OECD Integrity Review of Sweden

Efficient and effective procurement is critical to the fulfilment of the basic functions of public administration, including the delivery of public services, to establish citizens’ trust, and to ensure sustainable and inclusive economic growth. In addition, well-designed public procurement systems contribute to achieving pressing policy goals such as environmental protection, innovation, and ensuring responsible business conduct. In Sweden, public procurement is a key economic activity and a crucial pillar of service delivery. In 2023, it accounted for 17.2% of gross domestic product (GDP), well above the OECD average of 12.7% of GDP and the OECD-EU average of 14.8% of GDP (Figure ‎7.1).

Public procurement can be impacted by a wide range of risks and threats that can affect the procurement process itself, as well as broader risks to projects or service delivery (OECD, 2023[1]). Integrity threats remain a key concern in most countries due to the large amounts at stake, the complexity of procedures, the large number of stakeholders and the close interaction between the private and the public sector (OECD, 2015[2]). While the proportion of the Swedish population who perceive that corruption in general is widespread in the country is well-below the EU average, it is nevertheless higher than the EU average when it comes to corruption in public procurement and has increased over the last years (42% in Sweden and 37% in the EU) (European Commission, 2024[3]). According to the Swedish Anti-Corruption Institute (Institutet Mot Mutor) 6% of bribery conviction cases in Sweden are related to public procurement. 36.2% of corruption related cases investigated by the Police from 2012 to 2022 are linked to public procurement.

Furthermore, the Confederation of Swedish enterprises (Svenskt Näringsliv) has launched a survey to its members in 2022 and 2023 to understand the major issues companies are facing. Results of this survey show that corruption is among the top 10 issues faced by companies in public procurement. In addition, integrity breaches can also be linked with other issues faced by companies like insufficient documentation or disproportionate requirements (Figure ‎7.2).

Sound integrity-driven public procurement systems are thus essential not only for ensuring transparent and effective operations but also for generating the highest value added for society. Efficient and effective public procurement systems enable the public to track procurement activities, thereby helping in re-gaining trust in the public sector and democratic institutions (OECD, forthcoming[4]).

As explored in more depth elsewhere in this report, Sweden has three levels of government: national, regional (with 21 counties), and local (with 290 municipalities), responsible for different aspects of public service delivery (Table ‎7.1). The 1992 Swedish Local Government Act regulates the organisation and powers of the municipalities and regional councils (Government Offices of Sweden, 2025[5]).

In Sweden, in 2023, 68% of public procurement spending took place at the subnational levels (OECD, 2025[7]). Simultaneously, different reports and discussions with stakeholders highlighted that integrity issues are more widespread at the subnational levels. These findings are also shared by municipalities and regions who believe that procurement and purchasing are a key risk area. In addition, to deliver public services, many municipally and regionally owned companies were established, which pose challenges in terms of governance and control (Swedish Agency for Public Management, 2023[8]). Over time, the number of such companies has increased, and they account for a very large share of public procurement spending.

Aware of the relevance of integrity risks, the Swedish government considers public procurement as a key area in the APACUI. Box ‎7.1 provides an overview of key actions.

This chapter aims to assess Sweden’s effort to promote and ensure the integrity of public procurement throughout the procurement cycle and provides key recommendations to enhance the system in place. It recommends that Sweden could:

• build a regulatory and strategic framework to further highlight integrity values

• further clarify the concept of Conflict of Interest and its application to public procurement

• develop its revolving door policies for public procurement

• ensure further clarity of provisions related to official misconduct in public procurement

• curb corruption by enhancing competition

• advance the professionalisation of the procurement workforce on integrity related matters

• further convey integrity principles and ethical values to the private sector

• further the publication of public procurement data and information

• centralise the publication of public procurement notices for better transparency

• ensure interoperability between databases to increase efficiency and the verification of exclusion grounds

• use data to better identify irregularities

Swedish procurement legislation is based on EU directives and EU primary law and is regulated in the Public Procurement Act (PPA), the Utilities Procurement Act, the Concessions Procurement Act, and the Defence and Security Procurement Act. Procurement procedures must observe the basic principles of transparency, equal treatment, non-discrimination, proportionality, and mutual recognition which are all linked to the integrity principles (Swedish competition authority, 2016[10]). Each procurement act contains rules for tender procedures that fall within the scope of the applicable EU directive, as well as rules for procedures that are only subject to national provisions. The estimated value of the contract dictates whether the procurement procedure is covered by the EU directives. Only tender procedures above certain thresholds are subject to the directives (Swedish Agency for Economic and Regional Growth, 2025[11]). The PPA mainly looks at integrity in the context of criminal offenses in relation to the mandatory exclusion grounds.

