Sweden’s system of government is greatly devolved, and subnational levels of government are highly autonomous and responsible for delivering a high proportion of public services. However, they are increasingly vulnerable to the influence of organised crime groups, which are exploiting weaknesses in the public integrity framework to gain undue advantage. This chapter assesses Sweden’s integrity framework at the subnational level. It makes recommendations for improving the understanding of corruption and unlawful influence at the subnational level, aspects of the accountability framework in subnational authorities, processes for upholding integrity at different stages of the employment cycle, and rules and structures for reporting corruption in regional and municipal government.
OECD Integrity Review of Sweden
Abstract
The subnational level of government in Sweden has changed considerably in the last 50 years. Firstly, the number of municipalities and regions has been reduced. Sweden is now divided into 290 municipalities (kommuner) and 21 regions (regioner). These forms of subnational government represent both a level of self-government and of de-concentrated state authority. Regions and municipalities do not hold legislative powers, but they do have a large degree of autonomy, a constitutional right to levy taxes, and in recent decades have developed their responsibilities for providing a high proportion of public services (Figure 6.1). There is no hierarchical relation between municipalities and regions, since all have their own self-governing local authorities with responsibility for different activities.1
This development of responsibilities and the reduction in the number of subnational authorities has also seen a significant change in their staffing and bureaucracy. In the mid-twentieth century, subnational authorities were ‘lay administrations’, in which politicians were involved in every stage of the policy cycle and supported by relatively few civil servants. As the size and responsibilities of subnational authorities has developed, a professional bureaucracy has grown in which, although political members have maintained overall oversight, civil servants at the subnational level have become more responsible for preparatory and executive functions, along with aspects of the oversight and evaluation of work (Erlingsson et al., forthcoming[2]). There are now approximately 36 000 political positions in the 290 municipalities and 4 600 political positions in the 21 regions. This means that around 1% of the adult population in Sweden holds a subnational-level political position. The political members of the two levels of self-government are elected in local elections every fourth year on the same date as national elections. Overall, municipalities and regions employ approximately 1.2 million people, which is roughly 25% of total employment in Sweden. Municipalities employ approximately 900 000 people and regions employ around 310 000 (SALAR, 2024[3]).
Alongside this process of professionalisation and the developing responsibilities of subnational government, accountability and governance processes have also become more formal, both between the state and subnational levels and within subnational authorities themselves. Local self-government is stipulated in the Instrument of Government (1974:152), one of the four pillars of the Swedish Constitution, and the extent to which national government can intervene in subnational governance is clearly defined and limited. Within subnational levels of government, governance and key aspects of the integrity framework are underpinned (as well as by the Instrument of Government) by the Local Government Act (LGA) (2017:725) (Figure 6.2).
Source: (SALAR, n.d.[4])
While the parameters of interaction between central and local government are therefore well established, there is an ongoing dialogue about how the national government can better support the subnational level. For instance, a Swedish Government inquiry has recently made several assessments and proposals relating to the state's collaboration with municipalities and regions, including the state's collaboration with the Swedish Association of Local Authorities and Regions (SALAR) (Statskontoret, 2024[5]). These proposals include introducing new structures for collaboration among municipalities and regions in the form of regional councils, and putting provisions for regular consultations between state and subnational governments into law.
This chapter explores the integrity framework at the subnational level in Sweden and makes recommendations for how the national government can better support regions and municipalities to uphold integrity and counter the developing threat of unlawful influence. It assesses the understanding of corruption and unlawful influence at the subnational level, aspects of the accountability framework in subnational authorities, processes for upholding integrity at different stages of the employment cycle, and rules and structures for reporting corruption in regional and municipal government. It recommends that:
Sweden could develop a more coherent understanding of corruption and unlawful influence at the subnational level through enhanced, targeted capability building.
Sweden should support subnational level authorities to implement preventative internal control and risk management processes.
Internal audit at the subnational level should involve certified auditors.
Merit-based recruitment of employees at the subnational level could be enhanced.
Sweden could put the provisions on suspension of employees in subnational authorities on a statutory footing.
Sweden should develop support to employees and authorities at the subnational level on the reporting of corruption and unlawful influence.
As discussed elsewhere in this report, Sweden has no legal definition of corruption which applies at either the state or municipal level. The safeguards which apply to anti-corruption work at both the national and subnational level are instead constitutional principles such as legality and objectivity. In the past ten years, the Government has tried to add to these principles by introducing a broad working definition of corruption, which is that corruption involves the exploitation of a public position to obtain undue gain for oneself or another. There is also no legal definition of unlawful influence, although, as Chapter 1 of this report notes, the Brå has defined unlawful influence in public administration as an external party carrying out actions with the aim of influencing an official to act in an unethical or biased manner in the exercise of their authority or service.
Despite these efforts to clarify these concepts across the public sector, however, the Statskontoret has noted that in the last fifteen years there has been minimal change in the levels of understanding of corruption, unlawful influence, and the policies and processes to combat them at the subnational level (Statskontoret, 2023[6]). Stakeholders interviewed for this report also noted that in subnational authorities corruption is still primarily associated with acts of bribery, and that the basic understanding of what corruption is, why it is a problem and how it can be counteracted needs improvement.
The Swedish government and subnational authorities themselves are trying to build understanding in regional and municipal administrations by offering extensive awareness and capability building materials on corruption and unlawful influence. There is scope, however, given the persistent lag in knowledge and understanding at the subnational level, to enhance this offering further.
6.2.1. Sweden could develop a more coherent understanding of corruption and unlawful influence at the subnational level through enhanced, targeted capability building
Some subnational authorities offer training and guidance on corruption and unlawful influence themselves. The Statskontoret noted that in 2022 89% of subnational authorities had developed internal rules or documents that guide employees on how to act to avoid risks of corruption and irregularities. However, for training the picture is more mixed. The Statskontoret noted that in 2022 one third of subnational authorities had not provided training to increase knowledge about corruption and irregularities in the past two years. Only just under a third of municipalities and regions had included corruption in their introductory training, and only just over half of them had conducted training on corruption and irregularities for elected officials. 72% of subnational authorities develop materials to inform employees about which function they can approach for answers to questions about corruption and irregularities (Statskontoret, 2023[6]).
