On March 1, 2026, the Act (2026:56) on Penalties for Unauthorized Financial Activities will take effect. Under this Act, it will be a criminal offense to engage in financial activities subject to licensing or registration requirements without approval from the Swedish Financial Supervisory Authority.

Previously, violations were primarily addressed through administrative measures, such as orders, penalties, or administrative fines. The new law introduces criminal liability. This means that anyone who, intentionally or through gross negligence, conducts an activity requiring a permit without a permit may be sentenced to a fine or imprisonment for up to two years. If the offense is deemed aggravated, the penalty may be imprisonment for a minimum of six months and a maximum of six years.

What does the law cover?

The law itself does not define what constitutes financial activity, but refers to other regulations, such as:

• The Payment Services Act
• The Electronic Money Act
• The Banking and Financial Services Act

If an activity requires a permit or registration under these regulations, and such a permit or registration is lacking, liability may arise.

This is particularly relevant for businesses that:

• Receives and processes payments between parties
• Temporarily manages clients' funds
• Uses its own accounts to hold client funds
• Acts as an intermediary in payment flows

When is the crime considered aggravated?

In making this assessment, particular consideration should be given to whether:

• The business has been conducted on a larger scale
• Significant amounts handled
• The operations have been systematic
• The act was of a particularly dangerous nature

This means that platforms and marketplaces that handle large amounts of customer funds may be subject to a more rigorous review if they do not have a license.

Changes in the Risk Landscape for the Company and Management

The new law represents a significant tightening of the rules. It is no longer merely a matter of regulatory sanctions, but of potential personal criminal liability for representatives who, intentionally or through gross negligence, conduct activities requiring a license without authorization.

This changes the risk landscape for the board and management of companies that handle payments or customer funds.

What should companies do now?

Companies that:

• Handles payments between customers and suppliers
• Holds customers' funds
• Involves arrangements similar to escrow, a deposit, or intermediary payments

should ensure that the operations have been properly analyzed in light of applicable regulations.

It is particularly important to:

1. Map the actual payment flow
2. Determine whether the business is subject to a licensing or registration requirement
3. Ensure that the appropriate regulatory framework is in place

Uncertainty regarding licensing requirements should not be left unaddressed in light of the new legislation.

What's next?

Contact us at Ping Payments. We’ll help you assess your business needs and ensure that you comply with regulations and enhance security.

Why the payment platforms of the future are industry-specific—and why compliance has become central.

The payments market is changing rapidly. But it is not new payment methods that are driving this change. What is reshaping the market as we approach 2026 is how payments are linked to business processes, accountability, and regulation. In 2025, several structural shifts have become apparent. As we approach 2026, these are no longer trends—they are new fundamental conditions.

Compliance is no longer an add-on—it is the payment flow itself
Compliance has evolved from a support function to a core function. Today, every payment entails regulatory responsibility, with requirements for AML, CTF, sanctions screening, traceability, and reporting being an integral part of the flow.
In industry-specific payment platforms, compliance is built into the transaction logic—from onboarding and risk assessment to monitoring and reporting.

From the Moment of Payment to a Coherent Business Process
Payments are not isolated events. They are part of larger workflows that encompass authorizations, settlement, accounting, and responsibilities among parties.
When a payment platform is built around real-world processes, it becomes deeply integrated into the business and thus difficult to replace.

Embedded payments drive both business and loyalty
When payments are embedded in the primary business process, the customer relationship changes. The focus shifts from the price per transaction to the value of a seamless end-to-end flow.
This builds loyalty, increases customer lifetime value, and enables business models where payments contribute to revenue—rather than being merely a cost.

Why Generic Payment Services Are Losing Ground
Generic payment services are efficient for transactions but lack context. When value shifts to processes, data, and accountability, payment processing becomes a commodity and the customer relationship becomes more interchangeable.
What customers are willing to pay for is not the payment itself—but how it is handled.

Regulation Drives Specialization—Not Consolidation
Increased regulation does not lead to fewer players, but rather to greater specialization. As requirements become more detailed, players that are designed for a clear context and clear responsibilities are favored.
It is within this reality that the next generation of payment platforms is emerging.

Ping Payments and the Road to 2026
Ping Payments is built for this evolution—with a focus on industry-specific payment flows, built-in compliance, and a deep understanding of customers’ actual processes.

In 2026, the biggest change to Sweden’s payment infrastructure in decades will take place.
“For the first time, we can process payments digitally from start to finish—without anymanual steps and without file formats.”
— Petter Sehlin, founder of Ping Payments

Older payment solutions are being phased out and replaced by digital communication based on a common European standard. The change is taking place behind the scenes, but it affects both digital systems and day-to-day financial management in associations and civil society.

