
Newsletters in the public sector: requirements, accessibility and a practical setup
Newsletters in the public sector are email sends from municipalities, regions, government agencies and publicly controlled bodies to residents, employees, the press or other stakeholders. The difference from commercial sends is legal: the language is covered by the plain language requirement in the Swedish Language Act, the web pages and forms that the send leads to are covered by accessibility requirements, and the subscriber list can be an official document.
This guide goes through what actually applies to you if you work with communication in a municipality, region, government agency or municipal company. We cover plain language, accessibility, legal basis under the GDPR, the principle of public access, procurement and data storage, and finish with a practical setup for lists, segments and crisis communication. If you want to get started right away, you can try our tool for newsletters for free.
Contents
- What sets public sector newsletters apart from commercial ones
- Plain language is a legal requirement, not an ambition
- Accessibility: what the DOS Act actually covers
- Legal basis, the GDPR and the principle of public access
- Procurement: when a direct award is enough
- Data storage and data processors
- Tools for municipalities, regions and government agencies
- Build and maintain the subscriber list
- Service information and crisis communication
- Measurement and follow-up
- Checklist before sending
- Frequently asked questions
What sets public sector newsletters apart from commercial ones
In a company, the goal of a send is usually to sell. In the public sector, the goal is almost always to inform, explain or invite to something, and the recipient has rarely chosen you as a supplier. They are a resident, patient, guardian, business owner in the municipality or an employee. That changes three things at the core.
- Clarity comes before persuasion. A send that is not understood is not a weak send, it is a failed public assignment.
- Everyone must be able to take in the content. You cannot leave out a group of recipients because the solution became simpler that way.
- Documents can be requested. Both the send and the list may be examined under the principle of public access.
The basic craft questions, subject line, structure, images and follow-up, do not differ, however. If you want them in one place, read our guide to better newsletters and our newsletter templates.
Plain language is a legal requirement, not an ambition
Many believe that plain language is a recommendation from the communications department. It is a legal rule. Section 11 of the Swedish Language Act (2009:600), the so-called plain language section, states that the language in the public sector shall be cultivated, simple and comprehensible. The requirement applies to all public activities and in practice to all information that leaves the organization, which includes newsletters and SMS.
The Institute for Language and Folklore follows how the rule is applied and publishes writing rules and guidance. Three things have the greatest effect in a send:
- Write the most important thing first. What has happened, what it means for the recipient, what they need to do. In that order.
- Replace technical terms or explain them. Write "you can appeal the decision" instead of "the decision may be subject to review".
- One thing per paragraph and concrete headings. Headings that say what the section is about, not "Information".
A good test is to read the subject line aloud and ask whether a recipient without prior knowledge understands what the send is about. If it fails that test, it is the subject line that should change, not the recipient.
Accessibility: what the DOS Act actually covers
This is where many go wrong, in both directions. The Act (2018:1937) on accessibility to digital public services, the DOS Act, applies to digital services that a public body provides through a website or an application. The Agency for Digital Government, Digg, exercises supervision and issues regulations, and the requirements are based on WCAG.
What does that mean for a newsletter?
- The web version of the send is a web page. If the newsletter is published at an address that the recipient can open in a browser, that content is covered.
- The subscription form and the pages you link to are covered. That is where most of the actual accessibility problems are, not in the email itself.
- The email itself in the inbox is neither a website nor an application. That does not make accessibility optional. The requirement for comprehensible language still applies under the Language Act, and the Act on the accessibility of certain products and services (2023:254), which implements the European Accessibility Act and has applied since June 28, 2025, broadens the accessibility requirements further for several types of organizations.
The conclusion for practical work is simple: build the send to be accessible regardless of how the legal line is drawn. A send that cannot be read with a screen reader does not get through, and getting through is the whole point of the assignment. How to do it in detail, heading hierarchy, alt text, contrast, reading order and link text, is covered in our guide to accessible newsletters.
Also remember the accessibility statement. If you have a statement for your website, it should cover the pages that your sends lead to, including sign-up forms and web versions.
Legal basis, the GDPR and the principle of public access
Two questions need an answer before you send, and they are not related.
Which legal basis applies to the send?