To supplement subnational authorities’ own awareness and capability building efforts and to address some of these gaps, several Swedish government agencies provide additional support and advice on corruption and unlawful influence, including the Statskontoret, ESV, Brå and SALAR. Non-state actors also provide training and advice, including the Swedish Institute against Bribery (IMM), Transparency International Sweden, and private consulting firms employed on specific aspects of municipalities’ governance frameworks (such as internal audits). SALAR’s offering is particularly developed, and includes publications, short courses, training modules, ethical dilemma exercises, films and podcasts (Table 6.1). Overall, the offering from these state and external agencies is well-known among municipalities and demand for support is increasing (Statskontoret, 2023[6]).
However, the Statskontoret has also noted that the way in which subnational authorities use awareness and capability building could be improved. In many instances, municipalities and regions too often implement training as a single training opportunity rather than a sustained offering, especially where it is provided by external consultants. In other cases, introductory training focuses more on welcoming new employees to the authority rather than introducing them to their obligations and to safeguards against corruption and unlawful influence (Statskontoret, 2023[6]). This unsystematic use of capability and awareness building opportunities may contribute to the minimal changes in understanding of corruption and the available processes to combat it at the subnational level. Agencies have existing assignments to continue to support the use of capability and awareness building measures in subnational authorities, and they should continue to prioritise encouraging sustained use of support opportunities in the future. Their assignments in this area should also continue to be renewed by the relevant Government Offices.
Government agencies’ existing support offering could also be developed. The impact of awareness and capability building materials can be limited where they are not directly linked to the application of the principles they highlight in practice. Especially where training materials are not mandatory or are delivered as one-offs, it is too easy for participants to forget or not to apply principles afterwards in their day-to-day work. In addition, non-mandatory training is also often only accessed by people who have identified a problem or a gap in their knowledge and want to know more, which may not necessarily be the most at-risk groups. One solution for Sweden, used by other countries (Box 6.1), could be to supplement the existing more traditional capability and awareness raising offering by mapping processes to understand where the opportunities for corruption or unlawful influence might be, or where adherence to standards and protocols might be more challenging. Rather than developing training materials and then expecting employees to seek them out and to apply them in their own day-to-day work, Swedish authorities could support implementation of standards by identifying where and when to provide prompts to employees at certain moments in their work to remind them of integrity principles and nudge them into upholding standards more effectively.
In 2018 the Romanian government adopted a standardised methodology for corruption risk management through Decision 599/2018, but after several years had still only achieved minimal and inconsistent implementation. To raise awareness, share good practices and improve implementation the Ministry of Justice offered support and assistance on demand. However, this support was not well known among public authorities and not often requested.
Analysis of Decision 599/2018 revealed that the process it proposed was more complicated than originally assumed. While the methodology proposed seven steps to manage corruption risk, a more detailed assessment which mapped the actual steps required showed that in reality there were at least 22 steps involved in logically completing the process. These additional steps included gathering and reviewing information, deducing risks from corruption incidents, establishing event causes that are abstract and multi-causal, gathering information to have an awareness of how corruption affects other institutions, predicting the effects of intervention measures and collecting feedback on the evolution of risks. The standard was therefore not as intelligible or as useful as first assumed.
To address this issue of latent complexity, Romania designed new more targeted guidance materials and dedicated points of contact to support users of the methodology in Decision 599/2018 and to improve implementation across the public sector.
Source: (OECD, 2023[8])
Risk management, internal audit and internal control systems provide assurance that public resources are applied efficiently, effectively and in line with their intended purpose. To offer greater assurance that governments are operating optimally to deliver programmes that benefit citizens, well-designed internal control and risk management policies and processes also reduce the vulnerability of public sector organisations to fraud and corruption (OECD, 2020[9]; OECD, 2017[10]). These principles apply to all levels of government, including at the municipal and regional level.
The OECD PIIs show that Sweden has an established and highly functioning internal control, risk management and internal audit framework in place, which compares well to other OECD countries (OECD Public Integrity Indicators, 2025). Sweden intends to strengthen this framework further with the merger of the Statskontoret and the ESV in January 2026, which will provide a single authority tasked with assessing and analysing the public administration's functioning, efficiency, organisation and development (Statskontoret, 2025[11]).
Much of the existing internal control framework only applies at the state level, however, and internal control, risk management and internal audit in subnational authorities could be improved to ensure they remain efficient and resilient to corruption. The new, merged Statskontoret could help in this regard. This section assesses the internal control, risk management and internal audit framework at the subnational level. It suggests that the new Statskontoret and SALAR could improve support to subnational authorities on internal control and risk management, and that internal audit at the subnational level should involve certified internal auditors.
6.3.1. Sweden should support subnational level authorities to implement preventative internal control and risk management processes
The responsibility to manage corruption risks lies with personnel at all levels of a public authority. However, management is responsible for creating and maintaining a control environment that emphasises integrity in accordance with the three lines model (The Institute of Internal Auditors, 2024[12]). Internal control and risk assessments should aim to ensure the efficient and lawful use of funds and the prevention of corruption as a threat to an authority’s objectives and efficiency. The exact form that internal control and corruption risk assessment takes in a public authority should depend on its size, its resources, and whether it operates in a high-risk sector (for example, public procurement or infrastructure). Corruption and fraud risk assessments can be stand-alone exercises or embedded into an authority’s risk assessment activities, recognising the interlinkages among different risk categories, such as strategic, operational, financial, compliance and reputational risks. Risk management should also be an iterative process of establishing the context, assessing and treating risks and ensuring ongoing monitoring, communication and consultation.