Indeed, in line with the EU directives, the PPA provides different grounds for excluding suppliers from participating in a public procurement process due to integrity breaches including criminal offences and other misconduct regarding a supplier’s operations. The information can be provided by submitting the European single procurement document (ESPD) which is a self-declaration form used by companies in public procurement procedures (European Commission, n.d.[12]). Box ‎7.2 provides examples of these exclusion grounds.

In addition, chapter 4 of the PPA mentions that if a tenderer has participated in the preparation of a procurement, the other tenderers shall be informed about the information relevant to the procurement that has been given in that context. A candidate or tenderer that has participated in the preparation of a procurement may be excluded from the procedure only if there is no other way to ensure that the principle of equal treatment is observed. Before the candidate or tenderer is excluded from the procedure, they should be given the chance to present an investigation showing that their participation in the preparations cannot lead to distortion of competition. The verification of some exclusion grounds will be discussed in section ‎7.4.3.

The national public procurement strategy from 2016 covers the prevention of corruption and conflicts of interest within the legal certainty of public procurement as one of its seven key objectives (Ministry of Finance, 2016[13]). To achieve it, the strategy called upon entities to take several actions including “producing internal guidelines on bribery and corruption, in order to provide employees with the right knowledge to prevent conflicts of interest and corruption”. While the strategy was published in 2016, it does not have a clear timeline for implementation which could hinder the delivery of the different actions. In 2023, the strategy was reviewed on the initiative of the Swedish government with roundtable discussions, analyses, and a broad engagement process. The conclusion from the review was that the strategy is considered to still be valid and relevant, but the implementation is lagging (The National Agency for Public Procurement, n.d.[14]). Therefore, additional measures from the government are expected to enhance implementation of the strategy. The government has also given the National Agency for Public Procurement an assignment in the letter of appropriation for 2025 to evaluate the strategy through a national survey. The assignment should be reported to the government at the latest on the 15 March 2026. It could be beneficial to clarify the implementation timeline of this strategy and of the different actions. In addition, the government should clarify the measures related to the implementation of the strategy. Furthermore, while the strategy focuses on corruption, bid rigging, and conflict of interest, it does not mention fraud or undue influence which are also relevant integrity breaches. Given the larger scope of integrity breaches and the emerging topic of undue influence, it could be beneficial to cover all integrity breaches in the public procurement strategy and implementation measures.

Preventing and managing conflicts of interest in the public sector is crucial to helping governments strengthen and enhance public integrity. Left undetected or inappropriately managed, such conflicts can undermine the integrity of public officials, decisions, agencies, and governments (OECD, 2004[15])). This holds particularly true for public procurement where managing conflicts of interest is crucial to ensure taxpayers money is spent adequately.

If conflicts of interest are left unresolved, they may ultimately lead to private interests capturing the policy process. While conflict of interest is mentioned in the public procurement regulatory framework, in contract clauses, and related guidance documents, there is no clear definition of the concept in Sweden at the national level (see Chapter 5 of this report). Indeed, Sweden did not fully transpose Article 24 of the European Public Procurement Directive which provides clear guidance for the definition of conflict of interest in a public procurement context (Box ‎7.3).

The Administrative Procedure Act (Förvaltningslagen) and the Local Government Act (Kommunallagen) foresee conflict-of-interest situations where an official should be disqualified (Swedish Government, 2017[17]). However, these situations lack clarity and could be considered in some instances as subjective . For instance, in the provision related to an official having to be disqualified if he/she or a “close person” is a party in the matter or can otherwise be assumed to be affected by the decision to a significant extent, the definition of a close person is not clear, which affects its interpretation in a procurement context. This lack of clarity hampers the effective implementation of these provisions. In addition, there is no clear procedure or guidance to follow in case of conflict of interest. In practice, an official would report the situation to their line manager or to the head of entity. In this context, as suggested in Chapter 5 of this report, it would be beneficial to clarify the concept of conflict of interest at the national level and to provide clear guidance on how to report these situations. Furthermore, certain public officials and political appointees do not have clear limitations in participating in public procurement procedures. For instance, there is no prohibition or restriction on the holding of financial interests by members of Parliament (MPs) or on them signing contracts with the state (OECD, 2024[18]). It would be beneficial for Sweden to also clarify conflict-of-interest safeguards for political appointees participating in public procurement.