For a voluntary newsletter that someone signs up for themselves, consent is the most common basis. For information that you are obliged to provide, or that falls within your remit, a task carried out in the public interest may be the right basis instead. The difference has practical consequences: with consent, unsubscribing must be easy and the consent documented, while with public interest, other rules apply to objections. Legitimate interest, on the other hand, is normally not available to public authorities in the exercise of their official authority. Check with your data protection officer which basis applies to which send, and keep the types of sends separate in the tool.
We cover the bases themselves in the guide on what the GDPR means, and the practical side of consent in the guide on sending newsletters under the GDPR.
Is the subscriber list an official document?
This is the question that tends to be forgotten. A list of email addresses that has been received by a public authority can be an official document and can therefore be requested. Whether it is to be disclosed is decided by a secrecy assessment in the individual case. Raise the question with the registrar or a lawyer before you start the list, not after the first request. It also affects what you should collect: fields that you do not need, you should not have.
This guide is general information and not legal advice. Assessments under the GDPR, the principle of public access and accessibility legislation need to be made based on your own organization.
Procurement: when a direct award is enough
A tool for sends rarely costs much, but it is not the price tag on the monthly fee that decides how the purchase should be made.
- The direct award threshold under the Public Procurement Act (LOU) is 700,000 SEK excluding VAT for goods and services. It is set in the law and therefore does not change automatically with the EU thresholds.
- The value is added up. The entire organization's need for the same type of service during the contract period must be added together. You may not split a purchase to get below the threshold.
- Framework agreements come first. If there is an applicable framework agreement, it must be used even for small purchases.
- Internal guidelines can be stricter than the law, with their own amount limits and documentation requirements.
If you are going to formulate requirements in a procurement or a direct award, these are the things usually worth including: where the personal data is stored, which subprocessors are used, how accessibility is handled in both the tool and the send, whether data can be exported at the end of the contract, and whether support is available in Swedish. Feature lists are easy to copy between suppliers, these points are not.
Data storage and data processors
If you choose a supplier that processes personal data on your behalf, you need a data processing agreement, and you need to know where the data is actually stored. Transfer to third countries is a separate question to handle, not a detail in a product sheet.
Paloma is a Swedish platform and stores data on Swedish servers at Telia Cygate. Telia Cygate is certified under ISO/IEC 27001:2022.* We sign data processing agreements and disclose which subprocessors are used.
* The certification refers to Telia Cygate's operations as a hosting provider. Paloma in Sweden AB has no ISO certification of its own.
Technical sender authentication also belongs here, since sends from a public sender are an attractive target for spoofing. Set up SPF and DKIM for your domain and complement them with DMARC.
Newsletter tools for municipalities, regions and government agencies
Paloma is used by more than 40 municipalities, 6 regions and more than 25 government agencies, universities and university colleges, among them 8 county administrative boards. Together with municipal federations, that makes over 80 public organizations with around 160 accounts. Many have several accounts, for example one for the municipal executive office, one for the culture department and one for the business development unit.
This is what public organizations usually ask about when they choose a tool, and how Paloma answers:
- Where is the data stored? In data centers in Sweden, at Telia Cygate.
- Is there a data processing agreement? Yes, and we disclose which subprocessors are used.
- Are backups taken? Yes, daily.
- Is support available in Swedish? Yes, by email, chat and phone depending on the package.
- Is there a lock-in period? No. The number of contacts is unlimited in all packages.
- Can several channels be combined? Yes. Newsletters, SMS and registrations for meetings and events are in the same platform.
- Can we try it first? Yes. The free account includes up to 250 emails a month, and the Bas package costs 95 SEK a month for 500 emails a month.
If you want to compare several suppliers side by side, see our comparison of newsletter tools.
Build and maintain the subscriber list
Public organizations often have several target groups in the same tool, and that is where things tend to get messy. Keep them separate from the start:
- Residents and citizens. Voluntary subscription, a clear purpose, easy unsubscribing.
- Employees and elected representatives. Internal information with a different legal basis and a different tone. See the guide on internal newsletters.
- Press and media. A separate list, a separate frequency, often a separate sender.
- Business owners, associations and partner organizations. Business news and similar sends.
How to get subscribers without buying lists is covered in the guide on building an email list. A welcome email that confirms what the recipient has signed up for and how often the sends come reduces both unsubscribes and questions to the contact center.
