COMMISSION STAFF WORKING DOCUMENT 2025 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 2025 Rule of Law Report The rule of law situation in the European Union
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Sweden, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.7.2025  SWD(2025) 927 final  COMMISSION STAFF WORKING DOCUMENT 2025 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 2025 Rule of Law Report                                  The rule of law situation in the European Union {COM(2025) 900 final} - {SWD(2025) 901 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
ABSTRACT  

In Sweden, the level of perceived judicial independence continues to be very high among the 
general  public  and  is  now  high  among  companies.  The  Government  presented  proposals 
amending  the  Constitution  to  further  strengthen  judicial  independence,  in  particular  as 
regards judges’ appointments, disciplinary procedures, and establishing a more independent 
court administration agency. The debate on strengthening safeguards to ensure independence 
in  the  nomination  of  lay  judges  is  still  ongoing  but  has  not  yet  led  to  any  changes.  The 
Swedish courts were granted increased financial resources to deal with an increase in  cases 
and to increase security at courts. Swedish judges’ salaries are set within the parameters of a 
collective  agreement  between  the  National  Courts  Administration  and  the  trade  union 
representing  judges,  and  reviewed  annually  based  on  an  individual  assessment.  Initiatives 
related to the right to an effective remedy are on-going, including as regards the threshold to 
qualify  for  legal  aid.  The  justice  system  continues  to  perform  efficiently  despite  a  peak  of 
incoming cases in 2024. 

The perception among experts, citizens and business executives is that Sweden is one of the 
least  corrupt  countries  in  the  world.  New  legislation  on  limitation  periods  has  now  entered 
into  force  while  the  Government  continues  to  review  criminal  legislation  in  relation  to 
corruption.  The  investigation  and  prosecution  of  corruption  continues  to  achieve  results, 
although addressing foreign bribery remains a challenge and law enforcement are concerned 
by  a  possible  underreporting  of  corruption  cases.  The  obligation  for  agencies  under  the 
Government  to  prevent  corruption  is  now  clarified  in  law,  while  some  gaps  in  asset 
declaration  for  public  officials  remain.  A  committee  recommended  reforms  to  the  political 
party financing framework and introduction of rules on lobbying, while there hasn’t been any 
follow-up  so  far  on  the  evaluation  of  the  rules  on  revolving  doors.  Measures  are  taken  to 
address  the  risk  of  infiltration  of  the  public  service  by  organised  crime  through  corruption, 
such as the adoption of legislation to strengthen background checks of municipal employees.  

The independent national regulatory authority, the Swedish Agency for the Media, deals with 
an  increasing  variety  of  tasks.  The  Government  is  preparing  to  renew  the  periodic  public 
service  mission  with  new  rules  for  independence  of  public  service  media.  The  access  to 
documents framework has been adjusted to counter the misuse of transparency by organised 
crime. The overall conditions for journalists remain favourable and the Swedish Agency for 
the Media has been tasked to monitor the safety of journalists. 

Some  stakeholders  express  concern  about  the  acceleration  of  legislative  preparatory  work 
which  they  consider  poses  challenges  to  public  participation.  The  Government  presented  a 
proposal amending  the Constitution to provide a framework to better deal with serious crises. 
It  also presented a proposal to strengthen the procedure for amending the Constitution.  The 
National  Human  Rights  Institution  has  obtained  an  A-status  accreditation  and  the 
Parliamentary Ombudsmen discharge their mandates effectively. There were further steps on 
the  legal  framework  for  the  funding  and  operation  of  civil  society  organisations,  which 
entered into force in 2025. The civil society space remains open. 

1 

 
 
 
RECOMMENDATIONS 

Overall,  concerning  the  recommendations  in  the  2024  Rule  of  Law  Report,  Sweden  has 
made: 

•  No  progress  on  ensuring  that  the  nomination  system  of  lay  judges  safeguards  their 

independence, taking into account European standards on judicial independence. 

•  No  progress  on  ensuring  the  appropriate  follow-up  to  the  evaluation  of  the  rules  on 

revolving doors. 

•  No further progress  on strengthening the fight  against foreign  bribery, by amending the 
existing legal definitions to improve on the prosecution of, and final judgments in foreign 
bribery cases. 

•  Significant  progress  on  continuing  efforts  to  ensure  that  the  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.  

•  Strengthen  the  fight  against  foreign  bribery,  including  through  amending  the  existing 

legal framework and improving enforcement. 

•  Ensure the appropriate follow-up to the evaluation of the rules on revolving doors. 

2 

 
 
 
I. 

JUSTICE SYSTEM1  

Independence  

The level of perceived judicial independence in Sweden continues to be very high among 
the  general  public  and  is  now  high  among  companies.  Overall,  76%  of  the  general 
population and 74% of companies perceive the level of independence of courts and judges to 
be  ‘fairly  or  very  good’  in  20252.  Among  the  general  public,  the  perceived  judicial 
independence has slightly decreased in comparison with 2024 (78%), although it is higher in 
comparison  with  2021  (71%).  The  perceived  judicial  independence  among  companies  has 
slightly decreased in comparison with 2024 (75%), although it is higher in comparison with 
2021 (71%).  

The Government presented proposals amending the Constitution to strengthen judicial 
independence,  including  by  establishing  a  more  independent  court  administration 
agency.  To  set  up  such  an  agency,  on  29  April  2025,  the  Government  presented 
constitutional3  amendments  based on a 2023  report of an all-party committee of inquiry on 
strengthening  the  protection  of  democracy  and  the  independence  of  the  judiciary  (‘2020 
committee  of  inquiry’)4.  The  new  court  administration  agency  is  designed  to  be  more 
independent from the Government than the current National Courts Administration, notably 
in  terms  of  being  headed  by  a  Board  –  where  the  majority  of  members  are  or  have  been 
judges – and that Board would appoint the agency’s director5. A decision to remove a Board 
member (other than at own request) could be taken only by the Parliament with at least three-
fourths of the voters and more than half of the members of the Parliament having to vote in 
favour. The nomination procedure for the Board members will be laid down in legislation. In 
that  respect,  in  its  2023  report,  the  2020  committee  of  inquiry  proposed  that  a  specific 
nomination  procedure  should  be  introduced  to  ensure  that  the  courts  have  a  significant 
influence over the composition of the Board and the Government may only appoint a person 
who  has  been  proposed  for  the  role  of  member  or  a  deputy6.  The  new  agency  would 
essentially  have  the  same  tasks  as  the  National  Courts  Administration.  The  constitutional 
amendments  also  cover  issues  on  retirement  of  judges  of  the  Supreme  Courts  and  other 
judges7,  laying  down  a  range  for  the  number  of  the  judges  at  the  Supreme  Courts,  and  a 

1   An overview of the institutional framework for all four pillars can be found here. 
2   Figures 50 and 52, 2025 EU Justice Scoreboard and 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  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. 

4   Swedish Government (2025f), and Swedish Government (2023b),. 
5   The  Board would appoint the Director of the new  agency, rather than the Government as is presently the 

case for the National Courts Administration. Swedish Government (2025f). 

6   The 2020 committee of inquiry considered that the courts should nominate two candidates per one vacant 
Board position for the judiciary, out of which the Government should appoint one of the two candidates. 
Swedish Government (2023b). 

7   The Committee of Inquiry proposed that the Constitution should provide that Supreme Court judges can be 
removed from office  only if they have reached a statutory retirement age and not apply retroactively. On 
application  from  a  Supreme  Court  judge,  the  new  courts  agency  would  be  able  to  decide  upon  a  higher 
retirement  age.  The  Committee  of  Inquiry  considered  that  the  proposals  for  the  Supreme  Court  judges 
should  also  apply  to  other  judges.  The  retirement  age  will  be  laid  down  in  law.  Swedish  Government 
(2025f),and Swedish Government (2023b). 

3 

 
 
special  joint  composition  with  judges  of  both  Supreme  Courts8.  For  the  constitutional 
amendments to be adopted, the Parliament must pass two identically worded votes in favour 
by  simple  majority  with  a  parliamentary  election  between  both  votes;  the  next  regular 
election is foreseen in September 2026. The legislative amendments should enter into force 
on 1 January 2027 and the constitutional amendments on 1 April 2027. The Government will 
present the relevant legislative amendments after the constitutional proposal. 

independence, 

The Government presented a proposal amending the Constitution to further strengthen 
judicial 
in  particular  on  judges’  appointments  and  disciplinary 
procedures.  On  29  April  2025,  the  Government  presented  proposals  for  constitutional 
amendments9. The constitutional amendments strengthen judicial independence by providing 
that the Government can appoint judges only after a proposal from a special body, such as the 
Judges Proposal Board, where a majority of its members are or have been permanent judges. 
At present, all permanent judges are appointed by the Government upon a recommendation 
by  the  Judges  Proposals  Board.  The  Government  is  not  bound  by  the Board’s  proposal  but 
cannot appoint a person who has not first been heard by the Board10. Furthermore, the 2020 
committee of inquiry proposed that a Disciplinary Board for Judges should be established and 
consisting  of  a  majority  of  members  who  are  or  have  been  judges.  The  Government’s 
constitutional amendments extend the right to judicial review in case of dismissal by a body 
other than a court. In such judicial review, only permanent judges may take part. It is further 
proposed that should a dismissal be decided by any other authority than a court, a majority of 
its  members  must  be  or  have  been  permanent  judges11.  As  one  part  of  that  process,  on  13 
May  2025,  a  committee  of  inquiry  presented  a  report  for  future  legislative  provisions  on 
disciplinary  procedures  for  permanent  judges,  establishment  of  a  Disciplinary  Board  for 
Judges  and  adjustments  to  the  Judicial  Proposals  Board.  The  report  has  been  referred  for 
public consultation until 26 September 202512. The work on the different strands is expected 
to be completed once the legislative amendments enter into force on 1 January 2027 and the 
constitutional amendments on 1 April 2027.  

Although  the  debate  on  the  nomination  system  for  lay  judges  continues,  there  was  no 
progress  made  on  the  2024  recommendation13.  Lay  judges  in  Sweden  are  nominated 
exclusively  by  the  political  parties  and  elected  by  municipal  councils  or  county  council 
assemblies14.  A national debate on the role of political  parties in  the nomination process  of 
lay judges is ongoing. The link between the lay judges and the political parties that nominate 
them  has  given  rise  to  public  concern  about  perceptions  of  lay  judges’  independence  and 
impartiality in some cases. The Swedish National Courts Administration noted that each year 

8   This may be appropriate, for example, if EU law is unclear in a particular area or a  question arises as to 
whether the Supreme Court or the Supreme Administrative Court are entitled to deal with a particular case. 