What’s being phased out
Several established solutions will be phased out in 2026:

• Bankgirot's Infrastructure
• BgMax and LB
• paper payments
• value notices

Integration solutions need to be reviewed ahead of the transition.

Why This Is Happening
The background to this change lies in a European initiative to modernize the payments market and create a common standard. By using the same technical format, both banks and digital platforms gain new opportunities to automate the exchange of information and payment flows.
This means that payments will be faster, more traceable, and linked to more data—which in turn paves the way for entirely new solutions and efficiency gains.

What's Next
The replacement system is digital and standardized, and is based on including more information with each payment so that reconciliation and checks can be automated:

• API Communication
• ISO 20022
• camt.054
• metadata
• automated matching

This enables a new level of automation, both for incoming and outgoing payments.

How Bankgirot Is Being Replaced in Practice
As BgMax and LB are phased out, they will be replaced by ISO 20022. This means that systems need to be adapted to the new formats in order to continue sending and receiving payments. The main difference is that more information is included with each transaction, which makes it easier to match payments and gain a clearer overview within the systems. The transition may vary depending on the bank and service, but the direction is the same: more standardized, more digital, and better opportunities to automate processes that previously required manual handling.

How this affects digital systems
Systems that currently use Bankgirot need to transition to APIs and support ISO 20022. This means that integration layers, data models, and payment processing need to be adapted.
For digital platforms, this represents a technological shift—but also an opportunity to offer more modern and business-oriented features.

How This Affects Organizations
For many organizations, this change primarily means a reduction in administrative tasks. Payments can be matched automatically, and disbursements can be made without manual checks.
For associations, it also provides peace of mind by eliminating the need for personal accounts and allowing payments to be tracked directly in the system, without the need for multiple people to manage financial flows.

Greater Security Through Transparency
The new infrastructure makes it possible to track payments in greater detail and detect anomalies more quickly. Standardization entails clearer requirements for traceability, identification, and verification in every transaction. This creates greater overall security—both for organizations and for the individuals who handle money in their operations.

Digital from Start to Finish
“This is one of the most important modernizations in many, many years. For the first time, we can process payments digitally from start to finish—without manual steps, without file formats, and without organizations having to build their own banking infrastructure. This creates transparency, security, and a whole new opportunity to automate everyday tasks.”
— Petter Sehlin, founder of Ping Payments

Summary
2026 will fundamentally modernize the Swedish payments system. File transfers will be replaced by API communication and information-rich transactions. The result will be less administrative work, better control, and a simpler day-to-day operation for both organizations and digital systems—while at the same time increasing the demands for transparency and security.

Digital tools have made it easier to run organizations. Payments, membership records, and communication are now often handled digitally. At the same time, new risks are emerging for which many nonprofit organizations lack clear procedures.

Here are five common areas that are important to keep an eye on.

1. When personal finances and the association's funds get mixed up

Personal Swish numbers or bank accounts are often used within clubs and sections. While this may work in everyday situations, it makes accounting, tracking, and auditing more difficult and increases the risk of errors and misunderstandings.

2. The Treasurer's Computer and Email

The treasurer often has access to both money and sensitive information. If security relies on a personal computer or email address, the association becomes vulnerable in the event of a breach, a mistake, or lost access.

3. Inadequate Procedures for Board Transitions

When roles change, there are often no clear procedures in place for access rights and logins. This can result in former representatives retaining access or important information being lost.

4. Fake payment requests

Fraud targeting organizations is on the rise. Fake emails, invoices, or payment instructions can be difficult to detect, especially when payments are processed manually and without clear safeguards.

5. Unclear roles between the association, the team, and the sections

When multiple parts of an organization manage their own funds without a common framework, it becomes difficult to maintain an overview, ensure accountability, and maintain traceability.

Summary

Most risks in association finances do not arise from malice, but rather when old ways of working encounter new digital opportunities. With clear structures, responsibilities, and the right system support, it is possible to reduce these risks—without making participation more complicated.

A new standard that changes how payments work

ISO 20022 is the new international standard for how payment information is structured and exchanged between banks, payment service providers, and systems.

It replaces older payment formats and makes it possible to send more detailed, structured, and machine-readable information with each payment.

The standard is being implemented as the payments market in Sweden and the EU undergoes modernization. Banks and clearing solutions are transitioning to ISO 20022 for both domestic and international payments, which places new demands on systems and integrations.

For system providers, ISO 20022 means that payment flows and data models need to handle more detailed information. At the same time, it creates new opportunities for automated reconciliation, improved reporting, and smarter business logic.

For associations and organizations, the standard leads to clearer payment information, simpler bookkeeping, and less manual work.

Ping Payments' payment services are ready and already operational within the new payment infrastructure—where structure, traceability, and automation are integral components.