Private enforcement in Sweden: recent developments

Private competition enforcement in Sweden has recently experienced an awakening. The Swedish Patent and Market Court (“PMC”) is currently handling several high-value damages claims and actions for injunctions against alleged competition law infringements. The ongoing proceedings span a wide range of sectors, including digital markets, automotive cartels, sports governance, and utility pricing, illustrating private enforcement’s broad applicability.

Continue reading for an update on the current PMC proceedings.

Legal framework and recent developments

Private enforcement under the Swedish competition regime may be pursued essentially in two ways.

First, damages actions can be brought before the PMC pursuant to the Swedish Competition Damages Act (2016:964), implementing the EU Competition Damages Directive 2014/104. While the possibility to claim damages for competition law infringements has existed in Sweden since the Competition Act entered into force in 1993, such actions have historically been rare. The 2016 Damages Act was expected to change this, but it is only recently that a clear shift has become visible, with several substantial competition damages claims now pending before Swedish courts.

Second, the Swedish Competition Act (2008:579) grants private parties a subsidiary right to bring an action before the PMC, seeking an injunction against a potential competition law infringer. This option is only applicable to companies affected by the infringement, and only after the Swedish Competition Authority (the “SCA”) has decided not to pursue the case following a complaint.

Currently, several damages actions and private injunction cases are underway in Sweden. Three follow-on claims are pending before the PMC, following the European Commission’s (“Commission”) decisions in Google Shopping, the Trucks Cartel, and the Occupant Safety Systems (“OSS”) Cartels. Additionally, two private injunction actions are before the PMC, one brought by Sweetspot against Svenska Golfförbundet’s (the Swedish Golf Association, “SGF”) over IT system requirements, and another concerning Nevel’s alleged excessive pricing in district heating.

Below is an overview of the pending cases.

Google Shopping follow-on claim (PMT 1860-22, PriceRunner v. Google)

The PriceRunner v. Google case is a private enforcement action arising from the Commission’s 2017 Google Shopping decision, imposing a EUR 2.4 billion fine on Google for self-preferencing. That decision was upheld by the General Court in 2021 and the Court of Justice (“ECJ”) in 2024 (please find the Commission’s press release here, and the ECJ’s judgment here). In February 2022, PriceRunner filed a follow-on damages claim against Google before the PMC. Google has denied liability, arguing that it did not abuse its dominant position after the Commission’s decision and that PriceRunner has not suffered any damage at all.

The main hearing began in October 2025 and will continue until December 2025.

OSS Cartel follow-on claim (PMT 5791-23, Volvo v. ZF/TRW)

In April 2023, Volvo Personvagnar AB (“Volvo”) filed a EUR 420 million damages claim against Autoliv and ZF for participating in the OSS cartels during 2004–2011. The Commission established the existence of these cartels in two settlement decisions: OSS I (please find the press release here) and OSS II (please find the press release here). Volvo claimed that the cartels extended beyond the Commission’s findings or, alternatively, that the cartels resulted in umbrella effects affecting Volvo (i.e. inflated prices also charged by non-cartel firms as a result of the cartel).

On 3 October 2025, Volvo withdrew its action against Autoliv, but not against ZF. A possible reason for the withdrawal may be the UK Competition Appeal Tribunal’s dismissal of Stellantis’ claim for EUR 770 million in follow-on damages against Autoliv in February this year. Since Stellantis’ action was also based on umbrella effects derived from the OSS cartel, the lack of success in the UK court could perhaps have affected Volvo’s motivation. Dates for oral or main hearing in Volvo’s action against ZF have not yet been decided.

Trucks cartel follow-on claim (PMT 2018-25, STCC v. Scania)

In January 2025, the Dutch foundation Stichting Trucks Cartel Compensation (“STCC”), filed a EUR 12 million damages claim against companies in the Scania group (“Scania”) for participating in the so-called Trucks cartel during 1997–2011 (please find the press release to the decision involving Scania here). The General Court and the ECJ subsequently confirmed the Commission’s decision in 2024 (please find the judgment here). STCC represents customers that purchased approximately 3,500 trucks during the cartel period, calculating damages based on an average price of EUR 70,000 per truck and a 5% overcharge. Scania disputes the claims as time-barred and challenges STCC’s legal standing. The PMC has granted STCC’s request to stay proceedings pending parallel Dutch court cases involving the same customers, as well as a limitation period issue before the Dutch Supreme Court.

Tying of Golf IT system (PMT 15285-23, Sweetspot v. SGF)

In October 2023, Sweetspot filed a lawsuit against SGF, alleging abuse of a dominant position by tying SGF membership to its IT system, GIT, and by refusing Application Programming Interface (“API”) access to GIT. SGF is Sweden’s national golf federation and membership is essentially mandatory for golf courses; GIT is used by virtually all Swedish golf clubs. Following the SCA’s decision not to further pursue the case, Sweetspot sought an injunction before the PMC to make GIT optional for SGF members, grant GIT access to Sweetspot, and prohibit SGF from cross-subsidising GIT with revenues from its other businesses. SGF further requests that these obligations be subject to a conditional fine of SEK 30 million.

Main hearing will take place in March or April 2026.

Excessive pricing of district heating (PMT 20179-24, Krambo et al. v. Nevel)

In November 2024, four plaintiffs filed a lawsuit against Nevel AB (“Nevel”) before the PMC, alleging an abuse of a dominant position. Nevel, a district heating supplier, had announced significant price increases for district heating services between 2022 and 2023. The plaintiffs argue that Nevel has abused its dominant position in local district heating markets, which constitute natural monopolies. The plaintiffs argue that they are unable to terminate their contracts with Nevel as no alternative district heating suppliers exist. Following the SCA’s decision not to further pursue the case, the plaintiffs sought an injunction before the PMC to cap Nevel’s price increases at a maximum of 10 percent, subject to a conditional fine of SEK 50 million.

The main hearing is scheduled to begin on 2 December 2025.

Concluding remarks

While private enforcement of competition law has proliferated across Europe, particularly in jurisdictions such as Spain and the Netherlands, Sweden has until recently seen relatively few such actions. That picture is now changing. The cases outlined above demonstrate that Swedish courts are now handling private enforcement claims of unprecedented scale in Sweden, notably PriceRunner’s SEK 80 billion claim against Google. The outcomes of these cases will likely influence both the willingness of future claimants to pursue cases in Sweden, and the compliance strategies of companies operating in Sweden.

This evolution further marks a significant shift towards the goals envisaged by the EU Competition Damages Directive, where public enforcement by competition authorities is complemented by private enforcement actions. Whether this trend will continue remains to be seen, but private enforcement is clearly gaining ground in Sweden.