No limit is not a limit

Oct 22, 2026

On 8 October 2026, the Administrative Court of Appeal in Jönköping confirmed what should have been obvious from day one: an option called "no limit" is not a deposit limit. The companies behind bet365 in Sweden keep their warnings and pay SEK 44 million in total.

I wrote about exactly this on Twitter in January 2021, almost a year before the Swedish Gambling Authority (Spelinspektionen) opened its investigation:

Känns ju inte helt i linje med spellagen att kunna välja "Inga gränser" som insättningsgräns. #bet365 #spelinspektionen #spelansvar
("Doesn't feel entirely in line with the Gambling Act to be able to choose 'No limits' as a deposit limit.")
— @staffanschroder, 27 January 2021

A year before that, in January 2020, I had saved screenshots of what it looked like on my own account. I show them further down. Now, five and a half years after the tweet, three levels of the Swedish system have given the same answer. This post is about why, and about what those of us who design gambling experiences can take away from it.

What happened

Three levels have now said the same thing: Hillside (Sports) ENC and Hillside (Gaming) ENC, which run bet365.com in Sweden, seriously breached the duty of care and the rules on deposit limits. Only the amount changed along the way.

Date	Body	Outcome
2026-10-08	Administrative Court of Appeal, Jönköping	Appeals rejected. Warning + SEK 40m (Sports) and SEK 4m (Gaming) upheld
2024-06-13	Administrative Court, Linköping	Breaches confirmed, fees reduced to SEK 40m and SEK 4m
2023-04-24	Board of the Swedish Gambling Authority	Warning + SEK 65m (Sports) and SEK 14m (Gaming)
2022-04-19	bet365	"No limit" option removed, just under four months into the investigation
2021-12-21	Swedish Gambling Authority	Investigation opened
2019-01-01	bet365	Swedish licence takes effect, with "no limit" as an option

The reduction in the Administrative Court was about how the fee should be calculated, following a guiding ruling from the Supreme Administrative Court (HFD 2023 ref. 25). The assessment of the breaches themselves did not change. The Authority also noted that the breaches were serious enough to justify revoking the licence, but settled for a warning because the company had corrected the problems.

What the law actually says

The Swedish rules leave no room for "no limit". Four short provisions are enough:

Chapter 14, section 1, Gambling Act (duty of care): the operator must protect players from excessive gambling, help them reduce it when there is reason to, and continuously monitor gambling behaviour.
Chapter 14, section 7, Gambling Act: for online gambling, the player must set an upper limit on their deposits.
Chapter 11, section 3, Gambling Ordinance: the limit is set per day, week and month. A decrease applies immediately, an increase after 72 hours at the earliest.
Chapter 11, section 5, Gambling Ordinance: the limit must not be possible to exceed, and anyone who raises it, or sets it above SEK 10,000 a month, must be contacted by the operator.

The last point is the key. The whole mechanism depends on there being a number to compare against. bet365 argued that the law only requires the customer to decide on a limit, and that "no limit" is, in theory, such a decision. The Authority replied that this reading was not only wrong but remarkable and dismissive of an operator's obvious obligations. Without a limit, the SEK 10,000 rule cannot be followed at all.

The design choice: a limit of 500 million

"No limit" was not a technical mistake. It was a design decision that stayed live for three years and three and a half months, from the licence start on 1 January 2019 to 19 April 2022.

This is what it looked like on my own account in January 2020, almost two years before the investigation began:

Image 1. The Deposit Limits page, January 2020. "Inga gränser" = "No limits", "Byt" = "Change".

The page correctly explains that an increase takes 72 hours and that customer service cannot override your limits. But there are no limits to override: all three periods read "No limits", and the only way to change that is a button labelled "Change".

Image 2. The reminder shown at login, January 2020. The heading reads "Only play with money you can afford to lose".

Image 2 is even clearer. The heading says "Only play with money you can afford to lose", and directly below it "No limit" is listed three times. The primary action is a large green "Continue" ("Fortsätt"). Setting a limit is a small text link. The protection tool is on screen, but the interface leads the player past it.

