are not in place. Sweden’s culture of openness and disclosure of information enables 
transparency of lobbying, while the Government launched a parliamentary inquiry on political 
party financing legislation and lobbying. The Government launched an inquiry to evaluate the 
rules on ‘revolving doors’ for a wide range of public functions, which is ongoing and should 
be completed by August 2023.  

Sweden  has  a  strong  legal  framework  guaranteeing  media  freedom  and  pluralism  with 
safeguards stemming both from the Constitution and from legislation. A restructuring of the 
independent  Press  and  Broadcasting  Authority  is  being  prepared.  The  Government  has 
introduced new legislation to improve transparency of media ownership; it has also taken steps 
to  update  rules  on  broadcasting  licenses  and  extended  from  six  to  eight  years  the  licensing 
period for the terrestrial network for commercial television. The Government has additionally 
taken steps to  review the legislative framework  of the public service media and to  increase 
criminal law protection for journalists, who increasingly report instances of hate speech, threats 
and insults. In parallel, the Police has strengthened cooperation with publishers through joint 
seminars aimed at preventing crimes committed against journalists. 

The opinions of the Council on Legislation are followed by the Government in a large majority 
of  cases.  As  regards  the  Parliamentary  Ombudsmen,  amended  constitutional  and  legislative 
rules are expected to take effect in January 2027 and September 2023 respectively, reflecting 
the  parliamentary  review  on  their  functioning  and  mandate.  The  National  Human  Rights 
Institution is working towards an A-accreditation. As regards reforms of the legal framework 
for  the  funding  and  operation  of  civil  society  organisations,  one  legislative  proposal  was 
withdrawn  for  revision,  while  the  impact  on  civil  society  engagement  of  the  legislative 
initiatives  remains  to  be  ascertained.  Even  though  Sweden  continues  to  have  an  open  civil 
society space, recent developments have given rise to some concerns in that regard.  

1 

 
 
RECOMMENDATIONS  

Overall, concerning the recommendations in the 2022 Rule of Law Report, Sweden has (made):  

  Fully implemented the recommendation to continue the work of the Committee of Inquiry 
on strengthening the protection of democracy and the independence of the judiciary, taking 
into account European standards on judicial independence.   

  Some  progress  on  the  evaluation  of  the  scope,  impact  and  implementation  of  the  rules 

relating to revolving doors that cover top executive functions in the Government. 

  Some  progress  on  strengthening  the  fight  against  foreign  bribery,  including  through 
amending existing legal definitions and improving on prosecution and final judgments of 
cases.  

  Some progress on ensuring that on-going reforms to the legal framework for the funding 
and operation of civil society organisations do not unduly affect civil society engagement. 

On this basis, and considering other developments that took place in the period of reference, it 
is recommended to Sweden to: 

  Ensure that the nomination system of lay judges safeguards their independence, taking into 

account European standards on judicial independence.   

  Evaluate the scope, impact and implementation of the rules relating to revolving doors that 

cover top executive functions in the Government.  

  Strengthen the fight against foreign bribery, by amending the existing legal definitions to 

improve on the prosecution of, and final judgments in foreign bribery cases.  

  Continue efforts to ensure that the on-going reforms to the legal framework for the funding 
and operation of civil society organisations do not unduly affect civil society engagement. 

2 

 
 
 
 
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  administrative  courts  with  12 
administrative  courts,  four  administrative  courts  of  appeal  and  the  Supreme  Administrative 
Court.  There  are  also  two  special  courts1.  The  National  Courts  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.  Sweden  is  undertaking  steps  for  joining  the  European 
Public Prosecutor’s Office (EPPO)6. The Swedish Bar Association is an independent and self-
governing association established by law and is responsible for supervision of the professional 
activities of advocates and taking disciplinary measures against its members7.  

Independence  

The level of perceived judicial independence in Sweden continues to be high among the 
general public and among companies. Overall, 75% of the general population and 70% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in 20238. According to data in the 2023 EU Justice Scoreboard, no clear trend can be identified 
in the evolution of the perceived level of independence among the general public since 2016. 
Nevertheless,  the  perceived  judicial  independence  among  the  general  public  has  increased 
slightly  in  comparison  with  2022  (74%),  while  remaining  lower  than  in  2016  (77%).  The 
perceived judicial independence among companies remains at the same level as in 2022 and is 
higher than in 2016 (66%). 

The  Committee  of  Inquiry  on  strengthening  the  protection  of  democracy  and  the 
independence  of  the  judiciary  has  completed  its  work.  The  2022  Rule  of  Law  Report 
recommended to Sweden to “continue the work of the Committee of Inquiry on strengthening 

1   The Labour Court and the Defence Intelligence Court. Input from Sweden for the 2021 Rule of Law Report. 
For a description of the judicial structure, see CEPEJ (2021), Study on the functioning of judicial systems in 
the EU Member States. Sweden does not have a constitutional court. 

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 
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   Input from Sweden for the 2023 Rule of Law Report, p. 2. 
7   Code of Judicial Procedure, Chapter 8. 
8   Figures 49 and 51, 2023 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%). 

3 

 
                                                           
the  protection  of  democracy  and  the  independence  of  the  judiciary,  taking  into  account 
European standards on judicial independence”9. On 17 March 2023, the Committee of Inquiry 
delivered  a  comprehensive  report10  based  on  the  broad  political  consensus  underpinning  its 
composition11. It recommended the setting up of a new court administration agency that would 
be  more  independent  from  the  Government  as  compared  to  the  current  National  Courts 
Administration12, notably in terms of being headed by a Board13 – a majority of which are or 
have been judges, nominated by the courts – that would appoint the agency’s director14. In its 
assessment, the Committee of Inquiry took into account European standards15 and carried out 
a comparative overview with other European countries16. The report comprises proposals on a 
number of further aspects, such as the procedure for amending the Constitution17, adjustments 

9   2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 3-4. 
10   The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the protection of democracy and 

independence of the judiciary.  

11   Ibid. 
12   The  new  agency  would  essentially  have  the  same  assignments  as  the  National  Courts  Administration. 
Furthermore,  the  Government  should  be  required  to  obtain  a  draft  budget  from  the  new  agency.  If  the 
Government’ Budget Bill for the Parliament were to deviate from the new agency’s draft, it would have to 
provide  a  special  justification  for  doing  so.  The  2020  Committee  of  Inquiry  on  the  Constitution  (2023), 
Strengthening the protection of democracy and independence of the judiciary, pp. 47-50. 

13   The Board would be comprised of nine members, five of whom would have to be judges or previously have 
been judges. Each Board member should have a deputy. The members and their deputies would be appointed 
by the Government for a period of six years. A specific nomination procedure will be introduced to ensure that 
the courts have a significant influence over the composition of the Board. A Board member or deputy on the 
Board could not simultaneously be a  member of the Parliament,  a Government  minister, employed by the 
Parliament, employed in the Government Offices, employed at central level in a political party or hold another 
post or mandate rendering them ineligible. A decision to remove a Board member (other than at own request) 
would be taken by the Parliament, at the request of its Committee on the Constitution; at least three-quarters 
of the voters and more than half of the members of the Parliament would have to vote in favour on the decision. 
The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the protection of democracy and 
independence of the judiciary, pp. 47-50, 331-336 and 341-345. 

14   The Board would appoint the Director of the new agency, rather than the Government as is presently the case 
for the National Courts Administration. The Director would have a limited term of six years, with an option 
to extend by a further three years. A decision to remove the Director from office would be made by the Board. 
The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the protection of democracy and 
independence of the judiciary, p. 49. 

15   Among others, the Committee took into account the European Convention on Human Rights and the case law 
of the European Court of Human Rights (e.g. on requirements related to an independent and impartial tribunal 
established by law), the Charter of Fundamental Rights of the European Union, the Treaties as well as the case 
law of the Court of Justice (on Article 19(1) TEU and Article 47 of the Charter), the UN Basic Principles on 
the  Independence  of  the  Judiciary,  Council  of  Europe  Recommendation  CM/Rec(2010)12  on  Judges: 
independence, efficiency and responsibilities, the European Charter on the statute for judges, or the Venice 
Commission report on Independence of the Judicial System, Part I. The 2020 Committee of Inquiry on the 
Constitution (2023), Strengthening the protection of democracy and independence of the judiciary, pp. 221-
239. 

16   The Committee compared the situation of the topics covered in the report with Denmark, Finland, Iceland, 
Norway, Estonia, the Netherlands and Germany. The 2020 Committee of Inquiry on the Constitution (2023), 
Strengthening the protection of democracy and independence of the judiciary, pp. 241-276. 

17   Presently, the Parliament can amend the Constitution by passing two identically worded votes in favour by 
simple majority with a parliamentary election (ordinary or snap elections) between both votes. The Committee 
proposed that a qualified majority (two-thirds) in the Parliament should be required for the second vote. The 
requirement to obtain an opinion from the Council on Legislation should be extended to include constitutional 
amendments on fundamental freedoms and rights (presently this applies only to constitutional amendments in 
the  area  of  freedom  of  the  press  and  freedom  of  expression).  The  2020  Committee  of  Inquiry  on  the 
Constitution (2023), Strengthening the protection of democracy and independence of the judiciary, pp. 43-46. 

4 

 
                                                           
in the system of appointment of judges18, procedures for accountability of judges, including a 
new disciplinary body19, a statutory retirement age for judges of the Supreme Courts and other 
judges20, and a special joint composition with judges of both Supreme Courts21. It is foreseen 
that the necessary amendments to the Constitution proposed by the Committee and adopted by 
Parliament  could  enter  into  force  on  1  April  2027,  whereas  the  legislative  provisions 
concerning the nomination and composition of the new court administration agency and the 
Judges Proposals Board would enter into force on 1 January 202722. As an immediate next step, 
the Government launched a public consultation on the report in April23. As the Committee of 
Inquiry has completed its work, the recommendation in the 2022 Rule of Law Report is fully 
implemented. 

A wider societal discussion took place on the nomination system of lay judges which is 
done via political parties, and therefore raised concerns on ensuring their independence. 
The lay judges in Sweden are nominated exclusively24 by the political parties and elected by 

18   The  Committee proposed targeted changes to the current system of appointing judges, by providing in the 
Constitution that judges are appointed by the Government following the proposal of a specific body, a majority 
of whose members must be or have been judges. A new provision would be inserted in the Constitution on the 
conditions  under  which a  member or deputy  member of the  proposing body  may be removed from office. 
Furthermore,  the  Government  should  only  appoint  a  person  proposed  by  the  Judges  Proposals  Board  as  a 
judge. If the appointment proposal were to include more than one candidate and the candidates were ranked, 
the  Government  would  not  be  bound  by  the  ranking.  The  2020  Committee  of  Inquiry  on  the  Constitution 
(2023), Strengthening the protection of democracy and independence of the judiciary, pp. 50-51.  

19   The Committee touched upon the arrangements for examining under which circumstances a judge could be 
removed  or  suspended  from  office  or  obliged  to  undergo  a  medical  examination.  For  judges  (other  than 
Supreme Courts’ judges), this examination is presently conducted by the Government Disciplinary Board for 
Higher Officials and may be reviewed by a court. In the Committee’s view, the disciplinary system should not 
be linked to the executive power as is currently the case and judges’ accountability ought not be primarily 
dealt with as a matter of labour law. The Committee considered that a Disciplinary Board for Judges should 
be established, enjoying constitutional protection and consisting of a majority of members who are or have 
been  judges.  Given  that  this  proposal  was  outside  of  the  Committee’s  mandate,  the  latter  proposed  that  a 
separate inquiry be established. The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the 
protection  of  democracy  and  independence  of  the  judiciary,  pp.  52-53.  According  to  the  2023  EU  Justice 
Scoreboard, the percentage of women in the top judicial positions is below 30%. Figure 36, 2023 EU Justice 
Scoreboard. 

20   The Committee proposed that the Constitution should provide that Supreme Courts’ judges can be removed 
from office only if they have reached a statutory retirement age and not apply retroactively. Supreme Courts’ 
judges should be obliged to leave their office at the end of the month in which they reach the age of 69. On 
application  from  a  Supreme  Court  judge,  the  new  courts  agency  should  be  able  to  decide  upon  a  higher 
retirement age based on are relevant operational grounds. The proposals for the Supreme Court judges should 
also  apply  to  other  judges.  The  2020  Committee  of  Inquiry  on  the  Constitution  (2023),  Strengthening  the 
protection of democracy and independence of the judiciary, pp. 53-54. 

21   This proposal refers to a possibility for both Supreme Courts to examine cases jointly in a special composition. 
The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the protection of democracy and 
independence of the judiciary, p. 55. 

22   The  Committee  of  Inquiry  noted  that  separate  inquiries  would  be  needed  to  fully  implement  certain  of  its 
proposals,  such  as  relating  to  questions  on  labour  law  and  the  procedure  for  rendering  permanent  judges 
accountable. The necessary preparatory work should be concluded so that the relevant legislation could also 
enter into force on 1 April 2027. The 2020 Committee of Inquiry on the Constitution (2023), Strengthening 
the protection of democracy and independence of the judiciary, p. 56. 

23   The  public  consultation  is  open  until  1  September  2023.  Swedish  Government  (2023), public  consultation 

SOU 2023:12. 

24   There is no other way to be nominated than by a political party. National Courts Administration (2023), For 

those wanting to become lay judges. 

5 

 
                                                           
municipal  councils  or  county  council  assemblies25.  Lay  judges  participate  in  the  courts  of 
appeal, the administrative courts of appeal, the district courts and the administrative courts26. 
While there are no specific provisions requiring an individual to be a member of a political 
party to become a lay judge, the political parties themselves decide whether they want to require 
membership in order to nominate a person as a lay judge27. Even though the performance of a 
lay judge’s duties is required to be non-political, independent and impartial28, the nomination 
via  political  parties  has  given  rise  to  concerns  in  concrete  cases.  In  2023,  a  wider  societal 
discussion took place on the nomination system of lay judges with reactions from stakeholders 
and political parties underlining the importance of judicial independence29. This public debate 
started following a judgment in a criminal case on appeal, which had attracted significant media 
coverage; the political party having nominated two of the lay judges involved, invited them to 
a “coaching session”, after which the two lay judges resigned30. This has also made it more 
difficult to attract new lay judges31. The Judges Association and the Bar Association consider 
that  the  lay  judges  should  be  nominated  without  the  involvement  of  political  parties32. 