Internal control and risk management at the subnational level in Sweden is based on new requirements in Section 6 of the LGA, which came into force in July 2025. These new provisions were intended to introduce a more preventative approach to internal control and risk management at the subnational level (Box 6.2). The rationale was, as the APACUI noted, that it is only when municipalities and regions fully use internal control as a preventive tool against errors and irregularities that conditions for detecting and preventing such actions that can cause financial or other damage can be improved. Introducing these reforms was all the more important given the Swedish Government’s growing concern around the changing risks to subnational levels of government, including in relation to the use of unlawful influence by organised crime groups and actors to exploit loopholes in control mechanisms and to seize advantages to conduct criminal activities (Government of Sweden, 2024[13]).
Since entering into force on 1 July 2025, the new Section 6 of the LGA states that committees in regional and municipal authorities:
“shall each ensure within their area that the activities are conducted in accordance with the objectives and guidelines determined by the council and the provisions of laws or other statutes that apply to the activities. They must also ensure that internal control is sufficient to prevent errors and irregularities in the activities, and that the activities are conducted in an otherwise satisfactory manner. The same applies when the management of a municipal matter pursuant to Chapter 10.1 has been handed over to someone else.”
Source: The Local Government Act (2017:725).
The Swedish Government should now aim to support the implementation of the new preventative approach to internal control at the subnational level as far as possible. Firstly, in the medium and long-term, Sweden should assess whether the new provisions are having the desired effect. During the design and passage of the Bill introducing the reforms, several stakeholders raised concerns about the wording of the new provisions and how applicable they might be in practice. Among these concerns was that the wording of the new provisions was not specific enough to provide the intended clarity of subnational authorities’ responsibilities on internal control and risk management. Although the Swedish Government maintained that “it is neither necessary nor appropriate to include an exhaustive list in the legal text of all expressions or acts” that subnational authorities should now be seeking to prevent through internal control, several stakeholders called for greater clarity on what constitutes an irregularity or error in practice (Government of Sweden, 2024[13]). In addition, stakeholders argued that the new provisions deviate too much from similar provisions related to heads of government agencies’ internal control responsibilities, leaving the risk that differences in the national and subnational approach to anti-corruption work will grow (Statskontoret, 2024[14]). Sweden should therefore conduct a full ex post review of the new provisions to ensure that they are providing the intended clarity and effect on subnational authorities’ ability to prevent errors and irregularities, including corruption, through internal control. The merged Statskontoret would be well-placed to conduct a full assessment of the effectiveness of the new provisions, and could be given an assignment to that effect.
Secondly, subnational authorities should be offered further support and guidance to help them to implement their new responsibilities. The Statskontoret survey which prompted the Swedish Government to develop the new provisions noted that subnational authorities face several challenges in internal control and risk management, which the introduction of new legal requirements for a preventative approach will not solve alone. The Statskontoret noted that around 40% of subnational authorities have not analysed their risks of corruption and irregularities, and that only 42% of subnational authorities conduct an annual risk analysis compared to 53% at the state level (Statskontoret, 2023[6]). As well as less clear requirements on internal control for subnational authorities compared to the state level, which the new provisions are intended to address, the Statskontoret noted that subnational authorities were struggling to undertake risk management and internal control because of a lack of resourcing, expertise and guidance from the centre on what these processes should involve.
At the state level, several regulations set out explicit requirements for how authorities should ensure the efficiency and effectiveness of their work, including through risk management and internal control (including the Ordinance (2007:603) on Internal Governance and Control, and the Authority Ordinance (2007:515)). In addition, the Statskontoret and ESV have each issued detailed guidance documents to state authorities on how to conduct risk management and internal control (Statskontoret, 2022[15]; ESV, 2024[16]). In comparison, for subnational authorities no regulations elaborate the requirements for internal control and risk management, beyond the wording of the new provisions in the LGA, and there is little additional guidance from the state level or SALAR on how best to conduct these processes. Like they have done for the state level, therefore, and like other OECD countries (Box 6.3), the new Statskontoret, along with SALAR, could provide guidance to subnational level authorities, along with offering examples of challenges and good practices, to enable subnational authorities to better interpret and implement their responsibilities under the LGA and to mitigate resourcing and expertise constraints as far as possible. The Statskontoret and SALAR could also use existing forums for information sharing and exchange of best practices at the subnational level. Sessions could focus on realistic scenarios and proven best practices, helping subnational authorities to interpret and develop a common understanding of the new provisions. Doing so could help subnational authorities to develop and implement stronger internal control and risk management processes which better safeguard against corruption and unlawful influence.
The UK’s Local Government Association (LGA) is the representative body for local government. The UK’s LGA offers guidance to local authorities on risk management. Overall, the guidance aims to help those in leadership roles to understand what good risk management looks like and to undertake their roles in managing risk successfully.
The guidance notes that it is important to create a strong culture of risk management, with the importance of risk management processes understood across organisations and embedded in ways of working. It suggests that assurance should be continuous, not just an annual activity or one prompted by an unwanted event. With this in mind, it offers insights into:
the key ingredients of effective risk management as part of the organisation’s broader governance assurance arrangements.
senior political and managerial leaders’ roles in ensuring that risk management processes are carried out appropriately.
what good risk management looks like.
the questions to ask to receive the vital assurance that the risk management arrangements are effective and facilitating the successful achievement of objectives and keeping the local authority safe, compliant and accountable.
The guidance is published under the Sector Led Improvement Initiative (SLI), which is based on the underlying principles that local authorities are:
responsible for their own performance.
accountable locally, not nationally.
there is a sense of collective responsibility for the performance of the sector as a whole, and.
the role of the UK’s LGA is to provide tools and support.
Through a co-ordinated approach to sector-led improvement across local government, the UK’s LGA support helps local authorities continue their own improvement journey, access key resources and support and contribute to the improvement of local government as a whole.
6.3.2. Internal audit at the subnational level should involve certified auditors
As at the national level, internal audit is an important aspect of subnational authorities’ ability to achieve financial objectives and control resources, to improve decision making and risk management, and to support overall strategic and operational goals. As well as providing independent, objective assessments of the management of public resources, internal auditors can help public sector organisations to better manage and assess integrity risks. In practice, this can involve internal auditors identifying integrity risk factors and assessing whether they are being managed effectively by, for example, flagging and assessing corruption risk areas such as third-party relationships, outsourced activities or procurement (OECD, 2020[9]).