9   Swedish Government (2025f) Strengthening the protection of the independence of courts and judges. 
10   If the Government intends to appoint a person not proposed by the Board, it has to refer the matter back to 

the Board. 2020 Rule of Law Report, Sweden, p. 4. 

11   According to the new constitutional provision, where a judge has been removed from office otherwise than 
by  a  decision of  a  court,  they  are  entitled  to  a  judicial review.  The  same  applies  where a  judge  has been 
suspended  from  his  or  her  duties,  ordered  to  undergo  a  medical  examination  or  disciplined.  The  court 
considering the case consists of permanent judges only, with a majority of members who are or have been 
judges on any other deciding body. 

12   Swedish Government (2025j). 
13   The 2024 Rule of Law Report recommended to Sweden to “ensure that the nomination system of lay judges 

safeguards their independence, taking into account European standards on judicial independence”. 

14   2024 Rule of Law Report, Sweden, p. 6. 

4 

 
 
a  few  instances  attract  media  attention,  and  serious  irregularities  can  lead  to  a  mistrial15. 
Many stakeholders argue for a change of the nomination system16. The Government has not 
taken any specific steps to implement the recommendation of the 2024 Rule of Law Report17 
and therefore no progress has been made.  

Quality  

in  courts 

technology 

The digitalisation of justice in Sweden continues to be at a very good level overall. There 
are  procedural  rules  allowing  digital 
in  civil,  commercial, 
administrative, and criminal cases, as well as online information about the judicial system for 
the general public18. Efforts are ongoing to ascertain how legal information can be provided 
to the public in a digital, uniform, secure and efficient manner based on the users’ needs19. In 
2024, the Swedish National Courts Administration also took further steps towards making the 
case management process completely digital, by introducing the ability to sign judgments and 
decisions  digitally20.  Nevertheless,  some  gaps  remain  on  digital  solutions  to  conduct  and 
follow criminal proceedings. These gaps include the possibility for victims and defendants to 
access  their  ongoing  case  electronically,  accessing  first  instance  court  judgments  online,  or 
arrangements for machine readability of judgments21.  

The Swedish courts were granted increased financial resources for the period of 2025-
2027 to deal with an increase in cases and to increase security at courts. This increase in 
resources  was  part  of  a  broader  investment  in  the  entire  justice  system.  The  additional 
resources for the courts are meant to manage an increase in cases and to increase security in 
the courts22. Stakeholders in the judicial system consider that the financial resources for the 
period 2025-2027 are sufficient23. The National  Courts Administration expects  that most of 
the courts will use the additional funds for further recruitments and investments in security24. 
To strengthen the security of the courts, the National Courts Administration also submitted a 
proposal  to  the  Government  for  a  constitutional  amendment  to  enable  background  checks 
during  the  recruitment  phase  for  court  employees  to  reduce  the  risk  of  criminal  infiltration 
and irregularities25. 

Swedish judges’ salaries are set within the parameters of a collective agreement between 
the  National  Courts  Administration  and  the  trade  union  representing  judges,  and 
reviewed  annually  based  on  an  individual  assessment.  In  October  2024,  the  European 

15   National Courts Administration (2025), written input.  
16  Country  visit  Sweden,  Judges  Association,  Bar  Association,  Swedish  Institute  for  Human  Rights,  Civil 
Rights  Defenders  and  the  Swedish  Section  of  the  International  Commission  of  Jurists.  The  Swedish  Lay 
Judges Association considers that the challenges concerning the perception of lay judges’ independence and 
impartiality  could  be  addressed  with  better  training  of  lay  judges  and  the  political  parties  that  nominate 
them. Country visit Sweden, Swedish Lay Judges Association; ENNHRI (2025). 

17   Swedish Government (2025a) written input. 
18   2025 EU Justice Scoreboard, figure 40 and 41. 
19   The  National  Courts  Administration  submitted  a  report  to  the  Government  on  28  May  2025.  National 

Courts Administration (2025a).  

20   Swedish Government (2025a), written input, p. 2. 
21   2025 EU Justice Scoreboard, figures 46, 47 and 48. 
22   Swedish Government (2024f). From 2025 to 2027, their budget will increase from approximately EUR 744 

million to EUR 799 million (SEK 8.2 billion to SEK 8.8 billion). 

23   Country visit Sweden, Judges Association, National Courts Administration, Prosecution Service. 
24   Each court is its own Government agency, and consequently has its own budgetary responsibility and can 

use the resources as they see fit. National Courts Administration (2025), written contribution. 

25  Swedish Government (2024a). 

5 

 
 
Association  of  Judges  adopted  a  resolution,  urging  the  Swedish  Government  to  replace  the 
existing  salary  system  with  a  system  which  fully  excludes  any  possible  impact  on  judicial 
independence,  in  line  with  well-established  international  standards26.  Swedish  judges’ 
salaries  are  set  within  the  parameters  of  a  collective  agreement,  between  the  trade  union 
representing judges the National Courts Administration for newly appointed judges, but are 
then  subject  to  review  on  an  annual  basis  between  the  judge  and  the  responsible  court 
president27.  A  survey  commissioned  by  the  Swedish  Judges’  Association  highlighted  the 
challenges  of  Swedish  judges  related  to  the  existing  salary  system28.  The  Swedish  Judges’ 
Association  considers  that  this  remuneration  system  is  not  transparent  and  is  vulnerable  to 
interference  through  the  remuneration  of  (individual)  judges.  The  Swedish  Judges’ 
Association considers that the system has not alleviated problems with recruitment of judges, 
which was the intention of its introduction in 2005.  

Initiatives related to the right to an effective remedy are on-going. In January 2025, an 
all-party committee tasked with investigating issues relating to the protection of fundamental 
rights  and  freedoms  delivered  its  report  on  possible  amendments  to  the  Constitution29.  In 
particular, it noted that Swedish law does not contain a generally applicable rule on the right 
to  judicial  review  at  constitutional  level30,  whereas  such  provisions  are  included  in  the 
European  Convention  on  Human  Rights  and  the  EU  Charter  of  Fundamental  Rights.  The 
committee proposed that the right to judicial review should be enshrined in the Constitution31. 
Another issue linked to effective remedy has been explored since the Government mandated 
an  inquiry  in  202432  to  examine  specific  questions  related  to  legal  assistance,  including  as 
regards the review of the threshold for legal aid under the Legal Aid Act. The threshold for 
legal  aid  in  civil  cases  has  not  been  adjusted  to  inflation  since  1999  and,  as  a  result,  the 
number  of  persons  qualifying  for  legal  aid  has  steadily  decreased  in  the  past  decades33.  As 
regards  administrative  courts,  stakeholders  have  pointed  out  that  particular  challenges  exist 
with regard to effective judicial redress34. These concern, in particular, the fact that based on 
a ruling of the Supreme Administrative Court35, individuals do not get their costs reimbursed 
in  the  administrative  court  procedures,  even  if  they  win  their  case,  but  need  to  start  a  new 
court procedure in the general courts to this end. The inquiry will also consider whether, in 
certain cases, individuals should be able to obtain reimbursement of legal costs in the context 

26   European Association of Judges (2024), Resolution concerning the Remuneration of Judges in Sweden. 
27   The salaries are based on a collective agreement between the National Courts Administration and the Trade 
Union representing judges which states that remuneration may never be based on grounds contradictory to 
the  interest  of  independence  regarding  the  application of  the  law.  The  agreement  sets  minimum  levels of 
pay. Swedish Government (2020), written input, pp. 7-8. 

28   2024 Rule of Law Report, Sweden, p. 10.  
29   Swedish Government (2025b).  
30   The right to judicial review is laid down in individual laws, for example in the Code of Judicial Procedure, 
the  Administrative  Procedure  Act  and  the  Administrative  Procedure  Act,  as  well  as  in a  large  number  of 
sectoral laws. Swedish Government (2025i), p. 68-69. 

31   Swedish Government (2025b). 
32   Swedish Government (2024b).  
33   In addition, individuals that qualify for the aid have to pay a legal aid fee between 2% and 40%. 2023 Rule 
of Law Report, Sweden, p. 9. The threshold for the amount of earned income remains at SEK 260 000 per 
year.  The  average  salary  in  Sweden  in  2023  was  approximately  EUR  43 464  (SEK  478 800).  Dagens 
Juridik (2025), "The Legal Aid Institute is a castle in the air and a threat to the rule of law 2.0". 

34   In this context, stakeholders referred to a report noting that public authorities or private bodies conferred a 
public function can also exclude the possibility of a judicial review or obtaining compensation for damage 
from  the  state  for  administrative  decisions  that  were  ruled  to  be  illegal.  Centrum  for  Rättvisa  (2025), 
Report: No chance against the authorities?; ENNHRI (2025). 

35   Judgment of the Supreme Administrative Court of 4 March 2022, case 6184-19.  

6 

 
 
of  a  case  before  an  administrative  court.  ..  The  inquiry  report  should  be  submitted  by  1 
August 2025. 

Efficiency 

The justice system continues to perform efficiently despite a peak of incoming cases in 
2024.  The  number  of  incoming  civil  and  commercial  litigious  cases  has  remained 
comparatively low in 2023, while the number of incoming administrative cases remains the 
highest among EU Member States. The estimated time needed to resolve litigious civil and 
commercial  cases  at  all  court  instances  remains  comparatively  short  (in  2023,  157  days  at 
first  instance,  108  days  at  second  instance  and  150  at  third  instance).  The  estimated  time 
needed to resolve administrative cases at all court instances was among the lowest among the 
Member States (in 2023, 83 days at first instance, 72 days at second instance and 86 at third 
instance). The clearance rate for civil and commercial litigious cases has decreased (97% in 
2023  compared  to  102%  in  2022)  yet  improved  for  administrative  cases  (105%  in  2023 
compared to 103% in 2022). The number of pending litigious civil and commercial cases at 
first instance is one of the lowest among Member States36. According to the National Courts 
Administration, in 2024, the courts had the highest ever number of incoming (507 851, an 8% 
increase compared to 2023) and decided cases (504 398, a 6% increase compared to 2023)37. 
The  increase  in  cases  has  been  most  marked  at  the  Supreme  Court,  where  the  number  of 
pending  cases  has  continued  the  negative  trend  (2 774  pending  cases  at  the  end  of  2024  as 
compared to 1 041 pending cases at the end of 2020)38.  

II. 