25   Lay judges are elected every four years. The political parties represented in the municipal and regional councils 
nominate  individuals  reflecting  the  population  composition.  Based  on  the  political  parties’  relative 
representation  size  in  the  municipal  and  regional  councils,  parties  may  nominate  different  numbers  of  lay 
judges. The selected lay judges must meet the eligibility and suitability requirements, complete a mandatory 
training  (on  publicity  and  confidentiality,  disqualification,  ethics  and  the  non-political  nature  of  the 
assignment) and take the judicial oath before serving in the court. Lay judges and professional judges are on 
an equal footing when deciding a case, with each judge having an individual vote; the lay judges have a say 
in all aspects of the case, including  matters of law. In the  performance of their duties, lay judges  may not 
pursue  political  opinions  in  court  and  may  not  be  influenced  by  personal  values.  The  Constitution  also 
stipulates that no authority, not even the Swedish Parliament, may decide how a court shall rule in an individual 
case or how a court shall otherwise apply a rule of law in a particular case. Input from Sweden for the 2020 
Rule  of  Law  Report,  p.  4  and  written  contribution  by  the  Ministry  of  Justice  and  the  National  Courts 
Administration in the context of the country visit to Sweden. 

26   At a trial in the district courts and the administrative courts, three lay judges participate under the direction of 
a professional judge. At second instance at the courts of appeal and administrative courts of appeal there are 
two lay judges and three professional judges. Ibid. 

27   National Courts Administration (2023), For those wanting to become lay judges.  
28   Ibid. 
29   Svenska Dagbladet (2023), Commentary from the Judges Association: Lay judges should not be nominated 
by  the  political  parties,  Dagens  Juridik  (2023),  Commentary  from  the  Director  of  the  National  Courts 
Administration: “I understand that the Snippa ruling evokes emotions”, Dagens Juridik (2023), Commentary 
from  the  Lay  Judges  Association:  Lay  judges:  “We  agree  with  the  Director  of  the  National  Courts 
Administration”, SVT (2023), After the Snippa ruling, parties see problems with the jury system.  

30   SVT (2023), After the Snippa case: Two members of the Court of Appeal for Western Sweden leave the court, 

SVT (2023), Shekarabi: Social-democrats district wrong to contact lay judges in the Snippa ruling.  

  The Judges Association also referred to a similar incident, in 2018, when a political party initiated a procedure 
to exclude from its membership two lay judges it had nominated and considered to be representing the party. 
The stated reason being that the wording of a judgment, in which the two lay judges nominated by that party 
had participated, did not correspond to the party’s values. Written contribution and information received from 
the  Judges  Association  in  the  context  of  the  country  visit.  Centre  Party  webpage  (2018)  Solna  judgment: 
exclusion case. 

31   During the relevant period, the recruitment of lay judges for the term covering 2024-2027 was underway. SVT 

(2023), Difficult to recruit lay judges after the “Snippa” ruling: “Many are reluctant to continue”. 

32   The  Swedish  Bar  Association  considers  that  system  of  lay  judges  should  be  reformed  so  as  to  reduce  lay 
judges’ influence in the judicial process, lay judges should be apolitical and not appointed by political bodies, 
and not participating in rulings of appeal courts. The Swedish Bar Association (2021), The Bar Association’s 
Rule of Law Programme, p. 16. The Swedish Lay Judges Association is not in favour of changing the current 
system, despite noting that it is not without shortcomings. Among other things, it would like to see more lay 
judges  without a party affiliation and more  younger people becoming lay judges.  SVT (2023), Difficult to 
recruit lay judges after the “Snippa” ruling: “Many are reluctant to continue”.  

6 

 
                                                           
Proposals  on  modifying  the  appointment  system  by  reducing  the  number  of  lay  judges 
nominated  by  political  parties  were  put  forward  in  2002  and  2013  but  did  not  lead  to  any 
changes33.  In  accordance  with  the  case  law  of  the  European  Court  of  Human  Rights,  the 
principles applicable to  determining whether a tribunal can be considered “independent and 
impartial” apply equally to professional judges, lay judges and jurors34.  

Quality  

Some of the gaps regarding digitalisation of justice are being addressed and fully digital 
judgments in criminal cases at district courts were introduced. The use and availability of 
digital technology in Swedish courts is overall good35 and there has been further improvement 
on  digital  solutions  to  conduct  and  follow  criminal  proceedings,  notably  concerning  the 
possibility  for  victims  and  defendants  to  submit  written  statements  online36.  Nevertheless, 
some  gaps  remain  when  it  comes  to  accessing  first  instance  court  judgments  online,  and 
arrangements  for  their  machine  readability37.  In  October  2022,  the  first  fully  digital  district 
court judgments were adopted. A system change currently being introduced in all district courts 
for criminal judgments means that the digital judgment henceforth constitutes the original38. 
As noted in the 2022 Rule of Law Report, the project would be gradually integrated with other 
authorities  and  developed  to  handle  also  other  types  of  proceedings  and  judgments39. 
Moreover, as part of another effort to allow easier access to courts, parties and witnesses in a 
hearing will be able to participate remotely via video link from a state service office40.  

The courts were granted increased financial resources for the period 2023-2025. In the 
budget bill for 2023, the courts were granted more financial resources compared to the previous 
allocations  foreseen  for  the  period  2023-202541;  this  allocation  was  higher  than  what  was 

33   The Judges Association referred to two Government proposals:, in 2002, SOU 2002:61 proposed that 20 % of 
the  lay  judges  should  be  appointed  without  having  been  nominated  by  a  political  party  and  in  2013  SOU 
2013:49 proposed that at least half of the lay judges should be appointed without having been nominated by a 
political party Svenska Dagbladet (2023), Commentary from the Judges Association: Lay judges should not 
be nominated by the political parties, and information received from the Judges Association in the context of 
the country visit.  

34   Judgment  of  the  European  Court  of  Human  Rights  of  25  November  1993,  Holm  v.  Sweden,  14191/88, 
paragraph 30, Judgment of the European Court of Human Rights of 16  December 2003, Cooper v. United 
Kingdom, 48843/99, paragraph 123. 

35   Figures 41 and 42, 2023 EU Justice Scoreboard. 
36   Figure 46, 2023 EU Justice Scoreboard.  
37   Figures 47 and 48, 2023 EU Justice Scoreboard. 
38   The processing of criminal judgments, like other judgments, has been digital for a long time. Criminal case 
judgments in district courts are from now on signed digitally. All information in the judgment is entered in a 
structured form and the authorities that have access to the system automatically receive the information they 
need  from  the  judgment  without  the  court  having  to  send  the  information  manually.  National  Courts 
Administration (2022), The Swedish courts' first digital judgment and written contribution received from the 
National Council for Crime Prevention in the context of the country visit to Sweden. 
39   2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 5. 
40   The  purpose  of  the  service,  first  rolled  out  in  nine  state  service  offices,  is  to  increase  the  possibility  of 
attendance,  provide  a  shorter  travel  route  for  participants  and  fewer  cancelled  hearings  due  to  possible 
difficulties to attend hearings physically. National Courts Administration (2022), State service centre and the 
National Courts Administration working together to improve service to citizens.  

41   The courts were allocated approximately EUR 3.15 million (SEK 36 million) for 2023 and proposed to receive, 
approximately EUR 7.01 million (SEK 80 million) in 2024 and approximately EUR 14.89 million (SEK 170 
million) in 2025. National Courts Administration (2023), Budgetary, p. 7 and input from Sweden for the 2023 

7 

 
                                                           
requested by the National Courts Administration42. The increased allocations are intended to 
address additional tasks to be entrusted to the National Courts Administration43. Nevertheless, 
some stakeholders pointed out that the allocation would not benefit the human resources in the 
judiciary44  and  emphasised  challenges  in  recruitment  of  judges  and  other  personnel45. 
Furthermore,  the  Judges  Association  reiterated  that  the  remuneration  system46,  based  on  a 
collective  agreement47  and  individual  negotiations  of  the  salary  for  each  judge  is  non-
transparent and allows for remuneration of (individual) judges to be controlled politically48, 
while it did not alleviate problems with recruitment of judges, as had been intended with its 
introduction49. The National Court Administration referred to the collective agreement, which 

Rule of  Law Report,  p. 3. Written contribution received from  the Ministry of Justice in the context of the 
country visit to Sweden. 

42   As  noted  in  the  2022  Rule  of  Law  Report,  the  National  Courts  Administration  had  asked  for  additional 
resources of approximately EUR 10.7 million (SEK 115 million) for the operation of the courts in 2025. 2022 
Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 4-5 and information received 
from the Ministry of Justice in the context of the country visit to Sweden. 

43   The  Budget  Bill  2023  lists  eight  additional  tasks,  such  as  the  new  structure  for  the  civil  defence  and  the 
society´s crisis preparedness or the initiative related to safe houses for children and adults (related to domestic 
violence), or a new confiscation legislation. These additional tasks and initiatives are not only compensation 
generating  more  allocations  to  the  courts,  but  also  include  transfer  of  resources  from  the  courts  to  other 
authorities. Written contribution and information received from the Ministry of Justice in the context of the 
country visit to Sweden; Swedish Government (2022), Budget Bill for the judiciary 2023, p 74.  

44   The  Swedish  Bar  Association  also  emphasised  that  not  only  the  courts,  but  also  other  parts  of  the  justice 
system,  such  as  the  Police  and  the  Prosecution  Service  had  received  increased  budgetary  allocations. 
Information received from the Swedish Bar Association in the context of the country visit to Sweden. 

45   The Judges Association estimates that the  financial allocations  will be significantly impacted by increased 
building rental costs. Furthermore, the allocations to the courts are smaller than to the Police and Prosecution, 
which has an impact on the processing of cases in the courts. Information received from the Judges Association 
in the context of the country visit to Sweden. 

46   The Swedish National Courts Administration and the judge agree on a salary when the judge is appointed. The 
salaries are revised every year. New salaries are agreed between the individual judge and the president of the 
court (or a senior judge to whom this task is delegated). Input from Sweden for the 2020 Rule of Law Report, 
p. 8. 

47   As also noted in the 2021 Rule of Law  Report,  according to the Council of Europe recommendations, the 
principal rules of the system of remuneration for professional judges should be laid down in law. See notably 
Recommendation  CM/Rec(2010)12  of  the  Committee  of  Ministers  of  the  Council  of  Europe,  para. 53.;  in 
addition, the Venice Commission is of the opinion that for judges a level of remuneration should be guaranteed 
by law in conformity with the dignity of their office and the scope of their duties. See Venice Commission, 
Independence  of  the  Judicial  System,  Part  I,  CDL-AD(2010)004,  The  Independence  of  Judges,  para.  51. 
According to the Judges Association, a remuneration system for judges laid down in law already existed in 
Sweden. This  was the  situation up  until 2004,  when the  collective agreement  was introduced. Information 
received from the Judges Association in the context of the country visit to Sweden 

48   The Judges Association considers that the ability to recruit senior lawyers with higher salaries is an argument 
in favour of individual starting salaries, but should not have a bearing on subsequent individual salary setting, 
which could be achieved by recruiting new lawyers to a higher salary grade. The association points out further 
that the remuneration of judges can be controlled politically, in particular as it is ultimately the National Courts 
Administration being entitled to set individual salaries (although there is  currently a delegation decision to 
court  presidents).  The  association  points  out  that  the  Director  of  the  National  Courts  Administration  is 
appointed by the Government and it is Government agency. The association considers that there is nothing in 
current system that would prevent the Government, through the National Courts Administration, from exerting 
pressure on the courts by rewarding or sanctioning how law is being applied by individual judges. Written 
contribution from the Judges Association in the context of the country visit to Sweden. 

49   The Judges Association referred to recruitment problems with vacancies for judges in central Sweden, such as 
Linköping, Norrköping, Uppsala, Karlstad or Örebro. Information received from the Judges Association in the 
context of the country visit to Sweden. 

8 

 
                                                           
aims to ensure that the salaries and their development need to be competitive so that it can 
recruit and retain the most skilled individuals as judges50.  

The legal aid threshold for civil cases has not been adjusted for inflation since 1999, but 
the vast majority of population is insured for legal protection. In order to be eligible for 
legal  aid  in  civil  cases51,  applicants’  annual  revenue  must  not  exceed  the  threshold  of 
approximately EUR 22 770 (SEK 260 000)52, whereas the average annual salary in Sweden in 
2021 was approximately EUR 38 986 (SEK 445 200)53. Furthermore, a pre-requisite for legal 
aid is that the legal costs are not covered by an insurance, such as a home insurance. According 
to  the  Ministry  of  Justice,  the  vast  majority  of  population  in  Sweden  (96%)  has  a  home 
insurance,  which  usually  includes  a  legal  protection  coverage54.  In  2014,  a  special  inquiry 
mandated by the Government reviewed the legal aid system, and at that time, suggested to raise 
the threshold to SEK 400 00055. However, this was not taken forward, and as the threshold for 
legal aid in civil cases has not been adjusted for inflation since 1999, the number of individuals 
qualifying for the legal aid threshold has steadily decreased56. 

Efficiency 

The  Swedish  justice  system  performs  efficiently.  The  number  of  incoming  civil  and 
commercial  litigious  cases  has  remained  comparatively  low  in  202157.  The  estimated  time 
needed to resolve litigious civil, commercial, administrative and other cases at first instance is 

50   The National Courts Administration is together with the trade union of judges (Jusek) the contractual party to 
the collective agreement. It referred to the provision of the collective agreement (6 § Lokalt löneavtal 2011-
05-25 mellan Domstolsverket och Jusek, inom RALS 2010-T), which provides, among others, that the salary 
of a judge may never be made on grounds contrary to the interest of judicial independence or in a manner that 
would be objectively a reaction on how a judge rules or otherwise applies law in individual cases. The salary 
setting  of  a  judge  shall  be  based  on  the  assumption  that  the  judicial  decision-making  entails  a  special 
responsibility. Written input received from the National Courts Administration in the context of the country 
visit to Sweden. 

51   The legal assistance in criminal cases and in administrative cases is based on  need, and  not on an income 
threshold. Written contribution from the Ministry of Justice in the context of the country visit to Sweden. 
52   According to the Ministry of Justice, the basic idea behind legal aid in Sweden is that an individual should 
contribute to the cost to the extent that he or she can afford. A legal aid fee is therefore paid by the applicant, 
and it varies from 2% to 40% of the costs depending on the applicant’s income. Written contribution from the 
Ministry of Justice in the context of the country visit to Sweden. To determine the eligibility for legal aid, 
there are different factors that are taken into account to assess the annual income threshold, such as assets, 
debts, or certain types of revenues/reimbursements. National Courts Administration (2022),  Calculate your 
economic base.  

53   Written contribution from the Ministry of Justice in the context of the country visit to Sweden. 
54   Ibid Nevertheless, the Swedish Bar Association has pointed out that the legal protection coverage can have 
ceilings,  after  which  an  individual  may  not  receive  financial  coverage  from  the  insurance  for  legal  costs. 
Information received from the Swedish Bar Association in the context of the country visit to Sweden. 

55   Swedish Government (2014), public consultation SOU 2014:86, p. 224. Based on the average exchange rate 

in 2014, this would convert to approximately EUR 43 945.  

