Sweden

Contents

- The Swedish Act on Infrastructure for Alternative Fuels - The Swedish Energy Performance of Buildings Regulations (PBL and PBF) - The Swedish environmental regulations - The Swedish Electrical Safety Act (2016:732) - The Swedish Regulation (2019:525) on state support for the installation of charging points for electric vehicles

The Swedish Act on Infrastructure for Alternative Fuels

What is the regulation?

The Swedish Act (2024:960) on Infrastructure for Alternative Fuels (the “Act (2024:960)”) complements Regulation (EU) 2023/1804 (AFIR). The Swedish Ordinance (2024:460) on Infrastructure for Alternative Fuels (the “Ordinance (2024:460)”) is the regulatory instrument implementing the national legal framework in the Act (2024:960).

By implementing the Act (2024:960), Sweden seeks to promote a nationwide transition from conventional fossil fuels to cleaner alternatives, in line with broader EU strategies. The Ordinance (2024:460) does not lay down substantive requirements; instead, it designates the Swedish authorities responsible for supervision and enforcement under the AFIR. In addition, the Ordinance (2024:460) authorises these authorities to impose supervision fees.

Who do the regulations apply to?

The Swedish Act (2024:960) applies to the operators of EV charging infrastructure.

What are the requirements?

A key requirement for operators of recharging points is the transparent display of price information. Under the AFIR, operators must prominently provide prices. To support consumer transparency, the Act (2024:960) stipulates that essential price details, whether for charging or refueling, must be posted at refueling points so that consumers can easily compare costs. The Swedish government or a designated authority may issue additional regulations concerning price information. According to the Swedish Ordinance (2024:460), the authority currently responsible for such secondary legislation is the Swedish Consumer Agency (Sw. Konsumentverket).

Who enforces the regulations?

The Ordinance (2024:460) designates several Swedish agencies with distinct enforcement roles under the AFIR, as follows:

  1. Swedish Energy Agency ( 'Energimyndigheten') The Swedish Energy Agency is responsible for implementing the AFIR in Sweden. Its tasks include supervising the design and use of charging and refuelling stations, as well as monitoring compliance with the technical requirements for charging points. Furthermore, the Agency acts as an Identification Registration Organisation (IDRO) under the AFIR, primarily managing unique identification codes for charging point operators and mobility service providers.
  2. Swedish Transport Agency ('Transportstyrelsen') The Swedish Transport Agency supervises operators’ compliance with the AFIR’s requirements on user information and with the obligation to make infrastructure data and programming interfaces publicly available. Ensuring that such data is accessible on an open, non-discriminatory basis to all data users, via the Swedish national access points, is the responsibility of the Swedish Transport Administration ('Trafikverket').
  3. The Swedish Energy Market Inspectorate ('Energimarknadsinspektionen') The Swedish Energy Market Inspectorate is authorised to conduct analyses under the AFIR relating to electric vehicle charging and its effects on the energy system, including bidirectional charging.

The Swedish Energy Performance of Buildings Regulations (PBL and PBF)

What is the PBL and PBF?

The EU Energy Performance of Buildings Directive (the EPBD) imposes requirements for pre-cabling and the installation of charging points in new buildings and major renovations. In Sweden, the EPBD has been transposed through amendments to the Swedish Planning and Building Act (2010:900) (the PBL) and the Swedish Planning and Building Ordinance (the PBF). The PBF translates the PBL into practical rules, including obligations for installing EV charging systems in newly constructed or renovated buildings.

The establishment of EV charging outlets is not generally subject to any standalone permit system and does not, by itself, require a building or environmental permit. However, if setting up a charging station entails additional new structures, such as parking lots, these may be subject to the Swedish building permit regime, in which case the PBL applies. Under the PBL, the default rule is that construction of new in-scope buildings requires a building permit.

Municipalities are responsible for zoning and deciding on local plans that regulate the types and dimensions of buildings and roads permitted within an area. Where a zoning plan exists, any proposed construction must comply with the relevant zoning requirements to obtain a building permit. In rural areas, there may be no zoning requirements, in which case more relaxed rules apply. Extensive alterations to land, such as excavation, tree felling, or significant ground filling, may require a separate ground permit even if no other in-scope construction is planned.

Who do the regulations apply to?

According to the PBL, the “responsible developer” ('byggherre') is the party ultimately responsible for planning, financing, and overseeing construction.

What are the requirements?

Under the PBL, the responsible developer is accountable for overall compliance with building and zoning regulations. This responsibility is often delegated to the constructor through agreements (commonly based on industry-standard contracts), but it can also be assigned to the individual or entity initiating construction.

