Is it legal to record a meeting in Sweden?

Brottsbalken 4 kap. 9 a §, olovlig avlyssning, unlawful eavesdropping. The operative words: whoever, unlawfully and by means of a technical aid for the reproduction of sound, i hemlighet listens to or records speech made in solitude, a conversation between others (samtal mellan andra), or the proceedings of a meeting or other gathering to which the public does not have access and in which he himself does not take part (som han själv icke deltager i), shall be sentenced to a fine or imprisonment for at most two years.

The neighbouring provision, 4 kap. 8 §, brytande av post- eller telehemlighet, covers unlawfully obtaining access to a message conveyed by a postal or telecommunications operator or in an electronic communications network.

The framing is eavesdropping on others' conversations, not recording another person's words. That single fact decides Sweden.

Yes, and two elements fail independently. The offence reaches a conversation between others and proceedings in which the recorder does not take part; a meeting participant fails both. Separately it requires the recording to be done i hemlighet, so an announced recording is outside the offence before the participation question is even reached.

Nothing in Swedish criminal law requires you to say anything as a participant. GDPR does, and it wants the information before the substance of the meeting rather than after it.

Quick note before we start: I'm recording this so I can write my notes up afterwards. It transcribes on my laptop, nothing goes to the cloud, and I only keep the text. Say so now if you'd rather I didn't.

Longer versions, and what to do when someone says no, are on telling people you're recording.

On whether consent must be express, no Swedish authority was found saying a participant needs it. A written line in a calendar invite is a plausible way to discharge the Art. 13 duty for invitees, but no Swedish authority addressing that specific form was found either.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Sweden has no works council; the counterparty is the trade union. Medbestämmandelagen (1976:580) §§ 11 to 14 impose a primary duty to negotiate before the employer decides on important changes, and IMY states directly that "Det kan också finnas en skyldighet att förhandla med facket enligt medbestämmandelagen". We did not open the §§ 11 to 14 text itself.

IMY rules consent out as an employer's basis entirely: "IMY anser inte att en arbetsgivare kan använda samtycke som rättslig grund för att behandla uppgifter för kontroll av anställda." So an employer needs a legitimate-interest case, and IMY adds that security reasons weigh more heavily than efficiency reasons, which is not a helpful weighting for a note-taking tool.

One IMY statement has to be quoted precisely, because it is narrower than it first looks. IMY says it is as a rule not permitted "att använda ljudupptagning vid kamerabevakning på arbetsplatsen", to use audio recording in connection with camera surveillance at the workplace. That is a statement about audio attached to camera surveillance, not a general prohibition on workplace audio, and overstating it would be wrong.

Integritetsskyddsmyndigheten, IMY, formerly Datainspektionen, has a page on monitoring employees. What it says that bears on this: the available bases are a legitimate-interest balancing or a public task; security reasons weigh more heavily than efficiency reasons; collective-agreement provisions can support the processing; consent cannot be used; employees have a right to clear advance information about what checks may be made; and audio capture alongside camera surveillance is as a rule not allowed.

Nothing was found on standalone audio recording of meetings.

Because the binding layer in Sweden is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Brottsbalken (1962:700), 4 kap. 9 a §
• Lag (1976:580) om medbestämmande i arbetslivet
• IMY, kontroll och övervakning av anställda
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.