This chapter explores Sweden’s public governance model and its legal, institutional and conceptual framework for combating public sector corruption. It suggests that Sweden could be better placed to address organised crime groups’ increasing use of corruption as a tool to gain undue advantage by clarifying its conceptualisation of corruption and unlawful influence.
OECD Integrity Review of Sweden
Abstract
Sweden is among the world’s best performing countries on a range of socio-economic and governance issues. It has consistently ranked near the top of the Human Development Index which measures both economic growth and quality of life (UNDP, 2025[1]). It is also among the top OECD Members for low income inequality both before and after taxes, and wellbeing is high in almost all categories of the OECD Better Life Index (OECD, 2025[2]). Satisfaction with public services is high across sectors, with Sweden among the countries to have shown the greatest improvement in satisfaction scores in the last four years (OECD, 2024[3]). Swedish institutions and individuals also benefit from high levels of trust. For the last four decades, over half of Swedish people agree that most people in Sweden can be trusted, and for the last 20 years that number has been above 60% (World Values Survey, 2024[4]). In 2023, 43% of Swedish people reported high or moderately high trust in the national government (compared to the OECD average of 39%), which was an increase of 4% since 2021 (compared to a 2.4% average decrease in OECD countries). Swedish citizens also placed an above-average trust in many other key public institutions, including the police, national parliament, judiciary and political parties (OECD, 2024[3]).
These positive metrics correlate with Sweden’s corruption perceptions scores, having placed in the top ten countries in the Corruption Perceptions Index (CPI) since the index’s inception (Transparency International, 2025[5]). In 2025, the percentage of Swedish citizens who thought the problem of corruption was widespread in their country was also well below the EU average (at 51% and 69% respectively), as was the percentage of people who felt personally affected by corruption in their daily lives (at 12% and 30% respectively) (European Commission, 2025[6]). In addition, the OECD Public Integrity Indicators (PIIs) show that Sweden performs above average in key areas of its integrity framework, including the quality of its anti-corruption strategy and its risk management and internal audit mechanisms (Figure 1.1).
However, there is growing concern in Sweden around the influence of organised crime groups and their use of corruption as a tool to gain undue advantage. In recent years the threat and power of organised crime groups in Sweden has increased, so much so that the Swedish Prime Minister has cited the ‘systemic threat’ which criminality now poses to Swedish society (Government of Sweden, 2023[7]). Indeed, the Swedish Police Authority has estimated that the Swedish criminal economy now has an annual revenue of SEK 100–150 billion (c. EUR 8.9–13.3 billion as of July 2025) and cases of gun violence have almost tripled since 2011 (Government of Sweden, 2023[7]). At the same time, as other countries have also observed, organised crime groups have increasingly begun to exploit and influence Swedish public organisations and employees to manipulate, control and defraud public systems and processes including those relating to benefits, welfare, healthcare, public procurement, construction, or licensing and permitting (Europol, 2025[8]).
As a result, the Swedish Government has recognised that Sweden is not immune to corruption and is taking steps to address emerging and new corruption risks at all levels of government under the National Strategy Against Organised Crime and the 2024-2027 Action Plan Against Corruption and Undue Influence (APACUI). These strategic frameworks aim to provide a clearer direction for the work against organised crime and to reduce the public sector vulnerabilities which organised criminals seek to exploit to gain undue advantage. These are significant steps, but there is scope to go further.
Despite the positive perceptions of Sweden’s record on corruption, the OECD’s PIIs show there is scope to improve several aspects of Sweden’s public integrity framework, including managing conflicts of interest, lobbying and political financing where Sweden sits beneath the OECD average (Figure 1.1). These shortcomings may provide organised crime groups, and any other malign actors, ongoing opportunity to exploit vulnerabilities in the Swedish public sector to their own ends.
Note: Data for conflict-of-interest practices, including interest declaration submission rates for key public office holders, are not centrally available for Sweden.