Further, per the PBL, buildings must have the technical characteristics necessary for EV charging. From 1 January 2025, according to the PBL, all commercial operators with more than 20 parking spaces have an obligation to have at least one charging point installed. Additionally, there is an existing requirement under PBL for new commercial buildings with a minimum of 10 parking spaces to ensure that at least 20% of those spaces are equipped with charging infrastructure, and that there is at least one charging point.

Who enforces the regulations?

Under the PBL, municipal building committees ('byggnadsnämnder') serve as the primary enforcement authorities responsible for ensuring compliance with planning and building requirements. Their duties include reviewing applications, verifying technical plans, and imposing sanction fees if developers fail to adhere to relevant rules. Once construction commences, they may conduct site visits and request documentation from property owners or developers to confirm that EV charging units satisfy safety, capacity, and accessibility requirements under the PBL.

Additionally, the local regional board ('länsstyrelsen') exercises supervisory authority, particularly over projects that may conflict with national interests (e.g., major roads or environmental protections).

The Swedish environmental regulations

What is the regulation?

The Swedish Environmental Act (1998:808) and the Swedish Environmental Assessment Ordinance (2013:251) together form Sweden’s principal framework legislation for environmental protection, setting out the general provisions intended to foster sustainable development.

Who do the regulations apply to?

The Swedish environmental regulations apply to any person or operator whose activities could affect the objectives of the Swedish Environmental Act by materially altering the natural environment. When determining whether a measure may cause a significant change to the natural environment, consideration should be given to the nature and sensitivity of the area, as well as to the measure itself and its impact. The possibility of harming biodiversity, including injury to species and habitats, should also be factored into the assessment. In areas with high natural or cultural environmental value, or in otherwise sensitive areas, even a relatively minor measure may have a significant impact.

An electric charging station would not usually fall within the scope of operations requiring an environmental permit under the Swedish Environmental Act and the Swedish Environmental Assessment Ordinance. However, the construction of a charging station (including excavation works to lay cables underground) could, in certain circumstances, be deemed to materially alter the natural environment within the meaning of Chapter 12, Section 6 of the Swedish Environmental Act.

What are the requirements?

A person intending to undertake measures that may materially alter the natural environment must submit notice for formal consultation with the local regional board before initiating the planned measure. Per Chapter 12, Section 6 of the Swedish Environmental Act, in-scope measures may not begin until at least six weeks have elapsed following the submission of a complete consultation notice. The regional board may require the notifier to adopt the necessary measures (including modifications to the proposed activity) to limit or counteract harm to the natural environment.

If such measures are considered insufficient, and if it is deemed necessary for the protection of the natural environment, the regional board may prohibit the measure entirely.

Who enforces the regulations?

Enforcement of these environmental regulations rests with the competent local regional board. The supervisory authority may direct the person subject to the notification obligation to implement measures necessary to limit or counteract harm to the natural environment. If such measures are deemed insufficient, and if it is necessary for environmental protection, the authority may prohibit the activity. Where an activity is prohibited in this way, the operator may be entitled to compensation.

Breaching these environmental regulations may result in criminal liability. Any individual who, intentionally or negligently, commences or carries out an activity or action requiring consultation under Chapter 12, Section 6 of the Environmental Code, without having given notification, may be found guilty of unauthorised environmental activity and sentenced to a fine or imprisonment of up to two years. The same applies if, after submitting a notification, the activity commences without observing the six-week waiting period before starting the activity.

The Swedish Electrical Safety Act (2016:732)

What is the regulation?

The Swedish Electrical Safety Act (2016:732) (the “Electrical Safety Act”) aims to promote high electrical safety and reduce the risk of electricity causing personal injury or property damage.

Who do the regulation apply to?

The EV regulations in the Electrical Safety Act apply to owners of EV charging stations.

What are the requirements?

Per the Electrical Safety Act, the installation of charging stations must be conducted by an electrical installation company registered with the Swedish National Electrical Safety Board ('Elsäkerhetsverket'). The work must be performed by a qualified professional holding the appropriate authorisation for either low-voltage or high-voltage facilities, as required by the specific situation. Although a charging point in itself may be regarded as a low-voltage facility under the Swedish National Electrical Safety Board’s definition in ELSÄK-FS 2021-5, construction of a new charging station (including the cables leading to the charging point) will typically be deemed a high-voltage facility ('starkströmsanläggning') under the Electrical Safety Act. In such cases, the professional must possess Class A authorisation for all types of electrical work.

Who enforces the regulations?