In Sweden, internal audit in subnational authorities is carried out by teams of elected auditors and professional experts. For every term of office, subnational authorities are legally required to appoint a minimum of five elected auditors, though in practice this number tends to be slightly higher (SALAR, 2023[19]). These elected auditors are ultimately responsible for the audit and are typically affiliated to one of the political parties represented in the subnational council. They thus contribute both oversight and an understanding of the operation of subnational authorities and the democratic process at this level (SALAR, 2024[20]). To preserve their independence, the elected auditors do not represent their party in any subnational authority board or committee during the time they serve as an auditor.
Elected auditors must engage professional experts to assist them in the audit, a process which is regulated by the LGA. Only the elected auditors can decide which experts they engage, meaning that no other body in the municipality or region can do so. Given that at the subnational level audit assignments are broad and include financial and operational audits to assess the work of the executives and committees, elected auditors must engage expert assistance to the extent necessary to fulfil the assignment in accordance with good auditing practice, based on their own assessment of the support they need to submit a well-founded audit report (SALAR, 2024[21]).
However, while in practice a large proportion of experts are certified municipal professional accountants or authorised public accountants, the competence requirements for professional experts could be enhanced (SALAR, 2023[19]). At present, the only competence requirement which the LGA places on the recruitment of professional experts is that they ‘must have the insight and experience of municipal operations required to be able to fulfil the assignment’. This legal requirement is interpreted in several pieces of guidance recently published by SALAR (Box 6.4). Beyond the broad requirement in the law and SALAR’s guidance, though, there is no detailed requirement around the formal competence which professional experts should have to be eligible for hire in subnational government audit. SALAR has noted that this lack of specificity allows for experts with different training and experience to be appointed depending on what is needed in a given assignment (SALAR, 2024[21]). However, placing more formal requirements on auditors’ competency would not necessarily preclude this range of expertise and may assure the quality and usefulness of subnational audit.
SALAR’s Good Auditing Practice in Municipal Operations guidance notes that:
“Experts are certified municipal professional accountants, authorised public accountants or other specialists in municipal operations.”
It also notes that:
“According to the Local Government Act, experts must have sufficient knowledge of and experience in municipal operations. This means knowledge of audit methodology as well as, among other things, finance, organisation, governance and internal control, and of the municipal operations that the audit examines”.
SALAR’s Procurement of Experts in Municipal Auditing guidance further notes that:
“Knowledge and experience of municipal operations means theoretical and practical experience in, for example, care and welfare, social services, healthcare, education, law, IT, strategic planning, municipal technology and properties, infrastructure, culture and leisure. This means that competence must be available in various branches of activity and functions that occur in municipalities and their companies. Understanding of operations is therefore an important ingredient in the experts' qualifications, as well as insights into the political system, its conditions and operations”.
Source: (SALAR, 2022[22]; SALAR, 2024[21])
Like other OECD countries, Sweden should require that financial and performance audits at the subnational level involve certified auditors (Box 6.5). Several certification bodies in Sweden already provide different certification schemes. The Swedish Association of Professional Local Government Auditors (SKYREV) offers a certification in municipal auditing, which requires, among other things, a university education at least at bachelor's level in economics or public administration, current continuing education and supervised practical experience in municipal auditing (SKYREV, 2025[23]). This scheme is in addition to the certification schemes offered by the Institute for the Accountancy Profession in Sweden (FAR) (FAR, 2025[24]). There is already, therefore, an established infrastructure for the certification of auditors in Sweden whose professional ethical principles and quality standards are recognised in the recently published Standard for Municipal Financial Auditing, and which could be more formally required in subnational audit (FAR - SALAR - SKYREV, 2024[25]).
Requiring that each audit of subnational levels of government includes experts accredited through these established and recognised frameworks could enhance the professionalism, reliability and competence of municipal audit. Having auditors who are subject to external accreditation introduces an important institutional safeguard that directly interferes with the operating space of organised criminal networks. Accredited auditors would not only be employees of the local authority. They are bound by professional standards, external oversight, and independent disciplinary mechanisms, which makes them harder to manipulate or intimidate. The risks of detection rise, as do the consequences for any attempt to bribe or pressure them. For the criminal actor, the cost-benefit calculation shifts. Influencing a compliant, unaffiliated auditor may be easier, but attempting to compromise someone who operates under professional scrutiny and is required to report irregularities is harder and riskier. Accredited auditors also apply standardised audit methodologies and are trained to identify patterns associated with fraud, collusion, and misuse of funds, all common features of organised crime schemes. Their work is not only more technically robust, but also more likely to trigger formal reporting mechanisms and reach higher levels of administrative or judicial review. Accreditation also gives auditors a degree of protection and professional solidarity that reduces their vulnerability to pressure. They are part of a recognised profession, often with national or international backing, which offers them channels for support, professional development, and protection if they blow the whistle or refuse to comply with improper demands. In an environment where fear, silence, or resignation can easily take hold, this external accountability helps reinforce ethical resistance. Including auditors subject to accreditation standards could therefore offer an additional layer of assurance over the conduct and integrity of auditors and the audit which, as SALAR has noted elsewhere, could provide a valuable safeguard and countermeasure to the increasing influence of organised crime at the subnational level (SALAR, 2024[26]).
Municipal audit in the UK
The UK’s LGA offers guidance to local authorities on conducting audits in its Must know guide: Working with auditors. This guidance makes clear that the UK’s Accounts and Audit Regulations 2015 (SI No. 234), Part 2 (Internal Control), Section 5, states that a relevant authority (including local authorities) “must undertake an effective internal audit to evaluate the effectiveness of its risk management, control, and governance processes, taking into account public sector internal auditing standards (PSIAS) or guidance”.