Source: Public Integrity Indicators, 2025
The following chapters align with the structure of Sweden’s APACUI and explore key aspects of Sweden’s integrity framework. They draw on OECD standards, data and international practices to make suggestions for improvement which are tailored, realistic and compatible with the scope and confines of Sweden’s constitution and public governance model. Overall, three main themes run throughout the report and its recommendations. Firstly, Sweden maintains a strong culture of public integrity, based on high levels of interpersonal and institutional trust and developed public service values. Secondly, the devolved nature of Sweden’s public governance model allows public authorities to shape and apply integrity and public service principles according to their context and need, and to ensure that risk and decision-making sits at the right level. However, this decentralisation means the integrity framework is often applied inconsistently across the Swedish public sector. Further legislative, capacity-building and oversight measures could be introduced to improve the consistency of the integrity framework’s implementation. And thirdly, the evolving threat of organised crime and its connections to corruption have raised the stakes around public integrity in Sweden and the need for reform. Sweden has therefore recognised that stronger safeguards are needed to protect public authorities, their employees and the public policy cycle. The following chapters pay close attention to organised crime as a driver of corruption in the Swedish public sector and, although responding to the threat of organised crime as a whole is beyond the scope of this report, many of the solutions drawn from the integrity toolkit in the ensuing chapters could help Sweden to combat organised crime and ensure public services and processes continue to be efficient, effective, and aligned to the public interest.
This review assesses Sweden’s integrity framework and makes suggestions for improvement based on the OECD’s public integrity standards. Together, the OECD’s Recommendation on Public Integrity, the Recommendation on Transparency and Integrity in Lobbying and Influence, and the Recommendation on OECD Guidelines for Managing Conflict of Interest in the Public Service provide countries with a blueprint for improving public sector integrity. Public integrity is a prerequisite for prosperous economies, stable democracies, and dignified and thriving societies. It involves the “consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector” (OECD, 2017[9]). As the Recommendation on Public Integrity sets out, strong public integrity frameworks prioritise a whole-of-society approach, ensuring that the value of integrity is understood at all levels of the public service, the private sector, and wider society. They also move beyond ad hoc integrity policies, focused on the creation of more rules, stricter compliance and tougher enforcement measures, and shift the focus to a strategic, context-dependent, and risk-based approach which nurtures a culture of public integrity.
Establishing a coherent integrity system requires balanced attention to three equally important pillars (Figure 1.2). Firstly, a public integrity system must be based on political commitment and clear institutional responsibilities, a strategic and evidence-based approach to anti‑corruption policymaking, and high standards of conduct for public officials. Secondly, effectively countering corruption and fostering integrity involves partnerships between government, the private sector and civil society. This pillar emphasises investment in integrity leadership and the professionalisation of the public sector, especially through sufficient training and guidance and the cultivation of open organisational cultures. And thirdly, integrity systems must incorporate robust internal control and risk management measures, enforcement and accountability mechanisms, external oversight, transparency of public information, and stakeholder engagement in policymaking.
Source: (OECD, 2017[9])
To support its assessment, the review uses data gathered through the OECD’s PIIs to evaluate the performance of Sweden’s integrity framework. The PIIs offer objective primary data, validated by the Swedish Government, on the main regulations and practices in Sweden’s integrity framework, including the main strengths and areas for improvement (Box 1.1). In addition to the PIIs data, the assessment considers the latest reports and analysis of Sweden from international organisations, civil society, academia, and the Swedish Government’s own inquiries, several of which ran concurrently to the preparation of this report. The intention is not to duplicate any of these reviews, but to supplement their findings with fresh insights and to enable stronger implementation of several of their recommendations. Throughout spring and summer 2025, the OECD also undertook in-person and online interviews with representatives from the Swedish Government, civil society, academia and the private sector to shed further light on the strengths and challenges in Sweden’s integrity framework.
The Public Integrity Indicators (PIIs) are designed to measure the implementation of the OECD Recommendation on Public Integrity. The indicator framework establishes standard indicators for measuring the preparedness and resilience of national-level public integrity systems to prevent corruption and the mismanagement and waste of public funds, and for assessing the likelihood of detecting and mitigating various corruption risks by different actors in the system.