56   The  Swedish  Bar  Association  emphasised  that  the  Swedish  legal  aid  system  has  changed  towards  an 
increasingly privately funded regime, instead of a state funded legal aid regime . The absence of an increase 
of the threshold or adjustment for inflation had resulted in a steadily decreasing number of individuals eligible 
for legal aid in civil cases. Written input and information received from the Swedish Bar Association in the 
context of the country visit to Sweden. The Civil Rights Defenders have pointed out that with the threshold of 
SEK 260 000 there was 80% of population eligible in 1999, whereas presently only 36% of population falls 
below that threshold. Information received from the Civil Rights Defenders in the context of the country visit 
to Sweden.  

57   Figure 3, 2023 EU Justice Scoreboard. 

9 

 
                                                           
short (148 days  in  2021) and has continued to  decrease (161 days in  2020 and 167 days in 
2019)58. The clearance rate has stayed positive at a stable level for both civil and commercial 
litigious cases (102.8% in 2020 and 102.7% in 2021) and further improved for administrative 
cases (from 102.3% in 2020 to 103.4% in 2021)59. The number of pending civil and commercial 
cases  at  first  instance  remains  stable  at  a  low  level60.  According  to  the  National  Courts 
Administration’s data, the number of incoming and decided cases has continued the decreasing 
trend since 201861. In 2023, the use of the fast-track criminal procedure for adult offenders to 
shorten the time taken to prosecute certain offences was expanded to all courts62.  

II. 

ANTI-CORRUPTION FRAMEWORK  

Sweden  has  the  legislative  and  institutional  framework  to  combat  and  prevent  corruption 
broadly in place. There is no independent anti-corruption authority or agency in Sweden, but 
the Agency for Public Management is responsible for the good administrative culture across 
Government. The National Council for Crime Prevention is a knowledge centre for the criminal 
justice  system  and  its  mandate  includes  developing  crime  prevention  work  at  the  national, 
regional  and  local  level.  The  National  Anti-Corruption  Unit  (NACU)  is  the  specialised 
prosecution  agency  within  the  Swedish  Prosecution  Authority  responsible  for  all  criminal 
investigations, related to corruption and bribery, including foreign bribery, in cooperation with 
the National Anti-Corruption Unit of the Swedish Police Authority (NACPU). As part of the 
Swedish  Police  Authority,  the  National  Anti-Corruption  Police  Unit  is  tasked  with 
investigating  corruption  crimes,  asset  recovery  and  preventing  corruption  by  providing 
knowledge  to  different  public  authorities  as  well  as  business  associations.  The  Special 
Investigation  Department  of  the  Police  Authority  handles  internal  investigations  of  police 
officers  and prosecutors (including as regards  corruption offences). The Swedish  Economic 
Crime Authority organised under the Ministry of Justice has the mandate to investigate and 
prosecute serious financial crimes, including the recovery of proceeds of crime. Other agencies, 
such  as  the  National  Audit  Office,  the  National  Competition  Authority  and  the  Financial 
Intelligence Unit of the Swedish Police, are in charge of the prevention and investigation of 
corruption, and of forensics and auditing. 

The perception among experts and business executives is that Sweden is one of the least 
corrupt countries in the world.  In the 2022 Corruption Perception Index by Transparency 
International, Sweden scores 83/100 and ranks third in the European Union and fifth globally63. 
This  perception  has  been  relatively  stable  over  the  past  5  years64.  The  2023  Special 

58   Figure 6, 2023 EU Justice Scoreboard. 
59   Figures 11 and 12, 2023 EU Justice Scoreboard.  
60   Figure 13, 2023 EU Justice Scoreboard.  
61   According to the National Courts Administration’s data, in 2022 the number of incoming and decided cases 
has continued to decrease (by 7% for incoming and 6% for decided cases compared to 2021), while the number 
of cases pending at end of the year has continued to decrease (160 727 in 2022 compared to 158 245 in 2021). 
National Courts Administration (2023), Annual report 2022, pp. 12 and 13. 

62   National Courts Administration (2023), Annual report 2022, pp. 85-86. 
63   Transparency International, Corruption Perceptions Index 2022, pp. 2-3. The level of perceived corruption is 
categorized as follows: low (the perception among experts and business executives of public sector corruption 
scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50), high (scores 
below 50). 

64   In 2018 the score was 85, while, in 2022, the score is 83. The score significantly increases/decreases when it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

10 

 
                                                           
Eurobarometer on Corruption shows that 36% of respondents consider corruption widespread 
in  their  country  (EU  average  70%)  and  10%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 24%)65. As regards businesses, 37% of companies 
consider that corruption is widespread (EU average 65%) and 13% consider that corruption is 
a problem when doing business (EU average 35%)66. Furthermore, 34% of respondents find 
that  there  are  enough  successful  prosecutions  to  deter  people  from  corrupt  practices  (EU 
average 32%)67, while 45% of companies believe that people and businesses caught for bribing 
a senior official are appropriately punished (EU average 30%)68.  

As part of the National Anti-Corruption Plan, work is ongoing towards a final report in 
December 2023. The aim of the Action Plan is to provide public agencies with tools and best 
practices on the prevention of corruption69. As noted in the 2022 Rule of Law Report, part of 
the Action Plan was the publication of an interim report, which highlighted three factors for 
improvement: the various authorities’ understanding of the concept of corruption, the role of 
the management and the availability of the necessary resources and expertise70. Following the 
publication  of  its  first  interim  report71  that  looked  into  the  risks  analyses  and  reporting 
structures of 209 Government authorities, the Agency for Public Management will present a 
final report in December 202372. This report will include recommendations to the Government. 
The Government will not respond to the interim report73 but intends to await the final report. 
As part of the Anti-Corruption Plan, the Agency for Public Management produced two manuals 
on best practice for public agencies in relation to analyses of corruption risks74. The Agency does 
not monitor the implementation of these manuals and will ask the agencies about implementation 
for the final Anti-Corruption Plan report75. Civil society has expressed concerns on the level of 
commitment and actions in the Action Plan76. 

There  have  been  no  developments  following  a  proposal  by  a  committee  of  inquiry  to 
extend the statute of limitations for corruption and other serious offences. As noted in 
previous Rule of Law Reports77, a committee of inquiry tasked with reviewing the statute of 
limitations  has  proposed  to  extend  this  statute  as  applied  to  serious  crimes,  including  the 
offences of ‘gross taking of a bribe’ and ‘gross giving of a bribe’ from 10 years to 15 years78. 

65   Special Eurobarometer 534 on Corruption (2023). The Eurobarometer data on citizens’ corruption perception 

and experience is updated every year. The previous data set is the Special Eurobarometer 523 (2022). 

66   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year.  The  previous  data  set  is  the  Flash 
Eurobarometer 507 (2022). 

67   Special Eurobarometer 534 on Corruption (2023).  
68   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023).  
69   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 6 and 2022 Rule of Law 

Report, Country Chapter on the rule of law situation in Sweden, p. 8. 

70   2022 Rule of Law Report, Country chapter on the rule of law situation in Sweden, p. 8.  
71   Ibid. 
72   Information received in the context of the country visit to Sweden from the Agency for Public Management.  
73  Information received in the context of the country visit to Sweden from the Ministry of Justice.  
74   Input from Sweden for the 2023 Rule of Law Report, p. 7.  
75   Information received in the context of the country visit to Sweden from the Agency for Public Management.  
76   2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8, and 2021 Rule of Law 

Report, Country Chapter on the rule of law situation in Sweden, p. 6.  

77   2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 5 and 2021 Rule of Law 
Report, Country Chapter on the rule of law situation in Sweden, p. 6 and 2022 Rule of Law Report, Country 
Chapter on the rule of law situation in Sweden, p. 8.  

78   2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8.  

11 

 
                                                           
The  Government  intends  to  implement  this  proposal  but  did  not  provide  for  a  concrete 
timeline79.  In  February  2023,  an  inquiry  on  undue  influence  and  corruption  was  closed. 
Reportedly, the new Government considered the mandate of the inquiry unclear, which would 
result in an overly general mapping that did not meet the present priorities80. The Government 
therefore intends to appoint a new committee of inquiry on bribery and other corruption related 
offences focusing on criminal law, but the detailed mandate is still to be finalised81. This new 
committee of inquiry is expected to be appointed in the second half of 202382.  

Law  enforcement  agencies  responsible  for  anti-corruption  are  overall  well-resourced, 
although both the Police and the Prosecution Authority see space for improvement. The 
Prosecution Authority and the Police have sufficient resources83. However, the Police consider 
that  the  anti-corruption  related  work  would  benefit  from  more  personnel  in  the  intelligence 
unit84 and the Prosecution Authority indicates that putting a larger focus on corruption crimes 
would  also  strengthen  their  corruption  work85.  Good  cooperation  exists  between  the  law 
enforcement  agencies  involved  in  the  investigation  and  prosecution  of  corruption,  although 
some overlaps in their responsibilities can sometimes lead to uncertainty as to the service in 
charge  of  investigation86.  Data  from  the  National  Council  for  Crime  Prevention  indicates  a 
decrease in reported bribery cases in 2022 compared to 2021, in particular the number of reports 
on received bribes87. In 2022, prosecutions were initiated for 73 bribery-related offences and 
50 convictions were obtained, of which two resulted in imprisonment88. Following the critical 
remarks of the Swedish National Audit Office about the functioning of the Economic Crime 
Authority89,  the  Economic  Crime  Authority  is  taking  measures  and  will  report  back  to  the 
Government by the end of 202390. 

Corruption  related  to  infiltration  of  organised  crime  groups  into  the  public  service 
remains a concern. According to the authorities, there are several examples of organised crime 
trying  to  infiltrate  public  services  at  local  level,  often  in  areas  where  criminal  gangs  are 
influential91. At the same time, the willingness to report on this type of infiltration is negatively 

79   Information received in the context of the country visit to Sweden from the Ministry of Justice.  
80   Ibid.  
81   Ibid. 
82   Ibid. 
83   Information received in the context of the country visit to Sweden from the Prosecution Service and the Police. 
The National Anti-Corruption unit of the Police consists of 28 persons, which includes police officers, civil 
investigators and forensic accountants. Within the Public Prosecution there are 10 senior public prosecutors 
working on economic crime. 

84   Information received in the context of the country visit to Sweden from the Police.  
85   Information received in the context of the country visit to Sweden from the Prosecution Service.  
86   Ibid.  
87   In 2021, there were 309 reports on received bribes, whereas in 2022 the number of reports on receiving a bribe 
was 80. Compared to the last four years, the number of reported bribery cases has been relatively stable. In 
2019 there were 73 reports on received bribes and in 2020 58 reports on received bribes. Written contribution 
from the National Council for Crime Prevention in the context of the country visit to Sweden. 

88   Ibid.  
89   National Audit Office (2021), The Economic Crime Authority ‘The work towards the organised economic 
crime’, pp. 5-7, and 2022 Rule of Law Report, Country Chapter on the Rule of law situation in Sweden, pp, 
8-9.  

90  Information received in the context of the country visit to Sweden from the Economic Crime Authority.  
91   Information received in the context of the country visit to Sweden by the Prosecution Service, and Sweden’s 
Municipalities  and  Regions  (2021),  Welfare  offences  and  unauthorised  influences,  p.  5:  ‘The  problem  of 
unauthorized  influence  seems  to  be  increasing.  Sometimes  the  attempts  to  influence  are  linked  to  welfare 

12 

 
                                                           
affected by threats and harassments92. However, corruption related to infiltration of organised 
crime  is  not  reflected  in  the  number  of  investigations  and  prosecution  cases93,  reportedly 
because the enforcement priority of the Police has been focusing more on gang-related  and 
organised  crime.  The  Government  organised  a  roundtable  discussion  in  early  2023  where 
the  Government 
municipalities  and  police  shared 
commissioned  the  National  Council  for  Crime  Prevention  to  study  the  role  and  function  of 
enablers  or  insiders  in  public  institutions  conducting  criminal  activities  linked  to  criminal 
networks95.  According  to  the  Government,  such  an  analysis  presently  does  not  exist96.  The 
study will include a proposal for preventive and counteractive measures and is planned to be 
presented in March 202497.  

their  experiences94.  Furthermore, 

Some progress has been made as regards efforts to prosecute foreign bribery cases, but 
so far, the limited legal definitions of foreign bribery remain unchanged. The 2022 Rule 
of  Law  Report  recommended  to  Sweden  to  “strengthen  the  fight  against  foreign  bribery, 
including through amending existing legal definitions and improving on prosecution and final 
judgments of cases”98. The Government introduced new legislation on foreign bribery in 201999 
and  continues  to  monitor  its  effectiveness100.  The  authorities  have  adequate  resources  and 
collaborate internationally to investigate and prosecute foreign bribery101. Despite a generally 
difficult  situation  with  mutual  legal  assistance  requests,  the  international  cooperation  is 
extensive and efforts are made by the Prosecution Authority to set-up collaboration with third 
countries102. There have been a few notable high profile foreign bribery cases, which did not 
result in convictions103. It remains difficult to successfully attain convictions in foreign bribery 
cases due to legal limitations and a difficulty to gather all the necessary evidence104. The OECD 
has urged Sweden to  reform its laws  to  make sure that companies that bribe foreign public 
officials  to  obtain  advantages  in  international  business  are  properly  investigated  and 

crimes, sometimes to other decisions made by municipal officials and politicians. The interviews from officials 
who work in socio-economically vulnerable areas show that unauthorized influence from criminals can be 
present in daily work and lead to self-censorship and a culture of silence. Many officials interviewed describe 
this not only in terms of a work environment issue, but also as a threat to our democratic system’ 

92   Ibid.  
93   Information received in the context of country to Sweden from the Prosecution Service and Police.  
94   Swedish  Government  (2023)  Roundtable  on  unauthorised  influence  against  parties  and  public  decision-

making.  

95   Swedish  Government  (2023)  Assignment  of  studying  unauthorised  influence  by  systemically  threatening 

actors and groupings.  

96   Input received from Sweden for the 2023 Rule of Law Report, p. 10.  
97   Information  received  in  the  context  of  the  country  visit  to  Sweden  from  the  National  Council  for  Crime 

Prevention.  

98   2022 Rule of Law Report, Chapter on the rule of law situation in Sweden, pp. 9-10.  
99   Input received from Sweden for the 2023 Rule of Law Report, p. 1. 
100  Input received from Sweden for the 2023 Rule of Law Report, p. 1.  
101  Ibid, p. 7, and information received in the context of the country visit to Sweden from the Prosecution Service. 
According  to  the  Government,  the  Police  Authority  participates  in  international  networks  to  combat 
corruption, such as the Global Operational Network of Anti-Corruption Law Enforcement Authorities (GlobE 
Network) and the Global Law Enforcement Network against Transnational Bribery (GLEN). The Prosecution 
Service confirmed that they have adequate resources to investigate foreign bribery cases.  

