Foreign-investment screening timelines — a complete file starts the 25-day clock

Reading order

Name completeness before you start the 25-working-day clock. ISP’s process page and FAQ 14 say a notification is complete only when the requested particulars have been given and the file is concrete enough to support a review. ISP decides completeness. An incomplete upload does not start 14 §. Day one, on the process page, is the next working day after that complete date.

Then name which limb of the Act triggered the notification. Section 7 lists voting-right steps of 10, 20, 30, 50, 65 and 90 percent in an existing company, and also writes a greenfield-style formation limb. FAQ 7c says greenfield investments are notifiable on the same conditions as investments in existing companies. FAQ 8 says a move that stays between two thresholds — for example from 10 to 12 percent — need not be re-notified under that first limb, but other limbs in sections 7, 9 and 10 can still apply. The parent page already owns the protected-activity list in section 3. This page does not reprint it.

Then keep the in-depth clock, standstill and the EU comment windows on their own rows. Section 15 starts only when ISP has opened the granskningsfas. Section 16 is a statutory stop on completion. Regulation (EU) 2019/452, as ISP restates it, writes 15 calendar days to signal an intention and 35 calendar days for the comments. Those calendar days sit beside 14 § and 15 §. They do not replace them. ISP does not give förhandsbesked. A comfort call is not a 14 § decision.

• Completeness before anyone starts the 25-working-day clock.
• Greenfield can be notifiable — FAQ 7c.
• Standstill under 16 § is not a long-stop hope.
• The parent page already owns the sector list.

What a working-day clock and a month clock actually measure

The 25-working-day clock is a completeness clock. Section 14 starts only when the notification is complete. FAQ 19 says ISP treats a working day as a day that is not a public holiday under the Public Holidays Act and is not a Saturday, New Year’s Eve, Easter Eve, Epiphany Eve, Whit Eve, Midsummer Eve or Christmas Eve, and that the Act on computation of statutory time can move the last day to the next weekday. Those are handbook cells. They are not a typical Swedish hall clearance week.

The three-or-six-month clock is an in-depth clock. Section 15 does not run during the prövningsfas. Special reasons can extend the granskningsfas to six months. This page does not invent those reasons for a named buyer. Phase-2 outcomes on the process page are prohibition, approval, or approval with conditions. Prohibition and conditional approval may be appealed to the Government. Other decisions under the Act follow section 39 — this page does not invent an appeal from a leave-without-action letter.

Section 16 is a closing clock. FAQ 12 says the parties may sign an agreement before notification, but completion must be conditioned on ISP leaving the file without action or approving it, and the investor must not exercise the influence that the investment creates until that decision. A long-stop date in the share-purchase agreement is not a substitute for that statutory stop.

The EU 15 / 35 calendar-day comments are a cooperation clock. ISP’s process page restates them for a file that has already been taken to review and shared in the Union cooperation channel. They do not shorten section 14 and they do not authorise closing before ISP has acted. FAQ 1 adds that Swedish and EU-internal investments can still be notifiable under sections 7, 9 or 10; that is a notification trigger, not a shorter clock.

What named primary sources show

SFS 2023:560 remains the Swedish clock paper. Keep sections 7, 14, 15, 16, 32 and 39 attached to that file. ISP’s process page of 12 November 2025 is the same clock in handbook form, including the next-working-day start and the 15 / 35 calendar-day Union comments.

ISP’s FAQ of 13 July 2026 remains the greenfield, förhandsbesked, completeness and working-day paper. Use it to refuse an informal comfort call as a decision and to keep a greenfield notification on the file.

EUR-Lex 2019/452 remains the Union cooperation paper. The parent screening page remains the sector-list paper. This page does not re-print that list.

A matrix instead of an ISP-will-be-fine slogan

Draw one page with clock rows and evidence columns. First phase, in-depth phase, standstill and EU comments are different rows. Completeness, working days, months and calendar days are different columns. Empty cells stay empty. A 25-working-day cell does not fill a three-month cell.

Do not invent a clearance week for a named Swedish hall buyer. Those remain different objects.

Common misreads

The first misread is to start the 25-working-day clock on the upload day, including weekends and incomplete files. Section 14 starts from completeness; ISP writes day one as the next working day. The second is to treat a greenfield hall as outside the Act because section 7 also lists share thresholds. FAQ 7c still writes that a greenfield investment can be notifiable. The third is to treat a comfort call as förhandsbesked.

The fourth is to use the EU 35-day comment window as the Swedish decision date. The fifth is to close on a long-stop date while section 16 still applies. The sixth is to invent a typical hall clearance quarter. The seventh is to reprint the sector list here and call the parent page obsolete.

What to ask next

Ask whether the notification ISP holds is complete, and which working day is day one under section 14. Ask whether the deal is a section 7 voting-right step, a greenfield notification, or both. Ask which clock the long-stop date is waiting on — 14 §, 15 §, or an invented quarter. Ask whether standstill still blocks completion, and whether any EU comment window is open beside it.

Then open the parent screening page. If counsel will not name the clock and the completeness date, record the gap. Do not fill it from an ISP-will-be-fine slide. This is orientation, not counsel.

1. Is the live paper a complete 14 § file, an open 15 § review or only a comfort call?
2. Has a greenfield hall been treated as outside the Act?
3. Has a long-stop date been treated as a substitute for standstill?
4. Have EU calendar days been treated as the Swedish decision?
5. Has a hall clearance week been invented?

What this does and does not prove

This page proves that Act (2023:560) already publishes a 25-working-day first phase, a three-or-six-month in-depth phase and a standstill rule, and that ISP already publishes the next-working-day start, the no-förhandsbesked sentence and the greenfield notification sentence.

It does not prove which Swedish hall file is in which phase. It does not invent a clearance week. It does not reprint the protected-activity list.

Empty cells stay empty. Until a later primary source names a Swedish hall transaction with a dated ISP decision, the timeline clock stays a method, not a census.