ANTI-CORRUPTION FRAMEWORK  

The perception among experts, citizens and business executives is that Sweden is one of 
the  least  corrupt  countries  in  the  world.  In  the  2024  Corruption  Perception  Index  by 
Transparency  International,  Sweden  scores  80/100  and  ranks  fourth  in  the  European  Union 
and  eight  globally39.  This  perception  has  deteriorated  over  the  past  five  years40.  The  2025 
Special  Eurobarometer  on  Corruption  shows  that  51%  of  respondents  consider  corruption 
widespread  in  their  country  (EU  average  69%)  and  12%  of  respondents  feel  personally 
affected by corruption in their daily lives (EU average 30%). As regards businesses, 45% of 
companies consider that corruption is widespread (EU average 63%) and 16% consider that 
corruption  is  a  problem  when  doing  business  (EU  average  35%).  Furthermore,  29%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 
practices  (EU  average  36%),  while  51%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 33%)41. 

The 2024-2027 Action Plan against corruption and undue influence is the main strategic 
document in the fight against public sector corruption and continues to be implemented. 
The  ‘Action  Plan  against  corruption  and  undue  influence  2024-2027’  was  adopted  in  July 

36   2025 EU Justice Scoreboard, figures 2, 3, 6, 8, 10, 11, and 13. 
37   National Courts Administration (2025), The annual report for 2024 is submitted to the Government.  
38   Swedish Supreme Court (2025), Activity report of the Supreme Court, p. 49. 
39   The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60), 

relatively high (between 59-50), high (below 50). 

40   In 2020 the score was 85, while, in 2024, the score is 80. 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. 

41   Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).  

7 

 
 
202442.  The  Agency  for  Public  Management,  with  its  expanded  and  more  permanent  anti-
corruption role, is implementing the main workstrands. These include further analysis of how 
Government  agencies  and  local  government  implement  their  anti-corruption  obligations,  as 
well as study work on the perception of corruption of government employees43. Linked to the 
new Action Plan, the Government has asked the OECD to conduct an integrity review44. Civil 
society  is  satisfied  with  the  broad  consultations  to  prepare  the  Action  Plan  as  well  as  its 
expanded  scope45  where  the  private  sector  was  not  involved46.  A  governmental  Anti-
Corruption Forum will propose recommendations by the end of 2025 on  how to  strengthen 
the Government’s policy to prevent corruption47.  

New  legislation  on  limitation  periods  was  adopted  and  the  Government  continues  to 
work on reviewing criminal law legislation in relation to corruption. A law proposed by 
the Government in  November 2024 to extend limitation periods for serious crimes – notably, 
from ten to fifteen years for serious bribery offences48 was adopted by Parliament in February 
2025 and entered into force in April 202549. The law also ensures that the imposition of an 
imprisonment sentence is not subject to limitation periods. The new confiscation regime that 
entered  into  force  in  November  2024  includes  the  possibility  to  confiscate  unexplained 
wealth.  The  committee  of  inquiry  established  in  February  202450  with  a  broad  mandate  to 
review criminal law legislation on corruption, continues its work. It is expected to present its 
recommendations by the end of July 2025. 

While the work of the relevant committee is ongoing, there has been no further progress 
on  the  recommendation  concerning  the  fight against  foreign  bribery  in  the  absence  of 
improvement  on  the  legal  definitions  and  the  prosecution  of  foreign  bribery  cases51. 
Legal  limitations,  including  as  regards  the  definition  of  foreign  bribery  and  the  liability  of 
legal persons persist and hinder enforcement, as again highlighted by the OECD in December 
202452.  Amending  the  applicable  legislation  in  relation  to  foreign  bribery  is  one  of  the 
objectives  of  the  committee  that  will  examine  criminal  law  legislation  in  the  fight  against 
corruption53.  Both  the  OECD  and  civil  society  doubt  that  enforcement  difficulties  can  be 
addressed  without  legislative  change54.  Difficulties  to  gather  the  necessary  evidence,  and 
complex  mutual  legal  assistance  requests  with  some  third  countries  further  hamper 
enforcement55. Therefore, as the legal definitions of foreign bribery remain limited and there 

42   2024 Rule of Law report, Sweden, pp. 12-13. 
43   Country visit Sweden, Agency for Public Management and Ministry of Finance; and Swedish Government 

(2025), written input, p. 33. 

44   Swedish  Government  (2025),  written  input,  p.  3. In  essence,  an  integrity  review  is  a  broad  review  of  the 

country’s preventative anti-corruption policies. 
45   Country visit Sweden, Transparency International. 
46   2024 Rule of Law Report, Sweden, p. 12-13. 
47   Country visit Sweden, Agency for Public Management. 
48   Gross giving of a bribe and gross taking of a bribe. 
49   Swedish Government (2025), written input, p. 7.  
50   2024 Rule of Law report, Sweden, pp. 13-14. 
51   The 2024 and 2023 Rule of Law Reports 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’. 

52   Sweden’s  insufficient  action  leaves  companies  unpunished  for  foreign  bribery  offences,  says  OECD 

Working Group on Bribery. OECD (2024a), p. 7 and OECD (2024b). 

53   2024 Rule of Law report, Sweden, p. 14. 
54   OECD  (2024a),  p.4,  OECD  (2024b)  and  Country  visit  Sweden,  Prosecution  Service  and  Transparency 

International. 

55   OECD (2024a), pp. 29-30 and Country visit Sweden, Prosecution Service. 

8 

 
 
is  no  improvement  in  the  prosecution  of  foreign  bribery  cases,  there  has  been  no  further 
progress on the recommendation made in the 2024 Rule of Law Report.  

The investigation and prosecution of corruption continues to achieve results, although 
law  enforcement  is  concerned  by  the  possible underreporting  of  corruption  cases.  The 
Prosecution Authority and the Police Authority consider that they have a sufficient level of 
resources56,  although  issues  over  the  staffing  and  performance  of  the  Police  Authority’s 
intelligence unit in corruption cases remain57. These authorities continue to have a generally 
good cooperation and achieve results in the fight against corruption. Data from the National 
Council for Crime Prevention indicates that, following an increase in reported bribery cases 
in 2023, reports have decreased to 76 cases for passive bribery and 67 cases for active bribery 
in  202458. In 2023, prosecutions  were initiated for 166 bribery offences and 50 convictions 
were obtained in bribery cases, with one resulting in imprisonment59. The Police assumes that 
the  actual  number  of  corruption  cases  is  much  higher  but  is  underreported,  citing  a  lack  of 
incentive  to  report  such  conduct,  for  example  at  local  level  or  in  the  private  sector60.  In 
addition,  the  phenomenon  of  “corruption  brokers”  –  where  brokers  act  as  middlemen 
searching  for  bribes  –  is  on  the  rise61.  A  new  financial  intelligence  centre,  based  on  the 
cooperation  between  the  Tax  Authority,  the  police  and  the  Economic  Crime  Authority  was 
set up on 1 April 2025 to better combat fraud, money laundering and the criminal economy. 
The authorities expect that the new setup could also help detect corruption62. Sweden joined 
the  European  Public  Prosecutor’s  Office  in  2024  and  the  prosecutors  report  good 
cooperation63.  

The  obligation  for  agencies  under  the  Government  to  prevent  corruption  is  now 
clarified in law, while some gaps in asset declaration for public officials remain. Sweden 
relies on a strong culture of transparency, where ethical guidance is decentralised, and each 
individual  ministry  and  Government  agency  is  responsible  for  its  own  ethical  guidelines64. 
The  obligation  for  each  agency  to  implement  a  corruption  prevention  policy  is  now  more 
clarified in law65. A handbook summarising guidance for top-level officials on topics such as 
conflicts  of  interest,  restrictions  when  leaving  office  and  rules  on  travel  is  available66.  The 
ethical guidelines for all civil servants of the Government Offices (Regeringskansliet) remain 
under revision without a clear timeline67. Asset declaration obligations of ministers and state 

56   Country visit Sweden, public prosecution service and Police Authority. See also 2024 Rule of Law Report, 

Sweden, pp. 14-15. 

57   2024 Rule of Law Report, Sweden, pp. 14-15 and Country visit Sweden, Public Prosecution Service. 
58   In 2022, there were 80 reports on passive bribery, whereas in 2023 the number of reports on passive bribery 
was  115.  For  active  bribery,  there  were  90  reports  in 2022  and  146  in  2023.  National  Council  for  Crime 
Prevention (2025) and Public Prosecution Service (2025). 

59   Overall,  there  were  72  convictions  and  2  cases  that  resulted  in  imprisonment  for  all  corruption  offences 

including bribery and trading in influence. Ibidem.  

60   Police National Anti-Corruption Unit (2024) and Country visit Sweden, Police Authority.  
61   This  includes  for  example  in  the  motor  vehicle  inspection  sector  or  the  financial  sector  (lending).  Police 

National Anti-Corruption Unit (2024) and Country visit Sweden, Police Authority. 

62   The centre should be fully operational by 31 December 2027. Swedish Government (2025), written input, p. 

4 and Country visit Sweden, Ministry of Finance and Economic Crime Authority. 

63   Swedish Government (2025), written input, p. 4. 
64   2024 Rule of Law Report, Sweden, pp. 16-17. 
65   Regulation clarifying the responsibilities of government managers in the prevention of corruption. It entered 

into force on 1 July 2025.  

66   GRECO Fifth evaluation round – second compliance report, recommendation ii, paragraphs 14-22.  
67   Country visit Sweden, Ministry of Justice and Ministry of Finance 

9 

 
 
secretaries68  do  not  include  information  on  significant  liabilities  or  information  on  their 
spouses  and  some  dependent  family  members69.  Various  categories  of  officials,  including 
senior law  enforcement officials, do not need to  declare assets70. The Government does not 
plan to further amend the asset declaration regime71, despite the pending recommendation of 
GRECO72. 

An all-party committee of inquiry recommended to introduce lobbying rules, including 
a  transparency  register.  There  are  still  no  rules  on  how  to  engage  with  lobbyists  and  on 
disclosure  of  lobbying  contacts,  as  also  noted  by  GRECO73.  An  all-party  committee 
mandated to  consider whether there is  a need to strengthen transparency regarding contacts 
between  political  decision-makers  and  lobbyists74  recommended  in  May  2025  that  the 
Government  should introduce  – for the first  time  – clear  rules on lobbying. In particular, it 
recommended  introducing  a  transparency  register  where  lobbyists  would  need  to  register 
their  contacts  with  the  political  level  three  times  per  year75.  The  Government  will  examine 
the report and announce a possible follow-up in the future. 

