COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report The rule of law situation in the European Union
Date: 2026-07-17
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  Brussels, 17.7.2026  SWD(2026) 927 final  COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report                                    The rule of law situation in the European Union {COM(2026) 900 final} - {SWD(2026) 901 final} - {SWD(2026) 902 final} - {SWD(2026) 903 final} - {SWD(2026) 904 final} - {SWD(2026) 905 final} - {SWD(2026) 906 final} - {SWD(2026) 907 final} - {SWD(2026) 908 final} - {SWD(2026) 909 final} - {SWD(2026) 910 final} - {SWD(2026) 911 final} - {SWD(2026) 912 final} - {SWD(2026) 913 final} - {SWD(2026) 914 final} - {SWD(2026) 915 final} - {SWD(2026) 916 final} - {SWD(2026) 917 final} - {SWD(2026) 918 final} - {SWD(2026) 919 final} - {SWD(2026) 920 final} - {SWD(2026) 921 final} - {SWD(2026) 922 final} - {SWD(2026) 923 final} - {SWD(2026) 924 final} - {SWD(2026) 925 final} - {SWD(2026) 926 final} - {SWD(2026) 928 final} - {SWD(2026) 929 final} - {SWD(2026) 930 final} - {SWD(2026) 931 final}  
 
 
ABSTRACT 

In Sweden, the level of perceived judicial independence continues to be very high among the 
general public and is now very high among companies. Work on legislative  amendments to 
the Constitution, aimed in part at strengthening judicial independence, is progressing. While 
there are no plans to change the nomination system for lay judges, measures are examined by 
the Lay Judges Association to strengthen their functioning in the courts. Increased financial 
resources  have  been  allocated  to  courts  for  2026-2028  to  address  a  rising  caseload  and 
strengthen court security, while recruitment remains a challenge. A new collective agreement 
between  the  National  Courts  Administration  and  the  judges’  trade  union  clarifies  existing 
safeguards  and  introduces  new  measures  to  ensure  that  the  judges’  salary  system  support 
judicial  independence.  The  Government  is  reflecting  on  further  measures  to  strengthen  the 
right  to  an  effective  remedy,  while  stakeholders  continue  to  highlight  key  challenges  in 
practice. The justice system continued to function effectively despite a sustained high level of 
incoming cases, and the digitalisation of justice remained at a very good overall level. 

The  2024-2027  Action  plan  against  corruption  and  undue  influence  continues  to  be 
implemented,  with  the  next  strategic  document  expected  to  be  a  comprehensive  anti-
corruption  strategy.  The  Government  proposed  further  legislative  reforms  to  strengthen  the 
criminal  justice  framework  and  improve  accountability  for  corruption  in  line  with 
international recommendations. While the draft bill does not expand the definition of foreign 
bribery  or  introduce  a  corporate  liability  for  bribery  offences,  prosecution  of  such  offences 
has yet to improve. The investigation and prosecution of corruption are overall effective, with 
certain risks being monitored. While there are no plans to revise the asset declaration regime 
for public officials, the Government is reviewing relevant guidelines documents and reflects 
on  a  reform  of  the  conflicts  of  interest  rules.  There  is  no  proposal  to  change  the  rules  on 
revolving  doors.  New  legislation  strengthens  the  rules  on  political  party  financing  and 
introduces  a  mandatory  lobbying  register.  The  2021  Whistleblowers  Act  continues  to  be 
implemented  and  inspections  of  reporting  channels  in  the  private  sector  have  been  carried 
out. Measures are being taken to address the risk of undue influence in public administration 
and  of  corruption  in  public  procurement,  including  through  more  transparent  and  reliable 
procurement data and greater scrutiny of bidders and suppliers. 

The independent national regulatory authority, the Swedish Agency for the Media, is taking 
on  an  increasing  number  of  responsibilities.  Sweden’s  new  Public  Service  Act  came  into 
force in December 2025, updating rules and funding for public service media until 2033. The 
amended  framework  for  commercial  radio  channels  is  now  applicable,  harmonising  regime 
for analogue and digital commercial radio licenses. Changes to Sweden’s public access laws, 
aimed at  addressing privacy and security  needs,  prompt reactions regarding their impact  on 
transparency.  Sweden  continues  to  provide  a  supportive  environment  for  journalists,  with 
high levels of public trust despite challenges in the evolving media landscape. 

Some  stakeholders  continue  to  express  concerns  that  the  accelerated  pace  of  legislative 
preparatory work poses challenges to public participation and may in certain cases adversely 
affect the quality of legislation. Work on legislative amendments to the Constitution, aimed at 
providing a framework to better deal with serious crises, is progressing. On 1 January 2026, 
Sweden  had  no  leading  judgment  of  the  European  Court  of  Human  Rights  pending 
implementation,  a  decrease  of  one  as  compared  to  the  previous  year.  Civic  space  remains 
open, although stakeholders have identified certain challenges in the practical implementation 
of  the  recently  enacted  legal  framework  for  the  funding  and  operation  of  civil  society 
organisations.  The  National  Human  Rights  Institution  and  the  Parliamentary  Ombudsman 
continue to discharge their mandates effectively. 

1 

 
RECOMMENDATIONS  

Overall,  based  on  the  recommendations  in  the  2025  Rule  of  Law  Report,  and  considering 
other developments that took place in the period of reference, the Commission concludes the 
following:  

•  No  progress  has  been  made  on  ensuring  that  the  nomination  system  of  lay  judges 
safeguards their independence, as no measures have been introduced. As a national debate 
over  political  parties’  role  in  nominations  and  its  impact  on  lay  judges’  independence 
continues, it is recommended to Sweden to take measures to safeguard the independence 
of lay judges as regards their nomination and functioning, taking into account European 
stands on judicial independence.    

•  Some  progress  has  been  made  on  the  fight  against  foreign  bribery,  as  draft  legislation 
introduces  some  relevant  provisions.  Since  its  adoption  is  pending  and  prosecution  of 
these  offences  has  not  improved,  it  is  recommended  to  Sweden  to  strengthen  the  fight 
against foreign bribery, including by improving enforcement. 

•  No progress has been made to follow up on the inquiry on rules on revolving doors. As no 
measures  are  planned  in  this  regard,  it  is  recommended  to  Sweden  to  ensure  an 
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 very high among companies. Overall, 82% of the general 
population and 89% of companies perceive the level of independence of courts and judges to 
be  ‘fairly  or  very  good’  in  20262.  Among  the  general  public,  the  perceived  judicial 
independence  has  increased  in  comparison  with  2025  (76%)  and  significantly  increased  in 
comparison  with  2022  (74%).  The  perceived  judicial  independence  among  companies  has 
significantly increased in comparison with 2025 (74%), as well as in comparison with 2022 
(70%). 

Work  on  legislative  amendments  to  the  Constitution,  aimed  in  part  at  strengthening 
judicial independence, is progressing. The work on strengthening judicial independence is 
progressing as part of a broader constitutional reform package3. In October 2025, Parliament 
adopted  the  first  decision  on  constitutional  amendments  aimed  at  reinforcing  the 
independence of the judiciary and the protection of democracy4. It includes elements related 
to court administration, judicial appointments and disciplinary procedures. This package also 
includes  reforms  to  strengthen  the  procedure  for  amending  the  Constitution,  notably  by 
introducing stricter quorum and majority requirements. As required under the constitutional 
amendment  procedure,  a  second,  confirmatory  vote  must  take  place  after  the  parliamentary 
elections  scheduled  for  September  2026  before  the  amendments  can  enter  into  force, 
currently envisaged for 1 April 2027. 

