An investigative analysis of systemic failures in Sweden’s telemedicine sector—and what Nordic business leaders need to know about the future of digital health regulation
In an era where digital transformation promises efficiency and accessibility, Sweden’s telemedicine sector has become a case study in how rapid innovation can outpace regulatory frameworks—with costly consequences for taxpayers and patients alike.
Recent investigative testing by Swedish Radio (Ekot) has exposed fundamental flaws in how digital healthcare providers bill for services, while new antitrust penalties reveal an industry struggling with both compliance and competitive integrity.
The Ghost Visit Phenomenon: Billing Without Care
The core issue is startlingly simple: patients are being charged for doctor visits that never occurred.
In controlled tests conducted by Ekot reporters, researchers-initiated consultations through the Min Doktor app for common ailments—fever and sore throat—then abandoned the session before any healthcare professional joined the chat. Despite no actual medical interaction taking place, the app recorded a diagnosis and billed the reporters’ home regions for completed visits.
The billing trail reveals a systemic loophole. When reporters checked their records later, they found a doctor had attempted contact and documented: “Since you have not returned to our dialogue, I assume that you have received help in another way or are no longer in need of help.” This administrative closure was then converted into a billable event.
Kent Bobits, operations controller at Region Sörmland, was unequivocal when presented with the findings: “You haven’t had a doctor visit, but they’ve billed for it. And that’s bad.”
Min Doktor declined interview requests but provided a written statement asserting that such charges should not occur and that internal guidelines require “actual dialogue” between patient and healthcare professional. The company committed to examining how frequently these situations arise.
Ministerial Condemnation and the Unit Price Model Problem
Health Minister Elisabet Lann (KD) did not mince words: “I think it’s shameful that the Swedish healthcare system is being exploited in this way.”
The controversy highlights deeper structural issues with Sweden’s digital healthcare reimbursement model. Unlike traditional healthcare centres that receive capitation payments based on registered patient lists, digital providers typically operate on a per-visit fee structure. The Swedish Competition Authority has identified this unit price model as cost-driving, creating perverse incentives for providers to maximise visit volume rather than care quality.
The Stockholm Region’s medical record review of competitors Doktor.se and Kry found that over half of examined visits should not have been billed—findings the companies have disputed.
When asked whether national legislation would address these systemic flaws, Minister Lann remained cautious but open: “I don’t rule it out. I want to wait and see what the investigator comes up with. No one benefits or is interested in us running demand-driven care instead of needs-driven care—we won’t be able to afford that if we are afraid for our healthcare system.”
The Antitrust Dimension: Collusion in Digital Health
The billing controversy is not the only regulatory challenge facing Sweden’s digital healthcare sector. In April 2025, the Swedish Competition Authority (SCA) imposed combined fines of SEK 26.5 million (approximately €2.4 million) on three digital healthcare providers—Doktor.se (SEK 15 million), Min Doktor (SEK 6.5 million), and Doktor24 (SEK 5 million)—for anticompetitive agreements regarding Google advertising practices.
The investigation revealed that in 2020, these competing providers agreed to refrain from bidding on each other’s brand names in Google Search keyword advertising. This meant consumers searching for one provider would not see alternatives, artificially restricting market transparency and consumer choice.
Notably, Kry avoided penalties by proactively reporting the agreements to authorities under the SCA’s leniency program—a strategic move that may signal shifting competitive dynamics in the sector.
The Out-of-County Reimbursement Mechanism
Understanding these controversies requires grasping Sweden’s unique healthcare financing structure. Under the 2015 Patient Act, citizens have free choice of primary care nationwide. When patients use digital providers based outside their home region—many telemedicine firms are registered in Region Sörmland—the visit is billed as an “out-of-county” consultation.
The financial flow works as follows: the digital provider bills Region Sörmland, which then invoices the patient’s home region for reimbursement. For years, this out-of-county fee was set at SEK 500 per visit. In February 2024, Sweden’s municipalities and regions (SKR) recommended reducing this to SEK 435 for digital visits, with implementation required by June 1, 2024.
This decentralised payment structure creates accountability gaps. Each region supervises providers registered within its jurisdiction, but patients—and their data—move across regional boundaries, complicating oversight and quality assurance.
Current Regulatory Landscape and Future Implications
Sweden’s digital health sector stands at a regulatory inflection point. Several developments will reshape the operating environment:
European Health Data Space (EHDS): The EHDS Regulation entered force in March 2025, introducing a transition period through 2027. By March 2029, priority health data categories must be exchangeable across all EU member states. Sweden faces significant investment requirements—estimated at €150-400 million between 2025-2028—to build the necessary infrastructure.
AI Governance: Sweden’s implementation of the EU AI Act positions the Medical Products Agency (Läkemedelsverket) as the market surveillance authority for AI-integrated medical devices. The 2025 AI Commission Roadmap emphasizes moving from “cautious observer to leading implementer,” with significant implications for digital health platforms using algorithmic triage or diagnostic support.
Interoperability Requirements: The Swedish government intends to submit proposals in 2026 for a new act on interoperability requirements for public administration data sharing, directly impacting how digital health providers integrate with regional healthcare systems.
Business Analysis: Risk Factors and Strategic Considerations
For Nordic business leaders and investors, these developments present several critical considerations:
Regulatory Risk Escalation: The combination of billing fraud investigations and antitrust enforcement signals heightened regulatory scrutiny. Companies operating on per-visit reimbursement models face particular pressure to demonstrate value and prevent overutilisation.
Reimbursement Model Evolution: The trend toward capitation-based or value-based payment models—away from fee-for-service—will require digital health providers to build longitudinal patient relationships rather than transactional visit volumes.
Data Governance Requirements: The EHDS implementation will impose new technical and legal obligations on health data processors. Early compliance investments will provide competitive advantages.
Market Consolidation Pressures: The antitrust case suggests an industry where informal coordination was previously tolerated. Post-enforcement, competitive dynamics may favour larger platforms with robust compliance infrastructure or niche specialists with clear differentiation.
Regional Variation: Sweden’s decentralized healthcare system means 21 regions with varying digital maturity levels. Successful providers must navigate heterogeneous regulatory environments and reimbursement policies.
Conclusion: Toward Sustainable Digital Health
Sweden’s experience demonstrates that digital healthcare transformation requires more than technological innovation—it demands governance innovation. The gap between regulatory frameworks designed for physical care delivery and the realities of app-based healthcare has created opportunities for system exploitation.
As Minister Lann’s pending investigation concludes and EHDS implementation accelerates, Nordic healthcare stakeholders should anticipate:
1. Stricter billing verification requirements with automated audit capabilities
2. Harmonised regional reimbursement policies reducing arbitrage opportunities
3. Enhanced interoperability mandates enabling better cross-regional oversight
4. Clearer liability frameworks for AI-assisted diagnostic and triage systems
The companies that thrive will be those treating regulatory compliance not as a burden but as a competitive differentiator—building trust through transparency in an industry where trust is the ultimate currency.
About the Investigation
This analysis builds on investigative reporting by Emelie Rosén and Sven Carlsson of Swedish Radio (Ekot). Tips can be submitted via encrypted channels through Radioleaks.
Next In This Series
Coming next month: “The EHDS Effect: How Sweden’s €400 Million Digital Health Investment Will Reshape Nordic Healthcare Markets”
Our follow-up investigation will examine the business implications of the European Health Data Space implementation, including procurement opportunities for health tech vendors, the changing competitive landscape for data analytics providers, and how Swedish regions are preparing for mandatory cross-border health data exchange by 2029.
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