There has been no progress to follow up on the inquiry on rules on revolving doors, as 
the  Government  has  not  announced  any  action  in  response  to  the  report  of  the 
committee76. The Government continues to reflect on the results of the inquiry and has not 
yet  taken  any  position  on  future  legislative  (or  other)  changes  to  the  rules  on  revolving 
doors77. A committee of inquiry concluded in 2023 that the rules on revolving doors, while fit 
for  purpose,  should  be  amended,  for  example  to  extend  the  transitionary  restrictions  to  a 
wider  scope  of  individuals  namely  heads  of  Government  agencies,  and  to  allow  for  the 
possibility  to  widen  the  scope  to  lower-level  employees  executing  critical  functions78.  In 
2024,  the  Board  for  the  Examination  of  Transitionary  Restrictions  received  a  total  of  three 
reports.  The  Board  did  not  impose  restrictions  concerning  the  content  of  the  future 
employment in any of these cases79. Given that the Government is still examining the follow-

68   Ministers and state-secretaries are required to declare their financial interests; the declaration needs to be 
supported  by  statements  from  banks  and/or  stockbrokers.  These  are  checked  by  the  Government  Offices 
and  may  be  provided  to  the  public  upon  request  (GRECO  Fifth  evaluation  round  –  compliance  report, 
recommendation viii, paragraphs 50-52).  
69   2022 Rule of Law Report, Sweden, p. 11.  
70   As regards senior public officials, if it is necessary with regard to the existence of inside information within 
an  authority,  the  Government  may  decide  that  the  authority’s  management  must  report  their  holdings  of 
financial instruments. In such cases senior public officials at central level such as heads of central executive 
authorities, Secretaries-General, Directors-General, etc are covered. The authority may, in turn, decide that 
other employees and contractors that have access to inside information as a part of their employment must 
be covered by the same reporting obligations. See also 2024 Justice Scoreboard, Figures 60, 61, and 62. 

71   Country visit Sweden, Ministry of Justice. 
72   Reconfirmed  in  the  GRECO  Fifth  evaluation  round  –  Second  Compliance  report.  The  GRECO  Fifth 
Evaluation Round – Addendum to the Second Compliance Report confirmed that recommendation viii on 
the  control  of  asset  declarations  was  implemented,  while  the  recommendation  vii  on  the  inclusion  of 
significant  liabilities  and  declarations  for  spouses  and  dependent  family  members  remains  to  be 
implemented.  

73   Reconfirmed in the GRECO Fifth evaluation round –Second Compliance report. 
74   2024 Rule of Law Report, Sweden, pp. 17-18 . 
75   2023 Transparency Committee 
76   The  2024  Rule  of  Law  Report  recommended  to  Sweden  to  ‘‘ensure  the  appropriate  follow-up  to  the 

evaluation of the rules on revolving doors”. 

77   Country visit Sweden, Ministry of Justice and Ministry of Finance.  
78   2024 Rule of Law report, Sweden, p. 18.  
79   Board for the Examination of Transitionary Restrictions for Ministers and State Secretaries (2025).  

10 

 
 
up to its conclusions, there has been no progress on implementing the recommendation from 
the 2024 Rule of Law Report. 

An all-party committee of inquiry recommended reforms to the framework for political 
party  financing  to  increase  transparency.  An  all-party  committee  recommended  reforms 
following  a  review  of  the  transparency  of  financing  of  political  parties80.  The  committee 
recommended to completely prohibit anonymous donations and foreign contributions. It also 
recommended to introduce an obligation for parties to cover expenses, assets and debts (and 
not only income) in their financial disclosures81. The inquiry does not see the need to strictly 
regulate donations of trade unions to political parties, while providing some options on how 
this  could  be  achieved,  in  line  with  its  mandate82  The  Government  will  now  examine  the 
report  and  announce  a  possible  follow-up  in  the  future.  The  Legal,  Financial  and 
Administrative Services Agency (Kammarkollegiet), responsible for the oversight of political 
party  financing,  opened  a  total  of  10  enforcement  cases  in  202483.  The  political  party 
financing disclosures remain publicly available on the website of the Agency.  

The  2021  Whistleblowers  Act  continues  to  be  implemented,  although  some  issues  are 
noted with corruption-related reports84. The Police Authority received few whistleblower 
reports in relation to corruption allegations. The Authority considered that the general quality 
of reports was low – i.e. there is rarely sufficient actionable information for the Police to start 
an  investigation85.  Civil  society  considers  that  more  awareness-raising  is  needed,  as  people 
often report unrelated labour issues instead of submitting actionable whistleblower reports86. 

Measures  are  being  taken  to  address  the  risk  of  infiltration  of  the  public  service  by 
organised  crime  through  corruption,  such  as  the  adoption  of  legislation  to  strengthen 
background  checks  of  municipal  employees.  Businesses’  attitudes  towards  corruption  in 
the EU show that 32% of companies in Sweden (EU average 25%) think that corruption has 
prevented them from winning a public tender or a public procurement contract in practice in 
the  last  three  years87.  64%  of  companies  perceive  the  level  of  independence  of  the  public 
procurement  review  bodies  (administrative  courts)  as  very  or  fairly  good88.  The  Single 
Market and Competitiveness Scoreboard on access to public procurement in Sweden reports 
11% of single bids for 2023 (EU average 29%). Public procurement remains one of the main 
corruption  risk  areas,  which  is  being  addressed  in  the  new  Anti-Corruption  Plan89  and  the 
committee of inquiry focused on criminal law reforms related to corruption90. According to 
businesses,  high  local  and  regional  subsidiarity  results  in  fragmented  public  procurement 
processes,  and  the  system  shows  an  overall  lack  of  transparency91.  For  the  Government, 
addressing the possible infiltration of organised crime actors in the public service continues 

80   2024 Rule of Law Report, Sweden, pp. 18-19. 
81   2023 Transparency Committee.  
82   2023 Transparency Committee.  
83   The Legal, Financial and Administrative Services Agency (2025), pp. 69-70.  
84   Act on Protection of Persons who Report Wrongdoings, 2021:890.  
85   Country visit Sweden, Police Authority and Special Investigations Department.  
86   Country visit Sweden, Transparency International. 
87   Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is the same as 

the EU average. 

88   Figure 59, 2025 EU Justice Scoreboard. 
89   See above under section II. 
90   One  of  the  issues  under  discussion  is  how  to  better  address  corruption  in  public  procurement.  Swedish 

Parliament (2024). 

91   Country visit Sweden, Swedish Confederation of Industries. 

11 

 
 
to  be  a  major  strategic  priority92.  Local  authorities  are  particularly  vulnerable  due  to  their 
smaller scale despite a still large amount of funds managed93. This is a focus of the National 
Council  for  Crime  Prevention94.  Legislation  to  strengthen  background  checks  of  municipal 
employees  and  allowing  further  exchange  of  information  among  agencies  to  prevent  such 
infiltration  came  into  force  on  1  June  202595.  Further  analyses  are  ongoing  to  idenitfy  the 
extent of the risk96.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

The  independent  national  regulatory  authority,  the  Swedish  Agency  for  the  Media, 
deals with an increasing variety of tasks. The Agency considers to have adequate resources 
for  its  operations.  Its  financial  resources  were  increased  in  2024  to  address  new  functions, 
including those deriving from the Digital Services Act97. It has also started new tasks linked 
to the promotion of media and information literacy and the safety of journalists. In parallel, 
the  Agency  has  received  and  processed  applications  for  financial  support  under  the  Media 
Subsidies  Act  and  has  been  tasked  to  analyse  the  impact  of  the  support98.  The  envisaged 
temporary support scheme helping current affairs and news journals to  adapt to new digital 
market conditions has been discarded. This is because a public consultation revealed a need 
for  more  permanent  support  with  a  larger  scope99.  The  MPM  2025  continues  to  maintain  a 
very low risk regarding the independence and effectiveness of the media authority100. 

The  Government  is  preparing  to  renew  the  periodic  public  service  mission  with  new 
rules  for  independence  of  public  service  media.  The  Government  is  working  on  the 
upcoming  renewal  of  the  public  service  mission  2026-2033.  A  Government  bill  on  a  new 
Public  Service  Act,  including  amendments  to  the  existing  Radio  and  Television  Act  was 
submitted to the Parliament in May 2025101. The objectives of the new Act include to further 
clarify the remit of the public service mission, financing, the appointment of board members 
and the chief executive officer, and the conditions for content not directly related to television 
or radio broadcasting in the terrestrial network102. The reform also aims to align the national 
legislation  with  the  European  Media  Freedom  Act,  including  in  respect  of  independence 

92  2024 Rule of Law Report, Sweden, pp. 15-16 and Swedish Government (2025), written input, pp. 3-5.  
93   Country  visit  Sweden,  Economic  Crime  Authority  and  Public  prosecution  service;  and  Police  National 

Anti-Corruption Unit (2024), p. 2. 

94   In framework of the plan, the Agency for Public Management will carry out work regarding the protection 
of local elected officials and the prevention of corruption through internal control mechanisms at local and 
regional level. The Agency for Public Management and National Council for Crime Prevention will support 
the  work  against  undue  influence  in  the  public  administration.  It  will  do  so  by  creating  and  evaluating 
support materials and increasing awareness of the phenomenon, and report to the Government on its work 
by  May  2026  Country  visit  Sweden,  Agency  for  public  management  and  Swedish  Government,  written 
input, pp. 3-5. 

95  Ministry of Justice (2024) and Ministry of Justice (2025b). 
96   The National Council for Crime Prevention published a report on how system-threatening actors use illicit 
influence  against  politically  elected  representatives.  The  Swedish  Association  of  Local  Authorities  and 
Regions (SKR) has been given a similar task regarding regions and municipalities and submitted a report in 
March 2025.  

97   This increase was by approximately €562 900 (SEK 6.2 million). 
98   Swedish Agency for the Media (2025a), Swedish Agency for the Media (2024b) and Swedish Agency for 

the Media (2025b); Swedish Government (2025h). 

99   Swedish Government (2025c). 
100   2025 Media Pluralism Monitor, country report for Sweden, p. 10. 
101 Swedish Government (2025g). 
102   Swedish Government (2025a), written input, p. 10. 

12 

 
 
requirements.  The  Government  bill  also  includes  proposals  on  guidelines,  conditions  and 
funding  for  public  service  media  in  2026–2033103.  While  the  objectives  of  the  reform  are 
generally welcomed, public service media in Sweden have expressed concerns about some of 
the preliminary proposals made by the dedicated parliamentary committee’s report104, as they 
see  risks  to  their  independence.  These  are  related  to  the  sufficiency  of  the  public  service 
media’s future funding and ensuring an unbiased analysis of their productivity, impartiality 
and  efficiency105.  Other  stakeholders  have  asked  for  more  thorough  consideration  of  the 
sustainability of financing106. Increasing statements regarding an alleged lack of impartiality 
in  public  service  media  were  mentioned  as  a  growing  risk107.  The  MPM  2025  continues  to 
report a very low risk concerning the independence of public service media108. 