While  no  progress  has  been  made  on  the  recommendation  concerning  the  nomination 
system for lay judges, measures are under consideration by the Lay Judges’ Association 
to improve their functioning5. Lay judges continue to be nominated exclusively by political 
parties  and  are  formally  appointed  by  municipal  councils  or  county  council  assemblies6.  A 
national  debate  on  the  role  of  political  parties  in  the  nomination  process  is  ongoing,  with 
stakeholders calling for reforms to the current system in light of concerns about its impact on 
lay judges’ independence in certain cases7. At the same time, the Lay Judges’ Association is 
exploring  measures  to  improve  the  functioning  of  lay  judges  in  courts.  These  include  the 
introduction of a more comprehensive training programme from 2027 onwards8, joint public 
awareness-raising activities with the National Courts Administration to highlight the role of 

1  An overview of the institutional framework for all four pillars can be found here.  
2   Figures 48 and 50, 2026 EU Justice Scoreboard and Figures 51 and 53, 2024 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   2025 Rule of Law Report, Sweden, pp. 3-4. 
4   Sveriges Riksdag (2026) ‘The Riksdag votes no to referendum on constitutional matter’. 
5   The  2025  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.” 
No progress was previously assessed on this recommendation in 2025. 

6   2025 Rule of Law Report, Sweden, pp. 4-5. 
7  Country visit Sweden, International Commission of Jurists (ICJ), Civil Rights Defenders, Swedish Judges 

8 

Association, Swedish National Human Rights Institution. 
This training programme, provided for by the National Court Administration, would be divided into several 
modules  instead  of  the  current  single-module  format.  This  updated  training  material  is  intended  to  be  in 
place when the next lay judge elections take place in 2027. It should be noted that each court is independent 
and decides for itself how to use the material provided by the Administration, as well as how much time to 
allocate to training. 

3 

 
 
lay  judges,  and  enhanced  support  for  the  political  parties  responsible  for  nominations9  to 
promote the recruitment of suitable candidates10. In parallel, the National Audit Institution is 
conducting a study on the functioning of lay judges in courts which however does not cover 
the nomination process11. As the Government has not taken specific steps to implement the 
recommendation, no progress has been made in this area. 

Quality  

Increased financial resources have been allocated to courts for 2026–2028 to address a 
rising  caseload  and  strengthen  court  security,  while  recruitment  remains  a  challenge. 
The  additional  financial  resources  allocated  for  the  period  2026–202812  aim  to  address  a 
rising  caseload  and  enhance  court  security,  including  preparedness  measures.  This  follows 
several  years  of  substantial  funding  increases  as  part  of  broader  investments  in  the  judicial 
system13. The increase in funding has coincided with a significant rise in caseloads, which the 
National Courts Administration (NCA) attributes in part to broader investments in other parts 
of  the  criminal  justice  system,  including  additional  resources  for  law  enforcement 
authorities14.  The  NCA  expects  that  most  courts  will  use  the  additional  funds  for  further 
recruitment  and  investments  in  court  security15.  Stakeholders  have  generally  welcomed  the 
additional  resources.  Stakeholders  report  recruitment  challenges  driven  by  an  increasing 
workload, and the growing complexity of cases, which have reduced the attractiveness of the 
position, as well as by geographical disparities in staff availability16. 

The  National  Courts  Administration  and  the  judges’  trade  union  agreed  on  a  new 
collective  agreement,  clarifying  existing  safeguards  and 
introducing  additional 
measures to support judicial independence with regard to the judges’ salary system17. A 
new  collective  agreement  was  concluded  in  October  2025  between  the  National  Courts 
Administration  and  the  judges’  trade  union18.  The  revised  agreement  specifies  that  the 
salaries  of  judges  must  not  be  influenced  by  their  rulings,  reinforcing  and  clarifying 
safeguards  already  present  in  the  previous  framework.  The  updated  system  also  introduces 
mechanisms  for  resolving  disagreements  over  salary  decisions19.  Discussions  between  the 
National Courts Administration and the judges’ trade union on developing salary criteria for 
judges  are  ongoing  under  the  revised  agreement.  These  developments  have  been  generally 

9  The Lay Judges Association launched a reflection process on recruitment to strengthen the selection process 
of lay judges. This may include the development of standardised guidance materials for recruiting new lay 
judges,  such  as  sample  interview  questions  and  a  more  comprehensive  description  of  the  role  and 
responsibilities of lay judges. 

10  Country visit Sweden, Lay Judges Association. 
11  The review examines whether lay judges are sufficiently representative of the broader population, receive 
adequate  training,  and  whether  their  role  is  effectively  managed  by  the  courts.  Country  visit  Sweden, 
Swedish Supreme Audit Institution. 

12     Over  the  three-year  period,  the  total  additional  financial  resources  amount  to  EUR  2,443,674,696  EUR 

(SEK 26,276,072,000). 

13  2025 Rule of Law Report, Sweden, p. 5. 
14  Country visit Sweden, National Courts Administration. 
15    This includes measures focused on enhancing both physical security of courts, operational resilience as well 

as cybersecurity of courts, Swedish National Courts Administration (2026), Annual Report 2025. 
Ibid. 

16 
17  The  existing salary system  – based on a collective agreement combined with individual salary setting for 

each judge – remains in place. 

18  Country visit Sweden, National Courts Administration, National. Local Salary Agreement, National Courts 

Administration – Saco-S (2026). 

19   Local Salary Agreement National Courts Administration – Saco-S (2026), section 6.3.2. 

4 

 
 
 
 
 
welcomed by stakeholders20. The Swedish Judges’ Association maintains its criticism of the 
current salary system21. 

The Government is reflecting on further measures to strengthen the right to an effective 
remedy,  while  stakeholders  continue  to  highlight  key  challenges  in  practice22.  The 
Government decided not to proceed with a proposal made by the all-party committee tasked 
with  examining  the issues concerning the protection of  fundamental  rights  and freedoms to 
include  a  right  to  judicial  review  explicitly  in  the  Constitution23,  expressing  doubts  as  to 
whether it would ensure sufficient protection of the individual’s right to judicial review and 
considering  that  the  matter  required  further  examination24.  On  June  18,  2026,  the 
Government decided to appoint a new all-party committee of inquiry to investigate whether, 
and if so how, the right to judicial review needs to be strengthened by enshrining it as a new 
fundamental freedom and right in the Constitution25. As regards other issues related to access 
to justice, the financial threshold for legal aid in civil cases has not been adjusted to inflation 
since  1999,  leading  to  a  steady  decline  in  eligibility  and,  according  to  some  stakeholders, 
effectively restricting access to legal aid. This situation is considered by some stakeholders to 
undermine  effective  access  to  justice,  particularly  for  individuals  with  limited  financial 
resources.  They  also  consider  that  this  is  further  exacerbated  by  the  absence  of  collective 
redress  mechanisms,  which  discourages  litigation  due  to  potentially  substantial  financial 
risks26.  However,  the  Government  notes  that  there  is  national  legislation  that  allows  for 
group proceedings27. 

Efficiency 

The  justice  system  continued  to  function  effectively  despite  a  sustained  high  level  of 
incoming  cases,  and  the  digitalisation  of  justice  remained  at  a  very  good  overall  level. 
The  number  of  incoming  civil  and  commercial  litigious  cases  has  remained  comparatively 
low  in  2024,  while  the  number  of  incoming  administrative  cases  remained  comparatively 
high in 202428. The estimated time needed to resolve litigious civil and commercial cases at 
all  court  instances  remains  comparatively  short29.  The  estimated  time  needed  to  resolve 
administrative cases at all court instances also remains comparatively short (81 days at first 
stance, 75 days at second instance and 57 days at third instance)30. The clearance rate for civil 
and  commercial  litigious  cases  has  increased31,  while  it  has  decreased  for  administrative 

20  Country visit Sweden, Swedish Bar Association. 
21  They consider that this remuneration system is not transparent and is vulnerable to interference through the 
remuneration of (individual) judges, 2025 Rule of Law Report, Sweden, pp. 5-6. Instead, they argue for a 
more  transparent,  seniority-based  system  with  predetermined  progression  steps.  Country  visit  Sweden, 
Swedish Judges Association. 

22   2025 Rule of Law Report, Sweden, pp. 6-7.  
23   In  January  2025,  the  committee  delivered  its  report.  It  noted  that  Swedish  law  does  not  provide  for  a 
generally  applicable  constitutional  right  to  judicial  review,  in  contrast  to  the  provisions  contained  in  the 
European  Convention  on  Human  Rights  and  the  EU  Charter  of  Fundamental  Rights,  2025  Rule  of  Law 
Report, Sweden, pp. 6-7. 