102  Input received from Sweden for the 2023 Rule of Law Report, p. 7 and information received in the context of 

the country visit to Sweden from the Prosecution Service. 

103  National Courts Administration (2022) Four former Ericsson employees acquitted from charges of aggravated 

bribery.  

104  2022 Rule of Law Report,  Country chapter on the  rule of law situation in Sweden, p. 10, and information 

received in the context of the country visit to Sweden from the Prosecution Service.  

13 

 
                                                           
prosecuted105. Although no legislative changes are foreseen in the near future, the Prosecution 
Authority would welcome an extension of the scope of the offence on foreign bribery106. The 
Government intends to launch a new inquiry on bribery and other corruption related offences 
focusing  on  criminal  law  in  the  second  half  of  2023,  which  could  consider  changes  to  the 
legislation on foreign bribery, but no further details have been finalised yet107. Therefore, in 
view of the  efforts to  prosecute  foreign bribery  cases, there has been some progress  on the 
implementation of the recommendation made in the 2022 Rule of Law Report.  

The  Government  has  still  not  updated  the  Ethical  Guidelines  for  civil  servants,  and 
independent advice and oversight for ministers are not in place. Sweden relies on a strong 
culture of transparency in dealing with potential conflicts of interests and ethical breaches. As 
noted in the 2022 Rule of Law Report108, the Government is still in the process of updating the 
Ethical Guidelines that will apply to all employees of the Government Offices109. The revised 
Ethical Guidelines will not be legally binding110 or include supervision111 , nor is it clear when 
they would be finalised. The handbook for ministers, state secretaries and political advisers has 
been updated in autumn of 2022112. As noted in the 2022 Rule of Law Report113, a consolidated 
code of conduct covering high-level civil servants and political office holders is a longstanding 
recommendation by GRECO.114. As of now, ministers have an introductory training at the start 
of their term and a separate training on ethics115. They may ask for advice on integrity related 
matters  within  their  ministry,  however  there  is  no  central  independent  integrity  adviser  or 
committee in place116.  

Declaration requirements for ministers do not include significant liabilities. Ministers and 
state-secretaries are required to declare their financial interests which have to be supported by 
statements from banks and stockbrokers and are checked by the Government Offices117. A list 
of holdings of ministers may be provided to the public upon request. As also noted in the 2022 

105  In the context of its country specific monitoring in relation to the OECD Anti-Bribery Convention, the OECD 
has  called  on  Sweden  multiple  times  since  2014  to  address  issues  with  its  framework  on  foreign  bribery, 
including as regards corporate criminal liability, dual criminality and others. See also OECD (2019), Sweden 
must urgently implement reforms to boost the fight against bribery and information received in the context of 
the country visit to Sweden.  

106  According to the Prosecution Service, including sphere of influence and criminal liability for legal persons 
would strengthen their efforts to attain convictions in foreign bribery cases. Dagens Juridik, (2023) Debate: 
Need for revised anti-corruption legislation, and Smalaaningen (2023) Corruption prosecutor calls for stricter 
laws.  

107  Information received from the Ministry of Justice in the context of the country visit to Sweden.  
108  2022 Rule of Law Report, Country chapter on the rule of law situation in Sweden, p. 10. 
109  Information received from the Ministry of Justice in the context of the country visit to Sweden.  
110  2022 Rule of Law Report, Country chapter on the rule of law situation in Sweden, p. 10.  
111  In  the  evaluation  report,  GRECO  called  for  the  future  code  of  conduct  to  be  subject  to  some  form  of  a 
mechanism for its supervision. GRECO Fifth evaluation Round – Evaluation Report, recommendation v, para. 
20. 

112  Written contribution from the Ministry of Justice in the context of the country visit to Sweden. 
113  2022 Rule of Law Report, Country chapter on the rule of law situation in Sweden, p 10.  
114  Ibid.  
115  Information received in the context of the country visit to Sweden from the Ministry of Justice.  
116  Ibid.  
117  GRECO Fifth evaluation round – compliance report, recommendation viii, paras. 50-52.  

14 

 
                                                           
Rule of Law Report118, the declaration does not include information on significant liabilities 
and information on their spouses and dependent family members.  

The  Agency  for  Public  Management  is  preparing  an  introductory  training  for 
Government  employees and  developed  a survey on corruption in Swedish regions and 
municipalities. The Agency for Public Management has been tasked to develop and provide 
an  introductory  training  course  for  Government  employees119.  The  non-mandatory,  digital 
training is targeted for new employees under agencies of the Government120. The training will 
be available from 1 July 2023. Furthermore, the Agency for Public Management has also been 
tasked to develop a survey on corruption in Swedish regions and municipalities121. The aim of 
the assignment is to improve the ability of municipalities and regions to prevent corruption. 
The  survey  includes  local  government  enterprises,  which  have  been  overrepresented  in 
corruption statistics122. The survey results were published on 15 June 2023123. 

Sweden’s  culture  of  openness  and  disclosure  of  information  enables  transparency  of 
lobbying, while the public debate on regulating lobbying continues. Following debates by 
Parliament124,  and  several  civil  society  organisations  who  asked  for  the  introduction  of  a 
transparency  register  on  lobbying125,  on  15  June  2023  the  Government  appointed  a 
parliamentary inquiry committee to review the regulation on transparency in the financing of 
parties. The committee's mandate includes considering whether there is a need to strengthen 
transparency  in  political  decision-making  through  a  regulation  that  requires  transparency 
regarding contacts between political decision-makers and lobbyists. The committee must report 
on its work by 15 February 2025 at the latest126. A GRECO recommendation on introducing 
rules on guidance for decision-makers on how to engage with lobbyists and on disclosure of 
lobbying contacts remains outstanding127.  

Some progress has been made on the evaluation of the rules relating to revolving doors 
covering top executive functions in the Government, which is ongoing. The 2022 Rule of 
Law Report recommended to Sweden to “evaluate the scope, impact and implementation of 
the rules relating to revolving doors that cover top executive functions in the Government”128. 
According  to  the  current  Act  on  post-employment  for  ministers  and  state  secretaries129, 
ministers and state secretaries have to notify the Board for the Examination of Transitionary 
Restrictions for Ministers and State Secretaries before accepting any new assignment in the 

118  2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11. 
119  Input received from Sweden for the 2023 Rule of Law Report, p. 9.  
120  Swedish Government (2022) Task of analysing and improving the conditions for combating corruption within 

municipalities and regions, Fi2022/02296.  

121  Swedish Government (2022) Assignment to analyse and improve the conditions for combating corruption in 

municipalities and regions, Fi2022/02296.  

122  Input received from Sweden for the 2023 Rule of Law Report, p. 8.  
123  Agency for Public Management (2023) New challenges and old problems - Corruption in local and regional 

government, 2023:13. 

124  Information received in the context of the country visit to Sweden from the Ministry of Justice. On 24 February 

2023, a special debate took place on anti-corruption measures by the Swedish Government.  
125  Altinget (2022) Debate Six civil society organisations: How to stop future lobby scandals.  
126  Swedish Government (2023) A parliamentary committee is appointed with the task of investigating increased 

transparency in the financing of parties. 

127  GRECO  Fifth  evaluation  Round  –  Evaluation  Report,  recommendation  v,  paras.  51-52  and  GRECO  Fifth 

Evaluation Round – Compliance Report, recommendation v, para. 37. 

128  2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11. 
129  Act concerning restrictions when ministers and state secretaries transition to non-state activities, act 2018:676. 

15 

 
                                                           
private  sector  for  a  period  of  12  months  after  the  end  of  their  term  in  office.  Compared  to 
previous years130, the change of Government resulted in a significant increase in the number of 
reports of transfers to non-governmental activities. During 2022, the Board received a total of 
21 reports131. For the first time, the decisions made by the Board included restrictions: three 
thematic restrictions and one cooling-off period. The decisions by the board are made public, 
but there is no sanctioning mechanism foreseen in the law132. As noted in the last Rule of Law 
Report, the Government appointed an inquiry committee in June 2022 to evaluate whether the 
aims of the Act have been achieved133, and include an assessment of the post-employment rules 
of other public officials. The evaluation is ongoing and should be completed in August 2023134. 
Therefore, there has been some progress on the implementation of the recommendation made 
in the 2022 Rule of Law Report.  

The Government has appointed a parliamentary inquiry to review gaps in the existing 
framework for political party financing. The Legal, Financial and Administrative Services 
Agency (Kammarkollegiet), responsible for political party financing oversight, opened a total 
of  18  enforcement  cases  in  2022  which  is  according  to  the  Agency  a  substantial  increase 
compared to previous years135. The political party financing disclosures are publicly available 
on the website of the Agency136. However, a political debate on political party financing rules 
started following a media investigation showing  that five out  of eight  political  parties were 
willing  to  evade  the  existing  rules  on  anonymous  donations137.  On  15  June  2023  the 
Government  appointed  a  parliamentary  inquiry  committee  to  review  the  regulation  on 
transparency  in  the  financing  of  parties  and  to  consider  whether  it  needs  to  be  clarified  or 
supplemented; including as regards the rules on anonymous donations138.  

The Agency for Public Management assists public authorities with the implementation of 
the Whistleblowers Act. The Act that entered into force in December 2021 aims to transpose 
the  EU  Whistleblower  Protection  Directive139  and  applies 
to  private  and  public 
organisations140. According to the Police, the Act will have a positive effect on the number of 
corruption related reports141. The Agency for Public Management has published guidelines to 
assist  public  authorities  in  implementing  the  law142.  In  addition,  the  Government  has  given 

130  2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11. Between the entry 
into force of the relevant rules in 2018 and the end of May 2022, 21 notices by ministers or state secretaries 
were made to the Board for the Examination of Transitionary Restrictions for Ministers and State Secretaries.  
131  Board for the Examination of Transitionary Restrictions for Ministers and State Secretaries (2022) Report on 
the activities of the Board for reviewing the transfer restrictions of ministers and certain other officials in 2022. 
132  Act concerning restrictions when ministers and state secretaries transition to non-state activities, act 2018:676. 
133  2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11.  
134  Information received in the context of the country visit to Sweden from the ministry of Finance.  
135  The Legal, Financial and Administrative Services Agency (2022) Annual Report 2022, Dnr. 2.3.5-2629-23. 
136  The Legal, Financial and Administrative Services Agency (2022) Political party funding disclosures for 2021 

now available.  

137  The  Local  (2022)  Five  of  Sweden’s  political  parties  planned  to  evade  party  financing  laws.  According  to 
Swedish law, anonymous donations are prohibited if their value exceeds 0.05 times the “price base amount”, 
meaning SEK 2,380/EUR 230 in 2021. 

138  Swedish Government (2023), A parliamentary committee is appointed with the task of investigating increased 

transparency in the financing of parties 

139  Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law. 
140  Act on Protection of Persons who Report Wrongdoings, 2021:890.  
141  Information received in the context of the country visit to Sweden from the National Police.  
142  Information received from the Agency for Public Management in the context of the country visit to Sweden. 

16 

 
                                                           
state  funds  to  civil  society  organisations143  to  provide  information  and  advice  on  the 
Whistleblowers Act, which has been positively received by civil society organisations144. The 
Agency  for  Public  Management  received  several  inquiries  from  institutions  about  the 
implementation and intends to organise an experience-sharing meeting with agencies that have 
reporting channels145.  

A special investigator was tasked to propose a reliable public procurement system that 
prevents ineligible suppliers from receiving public contracts. The Flash Eurobarometer on 
Businesses’ attitudes towards corruption in the EU shows that 19% of companies in Sweden 
(EU average 26%) think that corruption has prevented them from winning a public tender or a 
public procurement contract in practice in the last three years146. The Government has tasked a 
special investigator to propose an efficient and reliable system for supplier control related to 
public  procurement,  who  will,  among  others,  assess  whether  the  rules  on  the  exclusion  of 
suppliers from participation in freedom of choice systems147 should be tightened148. The aim 
of  the  new  system  is  to  promote  healthy  competition  and  prevent  unsuitable suppliers  from 
being awarded public funds149. The proposal should be finished by August 2023. Moreover, the 
Government  organised 
from 
construction, cleaning and transport sectors during which the exclusion of previously criminal 
convicted  providers  from  public  procurement  was  also  discussed150.  Furthermore,  the 
Government  has  commissioned  the  Swedish  Transport  Administration  to  report  on  the 
approach established to counteract corruption, bribery and conflict of interests151.  

round-table  discussions  with 

representatives 

industry 

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

The Swedish legal framework concerning media pluralism is established by the Constitution152 
and secondary law153. Freedom of expression is guaranteed by the Instrument of Government, 
the Fundamental Law on Freedom of Expression and the Freedom of the Press Act, the latter 
which  also  safeguards  access  to  information.  The  Swedish  media  regulator,  the  Press  and 
Broadcasting  Authority,  functions  according  to  the  Constitution154  and  the  Radio  and 
Television  Act  and  will  in  the  future  receive  staff  and  resources  from  the  Swedish  Media 
Council due to a planned merger. The Government has adopted amendments to the Radio and 

143  For example, Transparency International Sweden received funding with which they set up a national support 

line on the whistleblowers act.  

144  Information received in the context of the country visit to Sweden from Transparency International Sweden.  
145  Information received from the Agency for Public Management in the context of the country visit to Sweden. 
146  Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). This is 7 percentage 

points below the EU average. 

147  A system of freedom of choice is a procedure whereby the individual has the right to choose the supplier to 
perform the service from among the suppliers with which the contracting authority has approved and awarded 
a contract.   

148  Effective and reliable control of suppliers when awarding public contracts DIR 2022: 50, published 3 June 

2022 and Input from the authorities for the rule of law, pp. 10-11.  

149  Information received in the context of the country visit to Sweden from the Ministry of Finance.  
150  Information received in the context of the country visit to Sweden from the Government of Sweden.  
151  Swedish  Government  (2022)  Assignment  to  report  on  how  the  authority  works  to  set  requirements  in 

connection with procurements and implementation of operations in order to combat crime. 

152  The  Swedish  Constitution  consists  of  four  fundamental  laws:  the  Instrument  of  Government,  the  Act  of 

Succession, the Freedom of the Press Act and, the Fundamental Law on Freedom of Expression. 

153  Radio and Television Act. 
154   Relevant parts of the Constitution: the Instrument of Government and the Fundamental Law on Freedom of 

Expression. 

17 

 
                                                           
Television Act, which aim at increasing the transparency of media ownership and update the 
licensing system155. 