The  Government  plans  to  reform  the  licensing  of  commercial  radio  channels.  The 
Government  continues  to  work  on  a  proposal  aiming  to  set  conditions  for  revoking 
broadcasting licenses where there is a risk to national security109. In parallel, a Government 
bill  has  been  submitted  to  the  Parliament  that  aims  to  reform  the  licensing  of  commercial 
radio channels.  The proposed amendments in the Radio and Television Act aim to improve 
the  long-term  sustainability  of  commercial  radio  operations  and  support  independent  media 
by  having  the  same  tendering  procedure  for  the  licencing  of  both  analogue  and  digital 
commercial  radio  channels.  The  new  rules  would  also  replace  the  current  upfront 
broadcasting fee with  an annual fee based on the market value of the licence and is  largely 
supported  by  Swedish  media  stakeholders110.  A  mapping  prepared  by  the  Swedish  Agency 
for  the  Media  and  research  carried  out  by  an  academic  knowledge  centre  show  that  media 
ownership  of  radio,  television,  streaming  and  daily  newspapers  is  becoming  increasingly 
concentrated111. The MPM 2025 continues to give a high-risk score for the plurality of media 
providers in Sweden112. 

The  access  to  documents  framework  has  been  adjusted  to  counter  the  misuse  of 
transparency by organised crime. Legislation on access to documents generally guarantees 
wide  availability  of  information  and  the  MPM  2025  maintains  a  low  risk  in  the  field  of 
protection of the right to information113. New exceptions to the right to information have been 
introduced  to  the  Public  Access  to  Information  and  Secrecy  Act  to  counter  the  misuse  of 
transparency by organised crime and further amendments are under discussion114. Journalists 
considered that the amendments have collectively, to some extent, decreased the traditionally 
high level of transparency115. In November 2024, an inquiry presented its report on enhanced 
protection  of  personal  data  in  the  area  of  freedom  of  the  press  and  freedom  of  expression, 

103   Country visit, Ministry of Culture. 
104   Swedish Government (2024c). 
105  Country visit, Swedish  Television (SVT), Swedish Radio (SR) and Swedish Educational Radio (UR); SR 

(2024); Public Media Alliance (2024). 

106   Swedish Union of Journalists (2024), Swedish Financial Management Agency (2024). 
107   Country visit Sweden, Media ombudsman and SVT. 
108   2025 Media Pluralism Monitor, country report for Sweden, p. 19. 
109   2024 Rule of Law Report, Sweden, p. 21; Country visit, Ministry of Culture and the Swedish Agency for 

the Media. 

110   Swedish  Government  (2025e),  Swedish  Government  (2025a),  written  input  p.  10-11;  Country  visit, 

Ministry of Culture. 

111   Swedish Agency for the Media (2024a); Nordicom (2024). 
112   2025 Media Pluralism Monitor, country report for Sweden, pp. 15-16. 
113   2024 Rule of Law Report, Sweden, p. 22; 2025 Media Pluralism Monitor, country report for Sweden, p. 12. 
114   Swedish Government (2025k); Swedish Government (2024g); Swedish Government (2024d). 
115   Swedish Union of Journalists (2025); Country visit, Swedish Union of Journalists. 

13 

 
 
proposing constitutional amendments regarding the private sector search services that publish 
personal  data.  This  concerns  personal  data  available  about  violations  of  the  law,  as  well  as 
individuals’  addresses,  telephone  numbers,  marital  status  and  other  data  relating  to  their 
personal circumstances116. Sweden has ratified the Council of Europe Convention on Access 
to Official Documents117.  

The  overall  conditions  for  journalists  remain  favourable  and  the  Swedish  Agency  for 
the Media has been tasked to monitor the safety of journalists.  Due to its constitutional 
protection, the MPM 2025 deems the protection of freedom of expression to carry a low-risk 
score  in  Sweden.  Furthermore,  journalists  in  Sweden  have  generally  good  working 
conditions118.  To  support  journalists  further,  the  Swedish  Agency  for  the  Media  has  been 
officially assigned an ongoing task to monitor journalists’ safety119. In autumn 2024, it held 
seven dialogues with relevant stakeholders120. A specific report on the state of play regarding 
the  safety  of  journalists  was  adopted,  mapping  relevant  research,  legal  and  societal 
initiatives121.  The  Government  continues  to  financially  support  the  non-profit  organisation 
Victim  Support  Sweden  to  offer  help  to  journalists  and  other  media  workers  who  need 
protection122. In addition, the Government has decided to increase its support to organisations 
that  support  independent  journalists  around  the  world,  including  through  the  Reporters 
Shield, an international initiative123. Since the 2024 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  journalists124.  They  concern  the  vandalisation  of  the  building  of  the  Swedish 
Public Broadcaster SVT and a protest outside the home of a Swedish journalist. The Mapping 
Media Freedom monitoring report has identified nine alerts125. Besides the above-mentioned 
incidents,  these  alerts  concern  surveillance  and  harassment  of  certain  journalists  with 
threatening  emails  and  vandalisation  of  the  reception  area  of  the  editorial  offices  of  three 
private  newspapers.  The  police  and  media  publishers  have  continued  their  cooperation  to 
prevent crimes against journalists, with calls to do more126. 

IV. 

OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Some  stakeholders  express  concern  about  the  acceleration  of  legislative  preparatory 
work,  which  they  consider  poses  challenges  to  public  participation.  In  2024,  the 
Government  launched  304  public  consultations  on  legislative  initiatives.  The  average 
deadline  for  these  public  consultations  was  12.7  weeks127.  As  required  by  the  Constitution, 
the Government refers a report of a committee of inquiry for public consultation to relevant 

116   Swedish Government (2024h). 
117   Council  of  Europe  Convention  on  Access  to  Official  Documents  (CETS  No.  205),  also  known  as  the 

Tromsø Convention, entered into force on1 December 2020. 
118   2025 Media Pluralism Monitor, country report for Sweden, p. 11. 
119   Swedish Government (2025a), written input p. 11; Swedish Agency for the Media (2025c). 
120   Country visit Sweden, Ministry of Culture; Swedish Agency for the Media (2025b). 
121   Swedish Agency for the Media (2025c). 
122   Swedish Government (2025a), written input p. 11. 
123   Swedish Government (2024e); 2025 Media Pluralism Monitor, country report for Sweden, p. 5. 
124   Council of Europe, Platform to promote the protection of journalism and safety of journalists. Sweden has 

responded to one of the two alerts. 

125   European Centre for Press and Media Freedom, Media Freedom Rapid Response – Sweden. 
126   Country visit, Swedish Publishers’ Association, Swedish Union of Journalists. 
127   The shortest identified consultation period was two days, whereas the second and third shortest consultation 
periods  were  one  week.  The two  longest  consultation periods  were  20  weeks  long.  Swedish  Government 
(2025a), written input.  

14 

 
 
bodies,  municipalities  and  counties,  as  well  as  from  organisations  and  individuals128.  Some 
civil society stakeholders are concerned that the pace of legislative change makes it difficult 
to have an overview of initiatives across different sectors, as well as impacting on the quality 
of  legislation  and  due  consideration  for  human  rights.  Stakeholders  also  considered  that 
contrary to the established national practice, the terms of reference for inquiries increasingly 
tend  to  pre-determine  the  desired  outcome  of  the  inquiry129.  Since  February  2024,  the 
Government  also  used  shortened  inquiry  times  for  nine  legislative  initiatives  considered 
urgent and politically important, which overall take about 10-12 months from the launch of 
an inquiry until a proposal is presented to Parliament130. As far as constitutional checks are 
concerned,  in  2024,  the  Government  submitted  118  legislative  proposals  to  the  Council  on 
Legislation,  which  gave  a  negative  opinion  or  seriously  questioned  15  proposals.  In  four 
cases, the Government partially adjusted the proposals before them to Parliament, whereas in 
six cases the Government submitted the proposals without any adjustments131.  

Over  two  thirds  of  the  companies  surveyed  in  Sweden  express  confidence  in  the 
effectiveness of investment protection. 76% of companies are very or fairly confident that 
investments are protected by law and courts132. As regards authorities relevant for economic 
operators, 68% of companies perceive the level of independence of the national competition 
authority  (the  Competition  Authority)  as  very  or  fairly  good133.  There  are  no  judicial 
mechanisms  in  place  at  the  level  of  the  Supreme  Administrative  Court  to  ensure  the 
implementation of administrative court judgments134. 

The  Government  presented  a  proposal  amending  the  Constitution  to  provide  a 
framework to better deal with serious crises. On 5 June 2025, the Government presented 
proposals for constitutional amendments aiming to strengthen the constitutional preparedness 
and ensure an  effective,  democratic  and legal  governance in  war and other severe  crises135. 
The  Government  proposes,  among  other,  specific  rules  on  adopting  provisions  in  serious 

128   Swedish Government (2025a), written input. 
129   Liberties  (2025),  p.  20-21.  Country  visit  Sweden,  National  Forum  of  Voluntary  Organisations,  Swedish 
Institute  for  Human  Rights,  Civil  Rights  Defenders  and  the  Swedish  Section  of  the  International 
Commission  of  Jurists.  In  general,  civil  society  organisations  see  a  continued  reduction  in  Government 
interest in civil society consultations. Forum (2025), written input. ENNHRI (2025). 

130   2024 Rule of Law Report, Sweden, p. 25. The time for public consultations varies depending on the scope 
of  the  proposals  and  the  urgency  of  the  issue  but  is  normally  set  to  three  months  and  the  pre-legislative 
inquiry  is  normally  shortened  to  six  months.  This  procedure  is  used  for  initiatives  that  i)  are  considered 
urgent from a political perspective and could lead to significantly negative consequences for society if the 
Government  would  not  act  quickly,  ii)  can  be  managed  through  a  well-defined  assignment  with  a  clear 
focus,  and  iii)  need  to  be  dealt  with  more  urgently  than  within  the  time  deemed  necessary  through  the 
application of ordinary working methods. Swedish Government (2025a), written input. 

131   In the five remaining cases, the Government submitted a proposal that had been adjusted in accordance with 
the  views  of  the  Council on Legislation.  Where  it did  not  adjust  the  proposals  based  on  the  views  of  the 
Council on Legislation, the Government put forward arguments to the Parliament in support of its position. 
Swedish Government (2025a), written input. 

132   Figure 54, 2025 EU Justice Scoreboard. Only 8% and 5% of the surveyed investors  respectively perceive 
the frequent changes in legislation or concerns about the quality of the law-making process, and the quality, 
efficiency  or  independence  of  justice,  respectively,  as  a  reason  for  the  lack  of  confidence  in  investment 
protection. 

133   Figure 60, 2025 EU Justice Scoreboard. 
134   Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at 
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower 
instance administrative courts. 