24  Swedish Government (2026), written input, p.5. 
25   Country visit Sweden, Swedish Government.  
26  Country visit Sweden, ICJ and Civil Rights Defenders. 
27  See for example Group Proceedings Act (2002:599). 
28  Figures 2-3, 2026 EU Justice Scoreboard. 
29   In 2024, 150 days at first instance, 85 days at second instance and 209 days at third instance. Figure 6, 2026 

EU Justice Scoreboard. 

30  Figure 8, 2026 EU Justice Scoreboard. 
31   99% in 2024 compared to 93% in 2023, Figure 10, 2026 EU Justice Scoreboard. 

5 

 
 
cases32. The number of pending litigious civil and commercial cases at first instance is one of 
the lowest among Member States33. According to the National Courts Administration (NCA), 
in 2025 the courts saw an increase in the number of cases filed by 4% compared to 2024 and 
saw an increase in decisions taken of 3% compared to 2024. The increase in the number of 
cases  has  been  most  pronounced  in  the  district  courts34. With  respect  to  digitalisation,  the 
NCA is  working  on developing a new case management system  and is  actively  engaged in 
innovation  initiatives,  including  exploring  the  use  of  artificial  intelligence  to  streamline 
operations while maintaining information security. Nevertheless, some gaps remain in digital 
solutions for conducting and following criminal proceedings35, including electronic access for 
victims and defendants to ongoing cases, online access to first-instance court judgments, and 
machine readability of judgments36.  

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  2025  Corruption  Perception  Index  by 
Transparency International, Sweden scores 80/100 and ranks 3rd in the European Union and 
6th globally37. This  perception has deteriorated over the past  five years38. The 2025 Special 
Eurobarometer on Corruption shows that 53% of respondents consider corruption widespread 
in  their  country  (EU  average  71%)  and  13%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 30%). As regards businesses, 36% of companies 
consider that corruption is widespread (EU average 65%) and 10% consider that corruption is 
a  problem  when  doing  business  (EU  average  37%).  Furthermore,  34%  of  respondents  find 
that  there  are  enough  successful  prosecutions  to  deter  people  from  corrupt  practices  (EU 
average 38%), while 56% of companies believe that people and businesses caught for bribing 
a senior official are appropriately punished (EU average 31%)39.  

The  2024-2027  Action  plan  against  corruption  and  undue  influence  continues  to  be 
implemented,  while  the  next  strategic  document  is  expected  to  be  a  comprehensive 
national anti-corruption strategy with measurable objectives and monitoring indicators. 
The  Action  Plan  represents  the  most  comprehensive  strategic  anti-corruption  document  to 
date in  Sweden40. The forum  of seven agencies41 is  now progressing with  identifying areas 

32  99.7% in 2024 compared to 105.1 in 2023, Figure 11, 2026 EU Justice Scoreboard. 
33  Figure 13, 2026 EU Justice Scoreboard.  
34  89 670 ongoing cases at the end of 2024 compared to 85 086 ongoing cases at the end of 2021.  

Country visit Sweden, National Courts Administration. 

35  2025 Rule of Law Report, Sweden, p. 5.  
36  Figures 45, 46 and 47, 2026 EU Justice Scoreboard. The government notes that the parties to a proceeding 

may, upon request, have access to all documentation in the case in electronic form. 

37    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). 

38   In 2021 the score was 85, while, in 2025, the score is 80. The score significantly increases/decreases when 
it  changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5 points); has  been  relatively 
stable (changes from 1-3 points) in the last five years. 

39    Data from Special Eurobarometer 573 (2026) and Flash Eurobarometer 582 (2026). 
40  OECD (2025), Integrity Review of Sweden, p. 28.  
41  The forum of six agencies is a government-mandated coordination group of key Swedish authorities jointly 
responsible for reviewing the current Action Plan. The  Swedish Economic Crime Authority was formally 
added to the forum of six agencies, enhancing cross-agency collaboration. Country visit Sweden, Swedish 
Government. 

6 

 
 
not addressed in the current Action Plan. Following the 2025 OECD Integrity Review42, the 
forum along with the Agency for Public Management have been tasked with drafting an end-
of-term  report  and  contributing  to  developing  a  new  anti-corruption  strategy.  The  new 
strategy  is  expected  to  include  risk  analysis,  goal-setting,  indicators  and  follow-up 
processes43. 

The Government proposed further legislative reforms to strengthen the criminal justice 
framework  and  improve  accountability  for  corruption  in  line  with  international 
recommendations. On 15 January 2026, the Government referred a draft bill44 to the Council 
on Legislation, proposing increased penalties for bribery (including for its aggravated forms), 
gross  breach  of  trust,  gross  fraud,  gross  embezzlement  and  trading  in  influence45.  The 
Government  submitted  the  final  bill  to  Parliament  on  9  April  2026.  The  reform  is 
complemented by another government bill46 also submitted to Parliament on the same day47, 
proposing  a  criminal  offense  for  abuse  of  public  office  and  an  expanded  liability  of  public 
officials  for  intentionally  misusing  their  official  power.  The  bill  also  aims  to  address 
corruption  risks,  infiltration  and  undue  influence,  particularly  from  organised  crime.  The 
Government  reported  that  the  proposed  amendments  will  help  align  Sweden  with 
international standards48, as they address a number of legislative gaps49.. 

There  has  been  some  progress  to  address  the  recommendation  to  strengthen  the  fight 
against  foreign  bribery50.  The  aforementioned  government  bills51,  submitted  to  the 
Parliament on 9 April 2026, contain several measures addressing sanctions of bribery, as well 
as related offences and the introduction of a new corruption offence. Some of these measures 
are relevant for the fight against foreign bribery. The Committee of Inquiry52 recommends in 
its report, among other things, introducing a new offence of negligent financing of corruption, 
aimed at addressing corporate risk-taking53 and making it easier to bring actions on corporate 
fines, and abolishing the requirement of dual  criminality  for corruption offences committed 
abroad, which could facilitate the prosecution of foreign bribery cases. Stakeholders consider 

42   The adoption of a comprehensive anti-corruption strategy has also been recommended by the OECD in its 
Integrity Review of Sweden, a broad review by the OECD requested by the Swedish Government. OECD 
(2025), p. 26, and Country visit Sweden, Agency for Public Management. 

43  Country visit Sweden, Swedish Government. 
44  The draft bill is based on the Inquiry on Criminal Law Reform, appointed in June 2025, which in its report 
(SOU 2025:66) proposed inter alia increased penalties for a wide range  of offences, Swedish Government 
(2026), written input, p. 7. 

45   Swedish Government (2026), written input, p. 7. 
46  The  draft  bill  is  based  on  the  Inquiry  on  measures  under  criminal  law  against  corruption  and  official 

misconduct (SOU 2025:87).  

47  Country visit Sweden, Swedish Government. 
48  United  Nations,  United  Nations  Convention  against  corruption  (adopted  31  October  2003,  entered  into 
force  14  December  2005)  Art  19.  Article  19  of  the  UNCAC  encourages  States  to  criminalise  intentional 
misuse  of  official  powers  in  violation  of  law  to  obtain  an  undue  advantage,  even  where  no  bribery  or 
payment is involved. Country visit Sweden, Swedish Government. 
In its Integrity Review, the OECD also noted especially the need to expand accountability for corruption, 
improve enforcement by strengthening legal provisions on the reporting of corruption, corporate  criminal 
liability and sanctions, and ensure that all corruption offences have aggravated variants, OECD (2025), p. 
11. 

49 

50  The  2025  Rule  of  Law  Report  recommended  to  Sweden  to  “strengthen  the  fight  against  foreign  bribery, 
including through amending the existing legal framework and improving enforcement.” Some progress was 
assessed on this recommendation in 2023 and 2024 and no further progress was assessed in 2025. 

51  See footnotes 45 and 47.  
52  The  Committee  of  Inquiry,  established  in  February  2024  with  a  broad  mandate  to  review  criminal  law 

legislation on corruption, delivered its report in July 2025.  