Conflicts of interest may arise also in case of movement of personnel between employment in the public and private sectors; this phenomenon is known as a “revolving door”. Given the risks at stake, some OECD countries such as Italy have developed specific post-public employment measures that include cooling-off periods for high-risk areas including public procurement (Box ‎7.4). As mentioned in Chapter 4 of this report, Sweden does not have a post-public employment policy at the national level or for high-risk areas such as public procurement. Discussions with stakeholders highlighted that this issue is particularly concerning at the subnational levels, where interest groups are infiltrating decision-making bodies in municipalities to take decisions favouring specific companies. It would be beneficial for Sweden to include a focus on high-risk areas such as public procurement in any post-employment policy it develops, per the recommendations in Chapter 4.

The abuse of function in the public sector is a failure to perform an act by a public official, in violation of laws, to obtain an undue advantage. In the context of public procurement, this could be linked to integrity breaches such as favouritism (European Commission, 2014[20]). The European Directive on combatting corruption includes specific provisions related to “the abuse of function” (European Commission, 2023[21]).

In Sweden, Chapter 20 of the Criminal Code foresees specific criminal provisions related to the “abuse of function” under the name “official misconduct”. According to discussions with civil society organisations, “official misconduct” is the only crime for which a public official can be convicted in case of favouritism or nepotism, in the absence of bribery, fraud, or breach of trust. However, in practice, such cases rarely lead to convictions.

Several scandals including the “Vårdexpressen procurement” scandal highlighted gaps in the current legislation as integrity issues such as favouritism in procurement might not lead to criminal conviction. This scandal refers to the procurement of an AI-based system developed by the Swedish company Vårdinnovation. During its pilot, concerns were raised about the performance of the solution which led to investigations uncovering issues with the procurement process (Niemiec, 2023[22]). While in the first instance, the CEO of the company and two procurement officials were convicted by the District Court of bribery and breach of trust and sentenced to prison, the Court of Appeal acquitted one of the public officials who had deliberately manipulated a procurement tender for bribery charges. The Court of Appeal also acquitted the CEO and the two officials from charges based on the offence breach of trust. Civil society organisations highlighted in preparation for this report that this might not have a deterrent effect to commit integrity breaches.

In this context, the government has recognised the need for more comprehensive legal frameworks tasked a legislative inquiry (“Criminal Law Measures Against Corruption and Misconduct”, dir. 2024:14) to review whether the current laws on breach of trust and official misconduct are effective and whether their scope should be expanded. Sweden should consider further clarifying how the “official misconduct” offence applies to issues related to favouritism in public procurement. In addition, it could be useful to provide clear guidance and capacity building activities on this topic.

Ensuring access to procurement opportunities is a key principle of a sound public procurement system as it enables achieving value for money, driving innovation, quality, and efficiency (OECD, 2015[2]). A healthy level of competition, in turn, provides benefits for both governments and businesses by stimulating economic productivity, innovation, SME development, and integrity (OECD, 2024[23]). Indeed, there are strong links between competition and integrity breaches. Integrity breaches can limit access of companies to specific markets, distort competition, and reduce business appetite for foreign investors which can have significant financial impacts for governments, businesses, and citizens ( (OECD, 2016[24]). The strong links between corruption risks and market distortion have also been confirmed by researchers in Sweden (Wittberg and Fazekas, 2023[25]). In this context, the OECD Recommendation on Public Procurement calls for using competitive tendering and limiting the use of exceptions and single-source procurement (OECD, 2015[2]).

Aware of the benefits of competition, the Swedish government included “multiplicity of suppliers and well-functioning competition” as one of the seven objectives of the 2016 National Public Procurement Strategy (Ministry of Finance, 2016[13]). In practice, the proportion of procurement procedures awarded without any call for bid above threshold (negotiated procedures without publication) is relatively low compared to other countries; 4% in Sweden in 2024, 12% in Austria, and 26% in Bulgaria. However, this rate has been increasing over time as it represented only 1% of procedures in 2021, 2022, and 2023 (European Commission, 2025[26]).