135  Swedish Government (2025l), Strengthened Constitutional Preparedness. 

15 

 
 
peacetime crises to  be introduced in  the Constitution,  which would allow the Parliament, if 
needed,  to  grant  the  Government  specific  powers  to  adopt  provision136.  It  is  also  proposed 
that  the  possibilities  for  the  Parliament  to  convene  in  difficult  situations  should  be 
strengthened.  The  proposal  is  based  on  an  all-party  committee  report.  The  constitutional 
amendments should enter into force on 1 January 2027. 

The  Government  presented  a  proposal  to  strengthen  the  procedure  for  amending  the 
Constitution. On 29 April 2025, the Government presented a proposal on the procedure for 
amending  the  Constitution  based  on  the  proposals  of  the  2020  committee  of  inquiry.  At 
present, the Parliament can amend the Constitution by passing two identically worded votes 
in  favour  by  simple majority,  whereby  a  parliamentary  election  (ordinary  or  early  election) 
must be held  between the first  and second vote.  To strengthen the protection of democracy 
and, in line with a proposal of the 2020 committee of inquiry, the Government proposed that 
more than half of the members of Parliament must vote in favour of the first and second vote 
(quorum) and a two-thirds majority in the Parliament should be required for the second vote 
to  amend  the  Constitution.  The  proposal  to  amend  these  constitutional  rules  is  based  on  a 
unanimously  endorsed  report  of  the  2020  committee  of  inquiry.  The  constitutional 
amendments should enter into force on 1 April 2027137. 

The National Human Rights Institution has obtained an A-status accreditation and the 
Parliamentary Ombudsmen discharge their mandates effectively. The Swedish National 
Human Rights Institute has had adequate funds to carry out its ongoing level of operations, 
but it considers the funds would need to be gradually increased to allow it to completely fulfil 
its  mandate138.  In  November  2024,  the  Institute  obtained  an  A-status  accreditation  by  the 
Global Alliance of National Human Rights Institutions (GANHRI)139. In December 2024, the 
Government  appointed  two  new  members  to  the  Institute’s  Governing  Board140.  However, 
the  Institute  expressed  concerns  that  the  Government’s  appointment  process  had  not 
sufficiently  safeguarded  the  Institute’s  independence.  In  accordance  with  the  relevant  legal 
provisions,  the  Swedish  Bar  Association,  universities  and  colleges,  and  the  Institute’s 
Advisory Council were invited to submit nominations. The Government chose not to appoint 
any  of  the  candidates  nominated  by  the  Advisory  Council,  and  one  of  the  individuals  the 
Government  appointed  was  not  nominated  by  any  of  the  nominating  bodies.  GANHRI 
recommended  to  Sweden  to  strengthen  the  protection  of  the  Institute’s  independence  by 
clarifying  the  rules  for  the  appointment  of  Board  members141.  The  Parliamentary 

136   2024 Rule of Law Report, Sweden, p. 21. 
137   Swedish  Government  (2025f),  Strengthening  the  protection  of  democracy  and  the  independence  of  the 
judiciary.  The  Government  also  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 rights (presently this applies only to constitutional amendments in the area of freedom of the 
press and freedom of expression).  

138   The Swedish Institute for Human Rights was allocated approximately EUR 4.58 million (SEK 53.8 million) 

for the full year 2025. Swedish Government (2025), written input, p. 12. ENNHRI (2025). 

139   Country visit Sweden, Swedish Institute for Human Rights. 
140   Swedish  Institute  for  Human  Rights  (2024a),  The  Government  has  appointed  two  new  members  to  the 
Agency's  Board  of  Directors.  The  Swedish  Institute  for  Human  Rights  is  led  by  a  Governing  Board 
consisting of the Director agency and seven other members; the latter are appointed by the Government for 
a period of five years. The term of two members expired at the end of 2024 and the Government appointed 
the new members for the period 2025-2029.  

141   Swedish Institute for Human Rights (2024b), The government's appointment process raises concerns about 
the  institute's  independence.  The  Swedish  Bar  Association  refrained  from  nominating.  The  Governing 
Board did not make any judgement on the qualifications of the individuals appointed by the Government.  

16 

 
 
Ombudsmen consider that they have adequate resources and report good cooperation142 with 
and  adequate  follow-up  given  by  public  authorities  to  their  recommendations.  In  2024,  the 
complaints to the Parliamentary Ombudsmen increased by around 11% to 11 703 in total, the 
highest number in the history of that body143.  

On 1 January 2025, Sweden had 1 leading judgment of the European Court of Human 
Rights pending implementation, the same number as the previous year144. At that time, 
Sweden’s rate of leading judgments from the past 10 years that had been implemented was at 
86%  (compared  to  90%  in  2024;  14%  remained  pending),  and  the  average  time  that  the 
judgments had been pending implementation was 3 years and 7 months (compared to 2 years 
and 7 months  in  2024)145. The only  leading  judgment,  pending  implementation  for 4 years, 
concerned  insufficient  safeguards  in  bulk  signals-intelligence  gathering146.  As  regards  the 
respect  of  payment  deadlines,  on  31  December  2024  there  were  no  cases  awaiting 
confirmation  of  payments  (same  as  in  2023)147.  On  16  June  2025,  there  were  no  leading 
judgments pending implementation left148.  

There was significant progress on the recommendation concerning the legal framework 
for the funding and operation of civil society organisations, which entered into force in 
2025149. On 1 January 2025, the rules concerning a new “democracy condition”150 applying 
to  the state’s support to  religious communities and to  support from  the  General  Inheritance 
Fund,  entered  into  force.  With  this  condition,  the  Government  aims  to  ensure  that 
organisations or associations that promote extremism, undermine democracy or act contrary 
to  the  fundamental  values  of  society  do  not  receive  public  funds.  It  has  been  working  on 
introducing the new “democracy condition” in the grant regulations that regulate support to 

142   Parliamentary  Ombudsmen  (2023)  Report  of  the  Parliamentary  Ombudsmen,  p.  18.  In  2024  in  two 
instances, the Parliamentary Ombudsmen have however criticised the Prosecution Authority and the Police 
Authority for having failed to live up to constitutional obligations to assist the Ombudsmen. Decisions in 
cases 2478-2023 and 5614-2023. In order for the Parliamentary Ombudsmen to fulfil their tasks, they need 
access  to  accurate  and  complete  information.  The  Parliament’s  Constitution  Committee  underlined  the 
importance  of  always  complying  with  the  constitutional  obligation  to  provide  the  Ombudsmen  with 
information and opinions at their and to assist them in their investigations. 

143   Parliamentary Ombudsmen (2024), Report of the Parliamentary Ombudsmen 2024, p. 10. 
144   For an explanation of the supervision process, see the website of the Council of Europe.   
145   All figures calculated by the European Implementation Network (EIN) and based on the number of cases 
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 8-9. 
146   Judgment of the ECtHR, 35252/08, Centrum for Rattvisa v. Sweden, pending implementation since 2021.  
147   Council of Europe (2025), p. 157.   
148   Data according to the online database of the Council of Europe (HUDOC). 
149   The 2024 Rule of Law Report recommended to  Sweden to “continue efforts to ensure that the reforms to 
the legal framework for the funding and operation of civil society organisations do not unduly affect civil 
society engagement”. 

150   MUCF (2024), On 1 January 2025, new conditions for democracy will begin to apply to those who apply 
for state grants. An organisation’s purpose needs to be compatible with the values  of a democratic society 
and it needs to be democratically organised, respect  the ideas of democracy in its activities, including the 
principles of equality and non-discrimination. A grant may not be awarded if, in the course of its activities, 
the  organisation  or  any  of  its  representatives:  1)  uses  violence,  coercion  or  threats  against  a  person  or 
otherwise violates a person's fundamental rights and freedoms; 2) discriminates against persons, groups or 
otherwise violates the principle of equality; 3) defends, promotes or encourages the behaviour under 1) or 
2);  or  4)  opposes  the  democratic  system  of  government.  Support  may  also  not  be  granted  if  one  of  its 
partner organisations, or a representative of the partner organisation, is acting in a manner referred to under 
1). If an organisation, its representatives, its partner organisation or its representatives have acted in such a 
way that they do not meet the conditions of democracy, they can still be awarded a grant subject to specific 
reasons.  

17 

 
 
civil  society151.  Such  conditions  were  outlined  before  in  the  various  regulations  on 
Government  funding and the new rules aim to apply a uniform condition. The Government 
has also provided the Swedish Agency for Youth and Civil Society (MUCF), with resources 
to support grant-giving bodies in providing grants in a uniform way and to meet the needs of 
civil society152. Stakeholders have highlighted that it will be important to ensure that the new 
rules  are  implemented  in  a  predictable  and  objective  manner  153.  Considering  that  the  new 
rules regarding the funding and operation of civil society organisations came into force and 
are being progressively implemented, there has been significant progress.  

The civil society space remains open. Sweden is considered to have an open civic space154, 
which is overall functioning well155. However, stakeholders have expressed concerns related 
to the increasing uncertainty in public funding, notably in view of the defunding and funding 
cuts to certain organisations 156.  

151   Swedish Government (2025a), written input, p. 13-14. 
152   ENNHRI (2025) 
153   Country visit Sweden, National Forum of Voluntary Organisations, Swedish Institute for Human Rights and 

Civil Rights Defenders. 

154   According  to  the  rating  by  CIVICUS.  Ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed, 

obstructed, repressed and closed. 

155   Country  visit  Sweden,  National  Forum  of  Voluntary  Organisations,  Civil  Rights  Defenders,  Swedish 

Institute for Human Rights. 

156   As  reported  already  in  the  2024  Report,  stakeholders  referred  to  the  continued  impacts  in  view  of  the 
defunding of certain organisations and funding cuts to organisations involved in development cooperation 
student associations, or consumer associations. 2024 Rule of Law Report, Sweden, p. 27. ForumCiv (2024).   

18 

 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2024 Rule of Law report 
can 
https://commission.europa.eu/publications/2025-rule-law-report-targeted-
found 
stakeholder-consultation_en.. 

be 

at 

Board  for  the  Examination  of  Transitionary  Restrictions  for  Ministers  and  State  Secretaries  (2025) 
Report on the activities of the Board for reviewing the transfer restrictions of  ministers and certain 
other officials in 2024, https://data.riksdagen.se/fil/594AB75B-3209-4A15-8502-78CD48461AD4 

Centre for Media Pluralism and Media Freedom, Monitoring Media Pluralism in the Digital Era in the 
year 2024 (2025) Country report: Sweden. 