A  restructuring  of  the  media  regulatory  authority  is  being  prepared.  Following  an 
assessment  commissioned  by  the  Government156,  subordination  of  all  tasks  of  the  Swedish 
Media Council to the independent Press and Broadcasting Authority157 has been initiated158. 
The Swedish Media Council is a government agency with specialist functions concerning, for 
example,  media  use  by  children  and  young  people,  age  rating  of  films  and  coordination  of 
media and information literacy measures159. The changes are intended to provide more services 
under the same structure and will be effective as of 2024160. In parallel, the budget of the Press 
and  Broadcasting  Authority  has  been  increased  independently  of  the  merger.  The  authority 
might additionally be granted new tasks related to the monitoring of the Digital Services Act161. 
The MPM 2023 maintains a very low risk score regarding the independence and effectiveness 
of the media authority162. 

New legislation has been adopted to improve transparency of media ownership. Following 
an  assessment  in  the  context  of  the  transposition  of  the  Audiovisual  Media  Services 
Directive163, the Radio and Television Act has been amended in March 2023 to provide for the 
disclosure  of  more  information  concerning  media  ownership  structures  for  all  audiovisual 
media and radio service providers164. Compliance with the rules is supervised by the Press and 
Broadcasting Authority165. The legal provisions to protect the right to information are clearly 
defined  in  the  Swedish  constitution  and  the  MPM  2023  reports  a  low  risk  in  this  field166. 
However, Sweden has no sector-specific legislation on media concentration167 and the market 

155  Sweden ranks 4th in the 2023 Reporters without Borders World Press Freedom Index, compared to 3rd in the 

previous year. 

156  Swedish  Government  (2022)  Subordination  of  the  Swedish  Media  Council  to  the  Swedish  Press  and 

Broadcasting Authority, Ds 2022:17.  

157  The independence of the Swedish media regulator is stemming from the Constitution (IG Chapter 12, Section 

2). 

158  Swedish Government (2023) Assignment to the Swedish Press and Broadcasting Authority to prepare for the 
incorporation of the Swedish Media Council's tasks into the authority, Ku2023/00115; Press and Broadcasting 
Authority (2023) MPRT and the Swedish Media Council form a new media authority. 

159  Swedish Media Council (2022) About the Swedish Media Council. 
160  Information provided by the Ministry of Culture the Press and Broadcasting Authority in the context of the 

2023 country visit. 

161  Information provided by the Press and Broadcasting Authority in the context of the 2023 country visit; Press 
and Broadcasting Authority (2023) MPRT is proposed to become the competent authority with supervisory 
responsibility under the DSA; Regulation (EU) 2022/2065 of the European Parliament and of the Council of 
19  October  2022  on  a  Single  Market  For  Digital  Services  and  amending  Directive  2000/31/EC  (Digital 
Services Act). 

162  2023 Media Pluralism Monitor, country report for Sweden, p. 11. 
163  As reported in the 2020 Rule of Law Report, County Chapter on the rule of law situation in Sweden, p.8. 
164  Swedish Government (2022) Increased transparency in the ownership of broadcasters, Prop. 2021/22:262. 
165  Input by Sweden for the 2023 Rule of Law Report, p. 15; Information provided by the Broadcasting Authority 

in the context of the 2023 country visit. 

166  2023 Media Pluralism Monitor, country report for Sweden, p. 10 - 11. 
167  General competition rules apply to media concentration and mergers. 

18 

 
                                                           
is characterised by a high level of concentration, particularly in the audiovisual sector168. The 
MPM 2023 gives a high risk score for the plurality of media providers in Sweden169.  

The Government has taken steps to update rules on broadcasting licenses, notably adding 
the possibility to revoke them. The Radio and Television Act has been amended to extend the 
licensing period for the terrestrial network for commercial television from six to eight years, in 
addition  to  temporarily  synchronising  the  licensing  periods  for  analogue  and  digital  radio 
broadcasters. The aim has been to allow broadcasting companies to better plan their long-term 
operation and to reduce the administrative burden170. The Press and Broadcasting Authority 
has made suggestions regarding the licensing procedure for digital and analogue commercial 
radio in view of further reforms171. In August 2022, changes to the Radio and Television Act 
were proposed in a ministry memorandum to make it possible to revoke a broadcasting license 
in case of a risk to national security and where the revocation does not appear to be excessive172. 
This includes, for example, external security issues pertaining to national defence and internal 
security issues such as illegal attempts to systematically prevent citizens from exercising their 
democratic rights and freedoms. Relevant cases would be examined by a general court at the 
request of the Chancellor of Justice173. Certain stakeholders in the media sector have expressed 
criticism regarding the proposal’s negative impact on the freedom of expression, particularly 
if interpreted broadly174. 

The  Government  has  appointed  a  parliamentary  committee  to  review  the  legislative 
framework of the public service media. In order to strengthen and supplement the already 
existing  solid  safeguards  against  governmental  or  political  interference  in  public  service 
media175, a specific parliamentary committee has been set up176. It will review, among others, 
how the follow-up and review of the public service media’s operations can become clearer and 
more  transparent  and  how  its  content  assignment  within  the  public  service  remit  should  be 
designed during the next licensing period. The inquiry is mandated to report by April 2024. 
The aim is to propose new legislation to create good conditions for public service broadcasting 
and to maintain and safeguard its independence177. MPM 2023 continues to report a very low 
risk concerning the independence of public service media178. 

168  As  reported  by  the  2023  Reporters  Without  Borders  World  Press  Freedom  Index  country  specifics,  the 
Swedish audiovisual market is dominated by few players, four television and three radio groups (this includes 
publicly owned media). 

169  2023 Media Pluralism Monitor, country report for Sweden, p. 13. 
170  Information provided by the Ministry of Culture in the context of the 2023 country visit. 
171  Information provided by the Press and Broadcasting Authority in the context of the 2023 country visit; Press 

and Broadcasting Authority (2023) MPRT proposes future conditions for commercial radio. 

172  Input  from  Sweden  for  the  2023  Rule  of  Law  Report,  p.  13;  Swedish  Government  (2022)  Withdrawal  of 

broadcasting licences in the interests of Sweden’s security, Ds 2022:20. 

173  Swedish Government (2022) Withdrawal of broadcasting licences in the interests of Sweden’s security, Ds 

2022:20. 

174  Swedish Journalists’ Association (2022) No to proposal to revoke broadcast licenses; Journalisten (2022) PK 

warns of new bill on revocation of broadcasting licenses for television and radio. 

175 According to European Parliament’s Flash Eurobarometer: News & Media Survey 2022, 66% of citizens in 

Sweden state that they trust public service media TV and radio (above the EU average of 49%).   

176  As reported in the 2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 13-

14. 

177  Swedish Government (2023) Committee Directive: Long-term conditions for a solid and independent public 

service, 2023:27. 

178  2023 Media Pluralism Monitor, country chapter for Sweden, p. 17. 

19 

 
                                                           
Swedish journalists continue to work in overall favourable conditions but are subject to 
certain  emerging  threats.  The  MPM  2023  finds  that  Swedish  journalists  enjoy  highly 
favourable working conditions compared to other parts of the world but they increasingly face 
hatred, threats and insults179. The Government is currently planning to introduce amendments 
to criminal law to make it an aggravating circumstance if a crime has been committed against 
a  person  because  they  or  someone  close  to  them  has  professionally  engaged  in  news 
distribution or other journalism. The amendments are proposed to enter into force in August 
2023180. This follows the review conducted by an inquiry181 and has been largely welcomed by 
stakeholders182.  Over  the  past  months,  the  Police  has  organised  joint  seminars  with  media 
publishers with an aim to prevent crimes committed against journalists and to establish robust 
cooperation  with  the  national,  regional  and  local  level  newspapers183.  The  Government  has 
tasked the Police to combat hate crimes that threaten democracy, involving also journalists. 
The work is ongoing with the final report due at the end of 2023184. Since the publication of 
the 2022 Rule of Law Report, two new alerts have been recorded on the Council of Europe’s 
Platform to promote the protection of journalism and safety of journalists185. One alert concerns 
the detention of a journalist who was covering a public protest. Given that this was the fourth 
such detention in a short period of time in 2022, there have been calls for increased dialogue 
between the police force and journalists associations186 and the instances in question are being 
investigated  or  have  been  closed187.  The  second  alert  on  the  Council  of  Europe’s  Platform 
concerns new legislation on “foreign espionage”, which came into force in 2023, amending the 
Swedish Criminal Code, the Freedom of the Press Act and the Fundamental Law on Freedom 
of  Expression188.  It  makes  punishable,  under  certain  circumstances,  the  disclosure  of 
information that concerns Sweden’s international cooperation and that can damage Sweden’s 
relationship with another state or an international organisation. Swedish  media stakeholders 
have criticised the law’s potential chilling effect on media freedom189 while the Constitutional 
Committee  has  backed  it  with  a  broad  consensus  and  recognised  that  the  law  has  possible 
exceptions applicable to journalism190.  

179  2023 Media Pluralism Monitor, country chapter for Sweden, p. 11; Information received from the Swedish 

Journalists’ Association in the context of the country visit to Sweden. 

180  Swedish Government (2023) Stricter view of crimes against journalists and certain other functions useful to 

society. 

181  2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 9 and 2021 Rule of Law 

Report, County Chapter on the rule of law situation in Sweden, p. 12. 

182  Information received from the Swedish Media Publishers’ association in the context of the 2023 country visit; 
Swedish Journalists’ Association (2023), Good news about increased criminal law protection for journalists. 
183  Information  received  from  the  Ministry  of  Justice  and  the  Swedish  Media  Publishers’  Association  in  the 

context of the country visit to Sweden and input by Sweden for the 2023 Rule of Law Report, p. 15. 

184  Input from Sweden for the 2023 Rule of Law Report, p. 16. 
185  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Sweden. 
186  Aftonbladet  (2023)  Debate:  Journalists  are  seen  as  criminals  by  the  police  by  Reporters  Without  Borders 

Sweden and Swedish Journalists’ Association. 

187  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Sweden, Reply 

from the Swedish authorities (14 April 2023). 

188  Swedish Parliament (2022) Foreign espionage (pending draft constitution, etc.). 
189  Information  received  from  the  Media  Ombudsman  and  the  Swedish  Media  Publishers’  Association  in  the 
context of the 2023 country visit; European Federation of Journalists (2022) Tove Carlén: “The Swedish new 
law on public espionage provides little protection for journalists’ sources”. 

190  Information received from the Constitutional Committee in the context of the 2023 country visit; Letter from 
the Permanent Representation of Sweden to the Council of Europe Council of Europe (2023), on the Platform 
to promote the protection of journalism and safety of journalists, Sweden. 

20 

 
                                                           
IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Sweden  has  a  unicameral,  parliamentary  system  of  governance,  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,  the  Equality  Ombudsman  and  the 
Swedish Institute for Human Rights play an important role in the system of checks and balances 
and for upholding fundamental rights.  

The opinions of the Council on Legislation are followed by the Government in a large 
majority of cases. The Government is required to refer draft legislation in most areas to the 
Council on Legislation191. In 2022, the Government submitted 156 legislative proposals to the 
Council  on  Legislation,  which  did  not  endorse  seven  proposals192.  In  three  cases  where  the 
Council  on  Legislation  could  not  endorse  the  Government’s  proposal,  the  latter  decided  to 
nevertheless  submit  them  to  Parliament193.  In  its  report  delivered  in  March  2023,  the 
Committee of Inquiry on strengthening the protection of democracy and the independence of 
the  judiciary  proposed  that  the  requirement  to  obtain  an  opinion  from  the  Council  on 
Legislation  should  be  extended  to  include  constitutional  amendment  proposals  regarding 
fundamental freedoms and rights194. Furthermore, on 15 June 2023, the Government appointed 
a parliamentary inquiry committee to examine possible constitutional amendments concerning 
the protection of fundamental rights and freedoms; the committee should present its report by 
1 December 2024195. 

As regards the Parliamentary Ombudsmen, amended constitutional and legislative rules 
are expected to take effect in January 2027 and September 2023 respectively, reflecting 
the  parliamentary  review  on  their  functioning  and  mandate.  The  Parliamentary 
Ombudsmen consider having adequate resources and do not experience any obstacles in the 
cooperation with the public authorities within their remit; the Parliamentary Ombudsmen also 

191  The Council of Legislation consists of  members from the  Supreme Court and the Supreme Administrative 
Court. The examination by the Council on Legislation constitutes an important ex-ante constitutionality check 
of draft legislation. The Government and the Parliament may choose not to follow its opinion, but courts may 
take this into account when subsequently assessing the norm in question. 2020 Rule of Law Report, Country 
Chapter on the rule of law situation in Sweden, p. 11.  

192  In five of those cases, the negative opinion referred only to parts of the proposals. Information received from 

the Prime Minister’s Office in the context of the country visit to Sweden. 

193  The  proposals  in  questions  were:  ‘Confidentiality  in  Försäkringskassan's  processing  of  electricity  subsidy 
cases  and  abolished  obligation  to  provide  control  data  –  Proposal  2022/23:48’,  ‘Implementation  of  the 
Accessibility  Directive  -  Proposition  2022/23:42’,  ‘Faster  prosecution  of  crimes  -  Proposal  2021/22:279’. 
Written contribution received from the Prime Minister’s Office in the context of the country visit to Sweden. 
194  At present, the Government or the parliamentary Committee on the Constitution must obtain a statement from 
the Council on Legislation before the Parliament decides on a constitutional amendment in the area of freedom 
of  the  press  and  freedom  of  expression.  The  2020  Committee  of  Inquiry  on  the  Constitution  (2023), 
Strengthening the protection of democracy and independence of the judiciary, pp. 42-43. 

195  The  Committee  shall,  in particular, examine: i)  whether  new  fundamental rights and freedoms  – a right to 
abortion, a right to access to justice and a general protection against discrimination – should be added to the 
Constitution,  ii)  whether  the  right  to  citizenship  should  be  amended  to  allow  for  the  withdrawal  of  the 
citizenship under certain conditions, iii) whether there should be increased possibilities to restrict freedom of 
association vis-à-vis criminal associations, and iv) what general conditions should apply to restrictions on the 
freedom to conduct a business and protection of property. Swedish Government (2023), Some questions on 
fundamental rights and freedoms.  

21 

 
                                                           
do not experience any issues in the follow-up to their recommendations196. The rules on the 
functioning and mandate of the Parliamentary Ombudsmen’s work were reviewed197. After the 
vote in  Parliament  in June 2023, it is expected that  the amended constitutional  rules on the 
work  of  the  Parliamentary  Ombudsmen  will  take  effect  in  January  2027,  whereas  the 
amendments of legislative nature would take effect in September 2023198. The Parliamentary 
Ombudsmen,  on  behalf  of  the  Parliament,  and  the  Chancellor  of  Justice,  on  behalf  of  the 
Government, supervise courts and judges to ensure that they comply with laws and statutes and 
fulfil  their  obligations199.  Both  institutions  may  presently  initiate  disciplinary  procedures 
against  judges,  issue  non-binding  recommendations  and  critical  advisory  comments,  for 
example regarding the obligation to handle cases without undue delay200. In addition, in a report 
delivered  in  March  2023,  the  Committee  of  Inquiry  on  strengthening  the  protection  of 
democracy  and  the  independence  of  the  judiciary  proposed  to  amend  the  remit  of  the 
Chancellor of Justice so that it would no longer have any supervisory powers with regard to 
the judiciary, while maintaining the Parliamentary Ombudsmen’s powers unchanged in that 
respect201.  