53  Under the current framework, prosecution must establish that the funds were in fact used for a bribe. 

7 

 
 
that the recommended changes represent a step forward, although the bill does not expand the 
definition  of  foreign  bribery,  nor  introduce  criminal  liability  for  companies54.  The 
recommendations  of  the  Committee,  which  have  been  subject  to  consultation  with  relevant 
stakeholders, are now being considered within the Government Offices55. There has been no 
increase  in  reported  cases  of  foreign  bribery,  with  one  investigation  currently  ongoing56. 
Overall,  while  there  has  been  no  increase  in  investigating  and  prosecuting  foreign  bribery 
cases, the government bills approved by Parliament introduce some elements relevant for the 
fight  against  foreign  bribery,  and  the  outstanding  recommendations  of  the  Committee  on 
further legislative action are under consideration. Therefore, there has been some progress on 
this recommendation. 

The  investigation  and  prosecution  of  corruption  are  overall  effective,  while  certain 
risks,  including  underreporting  and  new  corruption  modalities,  continue57  to  be 
monitored  by  law  enforcement.  Resources  for  the  Swedish  Police  Authority’s  National 
Anti-Corruption Unit (NACU) are reported as sufficient for the current workload. Efforts are 
underway  to  broaden  NACU’s  investigative  scope  beyond  pure  bribery  cases,  to  include 
professional misconduct, embezzlement, fraud, and the misuse of confidential information58. 
According to the National Council for Crime Prevention, in 2025, active bribery was reported 
184  times,  passive  bribery  202  times,  and  trading  in  influence  and  negligent  financing  of 
bribery 18 times59. No high-level corruption cases were reported. Between 1 November 2024 
and 1 November 2025, 99 corruption-related cases60 were investigated by the Swedish Police 
Authority, compared to 105 cases in 202461. 13 prosecutions were initiated in 2025, resulting 
in 13 judgments in the same year62. The Swedish Police Authority estimates that many cases 
continue  to  go  unreported,  especially  at  the  regional  and  municipal  level.  Links  between 
bribery  and  other  offenses  such  as  violence,  threats,  extortion,  and  conflicts  of  interest  are 
increasingly recognised63. The Financial Intelligence Centre, set up in April 2025, has so far 
achieved results on asset confiscations64, while its impact on corruption cases is expected to 
materialise  as  expertise  increases65.  There  was  no  corruption-related  case  handled  by  the 
EPPO in Sweden in 202566.   

Measures  are  being  taken  to  address  the  risk  of  undue  influence  in  public 
administration.  There  is  an  increased  awareness  of  the  risks  connected  with  infiltration  of 

54  Country visit Sweden, Transparency International Sweden. 
55  Swedish Government (2026c), additional written input, p. 6. 
56   In  addition,  international  legal  cooperation  remains  a  significant  barrier  to  effective  investigation  and 

prosecution. Country visit Sweden, Prosecution Service. 

57   2025 Rule of Law Report, Sweden, p. 9. 
58  Country visit Sweden, Prosecution Service. 
59   Swedish Government (2026c), p. 9. In 2024, Sweden recorded 67 active  bribery cases, 76 passive bribery 
cases and 9 cases of trading in influence. National Council for Crime Prevention (2026), additional written 
input, p.1 

60  The cases involve breaches of trust, taking and giving of bribes, trading in influence, negligent financing of 
bribery,  wrongful  voting  and  misconduct.  Police  National  Anti-Corruption  Unit  (2025),  Corruption  in 
Sweden – a situational picture, p 5. 

61  19 cases were prosecuted, and 30 judgments were handed down during the period, of which 29 convictions, 
Swedish  Police  Authority,  National  Anti-Corruption  Unit  (2025),  Corruption  in  Sweden  –  a  situational 
picture, pp. 4-5.  

62   Swedish Police (2026), written contribution, p. 1. 
63  Country visit Sweden, Prosecution Service. 
64  Country visit Sweden, Swedish Government. 
65  The Centre can help detect corruption by identifying irregularities in money flows or through efforts aimed 

at detecting insiders within banks, Swedish Government (2026), written input, p.6. 

66   EPPO (2026), Annual report 2025, p. 57. 

8 

 
 
the  public  service  by  organised  crime  through  corruption.  On  1  July  2025,  the  Local 
Government  Act  introduced  obligations  for  municipalities  and  regions  to  protect  local  and 
regional politicians from threats and violence, helping reduce the risk of undue influence. In 
addition,  a  training  programme  on  undue  influence  in  the  public  administration  is  now 
available online67. 

While there are no plans to revise the asset declaration regime for public officials, the 
Government  is  reviewing  relevant  guidelines  documents  and  reflecting  on  a  reform  of 
the  conflicts  of  interest  rules.  The  Government  is  analysing68  the  OECD  2025  Integrity 
Review, which urges Sweden to clarify and harmonise conflicts of interest rules. It also calls 
for  strengthened  asset  and  interest  declaration  requirements  and  central  oversight  so  that 
conflicts can be more effectively detected, disclosed, and managed across the public sector69. 
Guidelines on the holding of financial instruments were revised in December 2025 to clarify 
conflicts  of  interest  risks  and  provide  clearer  support  for  ministers  and  state  secretaries  on 
reporting and managing  financial interests70. The revised ethical  guidelines for civil  service 
within  the  Swedish  Government  that  came  into  effect  on  2  June  2026  include  a  section  on 
anti-corruption and core public values71. A voluntary training program on undue influence is 
now available online for public administration employees72. 

Parliament has adopted legislation providing for an obligation for lobbyists to register 
and disclose their contacts with political decision-makers. The legislation  will enter into 
force  on  1  July  202773.  Following  the  report  of  the  all-party  committee  and  the  OECD 
recommendations74,  a  draft  bill  on  increased  transparency  of  political  processes  was 
submitted  to  the  Legislative  Council  on  3  March  202675,  which  has  completed  its  scrutiny. 
The  legislation  requires  legal  entities  to  register  their  lobbying  contacts  with  policymakers 
and include information such as the topics, counterparts, methods and frequency of contacts. 
It  also  establishes  oversight  and  enforcement  mechanisms,  with  a  public  register  and 
sanctions  for  non-compliance,  to  increase  public  insight  into  efforts  to  influence  political 
decisions.  The  proposed  lobbying  register  would  align  the  legislative  framework  with 
international standards76. Stakeholders welcome the proposal, while noting that extending the 

67   Swedish Government (2026), written input, p. 5. 
68  Swedish Government (2026), written input, p.5. 
69  Sweden  meets  44%  of  OECD  criteria  on  the  strength  of  conflict-of-interest  regulations  and  none  on 
practice, compared to OECD  averages of 76% and 40%. The  2025 OECD Integrity Review recommends 
improving  management  of  outside  interests  and  financial  disclosures,  strengthening  verification  and 
transparency,  clarifying  the  framework,  and  enhancing  guidance,  awareness,  and  proactive  risk 
management, OECD (2025), pp. 124 -142.  

70  Country visit Sweden, Swedish Government. The updated guidelines include a new section concerning the 
risks of conflicts of interest that can arise from the holding of financial instruments. Swedish Government 
(2026), written input, p.6. 

71   Ethical Guidelines of the Government Offices of Sweden (2026), pp.1-10 . 
72  Country visit Sweden, Swedish Government. 
73  The  Government  Bill  2025/26:258,  Increased  Transparency  in  Political  Processes  was  adopted  by 

Parliament on 16 June 2026.  Swedish Government (2026c), pp 9-10. 

74   In  its  2025  Integrity  Review  of  Sweden,  the  OECD  recommends  that  Sweden  introduces  a  dedicated 
lobbying  law,  increases  transparency  of  lobbying  activities,  establishes  a  lobbying  register  and  disclosure 
system, defines lobbying in a comprehensive manner, creates oversight and enforcement mechanisms and 
covers indirect and foreign lobbying, OECD (2025), pp. 85 - 115. 

75  Once the legal opinion of the Council on Legislation is obtained, the government can revise  the  proposal 
and then submit it to the parliament for debate and adoption. The entry into force is planned for July 2027. 
76   Country visit Sweden, Swedish Government. The updated guidelines include a new section concerning the 
risks of conflicts of interest that can arise from the holding of financial instruments. Swedish Government 
(2026), written input, p.6.  

9 

 
 
rules to regional and local level could also be considered, given the highly decentralised way 
of decision-making in Sweden77. 

