DeFi regulation & security
DeFi regulation in Sweden
Finansinspektionen distinguishes Swedish application documents from permitted English ICT-contract annexes. The filing route and fee process depend on the institution and service.
- Sources checked
- Published
- Prepared by
- DeFi Security Alliance
Scope: Swedish CASP application language, submission preparation and current entitlement checks. This guide does not provide an exhaustive 2026 tariff or personal tax advice.
Select the FI application or notification route
Finansinspektionen's crypto-asset services page distinguishes a new Article 62 application from eligible financial institutions' Article 60 notifications. The notification route is tied to the institution and equivalent services. It is not a general shortcut.
Describe the customer contract, execution and asset-control functions before choosing the route. For a DeFi interface, identify the operator and relevant control powers. Under MiCA, the name of the technology does not settle whether a person provides a regulated service.
Translate the policies, check the contract exception
FI's MiCA questions and answers calls for the application and descriptions in Swedish, including relevant operating, risk, continuity, ICT and AML material. It allows relevant ICT third-party contract attachments in English without translation. That exception should not be extended to every English-language policy.
The application page identifies email submission to FI and a case-reference process for fees. Wait for the authority's case and payment instructions rather than paying an assumed amount in advance. Application assessment, notification and annual supervision are different fee categories.
Prepare a Swedish file that matches production
This DeFiSec worksheet helps reconcile language, document versions and operating evidence. It is not an FI form.
| Decision | Evidence to prepare | Review question |
|---|---|---|
| Application route | Existing status and requested service list | Is the entity eligible for notification or does it need authorization? |
| Swedish documentation | Policies, descriptions and translated terminology | Can the reviewer follow one consistent operating model? |
| English ICT annex | Supplier contract linked to its Swedish description | Is the document within the stated contract exception? |
| Payment record | FI case reference and payment instructions | Does the payment identify the correct case and obligation? |
| Supplier changes | Updated contracts, continuity results and ownership | Does the filed description still match production? |
Pharos Production's DORA register engineering guide helps connect supplier contracts to the services described in the Swedish file. Retain the source contract and its relevant operational description together. Technical documentation does not replace the authority's language requirements.
Distinguish transition expiry from a court-specific position
FI's 1 July 2026 notice explains the end of the transition and also records specific appeal cases with permission to continue certain activities pending court review. A case-specific court position cannot be generalized to other providers.
Check the exact entity, services and any applicable decision before stating that a provider may operate. Keep a dated record of that assessment. The Danish DeFi principles guide expands control analysis, while the DORA guide covers continuing technical evidence.
Continue your research
Sources and further reading
Legislation and regulator publications establish the legal basis. Technical resources explain implementation. Source checks cover the passages cited in this guide.
- MiCA — Regulation (EU) 2023/1114European Union ·
- DORA — Regulation (EU) 2022/2554European Union ·
- DORA Register of InformationPharos Production ·
- Crypto-asset services: authorization and notificationFinansinspektionen ·
- Questions and answers on MiCAFinansinspektionen ·
- Crypto firms without permission must wind down in the EUFinansinspektionen ·