The PSIAS state that an audit should be overseen by a Chief Audit Executive, a person in a senior position responsible for effectively managing the internal audit activity in accordance with the internal audit charter and the mandatory elements of the International Professional Practices Framework. The Chief Audit Executive must have appropriate professional certifications and qualifications (CMIIA, CCAB or equivalent) and be suitably experienced. The chief audit executive must also obtain competent advice and assistance to ensure the internal auditors have the knowledge, skills, or other competencies needed to perform all or part of the engagement, including in the areas of fraud and digital technologies.
The guidance is published under the UK’s LGA’s Sector Led Improvement Initiative.
Municipal audit in Saskatchewan, Canada
Saskatchewan’s Municipal Audit Guidelines have been prepared to assist municipal councils, administrators and auditors in their roles and responsibilities related to the conduct of municipal annual financial statement audits. The Guidelines note that Section 188(1) of the Municipalities Act, Section 159(1) of the Cities Act and Section 210(1) of the Northern Municipalities Act state that every auditor of a municipality must be a member in good standing of an accounting profession recognised pursuant to the Accounting Profession Act, 2014.
The Accounting Profession Act states that the practice of professional accounting involves, inter alia, “performing an audit engagement and issuing an auditor’s report in accordance with the standards of professional practice published by Chartered Professional Accountants of Canada, as amended from time to time, or an audit engagement or a report purporting to be performed or issued, as the case may be, in accordance with those standards”. It further states that “no person who is neither a licensed member nor a licensed firm shall provide or perform [accounting] services”.
Developing a merit-based public service, in which integrity is upheld upon entry, throughout tenure, and on departure from public office, is essential to building a culture of integrity and ensuring efficient public service delivery. The Recommendation on Public Integrity recommends that countries should promote a merit-based, professional public sector dedicated to public service values and good governance, including through:
ensuring human resource management that consistently applies basic principles, such as merit and transparency, to support the professionalism of the public service, prevents favouritism and nepotism, protects against undue interference and mitigates risks for abuse of position and misconduct;
ensuring a fair and open system for recruitment, selection and promotion, based on objective criteria and a formalised procedure, and an appraisal system that supports accountability and a public service ethos (OECD, 2017[10]).
These values apply to all tiers of government, including at the state and subnational levels. Sweden recognises these principles and, as explored further elsewhere in this report, has an established framework for upholding a merit-based public service at all stages of the employment cycle.
In recent years, however, Sweden has begun to reassess the drivers of corruption risk especially at the subnational level. The influence of organised crime and its impact on public integrity at the subnational level has become a particular concern. The Brå has assessed how organised crime groups seek to exploit different stages of the employment cycle to recruit facilitators. The Brå has identified four different types of facilitators: manipulated, developed, profit driven and placed (Table 6.2). The first three types apply more (though not exclusively) to people already in roles, while the fourth type relates more to influencing people entering roles.
Sweden has already developed several measures, many through the APACUI and the National Strategy Against Organised Crime, to reform public office holders’ employment and working conditions at the subnational level in the face of increasing unlawful influence. These measures include proposals to introduce an obligation in the LGA for municipalities and regions to prevent ill health or accidents resulting from threats and violence against certain elected officials. Several other measures aim to enhance subnational authorities’ ability to check employees and candidates against the criminal record or suspect registers, and to reform legal provisions on the suspension of employees where there is reason to suspect their objectivity and impartiality. And still other measures aim to strengthen protections, physical security and wellbeing for public employees and elected officials with a particular focus on the subnational level. This is a comprehensive reform package, and Sweden should continue to press ahead with these efforts as a priority. In addition, though, Sweden could take several other steps to enhance public integrity and mitigate unlawful influence over the employment cycle at the subnational level. This section suggests improvements to the merit-based recruitment of civil servants in regions and municipalities and measures to suspend employees in subnational authorities where there is adequate reason.
6.4.1. Merit-based recruitment of employees at the subnational national could be enhanced
Merit-based recruitment is founded on the principle that staffing processes should involve the systematic and objective evaluation of skills, talent, experience, and competence to assess suitability for a role. Done well, merit-based recruitment can foster loyalty to public service and shared values, thus nurturing a professional civil service which is resilient to corruption, able to serve its democratically elected government and to deliver efficient and effective public services (OECD, 2020[9]).
In Sweden, merit-based recruitment is based on the Instrument of Government (1974:152) and the Public Employment Act (1994:260) (PEA). Chapter 1, Article 9 of the Instrument of Government states that courts of law, administrative authorities and others performing public administration functions shall pay regard in their work to the equality of all before the law and shall observe objectivity and impartiality. It therefore establishes a basic principle of objectivity, which also applies at the subnational level, including in recruitment. However, although Chapter 12, Article 5 of the Instrument of Government sets out that “when making appointments to posts within the central government administration, only objective factors, such as merit and competence, shall be taken into account”, no equivalent requirements exist in relation to local authorities. Likewise, while Section 4 of the PEA sets out that for recruitments into the Swedish civil service “consideration shall be given only to objective grounds, such as merit and skill [and that] skill must be given priority, unless there are special reasons for otherwise”, these provisions in the PEA only apply to civil servants employed at the state level, not employees of municipalities and regions. This means that, although many municipalities have voluntarily developed their own guidelines or collective agreement provisions that contain principles on recruitment, recruitment at subnational levels is not bound by the same explicit statutory principles of merit and skill as at the state level. There is no reason to believe that recruitment at subnational levels of government in Sweden does not generally follow due process, though concerns about nepotism at the subnational level have been raised consistently in the last decade (Statskontoret, 2023[6]). The relative absence of statutory safeguards on recruitment at this level, however, may mean municipal and regional governments are not as protected as they could be against undue influence, including, for instance, organised crime groups’ use of placed facilitators.
As well as through the Brå’s work, Sweden has recognised the threat of facilitators (also often referred to as insiders or enablers) in the National Strategy Against Organised Crime. There, the Swedish Government notes that research and government agency reports have shown that actors within criminal networks use insiders to facilitate criminal behaviours, commit offences, avoid detection, avoid or reduce criminal penalties or other sanctions, and launder the proceeds of crime. The Strategy also notes, as the Brå has done, that individuals with links to organised crime seek employment in specific activities for the purpose of obtaining information or exerting influence (i.e. placed facilitators). In addition, the Swedish Police Authority has assessed that intensified law enforcement could lead in turn to criminal actors intensifying their attempts to get access to information from inside government agencies to counter the Police’s efforts (Government of Sweden, 2023[31]).