There has been no progress on the recommendation to follow up on the inquiry on rules 
on revolving doors78. A committee of inquiry recommended in 2023 to extend the scope of 
revolving  door  rules  beyond  ministers  and  state  secretaries,  introduce  a  general  framework 
for  other  public  employees,  require  notifications  of  moves  to  the  private  sector  and  set  a 
maximum  duration  of  restrictions79.  The  proposals  remain  under  consideration  within  the 
Government  Offices80. Civil society also  supports the adoption of measures regarding post-
employment restrictions81. There has therefore been no progress on this recommendation.  

Recently adopted legislation strengthens the rules on political party financing, aligning 
the  Swedish  framework  with  international  standards  and  recommendations.  The  law, 
increasing transparency of political processes82, also aims to strengthen the rules on political 
party  financing83,  to  ban  foreign  political  donations,  and  to  expand  financial  reporting 
obligations for political parties to include both income and expenditure as well as assets and 
liabilities.  Moreover,  the  law  clarifies  the  definition  of  a  donor  and  bans  anonymous  and 
disguised donations. In addition, non-monetary contributions such as free services or labour 
would also have to be reported. Administrative sanctions would be imposed for breaking the 
rules.  Stakeholders  have  noted  that  a  potential  gap  may  remain  in  the  proposed  system  of 
banning  foreign  donations,  with  a  possibility  for  foreign  donors  to  route  money  through  a 
Swedish  intermediary84. Overall,  the  law  is  expected  to  contribute  to  aligning  the  Swedish 
framework with international standards and GRECO, EU85 and OECD recommendations86. In 
its  2025  Annual  Report,  the  Swedish  Legal,  Financial  and  Administrative  Services  Agency 
opened  five  enforcement  cases  in  2025  (down  from  10  in  2024)  and  received  one  external 
complaint regarding party financing oversight87.   

The 2021 Whistleblowers Act continues to be implemented and inspections of reporting 
channels in the private sector have been carried out. The Whistleblower Act88 continued 

77  Country visit Sweden, Transparency International Sweden.  
78   The  2025  Rule  of  Law  Report  recommended  to  Sweden  to  “ensure  an  appropriate  follow-up  to  the 
evaluation of the rules on revolving doors.” No progress was assessed on this 2024 recommendation in the 
2025 Rule of Law Report. The Committee of Inquiry was appointed in 2022 and it submitted its report in 
2023.  The  OECD  also  recommends  that  Sweden  develops  revolving  doors  policies  and  post-public 
employment  measures,  such  as  cooling-off  periods  and  targeted  restrictions  in  high-risk  areas  (such  as 
public procurement), OECD (2025), p. 174-175. 

79   Swedish Government (2023), ‘Transitional restrictions  – increasing trust in public services. Report on the 

Inquiry into Transitional restrictions in Public Activities’, pp. 15 – 236. 

80  Swedish Government (2026c), p. 8.  
81   Country  visit  Sweden,  Transparency  International  Sweden,  and  Liberties  (2026),  Rule  of  Law  Report  p. 

832. 

82   See footnote 73, p.10. 
83  Amending Act (2018:90) on transparency of party funding. 
84  Country  visit  Sweden,  Transparency  International  Sweden.  See  also  Transparency  International  Sweden, 
Referral  of  the  report  “Greater  Transparency  in  Political  Processes”  (SOU  2025:52)  (Ref.  No. 
Ju2025/01117). 

85   Commission  Recommendation  (EU)  2023/2829  of 12  December  2023 on  inclusive  and  resilient  electoral 
processes  in  the  Union  and  enhancing  the  European  nature  and  efficient  conduct  of  elections  to  the 
European Parliament.  

86  Sweden  remains  one  of  few  countries  without  restrictions  of  foreign  donations  to  political  parties  and 

candidates, OECD (2025), p. 106. 

87  Legal, Financial and Administrative Services Agency (2026), Annual Report 2025, p. 83. 
88   Act (2021:890) on protection of persons who report wrongdoings. 

10 

 
 
to  be  applied.  In  202489  the  Work  Environment  Authority  recorded  121  whistleblowing 
reports90.  The  Authority  recently  carried  out  inspections  in  the  private  sector91  and  will 
publish the results in a report92. A 2026 investigation by a media outlet found inconsistencies 
in  how different  Swedish  authorities handle whistleblowing  reports, noting that only a very 
small number of reports have led to disciplinary or criminal proceedings93. The Government 
notes  that  the  administrative  implementation  of  the  whistleblowing  framework  by  the 
relevant authorities reflects their high institutional independence, and that some reports filed 
through whistleblowing channels fall outside the scope of the Whistleblowing Act94.  

Measures are being taken to address the risk of corruption in public procurement, such 
as  enhancing  the  transparency  and  reliability  of  procurement  data  and  increasing 
scrutiny of bidders and suppliers. Businesses’ attitudes towards corruption in the EU shows 
that  30%  of  companies  in  Sweden  (EU  average  30%)  think  that  corruption  has  prevented 
them  from  winning  a  public  tender  in  practice  in  the  last  three  years.  85%  of  companies 
perceive the level of independence of the public procurement review bodies (administrative 
courts)  as  very  or  fairly  good,  which  has  significantly  increased  in  comparison  with  2025 
(64%)95.  The  Single  Market  and  Competitiveness  Scoreboard  on  access  to  public 
procurement in Sweden reports 23% of single bids for 2024 (27% EU average). A number of 
challenges  persist96,  also  taking  into  account  the  high  proportion  of  government  services 
outsourced to the private sector97. Digitalisation and centralisation of procurement data have 
been  identified  as  desirable  by  stakeholders98.  The  Government  has  introduced  several 
measures to reduce corruption risks in public procurement. Alongside reforms of corruption 
offences99,  the  Government  has  tasked  the  Swedish  Agency  for  Public  Management  with 
proposing  how  a  national  public  procurement  database  and  an  analytical  function  for 
procurement data and purchasing can be established to enhance transparency. The purpose of 
the  dedicated  data  analytics  function  is  to  monitor  procurement  and  purchase  data  to  flag 
potential corruption100. The National Audit Office is preparing a performance audit on public 
procurement,  addressing  also  possible  irregularities101.  Beside  public  procurement,  other 
sectors  representing  a  high  corruption  risk  include  construction  and  infrastructure,  law 
enforcement,  transport,  healthcare  and  social  care102.  Other  risk  factors  include  bribery 

89  Swedish Government (2026), written input, Annex 2. 
90   The reports were received from a wide range of sectors: most of them (74) concerned protection of privacy 
and  personal  data,  and  public  procurement  (19).  There  is  no  data  disaggregation  on  reports  concerning 
corruption. 

91   The inspections, carried out in November 2025 and March 2026, looked into 72 workplaces. 80 % of the 
inspected  workplaces  were  asked  to  address  the  identified  issues.  Swedish  Government  (2026b),  written 
input, p. 1. 

92   Swedish Government (2026b), p.1, Work Environment Agency (2025), Whistleblowing inspection.  
93   Publikt (2026), Major differences in how whistleblowers are handled.  
94   Swedish Government (2026b), p.1. 
95   Figure 59, 2026 EU Justice Scoreboard.  
96  These  risks  include,  notably,  organised  crime  infiltrating  procurement,  differing  practices  due  to 
decentralisation,  and  legal  gaps,  such  as  an  unclear  conflict-of-interest  definitions,  weak  revolving  doors 
restrictions and limited enforcement against favouritism, see also OECD (2025), pp. 168 – 188. 

97  During  the  country  visit,  the  Confederation  of  Swedish  Industries  reported  that  public  procurement 

spending amounts to 18% of GDP in Sweden, with the EU average being around 13%.  

98   OECD  (2025),  pp.  183  –  192.  See  also  country  visit  Sweden,  Confederation  of  Swedish  Industries  and 

Transparency International Sweden. 

99  See footnote 45, p. 6.  
100   Country visit Sweden, Swedish Government. 
101  It is scheduled for publication in October 2026. Country visit Sweden, National Audit Office.  
102    Institute Against Corruption, “Corruption offence judgments in Sweden 2025”, pp. 4–8. 