On 1 January 2023, Sweden had two leading judgments of the European Court of Human 
Rights pending implementation, the same number as the previous year202. At that time, 
Sweden’s rate of leading judgments from the past 10 years that remained pending was at 17% 
(compared  to  13%  in  2022),  and  the  average  time  that  the  judgments  had  been  pending 
implementation was 4 years and 1 month (compared to 3 years and 1 month in 2022)203. The 
oldest leading judgment, pending implementation for 6 years, concerns the failure of Swedish 

196  Information  received  from  the  Parliamentary  Ombudsmen’s  Office  in  the  context  of  the  country  visit  to 

Sweden. 

197  Following a report published in May 2022 by an all-party committee including members of the Parliament’s 
Constitution Committee, the Parliamentary Ombudsmen submitted their comments on the report in November 
2022.  Information  received  from  the  Secretariat  of  the  Constitution  Committee  and  the  Parliamentary 
Ombudsmen’s Office in the context of the country visit.  

198  The constitutional amendments would introduce a new decision-making and quorum rule for the dismissal of 
an  ombudsman  who  does  not  have  the  confidence  of  Parliament  aimed  at  strengthening  the  constitutional 
position of the ombudsmen. In addition, the legislative amendments to the Parliamentary Order would, among 
other things, extend the term of office of a new Ombudsman from four years to six years and set the term of 
office for re-election at three years. Swedish Parliament (2023) Review of the Ombudsman's office.  

199  Input from Sweden for the 2020 Rule of Law Report, p. 6. 
200  Ibid. 
201  The Committee of Inquiry considered that the supervisory duties of the Chancellor of Justice be seen as the 
Government’s control on the administration of justice of the courts and individual judges. In the Committee’s 
view, the Parliamentary Ombudsmen because they are appointed by the Parliament, their supervision of the 
judiciary  can  be  considered  be  more  closely  represent  the  public  interest.  Against  this  background,  the 
Committee proposed that the Constitution should provide that only the Parliamentary Ombudsmen and the 
National Audit Office may exercise supervision over or examine the administration of justice of the courts, 
but not the Chancellor of Justice. The 2020 Committee of Inquiry on the Constitution (2023), Strengthening 
the protection of democracy and independence of the judiciary, p. 52. 

202  The  adoption of necessary execution  measures  for a  judgment by the European  Court of Human  Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

203  All figures are calculated by the European Implementation Network and are based on the number of cases that 
are considered pending at the annual cut-off date of 1 January 2023. See the Contribution from the European 
Implementation Network for the 2022 Rule of Law Report, p. 7. 

22 

 
                                                           
courts  to  exercise  jurisdiction  in  respect  of  defamation  proceedings  concerning  a  television 
broadcast  from  a  foreign  country204.  On  15  June  2023,  the  number  of  leading  judgments 
pending implementation has decreased to one205. 

The  National  Human  Rights  Institution  is  working  towards  an  A-accreditation 
accreditation. The Swedish Institute for Human Rights commenced its activities on 1 January 
2022. The Institute’s stated objective is to meet the UN Paris Principles and achieve A-status 
accreditation by the Global Alliance of National Human Rights Institutions (GANHRI)206. As 
a  first  step,  the  Institute  is  carrying  out  a  gap  analysis,  which  would  be  followed-up  by  an 
accreditation strategy  engaging  with  the Government, Parliament and other stakeholders, in 
particular  civil  society  and  European  Network  of  National  Human  Rights  Institutions 
(ENNHRI)207.  The  gap  analysis  should  allow  to  identify  potential  issues  towards  A-status 
accreditation,  such  as  the  absence  of  a  specific  provision  allowing  the  Institute  to  table  its 
reports in Parliament208. The Institute became an associated member of ENNHRI in October 
2022209.  The  Institute  has  appointed  its  first  permanent  director210  and  is  in  the  process  of 
appointing  members  of  its  advisory  council211;  it  is  seeking  a  broad  composition  of 
representatives  of  civil  society  organisations  or  other  actors,  including  individuals,  with 
knowledge and experience of practical work with human rights212. The Institute considers that 
it has sufficient resources213. In April, the Institute214 and a number of civil society stakeholders 
called on the Government to confirm that the Swedish Institute for Human Rights will be able 

204  Judgment of the European Court of Human Rights of 1 March 2016, Arlewin v. Sweden, 22302/10, pending 

implementation since 2016. 

205  Data according to the online database of the Council of Europe (HUDOC-EXEC). 
206  Information received from the National Human Rights Institute in the context of the country visit to Sweden. 
207  The Institute expects that the fourth cycle of the Universal Periodic Review of Sweden, commencing in late 
2024,  would  also  coincide  with  the  possibility  to  address  any  identified  gaps  in  its  mandate.  Written 
contribution  and  information  received  from  the  Swedish  Institute  for  Human  Rights  in  the  context  of  the 
country visit to Sweden. 

208  Written contribution and information received from the Swedish Institute for Human Rights in the context of 

the country visit to Sweden. 

209  Information  received  from  the  Swedish  Institute  for  Human  Rights  in  the  context  of  the  country  visit  to 

Sweden. 

210  The Institute had an acting director since its establishment on 1 January 2022. Swedish Institute for Human 

Rights (2023) Director of the Institute for Human Rights appointed. 

211  The Advisory Council shall provide the Institute with knowledge and experience from civil society and other 
actors' work on human rights. The Council shall also submit proposals to the Government for members of the 
Institute's  board.  Swedish  Institute  for  Human  Rights  (2023)  Nominate  your  candidate  for  the  Advisory 
Council!. 

212  Ibid.  
213  A  proposal  concerning  the  Institute’s  budget  for  the  year  2024  is  expected  in  September  2023.  Written 
contribution  and  information  received  from  the  Swedish  Institute  for  Human  Rights  in  the  context  of  the 
country visit to Sweden.  

214  Swedish  Institute  for  Human  Rights  (2023)  A  government  must  stand  up  for  its  national  human  rights 
institution and the statement of the Institute’s Director at a conference on 21 April 2023 “… let me just shortly 
mention the current situation in Sweden. As was also mentioned yesterday we see that human rights in general 
are  being  challenged  in  the  public  debate.  In  that  context  the  existence  of  our  institution  is  also  being 
questioned. When an institution is questioned in such a way it is of utmost importance  with strong political 
backing, not least from the government. We have unfortunately not yet received any such support. We expect 
the  government  to  clarify  urgently  the  question  marks  that  currently  surrounds  the  continued  existence  of 
Sweden’s National Human Rights Institution.” Swedish Institute for Human Rights (2023) Fredrik Malmberg 
spoke at EU conference on institutional protection of fundamental rights. 

23 

 
                                                           
to  continue  its  work  in  the  present  form  and  with  undiminished  resources215.  This  was  in 
response  to  a  statement  of  a  spokesperson  from  a  political  party  cooperating  with  the 
Government  suggesting  that  that  political  party  had  discussed  the  function  of  the  National 
Human Rights Institution and concluded that the Institute was not necessary216. According to 
Council of Europe recommendations, all necessary measures should be taken to establish and, 
when  established,  maintain  and  strengthen  an  independent  the  National  Human  Rights 
Institutions in accordance with the UN Paris Principles217. 

Some  progress  has  been  made  as  regards  the  2022  recommendation  as  one  legislative 
proposal was withdrawn for revision, while the impact on civil society engagement of the 
legislative initiatives remains to be ascertained. The 2022 Rule of Law Report recommended 
to  Sweden  “to  ensure  that  on-going  reforms  to  the  legal  framework  for  the  funding  and 
operation of civil society organisations do not unduly affect civil society engagement”218. In 
November 2022, the new Government withdrew the legislative proposal related to the so-called 
‘democracy  conditions’219  In  December  2022,  and  following 
the 
Government220 invited civil society representatives to a meeting to present their views on the 
democracy  conditions  prior  to  resuming  its  work  on  a  proposal221.  In  November  2022,  the 
Parliament held the second of the two votes needed222 to amend the Constitution to extend the 
possibilities to restrict freedom of association by law in the case of associations that engage in 
or  support  terrorism  by  means  of  a  broader  criminalisation  of  participation  in  a  terrorist 
organisation  or  a  ban  on  terrorist  organisations223.  As  a  follow-up,  a  law  was  adopted  by 
Parliament224,  even  though  the  Council  of  Legislation  had  considered  that  that  legislative 

the  withdrawal, 

215  The  open  letter  was  signed  by  53  civil  society  organisations  in  Sweden,  including  Amnesty  International 
Sweden, Civil Rights Defenders, Human Rights Watch, Swedish Section of the International Commission of 
Jurists, or the Swedish Foundation for Human Rights. Swedish Foundation for Human Rights (2023) Open 
letter to Prime Minister Ulf Kristersson on the Human Rights Institute from 53 organisations. 

216  TV4  (2023)  Sweden  Democrats  want  to  discontinue  funding  for  work  against  racism  and  Altinget  (2023) 

Sweden Democrats want to close down human rights institute - but voted "yes" to it in Parliament. 

217  Recommendation CM/Rec(2021)1 of the Committee of Ministers to member States on the development and 

strengthening of effective, pluralist and independent national human rights institutions, para 1. 
218  2022 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 19-20. 
219  The  democracy  conditions  would  aim  to  prevent  distributing  public  funding  to  activities  which  are  not 
compatible  with  society's  fundamental  values.  Swedish  Government  (2019),  Democratic  conditions  for 
contributions to civil society. 

220  According to the latest Budget Bill, the Government distributes approximately EUR 2.31 billion (SEK 26,4 
billion) to civil society. Some of this  funding  goes directly to specific organisations,  while the  majority is 
distributed by different agencies, such as the Agency for Youth and Civil society, the National Board of Health 
and  Welfare,  the  Agency  for  Education  and  the  Environmental  Protection  Agency.  At  present,  grants  are 
distributed by approximately 40 agencies and based on about 80 ordinances stating the conditions for each 
grant. Input from Sweden for the 2023 Rule of Law Report, p. 21. 

221  Ministry of Culture (2022) Minister Jakob Forssmed in dialogue with civil society on democracy conditions 

and input from Sweden for the 2023 Rule of Law Report, p. 17. 

222  The  Swedish  Constitution  is  composed  of  four  fundamental  laws.  In  order  to  amend  the  Constitution,  the 
Parliament must adopt two decisions of identical wording with a general election between the two decisions. 
Swedish Parliament (2022), The Constitution. 

223  Some stakeholders considered that amendment would impact also legitimate civil society activities and pose 
a  risk  that  organisations  with  democratic  aims  or  individuals  engaged  in  international  oppositional  groups 
could be wrongly classified as terrorist organisations. See 2022 Rule of Law Report, Country Chapter on the 
rule of law situation in Sweden, pp. 19-20 and Swedish Government (2021), Government proposal 2021/22:42 
– Freedom of association and terrorist organisations.  

224  The  law  was  adopted  on  5  May  and  entered  into  force  on  1  June  2023.  Swedish  Government  (2022) 
Government proposal 2022/23:73 – A special criminal provision for participation in a terrorist organisation.  

24 

 
                                                           
proposal should not, as it stood, serve as a basis for legislation225. In particular, the Council of 
Legislation observed a clear risk for an excessively far-reaching criminalisation and expressed 
doubts that the proposal met the requirements of legal  certainty in  terms  of clarity required 
from criminal legislation226. Nevertheless, the Government considered that there was a need 
for specific criminal liability for participation contributing to the maintenance or strengthening 
of a terrorist organisation and, in its draft legislative proposal to Parliament, it has put forward 
its arguments on the Council of Legislation’s comments227. In view of the negative opinion of 
the Council of Legislation, civil society stakeholders had called the Government to reconsider 
its  proposal228.  As  for  the  pre-legislative  proposal  to  ban  racist  organisations  through  new 
criminal  legislation229,  the  Government  is  presently  still  analysing  the  public  consultation 
replies230. Against the above background, while some progress has been made as regards the 
2022 recommendation with regard to the democracy conditions proposal, the impact on civil 
society engagement of the legislative initiatives remains to be ascertained.  

Sweden continues to have an open civil society space, even though recent developments 
have given rise to some concerns in this regard. Sweden is considered to have an open civil 
society  landscape231.  The  consultation  processes  are  overall  inclusive,  even  though  some 

225  The Council on Legislation disagreed with the Government’s submission that the proposed criminal provision 
had a well-defined scope or that it was carefully balanced It discouraged that the proposal in its submitted 
form becomes law. Instead, it advised to reconsider whether legislation of that type should be introduced and, 
if so, how it should be formulated. Council on Legislation (2023), opinion on the special criminal provision 
for participation in a terrorist organization, pp. 20-21. 

226  Ibid. 
227  The Government has put forward its clarifications addressing the Council on Legislation’s comments in the 
draft legislative proposal. In the Government’s view, the proposal is not too far-reaching in relation to the need 
that  exists.  Furthermore,  the  Government  considers  that  the  definition  of  a  terrorist  organisation  in  the 
proposed Terrorist Offences Act is appropriate and leaves room for the trade-offs that need to be made, for 
example, regarding resistance movements that in totalitarian states work for the introduction of a democratic 
society,  even  though,  as  the  Council  on  Legislation  points  out,  this  is  not  clear  from  the  wording  of  the 
provisions. Written contribution from the Ministry of Justice in the context of the country visit to Sweden and 
Swedish Government (2022) Government proposal 2022/23:73 – A special criminal provision for participation 
in a terrorist organisation.  

228  On  2  May,  Amnesty  International  Sweden,  the  Civil  Rights  Defenders,  the  National  Forum  for  Voluntary 
Organisations  and  LSU-Sweden’s  child  and  youth  organisations,  published  a  call  to  the  Government  to 
reconsider the proposal in a daily newspaper. The stakeholders argued that the proposed criminal provision is 
not clearly defined and risks covering acts that should not necessarily be punishable, such as a political refugee 
supporting a liberation and resistance movement in his or her home country. The stakeholders also referred to 
the  opinion  of  the  Council  on  Legislation  that  there  is  a  risk  that  the  courts  will  have  to  make  political 
considerations in their assessment and that other states may try to put pressure on Sweden regarding how the 
legislation should be applied in relation to specific organisations and individuals. Svenska Dagbladet (2023) 
Debate: “The proposal is deeply problematic”.  