The Swedish Competition Authority (Konkurrensverket) is the supervisory authority for public procurement. The authority verifies whether contracting authorities comply with the laws on public procurement and systems of choice. When a contracting authority fails to comply with the laws, the Swedish Competition Authority can render supervisory decisions, impose fines, and initiate court actions. Due to Sweden’s awareness of the issue, the Swedish Competition Authority has gained more power as a supervisory authority since 1 January 2024. It may, besides its other responsibilities, make decisions on procurement fines in case of unauthorised direct awards.

Single bidding is a key indicator to assess the level of competition in public procurement. In recent years, single bidding is an increasing issue in several economies. Although the issue is more prominent in other EU countries (see Figure ‎7.4), based on TED data, single bidding, increased from 19% in 2021 to 21% in 2024 (as of July 2025) (European Commission, 2025[26]). Furthermore, according to a study conducted by the Swedish Confederation of Enterprises, 65% of suppliers (Swedish Confederation of Enterprises, 2024[27]) were already awarded a previous contract which shows a low rate of turnover between economic operators who win a public contract and a strong advantage for incumbents. This highlights the need to further investigate the level of competition in the Swedish public procurement market and to implement clear actions to improve participation of economic operators in public tenders in the country.

Investigation of competition issues requires access to a comprehensive set of public procurement data. The National Agency for Public Procurement - NAPP (Upphandlingsmyndigheten) is an agency established in 2015 with the aim of strengthening the strategic importance of public procurement. The agency built on the functions of previous agencies, including the Swedish Competition Authority, and before that the Procurement Assistance and Development Unit at the Legal, Financial and Administrative Services Agency and Vinnova (The Swedish Innovation Agency). NAPP plays a key role in public procurement by providing support and guidance within public procurement through know-how, tools, and methods. It is also a “statistics agency” with a remit to develop, manage, and disseminate statistics on public procurement. Since January 1, 2021, the agency is responsible for managing a statistics database where information from all procurement advertisements is collected. In this context, NAPP collects data from procurement notices in accordance with the Public Procurement Statistics Act. However, the Swedish Competition Authority does not have free and direct access to the full set of data due to confidentiality regulations. In addition, NAPP itself does not have full access to procurement data (see section 7.4.4). Given the oversight role of the Swedish Competition Authority, it could be beneficial for the entity to receive all the relevant data to conduct its mandate more efficiently.

The 2015 OECD Recommendation on Public Procurement calls upon countries to ensure that the public procurement workforce meets high professional standards for knowledge, practical implementation, and integrity. It thus provides a dedicated and regularly updated set of tools, for example, sufficient staff in terms of numbers and skills, recognition of public procurement as a specific profession, certification and regular trainings, integrity standards for public procurement officials, and the existence of a unit or team analysing public procurement information and monitoring the performance of the public procurement system (OECD, 2015[2]).

Professionalisation of the public procurement workforce is essential. It ensures that public buyers have the skills, knowledge, and integrity needed to perform their jobs and tasks in compliance with the law and in an efficient, effective, and strategic manner to deliver best value for money for citizens (OECD, 2023[28]) (European Commission, 2020[29]). Recent dynamic global trends and the current poly-crisis environment are contributing to making public procurement more complex than ever, demanding a sophisticated skillset from public procurement officials, as well as high standards of integrity and accountability (OECD, forthcoming[4]). Within OECD countries and those in the process of accession, some progress has been made in strengthening the public procurement function, but further efforts are needed to make it competitive. Although professionalisation initiatives are expanding, procurement is not yet widely recognised as a distinct civil service profession, and incentives for officials remain largely non-financial. Establishing procurement as a recognised, attractive career path is key to building a skilled workforce. Enhancing other stakeholders’ capacities could further professionalise the procurement ecosystem (OECD, forthcoming[4]).

Given the administrative organisation in Sweden, the professionalisation function is divided between the NPPA and contracting authorities. Although the public procurement function is classified as a standalone function (with jobs such as procurement official, category manager, and strategic procurement officer), there are no competency frameworks or certification frameworks at the national level (OECD, forthcoming[4]). However, there are initiatives at the level of contracting authorities or associations. For instance, the Swedish Association of Public Purchasers (Sveriges Offentliga Inköpare) has developed a competency framework (Swedish association of Public Purchasers, n.d.[30]).). Overall, there are different capacity building initiatives, but they are not integrated into a comprehensive skills development strategy for public officials.

