Sweden – Prohibition on number sub-allocation

The Swedish Post and Telecom Authority (PTS) has issued comprehensive guidance that fundamentally reshapes how communications providers operators can manage numbering in Sweden. The guidance, published on 12 June 2025, represents a decisive shift away from the previously tolerated practice of number sub-allocation, with far-reaching implications for the telecommunications sector.

The guidance is available in Swedish here.

The regulatory landscape transformed

Under the Swedish Electronic Communications Act (LEK), telephone numbers may only be used with authorisation from PTS. PTS has now clarified that sub-allocation of numbers in Sweden is no longer permitted, marking a complete prohibition on any form of number sub-allocation arrangements.

The guidance defines number sub-allocation as arrangements where a number licence holder provides numbers to another communications provider who then provides the licensed numbers to its end customer:

licensed number holder > communications provider > end user

This is no longer permitted and now the communications providers must have direct number allocations to provide numbers to end users. In other words, all communications providers must obtain number licences from PTS to provide numbers to their customers.  This requirement is designed to ensure transparency and traceability of numbers, as information about where a number is located and who is responsible for it is directly linked to the number licence. When numbers are used by an entity other than the licence holder, publicly available information risks becoming incorrect, undermining the regulatory framework's effectiveness and increasing the risk number misuse

Scope and application

The new guidance applies comprehensively to all types of numbers in Sweden. Importantly, these rules apply to existing and new numbering requirements, and all operators seeking fresh number allocations must comply immediately and companies must also address existing arrangements.

Enforcement priorities and compliance timeline

PTS has confirmed that addressing existing non-compliant arrangements represents an enforcement priority, with compliance investigations planned for later this year. This signals a proactive approach to ensuring market-wide adherence to the new framework.

For operators found to be infringing the new rules, the consequences are significant. Communications providers risk having their number licences revoked if licensed numbers are sub-allocated to other entities. The regulator can also issue injunctions requiring entities to comply with regulations, and such injunctions may be combined with penalties. However, we understand that administrative fines will not be applied at this initial stage, suggesting a measured approach to implementation.

Practical implications for market participants

Current sub-allocation arrangements

Operators currently engaged in sub-allocation arrangements face immediate compliance obligations. The guidance makes clear that if numbers licensed to one entity are used by another entity for providing electronic communication services, this constitutes use that is not compatible with the regulatory framework for number usage.

Licence holders must either cease sub-allocation activities or apply to PTS for transfer of the numbers to the entity that actually uses the numbers for its communication services. Where there is no genuine need for the numbers, they should be returned to PTS.

New number applications

For operators seeking new number allocations, direct application to PTS is now mandatory.

Looking forward

Operators must act swiftly to assess their current numbering arrangements and initiate necessary compliance measures. The regulator's stated its intention to commence compliance investigations later this year leaves little room for delay.

For more information please contact Ana-Maria Barbu-Nyström.