OECD Integrity Review of Sweden

Executive summary

Long perceived as among the least corrupt countries in the world, Sweden has a strong culture of public integrity, high interpersonal and institutional trust and developed public service values. However, Sweden is not immune to corruption. The growing power and influence of organised crime groups have refocused the Swedish Government’s attention on emerging public sector corruption risks.

The Swedish Government now regards organised crime as a systemic threat to society, with organised criminals infiltrating government agencies and political parties, silencing witnesses, threatening public employees, systematically defrauding welfare systems, and capturing public procurements. The Swedish criminal economy has an estimated annual revenue of SEK100–150 billion, and gun violence has almost tripled since 2011. Stronger safeguards are therefore needed to protect public authorities, their employees and the public policy cycle. The Swedish Government is implementing a range of reforms, including on corruption offences, lobbying and influence, the culture of integrity at national and subnational levels, and the digitalisation and use of data in public procurement.

However, Sweden could go further. The OECD Public Integrity Indicators (PIIs) show that, while Sweden sits above the OECD average for the quality of its anti-corruption strategy and risk management framework, it trails the OECD average on the management of conflicts of interest, lobbying, the revolving door and political finance. Moreover, although Sweden’s devolved public governance model allows public authorities to apply integrity and public service principles according to their context and needs, it can also lead to inconsistencies in understanding and efforts to address corruption and unlawful influence across the public sector. Further regulatory, capacity-building and oversight measures could enhance Sweden’s culture of integrity, improve the integrity framework’s implementation, and address the growing risks of corruption and unlawful influence.

Sweden’s strategic approach to integrity

Sweden’s 2024-2027 Action Plan Against Corruption and Undue Influence is its most comprehensive strategic document on anti-corruption yet. However, Sweden could improve its resilience to corruption and unlawful influence by developing a national anti-corruption strategy that extends coverage beyond the public sector and nurtures a whole-of-society approach to integrity.

Future strategies could be based on a stronger situation analysis that identifies opportunities, risks and existing mitigations. Sweden could also set more ambitious strategic objectives and clearer activities to achieve them, and could support implementation, monitoring and evaluation by using indicators to measure outcomes. It could also establish a stronger monitoring process that measures the implementation rate of strategic activities.

Corruption offences

Sweden's corruption offences are largely aligned with international standards. However, challenges with application of the law, often stemming from the legal provisions themselves, limit accountability for corruption.

Amending the trading in influence and official misconduct offences could make the legal framework more responsive to corruption and unlawful influence. Strengthening legal provisions on the reporting of corruption, corporate criminal liability and sanctions for natural and legal persons could help make the enforcement system more effective in practice. Ensuring all corruption offences have aggravated variants could strengthen investigative authorities’ use of available investigative techniques. Finally, reviewing the mandate of specialised anti-corruption police and prosecution units and building capacity among prosecutors and judges could ensure the legal framework is more effectively applied in corruption cases.

Strengthening transparency and integrity in public decision-making

Sweden maintains strong traditions of transparency and open government, through its developed legal framework and the disclosure of key datasets. Nonetheless, gaps remain in regulating lobbying, political finance, and post-public employment.

Sweden could adopt a dedicated lobbying law, with periodic reviews, that includes foreign influence. Ministries and agencies could establish transparency rules for expert policymaking groups, and lobbying disclosures could include policy targets, objectives, and supporting materials. The Legal, Financial and Administrative Services Agency could oversee lobbying regulations and provide guidance and education. Sweden could also ban anonymous and foreign political donations and regulate third-party campaigning activities. It could also adopt a risk-based approach to post-public employment rules, graduating restrictions according to the risk-profile of positions and increasing transparency around post-employment decisions.

Developing the culture of integrity

Swedish public authorities at all levels of government are largely equipped to uphold integrity and maintain a strong culture of public service. However, anti-corruption efforts are often fragmented, implemented unevenly across the public administration and overly focused on bribery. Integrity training and capacity building could be improved, as could safeguards against conflicts of interest and favouritism.

Sweden could produce guidance to better define real, potential, and apparent conflicts of interest, and which includes practical examples and procedures for managing conflicts of interest. Ministries and agencies could be encouraged to establish a clearly identifiable ethics function, while line managers could be trained to offer tailored advice to staff. The Statskontoret could also develop adaptable online training modules and in-person sessions on public integrity, including on conflict-of-interest prevention and unlawful influence, while agencies could be encouraged to regularly evaluate training materials. The Supreme Audit Institution could also conduct regular external reviews of public authorities’ internal controls.

Fostering integrity at the subnational level

Swedish regions and municipalities have become responsible for delivering a broad range of public services, supported by a large professional bureaucracy working within a stronger public governance framework. However, subnational governments are increasingly targeted by organised criminals using corruption and influence to gain undue advantage.

The Swedish national government could help subnational governments mitigate this evolving threat through targeted capability-building measures to improve understanding of corruption and unlawful influence. It could also offer better guidance on preventative internal control and risk management processes and ensure internal audit at the subnational level involves certified auditors. The national government could also extend requirements for the objective assessment of merit and skill in recruitment to the subnational level, formalise provisions on suspension of subnational authorities’ employees, and intensify awareness-raising activities around the reporting of corruption and unlawful influence.

Strengthening integrity in public procurement

Public procurement accounted for 17.2% of Sweden’s GDP in 2023. Sweden’s public procurement framework aligns with international standards, and improving integrity in public procurement is a key commitment area in the 2024-2027 Action Plan. However, the Swedish public perceive increasing corruption in public procurement and the threat of organised crime groups’ influence over procurements, particularly at subnational level, is evolving.

Sweden could clarify its procurement legislation relating to conflicts of interest, the revolving door, and official misconduct, and further professionalise the procurement workforce. It could also improve competition in public tenders and better convey integrity principles to the private sector. Finally, Sweden could further digitalise public procurement processes and make better use of data, including centralising the publication of procurement notices, ensuring the interoperability of databases, and using data to identify irregularities.