The PIIs combine sub-indicators establishing minimum legal, procedural and institutional safeguards for the independence, mandate and operational capability of essential actors in the integrity system, with outcome-oriented sub-indicators drawing on administrative data and surveys. The PIIs apply a mixed methods approach, drawing on both administrative data and big data provided directly by governments and surveys. The PIIs:
provide objective and credible measures of different elements of public integrity systems
are meaningful for governments because they are co-created by the OECD with governments and do not rely on subjective expert assessments. The aim is not to provide country rankings, but a tool for learning and informing better policies
are the first-ever comprehensive set of indicators based on an agreed international legal instrument, either from the OECD or beyond, and adhere to the same high statistical standards as other OECD indicators. Collected data is validated by OECD member countries
provide a better alternative to existing measures, enabling analysis of the impacts of anti‑corruption efforts through linking the disaggregated data to a range of economic and social outcomes. The PIIs could also provide the basis for establishing cost-effectiveness and cost-benefit ratios.
To date, the OECD has developed indicators and sub-indicators for six principles of the Recommendation on Public Integrity. Data has been collected for Principle 3 (strategic framework), 10 (risk management and internal audit) and 13 (accountability of public policymaking). Data collection is ongoing for Principle 11 (integrity of the justice and disciplinary systems). The PIIs cover 38 OECD countries, including Sweden, and 27 OECD partner countries.
In this report, data related to Sweden’s strategic framework (dataset P3) was first published in 2021, updated in 2023, and updated again in 2025. For risk management and internal audit (dataset P10), data was published in 2023. For accountability of public policymaking (dataset P13) data was published in 2022. All data used in this report has been re-checked for accuracy during the Swedish Government’s review of the draft.
Source: (OECD, 2024[10]); OECD Public Integrity Indicators, 2025, https://oecd-public-integrity-indicators.org/indicators.
1.2.1. Sweden’s unique public governance model
Sweden’s public integrity framework operates within its unique public governance model, which is characterised by its consensus-based and collective decision-making principles and its widespread delegation across different institutions at different levels of government. The Swedish national administration is composed of Government Offices and government agencies. Collective decision-making is stipulated in the constitution and is a strong principle of governance that is widely applied in the Government Offices. The Coordination Office of the Prime Minister’s Office is tasked with co-ordinating the government’s overall policy, ensuring that the government’s priorities are implemented, and preparing government meetings (Government Offices of Sweden, 2023[11]). In practice, its role mainly focuses on political co-ordination, preparation of cabinet meetings and resolving differences and clarifying directions across the Government Offices.
The Government Offices are organised as one agency, the Regeringskansliet, which is divided into several ministries (Government Offices of Sweden, 2023[11]). The 11 Government Offices comprise the Prime Minister’s Office, which constitutes the main Centre of Government entity, 10 government ministries, and the Office for Administrative Affairs. The Swedish Constitution stipulates that the Government Offices are responsible for the preparation of government business in their respective fields. The number of ministers or ministries is not subject to regulation, and it is up to the Government to decide how the government’s various duties are divided up. Given their focus on policymaking, the Government Offices are relatively small, with around 4 800 members of staff, of whom around 170 are political appointees (Government Offices of Sweden, 2023[11]). Ministries are headed by Ministers, with State Secretaries as their immediate subordinates. Ministries also have Press Secretaries and Political Advisers who serve as political aides to the Ministers and who with Ministers and State Secretaries are collectively referred to as the political executive. Each ministry also has several senior civil servants who are responsible for ensuring that the principles of legality, consistency and uniformity are observed in government business. Day-to-day ministerial business is conducted by various departments or divisions headed by a Director, which prepare items of business prior to the Government taking decisions and handle contacts with the government agencies sitting under the ministries.