As the National Strategy Against Organised Crime has made clear, in the face of these threats and despite a challenging labour market, it is important to maintain robust and diligent recruitment processes. It is essential that employers have the tools needed to conduct thorough and secure recruitment processes as part of the routine protection of their activities (Government of Sweden, 2023[31]). In addition to the ongoing reforms set above, therefore, Sweden could extend the statutory requirement for the objective assessment of merit and skill in recruitments to the subnational level. Such statutory requirements exist in other OECD countries (Box 6.6). These extended statutory provisions could be reinforced by up-to-date guidance on recruitment at the subnational level from SALAR, which identifies risks, collates good practices and supports subnational government to conduct merit-based recruitment and to counteract the threat of placed facilitators of organised crime.
In Finland, the principles for recruitment into the public service are laid out in the Constitution of Finland. Section 125 of the Constitution lays out the general qualifications for public office and other grounds for appointment, and states that “the general qualifications for public office shall be skill, ability and proven civic merit”.
This principle is then applied in the context of recruitment to municipalities in the Act on Municipal and Wellbeing Services County Officials, which recalls the general grounds for appointment to public services set out in the Constitution and establishes the procedure for recruitment in subnational authorities.
Source: The Constitution of Finland, 731/1999 English; Act on Municipal and Wellbeing Services County Officials, 304/2003.
6.4.2. Sweden could put the provisions on suspension of employees in subnational authorities on a statutory footing
In addition to establishing merit-based recruitment processes, OECD countries should also have policies and processes in place for maintaining integrity once employees are in their role, along with incentives for good behaviour and disciplinary measures (including sanctions) for breaches of conduct (OECD, 2017[10]; OECD, 2020[9]). Again, this principle applies at all levels of government, including the subnational level. Other chapters in this report have explored and made suggestions for improving Sweden’s framework for ensuring that public office holders continue to act with integrity once in role. Although many of the policies and processes explored in other chapters do not apply at the subnational level in Sweden, there is still an established legal framework for maintaining integrity at this level of government, including in the LGA and the applicable sections of the PEA and Employment Protection Act (1982:80). These legal provisions are supplemented by the General Provisions (AB), part of the main collective agreement (HÖK) between SALAR and the central trade unions, which contain general terms and conditions of employment, some of which relate to upholding subnational employees’ integrity (SALAR, 2025[32]) (Box 6.7).
Collective Agreement
In Sweden, the labour market is regulated both by laws, which stipulate minimum standards for employment conditions, and by collective agreements that supplement the legislation with additional conditions. Trade unions and employers negotiate the content of collective agreements which regulate matters such as terms and conditions of employment, working time and salaries. This ensures that Sweden has a flexible labour market with the scope to tailor certain conditions to different industries, companies and individuals, all without the involvement of the legislature.
Collective agreements set norms and minimum standards and are usually time limited. When agreements expire, the parties renegotiate the terms in a collective bargaining process. A collective agreement applies to everyone working within a sector or at a workplace covered by the agreement, meaning it is applied even to employees who are not members of a union.
General Provisions (AB)
In its role as an employers' organisation, the Swedish Association of Local Authorities and Regions signs collective agreements with the central trade unions for almost 1.2 million employees. The union is thus Sweden's largest employers' organisation. For municipal companies and municipal associations that are members of the Employers' Union Sobona, Sobona signs a corresponding collective agreement.
The General Provisions (AB) is a collective agreement, elements of which are renegotiated in annual negotiation rounds, between SALAR and Sobona – the Municipal Companies' Employers' Organisation, and along with trade unions such as the Swedish Municipal Workers' Union, OFR's union area General Municipal Operations and Health and Medical Care, and AkademikerAlliansen and affiliated national organisations. The General Provisions (AB), which were most recently renegotiated and published in May 2025, contains general terms and conditions of employment at the subnational level, including terms and conditions of employment, working time and salaries.
The growing focus on unlawful influence has prompted the Swedish Government to revisit the usefulness and applicability of integrity measures at the subnational level. Particular attention has been given to the possibility of conducting checks on employees and candidates against the criminal record and the suspect register as a means of counteracting criminal actors’ and networks’ attempts to identify, recruit and retain facilitators who already hold public sector roles at the subnational level (Table 6.2). In October 2024, an investigator concluded an investigation into the viability of expanded criminal and suspect register checks for employees in municipalities. Among other things, the investigator recommended that municipalities, municipal companies, foundations, and associations should be able to conduct register checks when hiring for positions that are critical to the municipality's ability to carry out its mission. No proposal was made, however, that municipal employers should have the right to regularly conduct renewed or ongoing register checks during ongoing employment (Ministry of Justice, 2024[35]). Although other stakeholders have maintained that such in-role checks are necessary (Transparency International Sweden, 2025[36]), the investigator argued that the infringement on individuals' privacy through ongoing checks could not be justified. In addition, the investigator noted that municipalities have the option to dismiss or suspend employees where certain criteria are met (Ministry of Justice, 2024[35]). The investigator’s extensive arguments about the unviability of in-role register checks notwithstanding, there may be scope for Sweden to improve the effectiveness of rules on suspension from employment in instances of serious misconduct, including related to unlawful influence.