Discussions with different stakeholders highlighted deficiencies in the professionalisation of the procurement workforce for topics related to integrity. These deficiencies are particularly widespread among municipalities, which is problematic because they are responsible for providing key public services to citizens and the largest public procurement spending takes place at the subnational level (68% in 2023) (OECD, 2025[7]). This has been confirmed by previous studies of the Swedish National Council for Crime Prevention (Brå) studies that underlines how municipalities are facing challenges in relation to competencies of the procurement workforce. At the same time, municipalities are facing greater risks of corruption than the central government due to a lack of resources to manage those risks. This highlights the need for further professionalisation, particularly at the subnational levels. This has been confirmed by the Swedish State Treasury which was assigned by the Government in 2022 to provide a situational picture of the prevalence of corruption at the municipal and regional levels. One of the ten recommendations included in its 2023 report is to “strengthen necessary knowledge and make employees more aware of corruption risks” (Swedish Agency for Public Management, 2023[8]). However, while the APACUI mentions the need to strengthen a good administrative culture, there are no specific actions related to professionalisation of the public procurement workforce (Sweden Government Offices, 2024[9]).

Professionalising the procurement workforce should follow specific steps: i) assessing the level of professionalisation, (ii) developing a professionalisation strategy, and (iii) implementing a professionalisation strategy. Actions to implement the strategy may include developing a competency model and a certification framework, developing capacity-building systems, setting up incentive mechanisms to increase the attractiveness of the public procurement profession, and promoting collaborative approaches with knowledge centres. (OECD, 2023[28]) (Figure ‎7.5). Some of these actions are complementary to each other. Sweden should consider undertaking the assessment of the level of professionalisation to implement the most adequate actions and ensuring that integrity and the concept of unlawful influence are covered. These should also be integrated into future iterations of Sweden’s strategic framework for anti-corruption.

In Sweden, each entity has overall responsibility for training, including on ethics and expected conduct, and on the prevention of corruption and conflicts of interest, which is based on materials produced by the Swedish Agency for Public Management (Statskontoret). Employees of the central public sector should follow the values of democracy, rule of law, objectivity, free formation of opinion, respect, and efficacy and service (Swdedish Agency for Public Management, 2022[31]). The promotion of integrity has been included within the principle of objectivity.

There are two categories of trainings which are relevant for the public procurement workforce: induction courses and regular trainings. Regarding induction courses, a public inquiry (the Delegation for Trust-Based Governance - “Tillitsdelegationen”) concluded in 2022 that public procurement which is a transversal topic for all jobs is not widely covered (less than half of induction courses) (Table ) (State Public Inquiries, 2020[32]). In 2024, the government introduced general digital induction trainings for all public officials. It could be beneficial to develop specific modules related to high-risk areas like public procurement for officials who will be involved in these activities.

Regarding regular courses, while some major contracting authorities like ADDA or Kammarkollegiet have introduced some practical public procurement dilemma exercises for their employees, there are no specific integrity or ethics trainings focusing on high-risk areas like public procurement available to the workforce. Aware of the need to enhance the integrity of the public procurement system, several countries in the European Union have developed integrity trainings on public procurement. For instance, Lithuania introduced a certification course in 2022, covering different topics including integrity and managing conflicts of interest (see Box ‎7.5). Given the emerging topic of unlawful influence, and the challenges in defining it, it could be beneficial to develop a dedicated training on this topic in public procurement. NAPP has suggested such training in the context of discussions in the network of Director Generals, co-ordinated by the Swedish Agency for Public Management. The proposals from this network will be presented to the Swedish government by the end of 2026.

As explored further elsewhere in this report, in Sweden each government agency is responsible for raising awareness of integrity principles and ethical values to establish a culture of integrity that prevents corruption and violations that may lead to disciplinary sanctions. The Swedish Agency for Public Management had developed a guideline to support employees implementing the common basic values (see previous section). While the document refers to a few public procurement examples, it does not provide concrete guidelines to the procurement workforce.

The 2016 Strategy on Public Procurement called upon entities to take several actions including “producing internal guidelines on bribery and corruption, to provide employees with the right knowledge to prevent conflicts of interest and corruption” (Ministry of Finance, 2016[13]). The Public Procurement Agency has developed specific guidelines on “preventing corruption in public procurement” which mainly covers corruption and conflict of interest issues throughout the procurement cycle. These guidelines are targeted at the management level and public procurement officials (National Public Procurement Agency, n.d.[33]) (National Public Procurement Agency, 2017[34]). Box ‎7.6 provides information on the main topics covered within the guideline targeting the management level. While these guidelines provide heads of entities and public procurement officials with support to prevent corruption and conflicts of interest, they do not cover the evolving topic of unlawful influence. The Swedish government could benefit from updating these guidelines to ensure they cover all potential integrity breaches including “unlawful influence”.