The government agencies are the authorities responsible for implementing the laws adopted by the Swedish parliament, the Riksdag, regulations adopted by the government and other government decisions. The Government Offices supervise the operations of the 367 government agencies by issuing appropriation directions and ordinances that contain instructions about their activities. These directions and ordinances serve as guidelines, stating the direction that activities should take and the issues that should have priority. However, due to an important ‘arms-length principle’ in Swedish public governance, the Government Offices may not determine how agencies should act in individual cases or how they should apply legislation (Government Offices of Sweden, 2023[11]). This arms-length principle, which also applies at the subnational level, aims in practice to keep the political executive relatively removed from the practical implementation of individual decisions within government bureaucracy, allowing decision-making based on law, merit and established procedures rather than on political expediency or loyalty to those currently in power (Erlingsson et al., forthcoming[12]). The typical policy cycle for new legislation in Sweden therefore involves several steps. Firstly, policy design and proposals are initiated by the Government Offices and prepared by an independent commission of inquiry. Secondly, the report of the commission is submitted to the government for analysis. Thirdly, the government organises consultations through the referral process and prepares policy proposals that are submitted to Parliament and which inform the legislative process. And fourthly, the public agencies implement policy and legislation and help to inform the Government Offices’ development of new policy (OECD, 2023[13]).
At the subnational level, Swedish government is divided into regional and municipal levels. At the regional level, Sweden is divided into 21 counties. Political tasks at this level are undertaken by the regional councils, whose decision-makers are directly elected by the people of the county, and by the county administrative boards which are the counties’ governing bodies. Some public authorities also operate at regional and local levels, including through county boards. At the municipal level, Sweden has 290 municipalities. Each municipality has an elected assembly, or municipal council, which takes decisions on municipal matters. The municipal council appoints the municipal executive board, which leads and co-ordinates the delivery of work in municipalities. Chapter 6 explores governance and integrity at the subnational level in more depth.
1.2.2. Sweden has a developed regulatory and institutional framework for public sector integrity
Within this public governance model, Sweden has a developed regulatory and institutional framework for upholding public integrity. Unlike many OECD countries, Sweden has no dedicated anti-corruption law. Rather, its regulations for preventing corruption are spread across several laws and ordinances, including inter alia employment legislation, laws regulating the devolution of powers between national and subnational government, access to public information legislation, or ordinances on the management of public finances. This legislative framework is supported by a range of codes, ethical guidelines and policies often applied at the level of individual authorities and agencies. Sweden’s framework for detection, investigation and enforcement against corruption is based on a range of corruption offences, which are largely aligned to international standards and explored in more detail in Chapter 3 of this report. Sweden’s regulatory framework is underpinned by the Instrument of Government (Regeringsformen), which outlines the principles of public administration and emphasises the core values of legality, objectivity, and impartiality in the exercise of public power.
There is also no single anti-corruption authority or agency in Sweden. Instead, at the level of the Government Offices, the Department for Public Administration in the Ministry of Finance is responsible for a range of public integrity policymaking, particularly related to the prevention of public sector corruption. This Department, currently working to the Minister for Public Administration, is responsible among other things for financial and legislative matters at the subnational level, government agency governance, statistics, state administration, central government employer policy, procurement law, consumer issues and the digitalisation of public administration (Government Offices of Sweden, 2025[14]). The Ministry of Justice also has several responsibilities, mostly related to the detection, investigation and prosecution of corruption. It is responsible for the authorities comprising the Swedish judicial system, including the police, the public prosecution service, the courts, and the Swedish Prison and Probation Service. In addition, several departments in the Ministry of Justice are responsible for legislation in the areas of constitutional and general administrative law, civil law, procedural law, criminal law, and public order and safety (Government Offices of Sweden, 2025[15]).
At the government agency level, the Agency for Public Management (also called the State Treasury or Statskontoret) is broadly responsible for good administrative culture across Government. The Statskontoret is tasked with promoting and co-ordinating the work for a good administrative culture and against corruption in the central government. To do so, among other things, it produces a knowledge base, arranges capacity building workshops and seminars, and runs the Agency Network Against Corruption (a forum of Sweden’s key anti-corruption agencies and authorities). Alongside the Statskontoret, the Swedish National Financial Management Authority (Ekonomistyrningsverket, or ESV) is responsible for maintaining the integrity of public finances through developing efficient financial management for central government agencies and analysing and making forecasts of central government finances. On 1 January 2026, the Statskontoret and ESV will merge under the common name Statskontoret, with the broad task of assisting the Government by assessing and analysing various parts of the public administration's functioning, efficiency, organisation and development.