The Swedish Government has recently developed legislative proposals that enable an employee to “be suspended from work if the employee exhibits behaviour that can be assumed to lead to termination or dismissal and there is a risk that continued work 1) damages trust in the authority, 2) hinders the proper conduct of the business or 3) hinders the continued investigation of the behaviour and whether the behaviour should lead to labour law measures” (Government of Sweden, 2024[37]). These proposals have been referred to the Council on Legislation for consideration, and a Government Bill is planned to be submitted to the Riksdag in September 2025, with a proposed entry into force on 1 January 2026. The Government’s argument for developing these new provisions was that in recent years general legal provisions for suspension of employees have been repealed (except for certain categories of public employee such as union representatives), as had a collective agreement containing similar provisions. The Labour Court also ruled in 2022 that a state employer cannot suspend an employee on the basis of a collective agreement or the general right to work management because the measure lacks legal support. The Government has therefore argued that in this context there is a need to expand the possibilities, with the support of law, to suspend government employees (Government of Sweden, 2024[37]).
However, this new provision only applies to central government employees. For subnational level employees, suspension due to misdemeanours is regulated by the General Provisions (AB) 25. According to the General Provisions, an employee may be suspended from work by the employer due to an offence. If an employee is suspected on probable grounds of or proven to be guilty of serious misconduct or negligence at work, a crime that may result in imprisonment, or a serious offence outside of employment, the employer has the right to suspend the employee pending a final decision. Suspension may also be made if there are other compelling reasons (SALAR, 2025[38]). Beyond the General Provisions, though, there are no statutory provisions for suspension of employees at the subnational level. Sweden could therefore adopt statutory provisions for employees at the subnational level along the lines recently adopted at the state level. As with the new provisions at the state level, any new legal provisions at the subnational level would need to undergo extensive consultation with stakeholders, particularly trade unions, to ensure the continued protection of employees’ rights. But once adopted, statutory provisions on the suspension of employees at the subnational level could provide greater parity between the state and subnational level, greater stability and clarity in the rules on suspension of employees for misdemeanours, and better safeguards against unlawful influence and organised criminals’ recruitment of facilitators in role. They may also support the investigation of suspected misdemeanours, and to mitigate the risk highlighted by the Statskontoret that the people suspected of committing crimes may themselves or through others possess violent capital and be strongly motivated destroy evidence and to hinder investigations (Statskontoret, 2023[6]).
Developing structures to enable the reporting of corruption, and a corresponding culture of openness in which people feel able to report, is vital to countries’ ability to uphold integrity and counter corruption. The Recommendation on Public Integrity calls on countries to support an open organisational culture within the public sector which is responsive to integrity concerns, including through:
Fostering an open culture where ethical dilemmas, public integrity concerns, and errors can be discussed freely, and where appropriate, with employee representatives, and where leadership is responsive and committed to providing timely advice and resolving relevant issues;
Providing clear rules and procedures for reporting suspected violations of integrity standards, and ensuring, in accordance with fundamental principles of domestic law, protection in law and practice against all types of unjustified treatments as a result of reporting in good faith and on reasonable grounds;
Providing alternative channels for reporting suspected violations of integrity standards, including when appropriate the possibility of confidentially reporting to a body with the mandate and capacity to conduct an independent investigation (OECD, 2017[10]).
In addition to ensuring adequate structures are in place within organisations, however, countries must also ensure that appropriate procedures are in place for authorities to investigate reports of corruption and to pass information to law enforcement agencies if appropriate. In this way, successfully acting on reports of corruption relies on the efficient and proactive collaboration of a range of actors within and outside the entity in which a report is received (OECD, 2020[9]).
As noted in the Working Group on Bribery’s Phase 4 review of Sweden, Sweden’s whistleblower protection legislation has evolved in recent years (OECD, 2024[39]). Sweden adopted a Whistleblower Act in 2016, applicable to public and private sector employees, but limited to those in a direct employment relationship (excluding, for example, volunteers and those pre- or post-employment). This legislation also did not guarantee anonymity. Whistleblowers could become exposed through a system of internal reporting and subsequent reporting to regulators. Following the 2019 EU Directive on the protection of people who report breaches of Union law (EU) 2019/1937, Sweden implemented the Act on the Protection of Persons Reporting Irregularities (2021:890) (the Whistleblowing Act). The Whistleblowing Act has a broad personal and material scope, and safeguards against liability, obstructive measures and retaliation apply to natural persons who report or publicly disclose information on irregularities acquired in the context of their work-related activities. In terms of reporting channels, any public or private operator which has 50 or more employees at the start of the calendar year is obliged to set up internal reporting channels and have reporting and follow-up procedures in place. Competent public authorities must also set up and maintain external reporting channels and make such channels accessible to reporting persons.
In addition to the Whistleblowing Act, Sweden has adopted two further supplementary regulations. Firstly, over 30 national authorities and all 21 County Administrative Boards have been nominated as competent authorities to handle whistleblowing reports in the Ordinance on the Protection of Persons Reporting Irregularities (2021:949). This regulation clarifies which national authorities are responsible for acting as external channels for each of the policy areas listed in the EU Whistleblowing Directive, with multiple authorities listed for several types of policy area. The Swedish Work Environment Authority is identified as the authority with responsibility for oversight over the functioning of the internal reporting channels. Secondly, the Ordinance on State Grants for Information and Advice on the Protection of Persons Reporting Misconduct (2021:950) tasks the Swedish Work Environment Authority with providing funding to trade unions, employer organisations and civil society organisations to ensure that whistleblowers covered by the protection under the new law receive clear, easily accessible and free information and advice on reporting.
In terms of the obligations on public authorities to report corruption to law enforcement agencies, as Chapter 3 of this report notes, state level authorities are required to report corruption to the Swedish Prosecution Authority under Section 22 of the PEA. This provision explicitly requires reporting of bribery and official misconduct offences, but there is also a requirement to report any other crime that could carry a sanction beyond just a fine.
Both Chapter 3 and the Working Group on Bribery’s Phase 4 review of Sweden have made several recommendations for improving authorities’ reporting of corruption to law enforcement agencies and for enhancing Sweden’s whistleblowing framework. These include extending the reporting requirements under the PEA to subnational authorities, and improving aspects of the Whistleblowing Act including clarifying the definition of retaliation and related sanctions and extending rights to compensation (OECD, 2024[39]). Beyond these recommendations, however, it is also clear that further support is necessary for both prospective reporters of corruption and unlawful influence and public authorities at the subnational level.