229  As noted in the 2022 Rule of Law Report, a group of 24 organisations, came out against that proposal arguing 
that it was not possible to design a ban that was both strong enough to safeguard the right of all vulnerable 
groups not to be subjected to racism and narrow enough not to threaten fundamental freedoms. Instead, they 
have advocated for a better use of existing legal instruments. Furthermore, the proposal is seen as risking to 
create a legal definition of racism that is far narrower than the common understanding of racism, which may 
be seen and used as legitimising groups embracing racist values. 2022 Rule of Law Report, Country Chapter 
on the rule of law situation in Sweden, p. 20 and information received from the National Forum for Voluntary 
Organizations in the context of the country visit.  

230  Information received from the Ministry of Justice in the context of the country visit to Sweden.  
231  Sweden’s civic space remains ‘open’ according to the rating by CIVICUS. Ratings are on a five-category scale 

defined as: open, narrowed, obstructed, repressed and closed. 

25 

 
                                                           
stakeholders observed at times shorter deadlines232. As regard civic space more generally, the 
Swedish Institute for Human Rights notes that some of the recent developments and polarising 
rhetoric233 may be harmful to the level of respect for civil society organisations’ freedom of 
expression  and  association.  In  particular,  a  number  of  stakeholders234  have  referred  to  an 
incident reported by media, in October 2022, where a senior political party member criticised 
and questioned the funding235 of the NGO Civil Rights Defenders in relation to its analysis of 
the Tidö Agreement236. These stakeholders considered that such criticism raised concerns as 
regards civil society organisations’ freedom to operate237.  

232  Information received from the Swedish Bar Association and Swedish Section of the International Commission 
of Jurists in the context of the country  visit to Sweden. The Swedish Bar  Association  has also observed a 
negative trend away from committees of inquiry with specialised legal experts towards legal proposals directly 
prepared by the Government Offices and/or the Ministries. 

233  The Institute referred to academics’ views that if such trends, notably related to policies, rhetoric and funding 
were to continue, they would affect the status and role of civil society. In this context, it referred to an increase 
in polarising, racist and inflammatory political rhetoric during the lead-up to the general elections in September 
2022, or the stricter prosecution of climate protesters. Written contribution and information received from the 
Swedish Institute for Human Rights in the context of the country visit to Sweden. In addition, the Civil Rights 
Defenders considered that climate protesters were being treated harsher for traffic blockades which used to be 
pursued  as  minor  offences  (“civil  disobedience”)  leading  to  fines,  while  recent  convictions  led  to  prison 
sentences (for criminal offence of ‘sabotage’). Information received from the Civil Rights Defenders in the 
context of the country visit to Sweden and contribution by the Civil Liberties Union for Europe, p 16-17. 
234  Information  received  from  the  Swedish  Institute  for  Human  Rights,  the  Civil  Rights  Defenders  and  the 

National Forum of Voluntary Organisations in the context of the country visit to Sweden. 

235  Expo (2022), Björn Söder wants to stop grants to organisations that criticize the Tidö Agreement, Altinget 

(2022), Sweden Democrats deny mapping of civil society's funding.  

236  The Tidö Agreement sets out the cooperation between the Government coalition parties (the Moderate Party, 

the Christian Democrats and the Liberals) and the Sweden Democrats.  

237  In a  similar development in  October 2022, the Civil  Right Defenders noted that an official from the  same 
political  party’s  parliament  office  contacted  the  Swedish  Society  for  Nature  Protection,  an  environmental 
NGO, a  week after that NGO also published its review of the Tidö Agreement,  wishing to find out  which 
private individuals and companies had made donations to that organisation. Dagens Nyheter (2022) Sweden 
Democrats requested a list of the Nature Conservation Society's donors  and information received from the 
Civil Rights Defenders in the context of the country visit. 

26 

 
 
                                                           
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2023 Rule of Law report 
can 
https://commission.europa.eu/publications/2023-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

Aftonbladet  (2023),  Debate:  Journalists  are  seen  as  criminals  by  the  police  by  Reporters  Without 
Borders Sweden and Swedish Journalists’ Association (Debatt: Journalister ses som brottslingar av 
polisen)  https://www.aftonbladet.se/debatt/a/venjBl/sjf-rsf-sverige-journalister-ses-som-brottslingar-
av-polisen. 

Agency for Public Management (2023), New challenges and old problems  - Corruption in local and 
regional government (Nya utmaningar och gamla problem – Om korruption i kommuner och regioner), 
https://www.statskontoret.se/publicerat/publikationer/publikationer-2023/nya-utmaningar-och-gamla-
problem--om-korruption-i-kommuner-och-regioner/  

Altinget (2022), Debate Six civil society organisations: How to stop future lobby scandals (Debatt Sex 
stoppas) 
kan 
civilsamhällesorganisationer: 
https://www.altinget.se/artikel/sex-civilsamhallesorganisationer-saa-kan-framtida-lobbyskandaler-
stoppas. 

lobbyskandaler 

framtida 

Så 

Altinget (2022), Sweden Democrats deny mapping of civil society’s funding (SD förnekar kartläggning 
av  civila  samhällets  finansiering),  https://www.altinget.se/artikel/sd-fornekar-kartlaggning-av-civila-
samhallets-finansiering. 

Altinget (2023), Sweden Democrats want to close down human rights institute - but voted "yes" to it in 
i  riksdagen), 
lägga  ner  MR-institut  –  men  röstade  ”ja” 
Parliament  (SD  vill 
https://www.altinget.se/artikel/sd-vill-lagga-ner-mr-institut-men-rostade-ja-till-det-i-riksdagen. 

till  det 

Centre for Media Pluralism and Media Freedom (2023), Media pluralism monitor 2023 – country report 
on Sweden. 

Centre Party webpage (2018), Solna judgment: exclusion case (Domen i Solna: Ärende om uteslutning), 
https://www.centerpartiet.se/lokal/stockholmsregionen/stockholms-
lan/startsida/nyheter/nyheter/2018-03-05-domen-i-solna-arende-om-uteslutning.  

Civil Liberties Union for Europe (2023), Contribution from Civil Liberties Union for the 2023 Rule of 
Law Report.  

Council of Europe: Committee of Ministers (2021), Recommendation CM/Rec(2021)1 of the Committee 
of  Ministers  to  member  States  on  the  development  and  strengthening  of  effective,  pluralist  and 
independent national human rights institutions. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists – Sweden 
https://fom.coe.int/en/pays/detail/11709586. 

Council on Legislation (2023), Opinion on the special criminal provision for participation in a terrorist 
organization, 
https://www.lagradet.se/wp-content/uploads/2023/03/En-sarskild-straffbestammelse-
for-deltagande-i-en-terroristorganisation.pdf. 

Dagens Juridik (2023), Commentary the Director of the National Courts Administration – “I understand 
that  the  Snippa  ruling  evokes  emotions”  (Thomas  Rolén  –  ”Jag  förstår  att  snippadomen  väcker 
känslor”),  https://www.dagensjuridik.se/kronikor/thomas-rolen-jag-forstar-att-snippadomen-vacker-
kanslor/. 

Dagens Juridik (2023), Commentary from the Lay Judges Association: Lay judges: “We agree with the 
Director  of  the  National  Courts  Administration”  (Nämndemännen:  ”Eniga  med  Domstolverkets 
generaldirektör”),  https://www.dagensjuridik.se/debatt/namndemannen-eniga-med-domstolverkets-
generaldirektor/.  

27 

 
Dagens  Juridik  (2023),  Debate:  Need  for  revised  anti-corruption  legislation  (DEBATT:  ”Behov  av 
reviderad korruptionslagstiftning”), https://www.dagensjuridik.se/nyheter/debatt-behov-av-reviderad-
korruptionslagstiftning/. 

Dagens Nyheter (2022) Sweden Democrats requested a list of the Nature Conservation Society's donors 
(SD begärde lista på Naturskyddsföreningens givare), https://www.dn.se/sverige/sd-begarde-lista-pa-
naturskyddsforeningens-givare/. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Sweden.  

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Sweden.  

European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Sweden.  

European  Commission  (2023),  2023  EU  Justice  Scoreboard.  European  Federation  of  Journalists 
(2022)  Tove  Carlén:  “The  Swedish  new  law  on  public  espionage  provides  little  protection  for 
journalists’  sources”  https://europeanjournalists.org/blog/2022/12/02/tove-carlen-the-swedish-new-
law-on-public-espionage-provides-little-protection-for-journalists-sources/. 

European  Parliament  (2022),  Flash  Eurobarometer:  News  &  Media  Survey  2022,  EB-ID 
2832/FL011EP https://europa.eu/eurobarometer/surveys/detail/2832. 

Expo (2022), Björn Söder wants to stop grants to organisations that criticize the Tidö Agreement (Björn 
Söder  vill  stoppa  bidrag  till  organisation  som  kritiserar  Tidöavtalet)  https://expo.se/2022/10/bjorn-
soder-vill-stoppa-bidrag-till-organisation-som-kritiserar-tidoavtalet. 

GRECO (2021), Fifth Evaluation Round – Compliance Report on Sweden on preventing corruption 
and promoting integrity in central governments (top executive functions) and law enforcement agencies.  

Journalisten (2022) PK warns of new bill on revocation of broadcasting licenses for television and radio 
(PK  varnar 
tv  och  radio) 
https://www.journalisten.se/nyheter/pk-varnar-nytt-lagforslag-om-aterkallelse-av-sandningstillstand-
tv-och-radio. 

lagförslag  om  återkallelse  av  sändningstillstånd 

för  nytt 

för 

The  Legal,  Financial  and  Administrative  Services  Agency  (2022)  Annual  Report  2022. 
https://www.kammarkollegiet.se/download/18.7ad5c4f61864b733be73b0b0/1677082762966/Kammar
kollegiet%20%C3%85rsredovisning%202022.pdf.  

Legal,  Financial  and  Administrative  Services  Agency  (2022)  Political  party  funding  disclosures  for 
2021  now  available  (Redovisningarna  av  partiers  finansiering  för  2021  är  nu  tillgängliga  – 
Kammarkollegiet)  https://www.kammarkollegiet.se/aktuellt/nyheter/2022-07-04-redovisningarna-av-
partiers-finansiering-for-2021-ar-nu-tillgangliga.  

The  Local  (2022)  Five  of  Sweden’s  political  parties  planned  to  evade  party  financing  laws.  
https://www.thelocal.se/20220818/five-of-swedens-political-parties-considered-evading-party-
financing-laws/al.se.  

Ministry  of  Culture  (2022)  Minister  Jakob  Forssmed  in  dialogue  with  civil  society  on  democracy 
conditions  (Statsrådet  Jakob  Forssmed 
i  samtal  med  civilsamhället  om  demokrativillkor), 
https://www.regeringen.se/artiklar/2022/12/statsradet-jakob-forssmed-i-samtal-med-civilsamhallet-
om-demokrativillkor/. 

National  Audit  Office  (2021),  The  Economic  Crime  Authority  The  work  towards  the  organised 
economic crime (Ekobrottsmyndigheten  – arbetet mot den organiserade ekonomiska brottsligheten), 
RIR 
2021:30 
https://www.riksrevisionen.se/download/18.7346a817da1ef2fefc840/1639129041226/RiR_2021_30_ 
webb.pdf.  

28 

 
 
National  Council  for  Crime  Prevention  (2023),  Written  contribution  from  the  National  Council  for 
Crime Prevention in the context of the country visit. 

National  Courts  Administration  (2022),  Calculate  your  economic  base  (Räkna  ut  ditt  ekonomiska 
underlag),  https://www.domstol.se/amnen/rattshjalp/behover-du-rattshjalp/rakna-ut-ditt-ekonomiska-
underlag/.  

National Courts Administration (2022) Four former Ericsson employees are acquitted from prosecution 
of  aggravated  bribery  (Fyra  tidigare  Ericsson-anställda  frikänns  från  åtal  om  grov  bestickning) 
https://www.domstol.se/nyheter/2022/06/fyra-tidigare-ericsson-anstallda-frikanns-fran-atal-om-grov-
bestickning/.  

National Courts Administration (2022) The Swedish courts' first digital judgment (Sveriges Domstolars 
första  digitala  dom),  https://www.domstol.se/domstolsverket/nyheter/2022/10/sveriges-domstolars-
forsta-digitala-dom/. 

National  Courts  Administration  (2022)  State  service  centre  and  the  National  Courts  Administration 
working together to improve service to citizens (Statens servicecenter och Domstolsverket i samverkan 
för  ökad  service  till  medborgare),  https://www.domstol.se/domstolsverket/nyheter/2023/01/statens-
servicecenter-och-domstolsverket-i-samverkan-for-okad-service-till-medborgare/. 

National Courts Administration (2023), For those wanting to become lay judges (För dig som vill bli 
nämndeman), 
https://www.domstol.se/om-sveriges-domstolar/namndeman----ett-
fortroendeuppdrag/for-dig-som-vill-bli-namndeman/. 

OECD  (2019),  Sweden  must  urgently  implement  reforms  to  boost  the  fight  against  bribery 
https://www.oecd.org/corruption/sweden-must-urgently-implement-reforms-to-boost-fight-
againstforeign-bribery.htm.  

Press and Broadcasting Authority (2023), MPRT and the Swedish Media Council form a new media 
mediemyndighet) 
en 
medieråd 
Statens 
authority 
https://via.tt.se/pressmeddelande/mprt-och-statens-medierad-bildar-en-ny-
mediemyndighet?publisherId=3235838&releaseId=3340050. 

(MPRT 

bildar 

och 

ny 

Press and Broadcasting Authority (2023), MPRT is proposed to become the competent authority with 
supervisory responsibility under the DSA (MPRT föreslås bli behörig myndighet med tillsynsansvar 
under  DSA)  https://www.mprt.se/nyhetsrum/nyhetslista/2023/mprt-foreslas-bli-behorig-myndighet-
med-tillsynsansvar-under-dsa/. 

Press  and  Broadcasting  Authority  (2023)  MPRT  proposes  future  conditions  for  commercial  radio 
(MPRT 
radio) 
kommersiell 
https://via.tt.se/pressmeddelande/mprt-lamnar-forslag-pa-framtida-villkor-for-kommersiell-
radio?publisherId=3235838&releaseId=3337272. 

framtida 

lämnar 

förslag 

villkor 

för 

på 

Reporters without Borders (2023), – Sweden https://rsf.org/en/country/sweden. 