The Swedish National Electrical Safety Board is the supervisory authority for ensuring compliance with the provisions of the Electrical Safety Act. Supervision may be conducted in two ways: through a review of documentation via written correspondence or by on-site inspections. During an inspection, the authority physically evaluates the installation to ensure that standard operating procedures correspond to its actual condition.

If any deficiencies are found, the owner is notified so that corrective measures may be taken. If the installation is in such disrepair that it poses an immediate risk of personal injury, the supervisory authority may shut it down until the problems have been resolved. In cases where criminal activity is suspected, the authority will file a police report.

The Swedish Regulation (2019:525) on state support for the installation of charging points for electric vehicles

What is the regulation?

The Swedish Regulation (2019:525) on state support for the installation of charging points for electric vehicles (“Regulation (2019:525)”) promotes sustainable transport in Sweden by providing state subsidies for the installation of EV charging points.

This Regulation (2019:525) establishes a framework for financial assistance aimed at accelerating the adoption of electric and plug-in hybrid vehicles nationwide. It primarily targets charging infrastructure situated at residential or workplace locations, stipulating that public or private property owners may receive up to 50% of eligible costs, capped at SEK 15,000 per charging point. Anchored in Sweden’s broader climate goals, the Regulation also complies with European Union rules on state aid, ensuring its compatibility with relevant EU regulations such as Regulation (EU) 2023/2831 and Regulation (EU) No. 651/2014.

In essence, the Regulation (2019:525) details the technical and administrative conditions under which applicants may obtain grants. It requires newly installed charging points to meet specific technical standards, including the use of connector types such as Type 2 or Combo 2. Through this incentive, the Swedish government expects a swifter transition to a low-emission transport sector - underpinned by the construction of essential charging infrastructure. Moreover, the Regulation (2019:525) expressly prohibits overlapping financial support, preventing subsidies for projects that have already secured financing from other programmes and thus ensuring efficient and transparent use of public resources.

Who do the regulation apply to?

The Regulation (2019:525) primarily applies to individuals and legal entities that own or hold property rights where the charging infrastructure is to be installed. It therefore encompasses both private and public actors who install, or plan to install, EV charging facilities. While the Regulation (2019:525) focuses on residential and workplace locations, it remains sufficiently flexible to accommodate various organisational structures, including cooperatives or municipal entities, so long as the charging infrastructure primarily serves on-site occupants or employees.

What are the requirements?

The Swedish Regulation (2019:525) establishes multiple requirements that an applicant must meet to receive subsidies, as it follows:

  • the charging points must be located on property that the applicant owns or holds with a special right;
  • the location of the charging points must be either a residence, or a workplace used primarily by occupants or employees;
  • installations comply with the Electrical Safety Act by employing qualified electrical contractors;
  • installations further require electricity metering and billing readiness, along with connectors adhering to established standards: Type 2 (EN 62196-2) or Combo 2 (EN 62196-3).

Eligible expenses include materials (such as cables, connectors, and related hardware) and labour, provided the latter is supplied by entities holding F-tax certification or equivalent international permits. Applicants must exclude costs already covered by other public funding, and adhere to a 50% subsidy limit, capped at SEK 15,000 per charging point.

Recipients must not contravene existing legislation or obtain duplicate funding from other schemes. Prospective beneficiaries must submit comprehensive documentation to the Swedish Environmental Protection Agency ('Naturvårdsverket') electronically within six months of completing installation. Required documentation includes invoices and proof of compliance with technical standards. Entities operating under EU state aid rules (i.e. Regulation (EU) 651/2014) must file applications before commencing installation.

Grant payments are disbursed only after the measure has been completed. Grant recipients must maintain detailed records and cooperate with any subsequent supervision or audit by the Swedish Environmental Protection Agency. Should it emerge that submitted information was incomplete or misleading, or if the subsidy conditions were breached, the Agency may withhold or reclaim previously allocated funds.

Who enforces the regulations?

The Swedish Environmental Protection Agency serves as the primary authority for enforcing Regulation (2019:525). Its responsibilities include determining eligibility, approving or denying applications, and imposing specific conditions for the installation process. Additionally, the Agency oversees compliance, with the power to request information and conduct site inspections to ensure installations conform to grant requirements.

If a grant is erroneously awarded or if an applicant provides inaccurate information, the Agency may cease payments or reclaim funds. Where the measure falls within the scope of EU state aid rules, further oversight may be exercised to confirm compliance with the relevant EU frameworks.

For projects involving EU-funded grants, the Swedish National Financial Management Authority ('Ekonomistyrningsverket') may also participate in follow-up activities.

Contact us:

Lukas Holmberg Partner, Sweden

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Ana-Maria Barbu-Nyström Associate, Sweden

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