Several other authorities and agencies have responsibility for different aspects of Sweden’s anti-corruption framework. The Swedish National Council for Crime Prevention (Brå) is a knowledge centre for the criminal justice system and its mandate includes developing crime prevention work, including through assessments and capacity building activities, at the national and subnational levels. The National Anti-Corruption Unit (NACU) is the specialised prosecution agency within the Swedish Prosecution Authority and is responsible for all criminal investigations related to corruption in co-operation with the National Anti-Corruption Unit of the Swedish Police Authority (NACPU). As part of the Swedish Police Authority, the National Anti-Corruption Police Unit is tasked with investigating corruption crimes, asset recovery and preventing corruption by providing knowledge to different public authorities as well as business associations. The Special Investigation Department of the Police Authority handles internal investigations of police officers and prosecutors. The Swedish Economic Crime Authority organised under the Ministry of Justice has the mandate to investigate and prosecute serious financial crimes, including the recovery of proceeds of crime. And other agencies, such as the National Audit Office, the National Competition Authority, and the Financial Intelligence Unit of the Swedish Police Authority, have their own responsibilities in relation to the prevention and investigation of corruption, forensics and auditing. Many of these departments and authorities, and their responsibilities at both the national and subnational level, are analysed further throughout this report and recommendations are made for enhancing their roles and co-operation in combatting corruption and unlawful influence in the public sector.
1.2.3. Sweden’s broad concept of corruption should be better mainstreamed throughout the public sector
There is no legal definition of the concept of corruption in Sweden. Instead, corruption is used in Sweden as a collective term to describe improper acts where someone exploits their position to benefit themselves or others. In recent years, Sweden has taken steps to develop and mainstream a broad definition and understanding of corruption throughout the public sector and wider society.
The need for a broader definition of corruption was established in the government communication Regeringens skrivelse (2012/13:167) Riksrevisionens rapport om statliga myndigheters skydd mot korruption. In this communication, the government stated that the concept of corruption in Sweden should not only be synonymous with bribery but should also extend to other penal provisions or acts that are not punishable in law but which can be perceived as corrupt. The communication therefore defined corruption as the exploitation of a public position to obtain undue gain for oneself or another, and established this definition as the starting point for the government's work against public sector corruption. The Riksdag later adopted the government's assessment and broad definition (report 2013/14:KU4, rskr. 2013/14:53). This definition is now the basis for Sweden’s strategic framework against public sector corruption, having been applied in its 2021-2023 Action Plan Against Corruption and again in the APACUI.
However, despite this broad conceptualisation of corruption, in practice understanding and application of the definition remains inconsistent across the Swedish public sector. In 2023, the Statskontoret noted that in many government agencies understanding of Sweden’s definition was lacking, apart from in those units or among individuals who work on corruption or in specific areas such as operational support. The Statskontoret also highlighted that understanding of corruption was particularly lacking in authorities with a large geographical spread, those divided into several smaller units, or those regularly recruiting staff from other countries or the business community (Statskontoret, 2023[16]). A later Statskontoret report focusing on the subnational level noted a persistent conflation of the concepts of corruption and bribery in regions and municipalities. This confusion was particularly problematic, the Statskontoret noted, since corruption in the form of bribes and improper offers is still uncommon in Swedish municipalities and regions compared to other forms of corruption such as nepotism and cronyism (Statskontoret, 2023[17]). The Statskontoret’s findings were corroborated by participants in the OECD’s fact-finding conversations in support of this report, who noted an ongoing focus on bribery in conversations about public sector corruption and that understanding of corruption within their organisations and across the Swedish public sector could improve.
As a result, and as the Statskontoret has noted (Statskontoret, 2023[16]), data collection on different forms of corruption is not as effective in Sweden as it could be, given the inconsistencies in classifying various acts as corruption, and authorities’ attempts to prevent and respond to corruption through evidence-based policy making could be improved. While, as the rest of this report notes, several government agencies have responsibilities for raising awareness and understanding of corruption throughout the public sector, Sweden must continue and intensify these efforts along with recording the impact of capacity-building measures wherever possible. Many of the recommendations throughout the following chapters relate to consolidating understanding and practices around Sweden’s single conceptualisation of corruption.