11 

 
 
through cryptocurrencies, as well as the proliferation of corruption brokers and the growing 
risk of corruption in critical sectors, such as the security industry103.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM  

The  independent  national  regulatory  authority,  the  Swedish  Agency  for  the  Media,  is 
taking  on  an  increasing  number  of  responsibilities.  In  November  2025  the  Government 
assigned  the  Swedish  Agency  for  the  Media  a  new  mission  to  develop  a  regular  survey  to 
monitor  threats,  violence  and  harassment  faced  by  journalists104.  The  assignment  also 
included designing appropriate methods to compare risks over time and identify partners for 
collaboration, and has transmitted to the Government a proposal setting out the methodology 
for conducting such future surveys. The Agency has also taken on expanded responsibilities 
under new laws that came into force in 2026105. These include monitoring media ownership 
transparency,  preventing  market  monopolies,  maintaining  a  database  of  media  owners,  and 
protecting editorial independence. To support these efforts, the Government has increased the 
Agency’s  budget  for  2026,  funding  its  new  regulatory  duties106.  The  Agency  currently 
considers  its  resources  sufficient  to  carry  out  these  tasks107.  The  MPM  2025  continues  to 
indicate  a  very  low  risk  regarding  the  independence  and  effectiveness  of  the  media 
authority108. 

Sweden’s new Public Service Act came into force in December 2025, updating rules and 
funding  for  public  service  media.  The  Public  Service  Act  took  effect  in  December  2025, 
updating  the  rules  for  public  service  media109.  It  clarifies  their  mission,  funding  and 
leadership  appointments,  bringing  provisions  on  public  service  into  a  single,  clearer 
framework110. In December 2025, the Government decided on the public service mission for 
the  period  2026-2033,  including  how  much  funding  the  public  service  companies  will 
receive,  following  guidelines  set  by  Parliament111.  While  the  reform’s  goals  are  generally 
supported112,  Swedish  public  service  media  continue  to  express  some  concerns  about 
financial sustainability and risks to their independence113. Stakeholders emphasise that rising 
costs  for  security,  resilience,  and  distribution  are  straining  budgets,  especially  as  public 
broadcasters must maintain  both  traditional terrestrial broadcasts and digital services, while 
many commercial broadcasters have moved to  providing their services only  online114. Only 
the public broadcasters Swedish Radio and Swedish Television are now using the terrestrial 

103   In the security industry this covers bribes to security and port guards to gain access to facilities and smuggle 
goods,  Swedish  Police  Authority,  National  Anti-Corruption  Unit  (2025),  Corruption  in  Sweden  –  a 
situational picture, p. 4. 

104  Swedish Government (2026), written input p. 10, Swedish Government Decision of 20 November 2025, 

Ku2025/01086. 

105  Swedish Government (2026), written input p. 9-10, Swedish Act (2025:1408); Swedish Act (2025:1242). 
106  Swedish Government (2026), written input p. 9-10, Swedish Agency for the Media (2026), written input pp. 

14-15. 

ibidem. 

107  Country visit Sweden, Swedish Agency for the Media. 
108   2026 Media Pluralism Monitor, country report for Sweden, p. 17. 
109  Swedish Government (2026), written input, p. 8, Swedish Act (2025:986). 
110  Swedish Government (2026), written input, p. 8. 
111 
112  2025 Rule of Law Report, Sweden, p. 13. 
113  Stakeholders mention that the current funding framework fails to fully account for actual costs. They also 
point out that the new remit introduces continuous reviews on productivity, impartiality, and efficiency. In 
their view, this shift not only diverts resources from core operations to administrative burdens, but also risks 
politicising public trust, as some political parties increasingly allege bias in public service media, Swedish 
Educational Radio (UR) (2026), Country visit Sweden, Swedish Television (SVT). 

114  UR (2026). 

12 

 
 
network covering all the country. Some stakeholders note structural challenges in the media 
sector, including the shift of advertising revenues away from traditional journalism to global 
digital  platforms115,  as  well  as  the  growing  concentration  of  media  ownership  in  larger 
corporate  groups116.  The  Swedish  Agency  for  the  Media  has  increased  support  for  news 
media in areas with limited local coverage117. 

The amended framework for commercial radio channels now applies, harmonising the 
regime for analogue and digital commercial radio  licenses.  An amendment  to  the Radio 
and Television Act  came into effect  in  November 2025,  making the rules  for licensing  and 
broadcasting the same for analogue and digital commercial radio118. The broadcasting fee for 
analogue  commercial  radio  has  been  replaced  with  an  annual  fee  based  on  advertising 
revenue.  The  objective  of  the  amendment  is  to  strengthen  the  long-term  viability  of 
commercial  radio  while  fostering  independent  media.  Swedish  media  stakeholders  have 
generally  supported  these  changes119.  On  22  January  2026,  the  Government  decided  not  to 
proceed with its legislative proposal that would have allowed the revocation of broadcasting 
licenses  on  national  security  grounds120.  The  Government  reasoned  that  such  a  measure 
would amount to  a disproportionate restriction  of freedom  of expression  and unlikely  to  be 
effective, since harmful actors could still broadcast via satellite or other means even if their 
terrestrial license was revoked121. 

Changes to Sweden’s public access laws aimed at addressing privacy and security needs, 
prompted  reactions  regarding  their  impact  on  transparency.  On  2  December  2025,  the 
Swedish  Government  proposed an amendment to  the  Freedom  of the Press  Act, preventing 
public access to data stored on digital devices seized during criminal investigations, though 
once  formally  included  in  cases  files,  the  data  would  then  become  accessible  under  public 
access laws122. The Government considers that this proposed change will align public access 
rights  with  suspects’ rights  and strengthens privacy, with  the change set to  take effect  on 1 
January 2027, if approved123. Meanwhile, the Public Access to Information and Secrecy Act 
is  under  frequent  amendment124,  with  recent  changes  expanding  data-sharing  between 
authorities for crime prevention and addressing NATO security requirements125. Stakeholders 
have  voiced  concerns  over  growing  legal  restrictions  and  tighter  access  to  information  in 
practice, citing increased document classification making it harder to obtain public records126. 
The  Media  Ombudsman  observes  that  Sweden  maintains  a  relatively  high  level  of 
transparency127. 

Sweden continues to provide a supportive environment for journalists, with high levels 
of  public  trust  despite  challenges  in  the  evolving  media  landscape.  The  MPM  2026 
continuous to assess the protection of freedom of expression as carrying a low-risk score in 

115  Country visit Sweden, SVT. 
116  Country visit Sweden, Media Ombudsman. 
117  UR (2026). 
118  Swedish Government (2026), written input, p. 8. 
119  2025 Rule of Law Report, Sweden, p. 13. 
120  Swedish Government (2026), written input, p. 9. 
121  Swedish Government (2026). 
122  Swedish Government (2026), written input p. 10; Swedish Government Proposal 2025/26:71. 
123 
124  Country visit Sweden, Swedish Government. 
125  Swedish Act (2009:400). 
126  Country visit Sweden, Swedish Union of Journalists, Media Ombudsman, SVT, UR (2026). 
127  Country visit Sweden, Media Ombudsman. 

ibidem. 