Centrum  for  Rättvisa  (2025),  Report:  No  chance  against  the  authorities?  (rapport  :  Chanslös  mot 
myndigheterna?), https://centrumforrattvisa.se/ny-rapport-chanslos-mot-myndigheterna/  

Council  of  Europe  Convention  on  Access  to  Official  Documents  (CETS  No.  205)  (2025), 
https://www.coe.int/en/web/conventions/full-list?module=signatures-by-treaty&treatynum=205. 

Dagens Juridik (2025), The Legal Aid Institute is a castle in the air and a threat to the rule of law 2.0, 
2.0), 
och 
(Rättshjälpsinstitutet 
https://www.dagensjuridik.se/opinion/rattshjalpsinstitutet-ar-ett-luftslott-och-ett-hot-mot-
rattssakerheten-2-0/ 

rättssäkerheten 

hot  mot 

luftslott 

ett 

ett 

är 

ENNHRI (2025), Sweden Country Report, https://rule-of-law.ennhri.org/node/270.  

European  Association  of  Judges  (2024),  Resolution  concerning  the  Remuneration  of  Judges  in 
Sweden, 
https://www.iaj-uim.org/iuw/wp-content/uploads/2024/10/EAJ-Resolution-on-the-
remuneration-of-judges-in-Sweden.pdf 

European Centre for Press and Media Freedom, Media Freedom Rapid Response – Sweden. 

European  Commission  (2024),  Sweden  officially  joins  the  European  Public  Prosecutor’s  Office, 
https://ec.europa.eu/commission/presscorner/detail/en/mex_24_3822 

European Commission (2025), EU Justice Scoreboard. 

European  Court  of  Human  Rights,  Judgment  of  25  May  2021,  Centrum  for  Rattvisa  v.  Sweden, 
35252/08. 

European Implementation Network (2025), Contribution from the European Implementation Network 
for the 2025 Rule of Law Report. 

Forum (2025), Contribution from Forum for the 2025 Rule of Law Report. 

Forumciv (2024), The government's reform of Swedish development assistance is hitting non-profit 
organisations  hard  (Regeringens  reform  av  det  svenska  biståndet  slår  hårt  mot 
ideella 
organisationer), https://forumciv.org/sv/Tidoattacken   

GRECO  Fifth  Evaluation  Round  –  Second  Compliance  Report,  15  November  2023, 
https://rm.coe.int/fifth-evaluation-round-preventing-corruption-and-promoting-integrity-i/1680ad4732  

GRECO  Fifth  Evaluation  Round  –  Addendum  to  the  Second  Compliance  Report,  3  April  2025, 
https://rm.coe.int/grecorc5-2025-3-final-eng-add-to-the-2nd-compliance-report-sweden-
publ/1680b50a94  

19 

 
Legal,  Financial  and  Administrative  Services  Agency 
https://www.kammarkollegiet.se/download/18.4f1f8bef194d33448f95256a/1740400141885/Kammar
kollegiets%20%C3%A5rsredovisning%202024.pdf  

(2025),  Annual  Report  2024,  

Liberties (2025), Rule of Law Report, https://www.liberties.eu/f/vdxw3e 

Ministry  of  Justice  (2024),  Extended  register  checks  when  hiring  in  the  municipality  (Utökade 
registerkontroller 
https://www.regeringen.se/rattsliga-
dokument/departementsserien-och-promemorior/2024/10/ds-202424 

anställning 

kommun), 

vid 

i 

Ministry  of  Justice  (2025a),  Government  gives  additional  directives  to  the  2023  Transparency 
Committee 
insynskommitté), 
tilläggsdirektiv 
https://www.regeringen.se/pressmeddelanden/2025/01/regeringen-ger-tillaggsdirektiv-till-2023-ars-
insynskommitte/ 

(Regeringen 

2023 

ger 

års 

till 

Ministry  of  Justice  (2025b),  Increased  opportunities  for  register  checks  to  combat  corruption  and 
illicit advocacy (Utökade möjligheter till registerkontroller för att bekämpa korruption och otillåten 
påverkan), 
https://www.regeringen.se/pressmeddelanden/2025/05/utokade-mojligheter-till-
registerkontroller-for-att-bekampa-korruption-och-otillaten-paverkan/  

MUCF (2024), On 1 January 2025, new conditions for democracy will begin to apply to those who 
apply  for  state  grants  (Den  1  januari  2025  börjar  nya  demokrativillkor  att  gälla  för  dig  som  söker 
statsbidrag) 
https://www.mucf.se/om-oss/aktuellt/den-1-januari-2025-borjar-nya-demokrativillkor-
att-galla-dig-som-soker-statsbidrag  

National  Courts  Administration 
innehall/rapporter/redovisning_en-saker-och-effektiv-tillgang-till-rattsinformation.pdf  

(2025a),  https://www.domstol.se/globalassets/filer/gemensamt-

National Courts Administration (2025b), The annual report for 2024 is submitted to the Government, 
https://www.domstol.se/domstolsverket/nyheter/2025/02/arsredovisningen-for-2024-lamnas-till-
regeringen/  

National  Council  for  Crime  Prevention  (2025),  Contribution  from  the  National  Council  for  Crime 
Prevention for the 2025 Rule of Law Report. 

Nordicom 
https://www.nordicom.gu.se/en/latest/news/media-market-concentration-increases-sweden  

concentration 

increass 

(2024), 

market 

Media 

in 

Sweden, 

(2024a), 

OECD 
https://www.oecd.org/en/publications/2024/12/oecd-anti-bribery-convention-phase-4-report-on-
sweden_ac496ae1.html 

Anti-Bribery 

Convention 

Report 

OECD 

Phase 

4 

Sweden, 

OECD  (2024b),  Sweden’s  insufficient  action  leaves  companies  unpunished  for  foreign  bribery 
activities  says  OECD  Working  Group  on  Bribery,  https://www.oecd.org/en/about/news/press-
releases/2024/12/sweden-s-insufficient-action-leaves-companies-unpunished-for-foreign-bribery-
offences-says-oecd-working-group-on-bribery.html 

Parliamentary Ombudsmen (2023), Report of the Parliamentary Ombudsmen (Justitieombudsmännens 
ämbetsberättelse), https://data.riksdagen.se/fil/C56AFFE2-75F7-45A6-AA48-5AA2F1897E92 

Parliamentary  Ombudsmen 
the  Parliamentary  Ombudsmen  2024 
(Justitieombudsmännens  ämbetsberättelse  2024),  https://data.riksdagen.se/fil/F16AE8EA-EF61-
40E9-B9CA-1BFAB601A753 

(2024),  Report  of 

20 

 
Police  National  Anti-Corruption  Unit  (2024),  Annual  Report  of  the  National  Anti-Corruption  Unit, 
https://polisen.se/siteassets/dokument/ovriga_rapporter/korruption-i-sverige---en-lagesbild-arsrapport-
fran-nationella-anti-korruptionsgruppen.pdf 

Public  Media  Alliance  (2024),  Sweden:  Public  media  fear  funding  proposal  is  “insufficient”, 
https://www.publicmediaalliance.org/sweden-public-media-describe-funding-proposal-as-
insufficient/. 

Public  Prosecution  Service  (2025),  Contribution  from  the  Public  Prosecution  Service  for  the  2025 
Rule of Law Report. 

Supreme Administrative Court, Judgment of 4 March 2022, case 6184-19. 

Supreme  Court  (2025),  Activity  report  of 
VERKSAMHETSBERÄTTELSE), 
https://www.domstol.se/globalassets/filer/domstol/hogstadomstolen/verksamhetsberattelser/hogsta-
domstolens-verksamhetsberattelse-2024.pdf 

the  Supreme  Court  (HÖGSTA  DOMSTOLENS 

Swedish Agency for the Media (2024a), The  media map of the Swedish Agency for the Media shows 
an  increasing  concentration  of  ownership  (Mediemyndighetens  mediekarta  visar  på  en  ökande 
https://mediemyndigheten.se/nyhetsrum/nyhetslista/2024/mediemyndighetens-
ägarkoncentration), 
mediekarta-visar-pa-en-okande-agarkoncentration/. 

Swedish  Agency  for  the  Media  (2024b),  191  applications  for  media  support  (191  ansökningar  om 
https://mediemyndigheten.se/nyhetsrum/nyhetslista/2024/191-ansokningar-om-
mediestöd), 
mediestod-for-2025/  

Swedish Agency for the Media (2025a), Contribution from the Swedish Agency for the Media for the 
2025 Rule of Law Report. 

Swedish  Agency 
https://mediemyndigheten.se/nyhetsrum/nyhetslista/2025/forsta-verksamhetsaret-for-
mediemyndigheten---arsredovisning-2024/. 

(2025b),  Annual  Report  2024 

the  Media 

for 

(Årsredovisning  2024), 

– 

Swedish  Agency  for  the  Media  (2025c),  Journalists’  Safety  –  Knowledge  Overview  (Journalisters 
säkerhet 
https://mediemyndigheten.se/globalassets/rapporter-och-
analyser/2025/journalisters-sakerhet--en-kunskapsoversikt.pdf, 
https://mediemyndigheten.se/globalassets/rapporter-och-analyser/2025/journalisters-sakerhet--en-
kunskapsoversikt.pdf. 

kunskapsöversikt) 

En 

Swedish  Financial  Management  Agency  (2024),  Public  service  in  troubled  times  (Public  service  i 
oroliga 
tider), 
https://www.regeringen.se/contentassets/1ea637356799430dbc3c8a44b10ed531/ekonomistyrningsver
ket.pdf. 

Swedish Government (2023a), Secure and efficient access to legal information (Uppdrag om en säker 
och 
rättsinformation),  
https://www.regeringen.se/regeringsuppdrag/2023/12/uppdrag-om-en-saker-och-effektiv-tillgang-till-
rattsinformation/https://www.regeringen.se/regeringsuppdrag/2023/12/uppdrag-om-en-saker-och-
effektiv-tillgang-till-rattsinformation/ 

tillgång 

effektiv 

till 

Swedish Government (2023b), Strengthening the protection of democracy and judicial independence 
oberoende), 
(Förstärkt 
https://www.regeringen.se/contentassets/fcde0b9ad7154db5a01527f72b0f4103/forstarkt-skydd-for-
demokratin-och-domstolarnas-oberoende-sou-2023-12.pdf 

domstolarnas 

demokratin 

skydd 

och 

för 

21 

 
 
Swedish  Government  (2024a),  Increased  possibilities  for  register  checks  (Utökade  möjligheter  till 
registerkontroller),https://www.regeringen.se/contentassets/08330e1b747c4951b2715e8433f6c47e/do
mstolsverkets-hemstallan-utokade-mojligheter-till-registerkontroller.pdf 

(2024b),  Legal  aid  and 

Swedish  Government 
https://www.regeringen.se/rattsliga-dokument/kommittedirektiv/2024/04/dir.-
202439#:~:text=R%C3%A4ttsliga%20bitr%C3%A4den%20och%20r%C3%A4tteg%C3%A5ngskost
nader%20%E2%80%93%20sk%C3%A4rpt,2024%3A39&text=En%20s%C3%A4rskild%20utredare
%20ska%20se%20%C3%B6ver%20regelverket%20f%C3%B6r%20ers%C3%A4ttning%20till%20r
%C3%A4ttsliga%20bitr%C3%A4den 

expenses 

legal  assistance, 

the 

for 

Swedish  Government  (2024c),  Responsibility  and  independence  -  public  service  in  troubled  times 
(Ansvar  och  oberoende  -  public  service  i  oroliga  tider),  https://www.regeringen.se/rattsliga-
dokument/statens-offentliga-utredningar/2024/05/sou-202434/. 