Image 3. My tweet from 27 January 2021, showing the form for changing limits.

Image 3 shows the choice itself. The dropdown runs from SEK 100 to SEK 1,000,000, and last in the list, on the same level as the amounts, sits "No limits". On my account it was selected for all three periods. A legal requirement for an upper limit had become one menu option among others.

Behind the option sat a technical cap of SEK 500,000,000 that the customer never saw. For comparison, Hillside Sports' entire Swedish gross gaming revenue in 2021 was around SEK 725 million. A single player could have deposited the equivalent of more than two thirds of the company's Swedish annual revenue before the system said stop.

The effect showed in the data. Of the ten customers who lost the most during the review period (17 October to 17 December 2021), six lacked a limit for at least one of day, week or month. Four had no limits at all.

As a UX person, I see three things here:

A protection tool was designed as a preference. A deposit limit is not one setting among many. It is a decision the player makes in a calm moment to protect themselves in a less calm one. Offering "no limit" as an equal alternative designs away the purpose.
The letter of the law was set against its purpose. "The customer chose it" is the same argument behind most dark patterns. The courts did not buy it.
The fix shows it was possible. After the investigation, every customer had to enter a fixed amount for day, week and month, and the company brought forward an empty free-text field instead of a pre-filled value. That is good design, and it could have been built in 2018.

Duty of care: the right signals, too soft a response

bet365 had a system that did detect risky behaviour. The problem was what happened next: messages with a "light tone", risk ratings set too low, and too long between interventions.

The Authority reviewed five customers in detail. Some examples from the decision:

Customer 1, born 2001: daily limit SEK 1 million, monthly limit SEK 5 million. Deposited on 53 of 62 days, often many times a day and at night, and lost about SEK 262,000. Rated "medium risk". Eventually self-excluded through Spelpaus, the national self-exclusion register.
Customer 2, born 1997: became a customer two days before the period. Raised their limits step by step to SEK 250,000 a month and lost about SEK 386,000. Rated "early risk".
Customer 3: no limits at all, played daily, lost about SEK 259,000. No individual intervention during the period.
Customer 4: switched a monthly limit of SEK 500,000 to "no limit" midway through the period. Received the same light-toned message three times.

One clear pattern is the time gap. Between the first reminder and the follow-up, customer 1 deposited about SEK 486,000 and customer 2 about SEK 135,000. The Authority stated that what counts is the effect on gambling behaviour, not that a message was sent. If information does not work, the operator must move on to restrictions.

On top of that, the operator's action plan initially left out two groups with known elevated risk: young players aged 18–24 and players returning from self-exclusion.

Lessons for those of us who design gambling experiences

The ruling is a signal to product teams, not just to lawyers. Five things I take away:

Design for the purpose of the law, not its letter. If a solution needs a creative reading to be legal, it probably isn't.
Safer gambling tools should not be optional. Limits, self-tests and self-exclusion are safety nets. A safety net with a "no thanks" button is not a safety net.
No pre-filled or extreme defaults. An empty field where the player types a number creates an active decision. A pre-selected million does not. And make the protective choice at least as prominent as "Continue" (compare image 2).
Measure effect, not activity. A sent message is not an intervention if behaviour doesn't change. Build the ladder: information, then contact, then restriction, with short intervals.
Lower the thresholds for the most vulnerable. Young players and players returning from self-exclusion need lower thresholds from day one.

What strikes me most is the time. A design decision from 2018 got its final legal answer in 2026. For more than three of those years, every customer could opt out of the limit the law said they must have. That is where UX responsibility lies: in the small choices in the interface, long before any regulator takes a look.

Sources

All official sources are in Swedish.

My own screenshots from bet365.com:

Image 1: the Deposit Limits account page (screenshot taken 16 January 2020)
Image 2: the "Only play with money you can afford to lose" reminder at login (screenshot taken 22 January 2020)