The Swedish authorities have released guidance in a reaction to the ECJ case C-907/19, Q-GmbH
According to the European Court of Justice, the granting of licenses for the use of an insurance product is not an insurance transaction per se, nor is it a service relating to insurance intermediation. The licensor is only bound by contract law in relation to the insurer that uses the product in question in accordance with the license agreement. The licensor is not responsible for the risks covered by the product. The licensor is also not in contact with both the insurer and the policyholder.
Source: skatteverket.se
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