Main Concerns

• Threshold values missing so even very small purchases are covered; combined with fact that changes in ownership stakes in certain intervals also subject to notification, means large number of completely unproblematic acquisitions must be notified.
• Includes reporting obligation for all investments falling within relevant business areas.
• That, regardless of investor's nationality so even Swedes or investors from other EU countries will have to notify acquisitions.
• Which activities covered in many parts unclear, potentially covers large economy parts.
• Apart from products with military connection, critical minerals, sensitive technologies, etc. with direct link to national security seen, e.g. category socially important activity not further defined; it shall be determined later in official regulations.
• This, coupled with tangible consequences in failure to report, risks many companies consider forced to report for safety's sake or refrain from investing if believed covered.

Conclusions

• Danger that considerable part of investments made on ongoing basis in Sweden will have to be notified, relevant authorities will have to spend large resources on checking problem-free acquisitions, what will reduce possibilities of acting against real threats.
• It will likely be difficult to stop such investments if bottlenecks arise in the authorities' review processes, which can be exploited by actors with bad intentions.
• Realize SWE is in absolute final phase of legislative process but it should not be too late to make adjustments that can not only make investment review more effective.
• But also minimize negative consequences for companies' competitiveness and for Sweden as an investment destination.