Swedish Government (2024d), A more legally secure and efficient court process (En mer rättssäker 
https://www.regeringen.se/rattsliga-dokument/statens-offentliga-
domstolsprocess) 
och 
utredningar/2024/06/sou-202451/. 

effektiv 

Swedish  Government  (2024e),  Government  increases  support  to  vulnerable  and  persecuted 
https://www.government.se/press-releases/2024/07/government-increases-support-to-
journalists, 
vulnerable-and-persecuted-journalists/ 

Swedish Government (2024f), Press release “From SEK 69 billion to SEK 100 billion in five years – 
continued extensive investments to restore security in Sweden” (Från 69 till 100 miljarder på fem år 
– 
Sverige), 
https://www.regeringen.se/pressmeddelanden/2024/09/fran-69-till-100-miljarder-pa-fem-ar--fortsatt-
omfattande-satsningar-for-att-ateruppratta-tryggheten-i-sverige/ 

återupprätta 

omfattande 

tryggheten 

satsningar 

fortsatt 

för 

att 

i 

Swedish 
https://www.regeringen.se/rattsliga-dokument/proposition/2024/10/prop.-20242520. 

Government 

Anonymous 

witnesses 

(2024g), 

(Anonyma 

vittnen), 

Swedish  Government  (2024h),  Personal  data  and  the  media  constitutions  (Personuppgifter  och 
mediegrundlagarna)  SOU  2024:75,  https://www.regeringen.se/rattsliga-dokument/statens-offentliga-
utredningar/2024/11/sou-202475/. 

Swedish Government (2025a), Contribution from the Swedish Government for the 2025 Rule of Law 
Report. 

report” 

Swedish Government (2025b), Press release “The 2023 Committee on Freedom and Rights submits 
betänkande), 
its 
https://regeringen.se/pressmeddelanden/2025/01/2023-ars-fri--och-rattighetskommitte-overlamnar-
sitt-betankande/ 

rättighetskommitté 

överlämnar 

(2023 

och 

fri- 

års 

sitt 

Swedish  Government  (2025c),  The  Government  is  not  proceeding  with  proposals  regarding  journal 
support 
tidskriftsstöd), 
vidare 
https://www.regeringen.se/pressmeddelanden/2025/02/regeringen-gar-inte-vidare-med-forslag-
gallande-tidskriftsstod/ 

(Regeringen 

gällande 

förslag 

med 

inte 

går 

radio 

(Regeringen 

Swedish Government (2025d), The Government decides on referral to the Council on Legislation on 
commercial 
radio), 
om 
https://www.regeringen.se/pressmeddelanden/2025/02/regeringen-beslutar-om-lagradsremiss-om-
kommersiell-
radio/#:~:text=Regeringen%20har%20i%20dag%20beslutat,digital%20och%20analog%20kommersie
ll%20radio.  

lagrådsremiss 

kommersiell 

beslutar 

om 

22 

 
Swedish  Government  (2025e),  Government  proposes  new  conditions  for  commercial  radio 
(Regeringen 
radio) 
villkor 
https://www.regeringen.se/pressmeddelanden/2025/04/regeringen-foreslar-nya-villkor-for-
kommersiell-radio/. 

kommersiell 

föreslår 

nya 

för 

Swedish Government (2025f), Strengthening the protection of democracy and the independence of the 
judiciary 
oberoende), 
demokratin 
https://www.regeringen.se/pressmeddelanden/2025/04/starkt-skydd-for-demokratin-och-
domstolarnas-oberoende/ 

domstolarnas 

(Stärkt 

skydd 

och 

för 

Swedish  Government  (2025g),  Bill  on  public  service  2026–2033  adopted  (Proposition  om  public 
service 2026–2033 beslutad), https://regeringen.se/pressmeddelanden/2025/05/proposition-om-public-
service-20262033-beslutad/. 

Swedish  Government  (2025h),  The  Media  Authority  will  follow  up  on  media  support 
(Mediemyndigheten 
mediestödet) 
https://regeringen.se/pressmeddelanden/2025/05/mediemyndigheten-ska-folja-upp-mediestodet/. 

följa 

upp 

ska 

Swedish Government (2025i), Some questions on fundamental rights and freedoms (Några frågor om 
grundläggande 
rättigheter), 
https://www.regeringen.se/contentassets/5bac301322db4e3b992b2d8d649a48b5/nagra-fragor-om-
grundlaggande-fri--och-rattigheter-sou-20252.pdf 

och 

fri- 

Swedish Government (2025j) Strengthening the protection of the independence of courts and judges 
oberoende) 
(Stärkt 
https://www.regeringen.se/remisser/2025/05/remiss-av-sou-202556-starkt-skydd-for-domstolarnas-
och-domarnas-oberoende/?mtm_campaign=Remiss&mtm_source=Remiss&mtm_medium=email 

domstolarnas 

domarnas 

skydd 

och 

för 

Swedish Government (2025k) Stronger protection for public employees against violence, threats and 
harassment,  etc.  (Ett  starkare  skydd  för  offentliganställda  mot  våld,  hot  och  trakasserier  m.m.) 
https://www.regeringen.se/rattsliga-dokument/proposition/2025/03/prop.-202425141. 

Swedish  Government  (2025l),  Strengthened  Constitutional  Preparedness  (Stärkt  konstitutionell 
beredskap), https://regeringen.se/rattsliga-dokument/proposition/2025/06/prop.-202425155  

Swedish  Institute  for  Human  Rights  as  part  of  ENNHRI  (2025),  Contribution  from  the  European 
Network of National Human Rights Institutions for the 2025 Rule of Law Report. 

Swedish Institute for Human Rights (2024a), The Government has appointed two new members to the 
Agency's Board of Directors (Regeringen har förordnat två nya ledamöter i myndighetens styrelse), 
https://mrinstitutet.se/nyheter/regeringen-har-forordnat-tva-nya-ledamoter-i-myndighetens-styrelse/ 

Swedish Institute for Human Rights (2024b), The government's appointment process raises concerns 
about  the  institute's  independence  (Regeringens  tillsättningsprocess  väcker  oro  för  institutets 
https://mrinstitutet.se/nyheter/regeringens-tillsattningar-vacker-oro-for-institutets-
oberoende), 
oberoende/ 

Swedish Media Publishers’ Association (2024) TU strongly criticizes search service investigation (TU 
riktar  stark  kritik  mot  söktjänstutredning),  https://tu.se/pressmeddelanden/tu-riktar-stark-kritik-mot-
soktjanstutredning/. 

Swedish  National  Courts  Administration  (2025),  The  annual  report  for  2024  is  submitted  to  the 
regeringen), 
Government 
https://www.domstol.se/domstolsverket/nyheter/2025/02/arsredovisningen-for-2024-lamnas-till-
regeringen/ 

(Årsredovisningen 

lämnas 

2024 

för 

till 

23 

 
Swedish Parliament (2024), Criminal law measures against corruption and misconduct (Straffrättsliga 
åtgärder  mot 
https://www.riksdagen.se/sv/dokument-och-
lagar/dokument/kommittedirektiv/straffrattsliga-atgarder-mot-korruption-och_hcb114/ 

korruption 

tjänstefel), 

och 

Swedish  Radio  (2024)  Proposals  leading  to  gradual  dismantling  (Förslag  som  leder  till  gradvis 
nedmontering), https://www.sverigesradio.se/artikel/forslag-som-leder-till-gradvis-nedmontering. 

Swedish Union of Journalists (2024), The Swedish Union of Journalists' consultation response to the 
ps-utredningen), 
PS 
https://www.sjf.se/aktuellt/202409/journalistforbundets-remissvar-pa-ps-utredningen. 

(Journalistförbundets 

remissvar 

inquiry 

på 

Swedish  Union 
Journalists 
https://www.sjf.se/yrkesfragor/oppenhet/oppenhetsdatabasen. 

(2025),  Transparency 

of 

database 

(Öppenhetsdatabasen) 

Transparency Committee (2023), Increased transparency of political processes (Ökad insyn i politiska 
processer),  https://www.regeringen.se/rattsliga-dokument/statens-offentliga-utredningar/2025/05/sou-
202552/ 

24 

 
 
Annex II: Country visit to Sweden 

The Commission services held virtual meetings in February 2025 with: 

•  Agency for Public Management  
•  Civil Rights Defenders 
•  Economic Crime Authority 
•  Swedish Judges Association 
•  Media Ombudsman 
•  Ministry of Culture 
•  Ministry of Finance 
•  Ministry of Justice 
•  National Council for Crime Prevention 
•  National Courts Administration 
•  National Forum of Voluntary Organisations 
•  Office of the Parliamentary Ombudsmen 
•  Office of the Prime Minister 
•  Police Authority, including Special Investigation Department 
•  Prosecution Service 
•  Secretariat of the Constitution Committee  
•  Supreme Administrative Court 
•  Supreme Court 
•  Swedish Agency for the Media 
•  Swedish Bar Association 
•  Swedish Confederation of Industries 
•  Swedish Educational Radio (UR) 
•  Swedish Institute for Human Rights 
•  Swedish Lay Judges Association 
•  Swedish Publishers’ Association  
•  Swedish Radio (SR) 
•  Swedish Section of the International Commission of Jurists 
•  Swedish Television (SVT) 
•  Swedish Section of the International Commission of Jurists 
•  Swedish Union of Journalists 
•  Transparency International 

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

•  Amnesty International  
•  Araminta  
•  Civil Liberties Union for Europe   
•  Civil Society Europe   
•  European Civic Forum   
•  European Partnership for Democracy  
•  European Youth Forum,  

25 

 
 
International Commission of Jurists   
International Federation for Human Rights (FIDH)  

• 
• 
•  JEF Europe  
•  Philea – Philanthropy Europe Association.  
•  Transparency International   

26