To promote a “whole of society” culture of integrity, integrity principles and ethical values should not only be conveyed to the public sector but also to the private sector. This should be done by different means, including trainings, awareness-raising sessions or the development of codes of conduct/ethics (OECD, 2017[35]).

In Sweden, there is no national code of conduct for public procurement suppliers. However, several organisations have developed their own. For instance, since 2010, Sweden's regions have collaborated towards sustainable procurement in a national effort. In this context, the regions have developed a common code of conduct for suppliers that covers the areas of human rights, workers' rights, the environment, and business ethics (Sweden's region, n.d.[36]). In addition, the Swedish Anti-Corruption Institute (IMM) administers the Code to Prevent Corruption in Business which includes specific sections on public procurement (The Swedish Anti-Corruption Institute, 2020[37]). Discussions with stakeholders highlighted that the IMM code is widely used and disseminated to the private sector. IMM also conducts awareness raising sessions. In addition, specific sectors including the construction and the pharmaceutical sectors have developed their own codes. Besides these codes, there are no efforts to promote integrity among suppliers. It could be beneficial to organise capacity building activities including awareness raising sessions to strengthen integrity values of the private sector. This is particularly relevant given the emerging topic of unlawful influence. These activities could be organised jointly by the Confederation of Swedish Enterprises together with public entities like NAPP.

An adequate and timely degree of transparency must be provided throughout the procurement cycle to promote fair and equitable treatment of potential suppliers, integrity, and competition. A lack of transparency and disclosure of information increases the risks of mismanagement, fraud, and corruption (OECD, n.d.[38]). Indeed, transparency can help mitigate risks of favouritism, corruption, and inefficiency by making procurement processes more open and accountable, enabling scrutiny of public procurement activities (OECD, forthcoming[4]). Figure ‎7.6 presents the share of OECD member and accession candidate countries publishing procurement documents and information in 2024.

In Sweden, contracting authorities publish relevant public procurement information throughout the public procurement cycle. However, compared to OECD good practices, two key documents are not published: procurement plans and information/contracts from non-competitive procedures. Indeed, once needs are identified, they should be translated into procurement plans. Their publication aims to draw early attention from the market to upcoming procurement opportunities. This increases transparency, which could help to decrease integrity breaches. Procurement plans are published in 83% of OECD member and accession candidate countries including EU countries like Austria, Belgium, Finland, Lithuania. While the publication of procurement plans is not mandatory in Sweden, some contracting authorities do publish them in line with international good practices.

In addition, there is no data or information available regarding negotiated procedures without publication. In Hungary, for instance, contracting authorities must publish all documents of the negotiated procedure without prior publication, including data regarding the invited and contracted economic operators which provides transparency on the use of this procedure (OECD, 2024[23]). Sweden would benefit from mandating the publication of information on non-competitive procedures and exploring the possibility to mandate the publication of procurement plans to enhance transparency in public procurement.

The APACUI places a strong focus on digitalisation in public procurement. In Sweden, the digitalisation of procurement includes two distinct processes:

• the e-procurement process which includes the preparation of tenders, their advertising, their evaluation, the contract signature, and the management of contracts; and

• the e-purchasing process which includes ordering, delivery, and invoice processing.

E-procurement solutions can be provided through a single or multiple e-procurement platforms that require certification and standardised business processes prescribed in the public procurement legislation. Similar to other EU countries like Spain or Portugal, Sweden has opted for an electronic procurement environment with privately owned multi-platforms (Competition Authority, 2025[39]). In 2025, five platforms were active in the market:

• e-Call-off

• KommersAnnons.se

• Mercell Ad Database

• Art pool

• Clira Ad Database

One key issue in Sweden is that there is no centralised national advertisement platform for the publication of procurement notices. As in every member state of the European Union, notices above the EU threshold are published in TED. Therefore, it is very challenging for economic operators and contracting authorities to have a real picture of the procurement opportunities at the national level. Despite having multiple platforms, Portugal has a national advertisement platform - the National Gazette (Diário da República) (OECD, 2024[40]) providing economic operators with a global picture of upcoming public procurement opportunities, enhancing access to market and transparency, which in its turn is also feeding the national procurement portal Base and provides information to the TED.

