AI Regulation Tracker / Proposal

Sweden's Official Inquiry Proposes a Complementary AI Act Law Naming PTS as Lead Market Surveillance Authority

Regulatory summary: SOU 2025:101 "Anpassningar till AI-forordningen" (Adaptations to the AI Regulation) is an official Swedish government inquiry report, delivered October 6, 2025 and sent for referral (remiss) on November 11, 2025, that proposes how Sweden should implement the EU AI Act nationally. It proposes a complementary act and regulation, a market.

The Swedish government inquiry SOU 2025:101 proposes a complementary law and regulation to implement the EU AI Act, with the Post and Telecom Authority (PTS) as the main market surveillance authority, a national regulatory sandbox at PTS, and a sanctions regime. The report is at referral stage, targeting the AI Act's August 2, 2026 application date, and has not been enacted.

Primary source

By Anthony Guerriero, Founder, The Leveraged Years · Reviewed by The Leveraged Years Editorial Desk · Published July 9, 2026 · Last updated July 9, 2026

Sweden's Official Inquiry Proposes a Complementary AI Act Law Naming PTS as Lead Market Surveillance Authority regulation briefing

The Leveraged Years AI Regulation Tracker

Key takeaways

Sweden moved from having no designated national AI Act enforcement structure to a concrete inquiry proposal. The report recommends a complementary act and regulation, a system of eleven market surveillance authorities and two notifying authorities, PTS as the main market surveillance authority, a PTS-run regulatory sandbox, and a sanctions and intervention regime. It also identifies a need for complementary provisions on secrecy, professional confidentiality, and information duties.
AI providers and deployers selling into or operating in Sweden; compliance and legal teams mapping which Swedish authority supervises their AI use case; high-risk AI operators in regulated sectors such as finance and data protection; and public bodies preparing to act as market surveillance or notifying authorities.
Status: Referral stage.
Map each of your AI use cases to the market surveillance authority likely to cover it under the proposal, with PTS as the coordinating market surveillance body and sector regulators such as the data protection and financial authorities handling their domains, and watch for the government bill that would confirm the structure and timing.

Regulatory Briefing

Bindingness: Proposal, not law. SOU 2025:101 is an official inquiry report (statens offentliga utredning). Its recommendations become binding only if the government turns them into a bill, the Riksdag enacts the complementary law, and the government issues the accompanying regulation. None of that is confirmed complete as of July 2026.
Scope: Providers, deployers, importers, and distributors of AI systems on the Swedish market, and the Swedish authorities that will supervise them. The report proposes a national framework that complements the directly applicable EU AI Act rather than replacing it.
What Changed: Sweden moved from having no designated national AI Act enforcement structure to a concrete inquiry proposal. The report recommends a complementary act and regulation, a system of eleven market surveillance authorities and two notifying authorities, PTS as the main market surveillance authority, a PTS-run regulatory sandbox, and a sanctions and intervention regime. It also identifies a need for complementary provisions on secrecy, professional confidentiality, and information duties.
Who This Affects: AI providers and deployers selling into or operating in Sweden; compliance and legal teams mapping which Swedish authority supervises their AI use case; high-risk AI operators in regulated sectors such as finance and data protection; and public bodies preparing to act as market surveillance or notifying authorities.
Current Status: Referral stage. Report delivered October 6, 2025; sent for referral (remiss) November 11, 2025; a lagradsremiss and government proposition to the Riksdag were not confirmed submitted as of July 2026. Not enacted.
Effective Date: No confirmed Swedish in-force date. The inquiry targets alignment with the EU AI Act's main application date of August 2, 2026, the date on which most AI Act provisions begin to apply. Whether Sweden's complementary law is in force by then depends on the legislative timetable.
Primary Source: https://www.regeringen.se/rattsliga-dokument/statens-offentliga-utredningar/2025/10/sou-2025101/
Secondary Analysis: Coverage from the Swedish authorities, including IMY's own statements on becoming a market surveillance authority under the AI Act (IMY, "blir marknadskontrollmyndighet"), and reporting via riksdagen.se on the inquiry's referral.
Workflow Impact: Once enacted, Swedish AI operators would need to identify their competent market surveillance authority, prepare for a national sandbox application route through PTS, and account for a sanctions regime that includes remarks, sanction fees, and mandatory orders backed by penalties. Until then, the workflow is tracking the bill and pre-positioning documentation.
Operational Next Step: Map each of your AI use cases to the market surveillance authority likely to cover it under the proposal, with PTS as the coordinating market surveillance body and sector regulators such as the data protection and financial authorities handling their domains, and watch for the government bill that would confirm the structure and timing.
Last Verified: July 10, 2026

Date	Jurisdiction	Rule	Affected professionals	Status or effective date
2026-07-09	Sweden / EU	Sweden moved from having no designated national AI Act enforcement structure to a concrete inquiry proposal. The report recommends a complementary act and regulation, a system of eleven market surveillance authorities and two notifying authorities, PTS as the main market surveillance authority, a PTS-run regulatory sandbox, and a sanctions and intervention regime. It also identifies a need for complementary provisions on secrecy, professional confidentiality, and information duties.	AI providers and deployers selling into or operating in Sweden; compliance and legal teams mapping which Swedish authority supervises their AI use case; high-risk AI operators in regulated sectors such as finance and data protection; and public bodies preparing to act as market surveillance or notifying authorities.	Referral stage. Report delivered October 6, 2025; sent for referral (remiss) November 11, 2025; a lagradsremiss and government proposition to the Riksdag were not confirmed submitted as of July 2026. Not enacted.

Frequently Asked Questions

Is Sweden's complementary AI Act law in force?

No. SOU 2025:101 is an official inquiry report at the referral stage. As of July 2026 the government proposition to the Riksdag had not been confirmed submitted, so no complementary law has been enacted.

Which authority would lead AI Act market surveillance in Sweden?

The inquiry proposes the Post and Telecom Authority (PTS) as the main market surveillance authority, within a system of eleven market surveillance authorities and two notifying authorities, with sector regulators covering their own fields.

What is the role of IMY and Finansinspektionen?

They sit among the sector authorities in the proposed structure. IMY, Sweden's data protection authority, has publicly described becoming a market surveillance authority under the AI Act, and Finansinspektionen is expected to cover high-risk AI in the financial sector.

Will there be an AI regulatory sandbox?

The inquiry proposes that PTS establish a national regulatory sandbox for AI, consistent with the AI Act's expectation that each member state offer at least one national sandbox.

What is the August 2, 2026 date?

It is the date most EU AI Act provisions begin to apply. The Swedish inquiry targets alignment with that date, but whether Sweden's complementary law is in force by then depends on the legislative timetable, which was not settled as of July 2026.