13 

 
 
Sweden128.  Since  the  publication  of  the  2025  Rule  of  Law  Report,  no  new  alerts  were 
registered by the Council of Europe’s Platform to promote the protection of journalism and 
safety  of  journalists.  The  Mapping  Media  Freedom  monitoring  report  has  identified  4 
incidents,  3  of  which  concern  impersonation  of  journalists  in  AI-generated  videos.  Media 
stakeholders highlight that  trust  in  Swedish  media, including  public service media, remains 
strong,  with  high  audience  numbers  and  broad  reach129.  Stakeholders  also  consider  that 
journalists face increasing criticism and political pressure130, and some have called for more 
support  in  that  regard131.  The  Media  Ombudsman  notes  that  journalists  at  major  media 
organisations  have  strong  institutional  and  legal  support132.  The  Swedish  Agency  for  the 
Media is working to improve journalists’ safety by organising events, publishing reports on 
the  current  situation  and  collaborating  with  stakeholders,  including  serving  as  a  focal  point 
for  the  Council  of  Europe’s  journalist  safety  campaign133.  The  legislation  with  the  aim  to 
transpose the EU Anti-SLAPP Directive has been adopted and covers cross-border cases134.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES  

Some stakeholders continue to express concerns that the accelerated pace of legislative 
preparatory  work  poses  challenges  to  public  participation  and may  in  certain  cases 
adversely affect the quality of legislation135. In 2025, the Government launched 334 public 
consultations  on  legislative  initiatives.  The  average  deadline  for  these  public  consultations 
was  12.6  weeks136.  Some  civil  society  stakeholders  have  expressed  concerns  that  the  rapid 
pace  of  legislative  developments  makes  it  challenging  to  maintain  a  clear  overview  of 
initiatives  across  sectors,  effectively  limiting  opportunities  for  stakeholder  input137.  The 
Government  also  used  shortened  inquiry  times  for  eight  legislative  initiatives  considered 
urgent and politically important138. In respect to constitutional checks, over the past year the 
Government submitted 142 legislative proposals to the Council on Legislation, which issued 
negative  opinions  in  nine  cases139.  Of  these,  four  proposals  were  nevertheless  submitted  to 
Parliament  without  changes,  three  were  submitted  following  partial  adjustments,  and  two 
were fully revised before submission140. The Council on Legislation has raised concerns that 
some legislation is  prepared too  hastily,  limiting opportunities for stakeholder input and, in 
some cases, affecting the quality of the final legislation141. 

Work on legislative amendments to the Constitution, aimed at providing a framework 
to  better  deal  with  serious  crises,  is  progressing.  In  December  2025,  the  Parliament 

128   2026 Media Pluralism Monitor, country report for Sweden, p. 13. 
129  Country visit Sweden, Swedish Agency for the Media, Media Ombudsman, SVT. 
130  Country visit Sweden, Swedish Union of Journalists, Media Ombudsman, SVT. 
131  Country visit Sweden, Swedish Union of Journalists. 
132  Country visit, Sweden, Media Ombudsman. 
133  Country visit Sweden, Swedish Government. 
134 Swedish Government (2026), Act (2026:241) on the protection of participation in public debate in disputes 

with cross-border implications. 

135   2025 Rule of Law Report, Sweden, pp. 14-15.  
136   Swedish Government (2026a). 
137  Country  visit  Sweden,  Swedish  ICJ  -  Civil  Rights  Defenders,  Swedish  National  Human  Rights 
Institution.   Under  the  relevant  OECD Indicators  of  regulatory  policy  and  governance (iREG), Sweden 
scores slightly below the EU average on stakeholder engagement.  

138  This  covers  those  legislative  initiatives  that  had  a  consultation  period  of  30  weeks  or  less,  Swedish 

Government (2026a). 

139  Country visit Sweden, Swedish Government. 
140   Country visit Sweden, Ministry of Justice. 
141   See for example Council on Legislation Opinion on government’s proposed criminal law reforms. 

14 

 
 
voted to adopt the first decision on amendments to the Instrument of Government concerning 
constitutional  preparedness142.  The proposal  includes  amendments  that  will  strengthen 
Parliament’s ability to convene in certain difficult situations and specific rules meaning that 
the Parliament,  with  a  qualified  majority  of  three-quarters  of  the  voters,  should  be  able  to 
grant the government special powers to adopt provisions in certain crisis situations. Since the 
proposals contains constitutional amendments a second decision of identical wording must be 
made by the Parliament after the parliamentary elections in the fall of 2026. The amendments 
are proposed to enter into force on 1 January 2027143. 

More  than  two  thirds  of  companies  surveyed  in  Sweden  express  confidence  in  the 
effectiveness of investment protection. 88% of companies are very or fairly confident that 
investments are protected by law and courts, a figure which has increased in comparison with 
2025  (76%)144.  As  regards  authorities  relevant  for  economic  operators,  82%  of  companies 
perceive  the  level  of  independence  of  the  national  competition  authority  (The  Competition 
Authority)  as  very  or  fairly  good145.  The  Supreme  Administrative  Court  has  jurisdiction  in 
some business-related cases, including in cases related to public procurement and economic 
regulation.  A  number  of  judicial  mechanisms  to  improve  efficiency  are  available  in  these 
cases,  including  the  possibility  to  apply  interim  measures  and  to  consolidate  multiple 
appeals146. 

On 1 January 2026, Sweden had no leading judgment of the European Court of Human 
Rights pending implementation, a decrease of one compared to the previous year147. The 
only remaining case concerning insufficient safeguards in bulk signals-intelligence gathering 
was closed by the Committee of Ministers in June 2025148. As regards the respect of payment 
deadlines,  on  31  December  2025  there  were  no  cases  awaiting  confirmation  of  payments 
(same  as  in  2024)149.  By  17  June  2026,  the  number  of  leading  judgments  pending 
implementation had remained 0150. 

The National Human Rights Institution and the Parliamentary Ombudsman continue to 
discharge their mandates effectively151. The Swedish National Human Rights Institute has 
been accredited with ‘A’ status by the Global Alliance of National Human Rights Institutions 
(GANHRI)  since  November  2024152.  The  Swedish  National  Humans  Rights  Institute 
considers that it has adequate funds to carry out its ongoing level of operations153. In October 
2025, the Government appointed two new members to the Institute’s Governing Board. The 

142  Govt. Bill 2024/25:155. 
143  Swedish Government (2026a). 
144   Figures 52 and 53, 2026 EU Justice Scoreboard. Only 4% and  3% of the surveyed investors respectively 
perceive  the frequent  changes  in  legislation  or  concerns  about  the  quality  of  the  law-making  process  and 
concerns  about  quality,  efficiency  or  independence  of  justice  as  a  reason  for  the  lack  of  confidence  in 
investment protection. 

145   Figure 60, 2026 EU Justice Scoreboard. 
146   Figures 66 and 67, 2026 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. 

147   For an explanation of the supervision process, see the website of the Council of Europe.   
148    Judgment  of  the  ECtHR,  35252/08,  Centrum  for  Rattvisa  v.  Sweden.  European  Implementation  Network 

(2026), written input, p. 9. 

149   Council of Europe (2026), p. 163. 
150   Data according to the online database of the Council of Europe (HUDOC). 
151  2025 Rule of Law Report, Sweden, pp. 16-17.  
152  2025 Rule of Law Report, Sweden, pp. 16-17. 
153   Country visit Sweden, Swedish National Human Rights Institution.  

15 

 
 
new members were nominated by universities and colleges in accordance with the provisions 
in the law governing the Institute154. The Parliamentary Ombudsman consider that they have 
adequate  resources  and  report  good  cooperation  with  public  authorities  as  well  as  adequate 
follow-up to their recommendations155. The Parliamentary Ombudsman reported a significant 
increase  in  complaints  concerning  general  courts,  mainly  related  to  lengthy  proceedings156. 
No similar increase has been observed in administrative courts. In 2025, the complaints to the 
Parliamentary Ombudsman increased by  around  33%  to 15.369 in  total,  the highest  number 
in the history of that body157. 

Civic  space  remains  open,  although  stakeholders  have  identified  certain  challenges  in 
the  practical  implementation  of  the  recently  enacted  legal  framework  for  the  funding 
and operation of civil society organisations. Sweden is considered to have an ‘open’ civic 
space  by  Civicus158.  As  of  1  January  2025,  a  new  regulatory  framework  establishing  a 
‘democracy condition’159 for state support to religious communities and for grants from the 
General  Inheritance  Fund  came  into  effect.  Efforts  are  ongoing  to  extend  an  equivalent 
condition  across  other  funding  schemes  for  civil  society  organisations160.  To  support 
implementation, the Swedish Agency for Youth and Civil Society (MUCF) has been tasked 
by  the  Government  with  supporting  both  grant-awarding  public  bodies  in  applying  the 
democracy condition and civil society organisations in understanding the new requirements. 
Measures include providing guidance to both grant-awarding authorities and CSOs, including 
through dedicated information resources, training tools and stakeholder outreach activities161. 
Stakeholders  have  expressed  some  concerns  regarding  the  application  and  interpretation  of 
the democracy condition162. In March 2026, MUCF published a report on structured meetings 
with  civil  society  organisations  to  gather  feedback  on  its  implementation.  The  report  noted 
concerns  that  several  key  concepts  underpinning  the  democratic  condition  remain 
insufficiently  defined,  creating  a  risk  of  inconsistent  interpretation  by  civil  society 
organisations  and  inconsistent  application  by  grant-giving  authorities.  Certain  CSOs  also 
highlighted  concerns  about  increased  administrative  burden  and  uneven  application  across 
different  authorities  and  levels  of  government163.  In  parallel,  additional  public  funding  of 
EUR  6.85  million  (SEK  74  million)  has  been  allocated  to  support  security-enhancing 
measures for organisations exposed to threats, violence and harassment164. 