Smalaaningen  (2023),  Corruption  prosecutor  calls  for  stricter  laws  (Korruptionsåklagare  vill  ha 
skarpare lag), https://www.smalanningen.se/2023-01-03/korruptionsaklagare-vill-ha-skarpare-lag 

Svenska  Dagbladet  (2023),  Commentary  from  the  Judges  Association:  Lay  judges  should  not  be 
nominated  by 
inte  nomineras  av  partierna), 
https://www.svd.se/a/695Rp0/sveriges-domareforbund-namndeman-bor-inte-nomineras-av-partierna.  

the  political  parties 

(Nämndemän  bör 

Svenska  Dagbladet  (2023),  Debate:  “The  proposal is deeply  problematic” (Debat:  “Lagförslaget är 
djupt 
https://www.svd.se/a/O8eVM3/lagforslaget-om-deltagande-i-
terrororganisation-ar-djupt-problematiskt-skriver-debattorer.  

problematiskt”), 

SVT (2023), After the Snippa ruling, parties see problems with the jury system (Efter snippa-domen – 
partierna  ser  problem  med  nämndemannasystemet),  https://www.svt.se/nyheter/inrikes/efter-snippa-
domen-partierna-ser-problem-med-namndemannasystemet. 

29 

 
 
SVT (2023), After the Snippa case: Two members of the Court of Appeal for Western Sweden leave 
the  court 
för  västra  Sverige), 
https://www.svt.se/nyheter/lokalt/vast/efter-snippa-fallet-tva-namndeman-lamnar-hovratten. 

(Efter  snippa-fallet:  Två  nämndemän 

lämnar  hovrätten 

SVT  (2023)  Shekarabi:  Social-democrats  district  wrong  to  contact  lay  judges  in  the  Snippa  ruling 
snippa-domen), 
att 
(Shekarabi: 
https://www.svt.se/nyheter/inrikes/shekarabi-1.  

nämndemän 

S-distrikt 

kontakta 

Fel 

av 

i 

SVT (2023), Difficult to recruit lay judges after the “Snippa” ruling: “Many are reluctant to continue” 
fortsätta) 
(Svårt 
https://www.svt.se/nyheter/inrikes/svart-rekrytera-namndeman-efter-snippa-domen-flera-tvekar-att-
fortsatta. 

”snippa-domen”: 

nämndemän 

rekrytera 

”Flera 

tvekar 

efter 

att 

Swedish  Government  (2014),  public  consultation  SOU  2014:86  (Rättvisans  pris,  SOU  2014:86), 
https://www.regeringen.se/rattsliga-dokument/statens-offentliga-utredningar/2014/12/sou-
201486/#:~:text=R%C3%A4ttvisans%20pris%20SOU%202014%3A86&text=Utredningens%20uppd
rag%20har%20varit%20att,en%20kostnadsd%C3%A4mpande%20effekt%20p%C3%A5%20anslaget
. 

Swedish Government (2018), Act concerning restrictions when ministers and state secretaries transition 
to  non-state  activities,  act  2018:676.  (Lag  (2018:676)  om  restriktioner  vid  statsråds  och 
statssekreterares 
verksamhet) 
http://europam.eu/data/mechanisms/COI/COI%20Laws/Sweden/4.%20Act%20on%20Restrictions%2
0on%20the%20Transfer%20of%20Ministers%20and%20State%20Secretaries%20to%20Other%20th
an%20State%20Activities%20of%202018_SWE.pdf. 

övergång 

annan 

statlig 

till 

än 

Swedish  Government  (2022),  Assignment  to  analyse  and  improve  the  conditions  for  combating 
corruption  in  municipalities  and  regions,  Fi2022/02296.  (Uppdrag  att  analysera  och  förbättra 
förutsättningarna 
regioner) 
och 
https://www.regeringen.se/regeringsuppdrag/2022/07/uppdrag-att-analysera-och-forbattra-
forutsattningarna-for-att-motverka-korruption-inom-kommuner-och-regioner/.   

att  motverka 

korruption 

kommuner 

inom 

för 

Swedish  Government  (2022),  Budget  Bill  for  the  judiciary  2023  (Utgiftsområde  4  Rättsväsendet), 
https://www.regeringen.se/contentassets/def2026cac0b4ef7acf4afeb988326ed/utgiftsomrade-4-
rattsvasendet.pdf. 

Swedish Government (2022), Increased transparency in the ownership of broadcasters (Ökad insyn I 
ägandet av radio- och tv-företag) Prop. 2021/22:262. 

Swedish Government (2022), Input from Sweden for the 2023 Rule of Law Report. 

Swedish Government (2022), Withdrawal of broadcasting licences in the interests of Sweden’s security 
Ds  2022:20  (Återkallelse  av  sändningstillstånd  med  hänsyn  till  Sveriges  säkerhet  Ds  2022:20) 
https://regeringen.se/contentassets/e67d0258de644d66b95dd6b2a14ad03a/aterkallelse-av-
sandningstillstand-med-hansyn-till-sveriges-sakerhet-ds-202220.pdf. 

Swedish Government (2022), Subordination of the Swedish Media Council to the Swedish Press and 
Broadcasting Authority Ds 2022:17 (Inordnande av Statens medieråd i Myndigheten för press, radio 
och 
https://www.regeringen.se/rattsliga-dokument/departementsserien-och-
promemorior/2022/08/ds-202217/. 

2022:17), 

tv,  Ds 

Swedish  Government  (2022),  Government  proposal  2022/23:73  –  A  special  criminal  provision  for 
participation  in  a  terrorist  organisation  (Regeringens  proposition  2022/23:73 
  En  särskild 
straffbestämmelse  för  deltagande  i  en  terroristorganisation)  https://www.regeringen.se/rattsliga-
dokument/proposition/2023/03/prop.-20222373.  

Swedish Government (2023), Assignment to the Swedish Press and Broadcasting Authority to prepare 
for the incorporation of the Swedish Media Council's tasks into the authority Ku2023/00115 (Uppdrag 
till Myndigheten för  press,  radio  och  tv  att förbereda  inordnandet  av  Statens  medieråds  uppgifter  i 
  Ku2023/00115)  https://www.regeringen.se/regeringsuppdrag/2023/02/uppdrag-till-
myndigheten 

30 

 
myndigheten-for-press-radio-och-tv-att-forbereda-inordnandet-av-statens-medierads-uppgifter-i-
myndigheten/. 

Swedish  Government  (2023),  Assignment  of  studying  unauthorised  influence  by  systemically 
threatening actors and groupings (Uppdrag att studera otillåten påverkan som utövas av systemhotande 
aktörer  och  grupperingar)  https://www.regeringen.se/regeringsuppdrag/2023/04/uppdrag-att-studera-
otillaten-paverkan-som-utovas-av-systemhotande-aktorer-och-grupperingar/ 

Swedish Government (2023), Committee Directive: Long-term conditions for a solid and independent 
public  service  2023:27  (Kommittédirektiv:  Långsiktiga  villkor  för  ett  hållfast  och  oberoende  public 
service 2023:27) https://regeringen.se/rattsliga-dokument/kommittedirektiv/2023/02/dir.-202327. 

Swedish  Government  (2023)  public  consultation  SOU  2023:12  (Remiss  av  SOU  2023:12), 
https://www.regeringen.se/remisser/2023/04/remiss-av-sou-202312-forstarkt-skydd-for-demokratin-
och-domstolarnas-oberoende/.  

Swedish Government (2023), Roundtable on unauthorised influence against parties and public decision-
making  (Rundabordssamtal  om  otillåten  påverkan  mot  partier  och  offentligt  beslutsfattande), 
https://www.regeringen.se/artiklar/2023/02/rundabordssamtal-om-otillaten-paverkan-mot-partier-
och-offentligt-beslutsfattande/.  

Swedish  Government  (2023),  Stricter  view  of  crimes  against  journalists  and  certain  other  functions 
useful to society (Skärpt syn på brott mot journalister och  31isa andra samhällsnyttiga funktioner), 
https://www.regeringen.se/rattsliga-dokument/lagradsremiss/2023/03/skarpt-syn-pa-brott-mot-
journalister-och-vissa-andra-samhallsnyttiga-
funktioner/#:~:text=F%C3%B6r%20att%20st%C3%A4rka%20det%20straffr%C3%A4ttsliga%20sky
ddet%20f%C3%B6r%20ut%C3%B6vare%20av%20vissa,funktion%20i%20hans%20eller%20hennes
. 

Swedish Government (2023), Some questions on fundamental rights and freedoms (Några frågor om 
grundläggande 
https://www.regeringen.se/rattsliga-
rättigheter), 
fri- 
dokument/kommittedirektiv/2023/06/dir.-202383. 

och 

Swedish Government (2023), A parliamentary committee is appointed with the task of investigating 
increased transparency in the financing of parties (En parlamentarisk kommitté tillsätts med uppdraget 
partier), 
att 
https://regeringen.se/pressmeddelanden/2023/06/en-parlamentarisk-kommitte-tillsatts-med-
uppdraget-att-utreda-forstarkt-insyn-i-finansiering-av-partier/ 

finansiering 

förstärkt 

utreda 

insyn 

av 

i 

Swedish Institute for Human Rights (2023), A government must stand up for its national human rights 
https://mrinstitutet.se/en/a-government-must-stand-up-for-its-national-human-rights-
institution 
institution/ 

Swedish Institute for Human Rights (2023), Director of the Institute for Human Rights appointed (Klart 
med  31irector  för  Institutet  för  mänskliga  rättigheter),  https://mrinstitutet.se/klart-med-direktor-for-
institutet-for-manskliga-rattigheter/. 

Swedish Institute for Human Rights (2023), Fredrik Malmberg spoke at EU conference on institutional 
protection of fundamental rights (Fredrik Malmberg talade på EU-konferens om institutionellt skydd 
för  grundläggande  rättigheter),  https://mrinstitutet.se/fredrik-malmberg-talade-pa-eu-konferens-om-
skydd-for-grundlaggande-rattigheter/. 

Swedish  Institute  for  Human  Rights  (2023),  Nominate  your  candidate  for  the  Advisory  Council! 
(Nominera  din  kandidat  till  Rådet  för  de  mänskliga  rättigheterna!),  https://mrinstitutet.se/wp-
content/uploads/2022/01/nominera_kandidat_till_radet_2023_Anpassad.pdf 

Swedish Journalists’ Association (2022), No to proposal to revoke broadcast licenses (Nej till förslag 
om  återkallelse  av 
sändningstillstånd),  https://www.sjf.se/aktuellt/202211/nej-till-forslag-om-
aterkallelse-av-sandningstillstand. 

31 

 
Swedish  Journalists’  Association  (2023),  Good  news  about  increased  criminal  law  protection  for 
journalists 
journalister) 
https://www.sjf.se/aktuellt/202303/gladjande-besked-om-okat-straffrattsligt-skydd-journalister. 

straffrättsligt 

(Glädjande 

besked 

skydd 

ökat 

om 

för 

Swedish Foundation for Human Rights (2023), Open letter to Prime Minister Ulf Kristersson on the 
Human Rights Institute from 53 organizations (Öppet brev till statsminister Ulf Kristersson om MR-
institutet  från  53  organisationer),  https://mrfonden.se/2023/05/02/oppet-brev-till-statsminister-ulf-
kristersson-om-mr-institutet/. 

Swedish 
https://www.statensmedierad.se/ovrigt/about-the-swedish-media-council. 

Council 

(2022), 

Media 

About 

the 

Swedish 

Media 

Council 

Sweden’s Municipalities and Regions (2021), Welfare offences and unauthorized influences – From 
grant  fraud  to  systemic  crime  (Välfärdsbrott  och  otillåten  påverkan  –  Från  bidragsfusk  till 
brottslighet), 
systemhotande 
https://skr.se/skr/tjanster/press/nyheter/nyhetsarkiv/valfardsbrottettvaxandeproblemikommunerna.587 
72.html.  

Swedish  Parliament  (2022)  Foreign  espionage  (pending  draft  constitution,  etc.)  (Utlandsspioneri 
(vilande 
https://www.riksdagen.se/sv/dokument-
lagar/arende/betankande/utlandsspioneri-vilande-grundlagsforslag-mm_HA01KU7. 

grundlagsförslag 

m.m.)), 

Swedish  Parliament  (2023)  Review  of  the  Ombudsman's  office  (Översyn  av  JO-ämbetet), 
https://www.riksdagen.se/sv/dokument-och-lagar/dokument/betankande/oversyn-av-jo-
ambetet_ha01ku32/. 

The  Swedish  Bar  Association  (2021)  The  Bar  Association’s  Rule  of  Law  Programme 
Program), 
(Advokatsamfundets 
https://www.advokatsamfundet.se/globalassets/advokatsamfundet_sv/advokatsamfundet/rattsstatligt-
program-2021.pdf. 

Rättsstatliga 

The 2020 Committee of Inquiry on the Constitution (2023), Strengthening the protection of democracy 
and  independence  of  the  judiciary  (Förstärkt  skydd  för  demokratin  och  domstolarnas  oberoende), 
https://www.regeringen.se/contentassets/fcde0b9ad7154db5a01527f72b0f4103/forstarkt-skydd-for-
demokratin-och-domstolarnas-oberoende-sou-2023-12.pdf. 

Transparency 
https://www.transparency.org/en/cpi/2022  

International 

(2023), 

Corruption 

Perception 

Index 

2022. 

TV4 (2023) Sweden Democrats want to discontinue funding for work against racism (SD vill avveckla 
bidrag till arbete mot racism), https://www.tv4.se/artikel/5TyAlxMqRNdEGzg13lZMG3/avsloejar-sd-
vill-avveckla-bidrag-till-arbete-mot-rasism. 

32 

 
Annex II: Country visit to Sweden 

The Commission services held virtual meetings in March 2023 with: 

  Economic Crime Authority 
  Agency for Public Management 
  Civil Rights Defenders 
  Ministry of Culture 
  Ministry of Finance 
  Ministry of Justice 
  National Courts Administration 
  National Forum for Voluntary Organisations 
  Swedish Institute for Human Rights  
  Office of the Parliamentary Ombudsmen 
  Office of the Prime Minister 
  Press and Broadcasting Authority 
  Media Ombudsman 
  Prosecution Service 
  Secretariat of the Constitution Committee 
  Supreme Administrative Court 
  Supreme Court 
  Swedish Association of Judges 
  Swedish Bar Association 
  Swedish Journalists’ Association 
  Swedish Media Publishers’ Association 
  Swedish public radio (SR) 
  Swedish public television (SVT) 
  Swedish Section of the International Commission of Jurists 
  Transparency International Sweden 

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

  ALDA (European Association for Local Democracy) 
  Amnesty International  
  Civil Liberties Union for Europe  
  Civil Society Europe 
  Culture Action Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum  
  European Federation of Journalists  
  European Partnership for Democracy  
  European Youth Forum  
  Free Press Unlimited 

33 

 
 
ILGA Europe  
International Commission of Jurists 
International Federation for Human Rights (FIDH)  
International Planned Parenthood Federation European Network 
International Press Institute  

  Front Line Defenders 
 
 
 
 
 
  JEF Europe  
  Osservatorio Balcani e Caucaso Transeuropa 
  Philea  
  Reporters Without Borders  
  SOLIDAR 
  Transparency International EU 

34