In addition, while the availability of data is a key element, its format significantly impacts the degree of transparency in public administration. Aware of the lack of open data, the Swedish Government adopted in 2019 “Sweden’s Open Government Partnership Action Plan 2023–2025” where the government committed to making procurement data open and available. The government also acknowledges in its commitment that “access to purchasing data also combats corruption by increasing transparency around public sector purchasing”. The Agency for Digital Government (DIGG) has been tasked with promoting the development of open access to procurement data (Swedish Government, 2023[41]). In its final report published in May 2025, DIGG recognised the need to have a centralised platform for publishing notices and for the State to have control and disposal over these datasets. It could be beneficial for Sweden to consider the centralisation of the publication of public procurement notices. NAPP has also been advocating for the centralisation of the publication of public procurement notices in Sweden in the context of the review of the EU public procurement directives.

Integrating public procurement with other digital systems and databases, such as finance, budgeting, human resources (HR), social security, tax, auditing, and enterprise resource planning (ERP) systems, can reduce administrative burdens, improve efficiency, enhance accountability, and minimise errors (OECD, forthcoming[4]). In Sweden, based on the 2024 OECD Survey on Public Procurement, e-procurement platforms were not yet integrated with any government platforms which hinders the verification of exclusion grounds including those related to integrity breaches.

However, stakeholders highlighted in preparation for this report that discussions on the integration of e-procurement platforms with other governmental platforms started in 2023. A bill on the integration of relevant databases was presented to parliament in August 2023 but was never adopted. This led to the development of solutions and initiatives by the private sector to support contracting authorities in verifying exclusion grounds. For instance, Kapitel 13 is a digital service provided by a private provider that supports contracting authorities in checking exclusion grounds. More specifically, it checks information on board members, CEOs, beneficial owners, and registered representatives of companies from all Swedish courts (general courts, administrative courts, and special courts) and documents from more than 600 different authorities (Kapitel 13, n.d.[42]). However, in 2024, invoking the General Data Protection Regulation, the Swedish Supreme Court rendered a judgement highlighting that the possibilities for private platforms to use large numbers of judgements and other criminal documents should be limited given the confidential nature of such information (Swedish Court, 2025[43]).

Aware of the urgent need to integrate procurement and other relevant government databases, the Swedish Companies Registration Office (Bolagsverket) was formally tasked by the government in 2025 to integrate the access to the registries of certain agencies, including the judicial records of the Police Authority. However, the interim report of the Swedish Companies Registration Office to the government published in April 2025 mentions several challenges related to integration that impact the initial implementation plan. While some challenges are technical, others are of a legal nature, in particular the lack of a legal basis to undertake the integration. The Swedish government should take the necessary measures to ensure the fast implementation of the integration of databases and information sharing to enhance efficiency in the public procurement process and to support contracting authorities in the verification of exclusion grounds.

Data has emerged as a key asset for governments (OECD, 2019[44]), informing decision-making processes, improving service delivery, and driving efficiencies. This holds true also in the public procurement area where using data throughout the procurement cycle can have several benefits including enhancing competition and detecting irregularities and misbehaviours.

In Sweden, the existence of multiple e-procurement platforms hinders the availability and access to data to identify and detect irregularities. Prior to 2019, public entities, including the Competition Authority had to pay e-procurement providers to receive public procurement data. This was considered an aberration by multiple stakeholders because public entities were paying to have access to data provided initially by other public entities.

For the tendering phase, a specific law on procurement statistics was adopted in 2019 (Swedish Parliament, 2019[45]). The Procurement Statistics Act (2019:668) provides the National Agency for Public Procurement – NAPP the responsibility to maintain a national database for statistics in the area of public procurement (statistical database).

Ordinance (2020:332) on procurement statistics adopted in 2020 (Swedish Parliament, 2020[46]) includes supplementary provisions to the Act (2019:668) on Procurement Statistics and enabled the National Agency on Public Procurement to specify in regulations what data should be reported by the e-procurement providers, how and when, and the rules on the allocation of a Swedish procurement-ID (National Public Procurement Agency, n.d.[47]). Information from a procurement notice needs to be reported to NAPP within 30 days from its publication. This timeline does not enable NAPP to receive real-time data to identify some issues relevant for policymaking and the provision of support.