154  Swedish Government (2026), written input, p. 11. 
155  Country visit Sweden, Parliamentary Ombudsman.  
156  This can be largely attributed to judicial staff shortages and recruitment difficulties, particularly in Northern 

Sweden, Country visit Sweden, Parliamentary Ombudsman. 

157   Parliamentary Ombudsman (2025), p. 16. 
158  Sweden’s  score  is  81/100.  Ratings  by  Civicus  are  on  a  five-category  scale  defined  as:  open,  narrowed, 

obstructed, repressed and closed. 

159  These conditions apply to those who apply for state grants. According to this condition, 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, 2025 Rule of Law Report, Sweden, pp. 17 – 18.  

160   To  date,  45  ordinances  of  grant-awarding  bodies  have  been  amended  to  implement  the  democracy 

condition, Swedish Government (2026), written input, pp. 12-13. 

161   Country visit Sweden, Swedish Agency for Youth and Civil Society (MUCF). 
162   Country visit Sweden, ICJ, Civil Rights Defenders. 
163   Swedish  Agency  for  Youth  and  Civil  Society  (2026),  Dialogue  on  the  implementation  of  democratic 

conditions, p. 8 

164   Swedish Government (2026), written input, p. 13. 

16 

 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2026 Rule of Law report 
can 
https://commission.europa.eu/publications/2026-rule-law-report-targeted-
stakeholder-consultation_en  

found 

be 

at 

Centre for Media Pluralism and Media Freedom (2026), Media pluralism monitor 2026. 

Civil  Liberties  Union 
https://www.liberties.eu/f/wtaqoq.  

for  Europe 

(2026),  Liberties 

rule 

of 

law 

report 

2026, 

Council of Europe (2026), Supervision of the execution of judgments decisions of the European Court 
of Human Rights – 19th Annual Report of the Committee of Ministers – 2025, https://rm.coe.int/2025-
annual-report/48802b1633.   

Council of Europe, HUDOC-ESC 

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

European Commission (2025), 2025 Rule of Law Report, Country chapter on the rule of law situation 
in Sweden. 

European Commission (2026), EU Justice Scoreboard. 

European Commission (2025), EU Justice Scoreboard. 

European Implementation Network (2026), Written input from the European Implementation Network 
for the 2026 Rule of Law Report.  

European Public Prosecutor’s Office (2026) Annual report 2025. 

Institute Against Corruption (2025), Corruption offence judgments in Sweden 2025 (Mutbrottsdomar i 
Sverige 2025). 

Legal, Financial and Administrative Services Agency (2026), Annual report 2025. 

Local Salary Agreement National Courts Administration – Saco-S (2026). 

National  Council  for  Crime  Prevention  (2026),  Additional  written  input  for  the  2026  Rule  of  Law 
Report. 

OECD (2026), Indicators of Regulatory Policy and Governance (iREG). 

OECD (2025), Integrity Review of Sweden. 

Parliamentary Ombudsman (2025), Report of the Parliamentary Ombudsman.  

Swedish  Police  Authority,  National  Anti-Corruption  Unit  (2025),  Corruption  in  Sweden  –  a 
situational picture. 

Publikt  (2026),  Major  differences  in  how  whistleblowers  are  handled  (Stora  skillnader  i  hur 
visselblåsare  hanteras),  https://www.publikt.se/nyhet/stora-skillnader-i-hur-visselblasare-hanteras-
27626.  

Sveriges  Riksdag  (2026)  The  Riksdag  votes  no 
https://www.riksdagen.se/en/news/articles/2025/oct/21/the-riksdag-votes-no-to-referendum-
on_cms9e9d74ca-264f-42e7-a05d-783c15f1258aen/.  

to  referendum  on  constitutional  matter, 

Swedish Agency for the Media (2026), Written input from the Swedish Agency for the Media for the 
2026 Rule of Law Report.  

Swedish Agency for Youth and Civil Society (2026), Dialogue on the implementation of democracy 
conditions (Dialog om implementeringen av demokrativillkor). 

Competition  Authority 

Swedish 
https://www.konkurrensverket.se/en/news/2025/sharper-tools-to-exclude-criminal-and-disreputable-
suppliers-from-systems-of-choice. 

(19  December 

(2025), 

release 

press 

2025),  

17 

 
Swedish Educational Radio (UR) (2026), Contribution for the 2026 Rule of Law Report. 

Swedish Government (2026),  Contribution from the Swedish  Government for the 2026 Rule of Law 
Report. 

Swedish Government (2026a), Additional written input from Sweden for the 2026 Rule of Law Report.  

Swedish Government (2026b), Additional written input from Sweden on whistleblowing for the 2026 
Rule of Law report. 

Swedish Government (2026c), Additional written input from Sweden for the 2026 Rule of Law report. 

Swedish Government (2023), Transitional restrictions – increasing trust in public services. Report on 
the Inquiry into Transitional restrictions in Public Activities. 

Swedish Government (2026) Ethical Guidelines of the Government Offices of Sweden 

Swedish  Institute  for  Human  Rights  as  part  of  ENNHRI  (2026),  Contribution  from  the  European 
Network of National Human Rights Institutions for the 2026 Rule of Law Report. 

Swedish  National  Courts  Administration  (2026),  Annual  Report  2025.  https://www.domstol.se/om-
sveriges-domstolar/statistik-styrning-och-utveckling/arsredovisning/arsredovisning-2025/.  

Swedish Police Authority (2026), Written contribution to the 2026 Rule of Law Report. 

Transparency International Sweden (2025), Referral of the report “Greater Transparency in Political 
Processes” 
Ju2025/01117), 
https://regeringen.se/contentassets/f6bc7d1544af4551b748f75c30cd19e0/transparency-international-
sverige.pdf.   

2025:52) 

(SOU 

(Ref. 

No. 

United Nations (2003), United Nations Convention against corruption. 

Work  Environment  Agency  (2025),  Whistleblowing  inspection  (Inspektion  av  visselblåsning) 
https://www.av.se/arbetsmiljoarbete-och-inspektioner/inspektioner-utredningar-och-
kontroller/inspektion/aktuella-inspektioner/inspektion-av-visselblasning/ . 

18 

 
 
 
 
Annex II: Country visit to Sweden 

The Commission services held physical and virtual meetings in March 2026 with: 

International Commission of Jurists (ICJ) 

•  Agency for Public Management 
•  Civil Rights Defenders 
•  Confederation of Swedish Industries 
•  Economic Crime Authority 
• 
•  Media Ombudsman 
•  Ministry of Culture 
•  Ministry of Finance 
•  Ministry of Justice 
•  National Audit Office 
•  National Council for Crime Prevention 
•  National Courts Administration  
•  Office of the Parliamentary Ombudsman 
•  Office of the Prime Minister 
•  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 Government 
•  Swedish Institute for Human Rights 
•  Swedish Judges Association 
•  Swedish Lay Judges Association  
•  Swedish National Human Rights Institution 
•  Swedish Police Authority, including Special Investigation Department  
•  Swedish Prosecution Authority 
•  Swedish Publishers’ Association 
•  Swedish Section of the International Commission of Jurists 
•  Swedish Supreme Audit Institution 
•  Swedish Television (SVT) 
•  Swedish Section of the International Commission of Jurists 
•  Swedish Union of Journalists 
•  Transparency International Sweden 

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

•  Civil Liberties Union for Europe 
•  Civil Society Europe 
•  End FGM EU 
•  European Civic Forum 
•  European Partnership for Democracy 
•  Human Rights Watch 
• 

ILGA-Europe 

19 

 
 
• 
International Federation for Human Rights 
•  Philea - Philanthropy Europe Association 
•  Transparency International EU 

20