6.5.1. Sweden should develop support to employees and authorities at the subnational level on the reporting of corruption and unlawful influence
While, as explored further in Chapter 3, Sweden relies heavily on reporting for the detection of corruption, in practice it is questionable both how far people are engaging with Sweden’s whistleblowing framework and how effectively subnational authorities are reporting corruption to law enforcement authorities. For whistleblowing, it is difficult to judge the exact levels and nature of engagement with the framework because, as the Working Group on Bribery noted (and suggested that Sweden should start), Sweden does not systematically keep statistics on the number of whistleblower reports received in relation to corruption or how those reports were dealt with (OECD, 2024[39]). However, the Statskontoret has noted a perceived culture of silence in municipalities and regions, with many employees at the subnational level reluctant to talk about or act when wrongdoing occurs due to a pervasive fear of reprisals including the loss of employment (Statskontoret, 2023[6]). Likewise, Swedish officials noted in preparation for this report that the legal framework for whistleblowing is complicated and that it can be difficult for prospective whistleblowers to understand how to raise concerns. This may cause a reluctance to engage and confusion about how to raise concerns through the whistleblowing framework and which processes should be engaged and when (Fast Lappalainen, 2023[40]). Where people do raise concerns, in many instances they do not qualify as whistleblowing reports, pertaining instead to, for instance, work environment issues which should be handled by HR functions (Statskontoret, 2023[6]).
In terms of authorities’ reporting of corruption to law enforcement agencies, the Statskontoret has also noted that it can be difficult for municipalities and regions to know how to handle situations where suspicions of corruption arise within their own organisation. This confusion includes how far the municipality or region should try to investigate the suspicions themselves, when they should hand cases to law enforcement agencies, and what happens to cases then (Statskontoret, 2023[6]). Swedish officials corroborated these points in preparation for this report, noting as well that in many subnational authorities only one person is responsible for corruption, in addition to their regular work, and that they often therefore lack the expertise and resourcing to be able to prevent corruption and respond to allegations when they arise. These tensions are also increasing as the threat of unlawful influence develops.
The Statskontoret, Brå and SALAR all conduct work to improve individuals’ and authorities’ abilities to report corruption at the municipal and regional level. These include the Statskontoret’s general assignment, due to finish in September 2027, to support the work against corruption in public administration (assignments Fi2023/03160, Fi2023/03216, and Fi2024/00096) and the Statskontoret and Brå’s joint assignment, due to finish in May 2026, to support the work against unlawful influence in the public administration (assignment Fi2024/01456). However, given that, as Chapter 3 notes, reporting of corruption offences has remained relatively stable over the last five years, that the threat of unlawful influence is growing, and particularly if Sweden chooses to introduce a legal requirement for subnational level authorities to report corruption to the police, these awareness and capacity building efforts could intensify. Other OECD countries have implemented extensive information campaigns regarding whistleblowing or have published detailed guidance to authorities on reporting corruption to law enforcement, which Sweden could take as an example (Box 6.8). Continuing and intensifying capacity building, and incorporating benchmarks and indicators for assessing its impact, could provide valuable safeguards against corruption and unlawful influence at the subnational level in Sweden.
The Slovak Republic’s “Speaking Up Is Golden” campaign
The Office for the Protection of Whistleblowers conducted a comprehensive awareness-raising campaign from September to December 2022 to better inform the public about the role of whistleblowing, the process for raising concerns, and the status and responsibilities of the Office. A key aim of the campaign was to improve citizens’ perceptions of whistleblowing, removing the stigma attached to raising concerns and introducing the notion that “Speaking up is golden”.
The national campaign included over 186 outputs on all traditional and social media, encompassing public debates, talk shows, concerts and a podcast called “The Unsilentables”. The Office was mentioned 508 times in the media. It enlisted national figures, such as the president of the police and Slovak celebrities, to act as champions of the campaign. In 2023, the campaign won the Association for Public Relations of the Slovak Republic’s Prokop award for best Slovak public relations project in the public sector category.
Results from opinion surveys conducted by the Office in January 2022, November 2022, and May 2023, indicate a positive and lasting impact of the campaign, in terms of citizens’ perceptions of whistleblowing, identification of the Office and its role, and their willingness to report corruption:
In May 2023, 66% of Slovak citizens surveyed perceived a whistleblower as ‘positive’ or ‘very positive’, compared to 61% in November 2022 and 58% in January 2022. Demand for whistleblower protection stabilised at 77%, compared to 79% in November 2022.
20% of Slovaks are aware of the existence of the Office and its role as a public institution for whistleblower protection. Awareness stabilised after it had previously risen from 11% (January 2022) to 19% (November 2022).
When asked to whom they would be willing to report corruption or fraud if witnessed at the workplace, most respondents selected their employer. The Office however is making progress, with almost two-fifths willing to report to them.
Lithuania’s guidance to civil servants and equivalent persons who have encountered corruption
Lithuania’s Special Investigation Service (STT) organises a range of anti-corruption awareness and capacity building measures aimed at increasing public employees’ and public authorities’ knowledge of how to report corruption. These measures include formal integrity education delivered to public office holders through the Integrity Academy, e-learning modules through the e-learning platform, an annual anti-corruption hackathon (designed to bring the public and private sectors together to find innovative ways of improving counter-corruption measures, including reporting), and formal guidance documents on the issue of reporting.
For example, the ‘If you are a civil servant (or a person equivalent thereto) and have encountered corruption, you must know…’ guidelines set out, inter alia, the responsibilities which public office holders and authorities have to report corruption, who to report to, the process for doing so, what will then happen to the report, and methods of assistance or protection for those making reports.
The STT collates annual statistics on the impact of its awareness raising measures, including data on the use of support materials (broken down by type of material), and the changing views on corruption reporting (broken down by type of potential reporter).
Source: OECD elaboration and (Office for the Protection of Whistleblowers, 2023[41]; STT, 2021[42])
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← 1. The only exception is Gotland, where the municipality also has the responsibilities and tasks normally associated with a region.