In addition, data received from e-procurement providers by NAPP is only based on e-forms notices. Therefore, some key information to assess the efficiency and integrity of the procurement system is not captured. For instance, notices do not capture data on “bids rejected” which could help understand the level of competition in a given market. This is particularly relevant given the increase in single bidding in Sweden (see section ‎7.2.5).

Furthermore, oversight bodies such as the Swedish Competition Authority do not have access to the data collected by NAPP for confidentiality reasons nor data from platform providers. This hinders the effective performance of their duty. Other oversight bodies in countries like Portugal were facing similar issues related to data access. For instance, to enhance its oversight system, in 2024, the Tribunal de Contas (the supreme audit institution) implemented a data-driven risk-based model with the support of the OECD. However, the implementation of this data-driven risk model faced a major challenge in accessing databases owned by other public institutions due to the General Data Protection Regulation (GDPR). To overcome this challenge, protocols of agreements were signed with several entities including IMPIC (The Institute of Public Procurement, Real Estate and Construction) which manages public procurement data (OECD, 2024[40]). Sweden should consider ensuring a full and timely access to all procurement data to NAPP and oversight bodies taking into account confidentiality requirements.

Aware of the need to have a global picture of public procurement spending, countries are increasingly considering the possibility to track data from the tendering phase to the payment of invoices. For instance, Finland is implementing a unique identifier to track procurement data from notices and invoices (Box ‎7.7).

In Sweden, NAPP has access to data from notices, but these do not cover the whole procurement cycle (from procurement notices to invoices) (Swedish Parliament, 2019[45]). In 2023, NAPP issued regulations on procurement ID which refers to a unique identification number for the procurement to which an advertisement relates (National Public Procurement Agency, 2023[48]). However, this identifier is used only for notices and is not yet used in invoices or orders.

During the contract management phase, many entities rely on e-commerce platforms for ordering and invoicing. While no data exists on the share of entities using e-commerce, stakeholders mentioned that it still is an area of improvement. In this context, the APACUI required DIGG to develop a training concept for contracting authorities and entities to increase the use of e-commerce systems (Sweden Government Offices, 2024[9]).

E-ordering is not mandatory, it is required for public entities with more than fifty employees. The Swedish Financial Management Authority conducted a survey in 2024 on the implementation of e-orders. The response received from 163 entities shows a low uptake of e-orders, with 57% of entities reporting that less than 30% of their orders are in an electronic format (DIGG, 2025[49]). Electronic invoices are regulated in Sweden by the “e-invoicing act” and DIGG strongly recommends suppliers to use the implementation of the European standard, Peppol BIS Billing 3 (DIGG, n.d.[50]). In practice, suppliers can use e-commerce platforms or their own ERP to issue invoices. However, there is no centralised database for invoices and there is no common link or identifier between procurement notices and invoices. DIGG only has data based on surveys on the penetration rate of e-invoices and matched e-invoices which represents invoices matched with purchase orders. This process enables the identification of discrepancies between orders and invoices. Table ‎7.3 shows that the share of e-invoicing has been increasing since 2019 but has not yet reached 100%. In the APACUI, the government has tasked Kammarkollegiet with increasing the possibility of digital support for call-offs from framework agreements (Sweden Government Offices, 2024[9]). Indeed, not all the call-offs are made using digital tools. This action will further support the digitisation of the procurement process, in particular when using efficiency tools such as framework agreements. In addition, despite increasing since 2019, the share of matched invoices has been slightly stagnating since 2023.

Given the lack of a centralised platform on e-invoicing led by the government, a private company collects and makes publicly available information from invoices of many public organisations in Sweden. Using artificial intelligence and machine learning algorithms, the company identifies discrepancies and deficiencies in the public sector spend. In this context, Sweden could benefit from establishing a common process to ensure the collection of data throughout the procurement cycle and ensuring the use of a common identifier across procurement notices, orders, and invoices. In a second stage, Sweden should consider centralising this data to perform different types of analysis that are not only relevant for efficiency but also for integrity and accountability, including the identification of red flags and irregularities. Discussions with NAPP highlighted the willingness of the entity to lead the establishment of this common process.

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[16] EU Parliament and Council (2014), “DIRECTIVE 2014/24/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL”, Official Journal of the European Union, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0024&from=EN (accessed on 31 January 2018).

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[48] National Public Procurement Agency (2023), Regulation on procurement ID, https://www.upphandlingsmyndigheten.se/globalassets/dokument/statistik/dokument-2023/foreskrifter/ufs_2023_2-om-upphandlings-id.pdf.

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