1.2.4. Sweden could build capacity around a stronger single definition of unlawful influence
Sweden has identified unlawful influence, particularly when perpetrated by organised crime groups, as a key driver of public sector corruption and threat to efficient and effective public governance. There is no single definition of unlawful influence, either in Swedish law or elsewhere. The concept of unlawful influence against public officials in Sweden was introduced by the Brå around twenty years ago. The APACUI notes that at that time the Brå referred to unlawful influence as serious harassment and threats as well as situations of violence against a person or property, which in addition to being a major work environment problem, risks affecting the individual official's exercise of authority, and which can therefore ultimately constitute a threat to democracy.
Since then, the definition and concept has evolved. A Brå report in 2016 developed the concept by listing the most common forms of unlawful influence over public officials, including harassment, threats, violence, vandalism, and corruption where the victim perceives the purpose being to influence the discharge of official duties (Brå, 2016[18]). In 2024, the APACUI set out that unlawful influence in public administration refers to 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. Unlawful influence can occur, the APACUI notes, either through actions that are punishable or otherwise illegal or through actions that are merely improper. And most recently, in 2025 the Brå noted that unlawful influence is an umbrella term for situations where an outsider, in a way that is illegal or perceived as unpleasant or inappropriate, tries to influence the professional behaviour of someone (Brå, 2025[19]). The Brå notes that the influencer must have an intention to influence and pursues this intention through, for example, harassment, threats, violence, vandalism or improper offers or relationships (such as bribery or cronyism). In certain contexts, unlawful influence can also be pursued through more indirect approaches that are not necessarily criminal, such as unpleasant indirect threats or inappropriate comments (Brå, 2025[19]).
While it is natural for concepts and definitions in government policy to evolve with the changing context, the lack of a single, stable definition of unlawful influence may be impeding Sweden’s ability to respond to the threat. As Swedish authorities noted in the preparation of this report, maintaining a certain level of abstraction in the concept of unlawful influence is useful because it allows authorities to flex the concept according to their individual contexts. In practice, however, Swedish public authorities have developed their own definitions which, though comprehensive, depart from the definition advanced by the Brå (Box 1.2). Indeed, the Brå has noted in its most recent report on the subject that the concept of unlawful influence has been used in an increasing number of contexts in the Swedish public sector, leading to confusion regarding what the term means and how to tackle the problem (Brå, 2025[19]). In addition to this confusion, inconsistent use of definitions in policymaking makes data collection harder, making it more difficult for the Swedish government to identify trends and to make strong, evidence-based policy. While a legal definition may not be necessary, Sweden could, therefore, consider developing, disseminating and capacity-building around a single definition of unlawful influence which will enable a more consistent policy response across the Swedish public sector and support data collection and analysis of this key issue.
Definition of Unlawful Influence
Unlawful influence refers to acts that constitute a criminal offence from an employee protection perspective (such as threats against a public official, unlawful threats, harassment, assault, or damage to property) and that are directed at an employee or their close relatives. These acts are perceived by the employee, their immediate supervisor, or the agency’s security function as an attempt to coerce the employee into performing—or refraining from performing—their duties. It is not required that the employee has actually been influenced by the attempted coercion.
Bribery, whether offering or receiving bribes, does not fall under the definition of unlawful influence in this context. Similarly, violence used in intervention situations—such as violent resistance or violence against a public official, when it is clearly intended only to obstruct an intervention in that specific situation—does not constitute unlawful influence under this definition.
Definition of Undue Influence
In addition, the Swedish Prison and Probation Service defines certain acts as “undue influence”. This refers to acts that resemble unlawful influence and are intended to affect the execution of official duties but differ in that they are not criminal offences. Examples include actions that violate good practice, ethics, and morality, which may be considered inappropriate from an administrative perspective.
Source: Provided by Swedish authorities in preparation for this report.
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