If you hold consultations, open houses, information meetings or training sessions, the registrations can be handled in the same platform through our event platform, so that the participant list and the sends are connected.
Service information and crisis communication
Email is the right channel for planned information. It is rarely the right channel when something needs to get through within an hour. For water shutoffs, canceled activities, changed opening hours or an acute disruption in public transport, SMS is far superior, since the message is read immediately and does not get stuck in spam filters.
The practical setup for defined groups, for example the households on a street or the guardians in a class, is covered in the guide on group SMS. Prepare templates and recipient groups in advance. Nobody writes good plain language under time pressure.
Measurement and follow-up
Open rate is a weaker measure than it used to be, since several email clients preload images. Follow these instead:
- Clicks on what the send was for. Did people get to the form, the registration or the information page?
- Unsubscribes over time. A rising curve means the frequency or relevance is wrong.
- Bounces. Many employee addresses are replaced during reorganizations, and old addresses hurt deliverability.
- Questions to the contact center after the send. The best clarity measure there is, and it is not in the tool.
Checklist before sending
- Does a recipient without prior knowledge understand the subject line?
- Is the most important thing first, before background and history?
- Do all images have descriptive alt text, and does the send work without images?
- Are the link texts descriptive instead of "read more" and "click here"?
- Is the contrast sufficient between text, buttons and background?
- Does the send work with a screen reader and on mobile?
- Is there a web version for those who cannot read the email in their client?
- Is unsubscribing clear and working?
- Is the right legal basis connected to the right list?
- Are the sender name and sender address recognizable as your organization?
Frequently asked questions
Do newsletters from a municipality have to follow WCAG?
The DOS Act covers digital services provided through a website or application, and the requirements are based on WCAG. The web version of the send, the subscription form and the pages you link to are web content and are therefore covered. The email itself in the inbox is neither a website nor an application, but the plain language requirement in the Language Act still applies, and in practice you build the send according to the same principles.
Is consent required to send newsletters to residents?
For a voluntary newsletter that the recipient signs up for themselves, consent is the most common legal basis. For information that falls within the agency's remit, a task carried out in the public interest may be the right basis instead. Which basis applies is determined by the purpose of the send and should be checked with your data protection officer.
Can someone request our subscriber list?
A list of email addresses held by a public authority can be an official document and can therefore be covered by a request for disclosure, with a secrecy assessment in the individual case. Decide on the question together with the registrar or a lawyer before the list is started, and do not collect more information than you need.
Do we need to procure a newsletter tool?
The direct award threshold under LOU is 700,000 SEK excluding VAT for goods and services. A sending tool normally falls below the threshold, but the entire organization's need for the same type of service must be added up, applicable framework agreements come first, and your internal guidelines can be stricter than the law.
What is plain language in a newsletter?
Under Section 11 of the Language Act, plain language means that the language in the public sector shall be cultivated, simple and comprehensible. In a send, this means that the most important thing comes first, that technical terms are explained or replaced, that each paragraph covers one thing, and that the headings say what the section is about.
How often should a municipality send newsletters?
Regularity is more important than frequency. A predictable rhythm, for example once a month, is easier to keep and easier for the recipient to relate to than frequent sends that fade after six months. Follow the unsubscribes: if they rise, the frequency or relevance is wrong.
Which channel should we use during an acute disruption?
SMS, since the message is read within minutes and does not risk getting stuck in spam filters. Email works for planned information and in-depth content. Prepare templates and recipient groups before they are needed.
Which newsletter tool suits a municipality or government agency?
Choose a tool where the personal data is stored in Sweden or within the EU, where the supplier signs a data processing agreement and discloses its subprocessors, and where support is available in Swedish. Paloma is a Swedish platform that stores data in Sweden and is used by more than 40 municipalities, 6 regions and more than 25 government agencies, universities and university colleges.
How many public organizations use Paloma?
Over 80 public organizations have around 160 accounts in Paloma: more than 40 municipalities, 6 regions, more than 25 government agencies, universities and university colleges, of which 8 are county administrative boards, as well as several municipal federations.
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Paloma is a Swedish platform for newsletters, SMS and events, with Swedish servers and support in Swedish. Over 1,500 customers in Sweden use it for their communication, among them more than 40 municipalities, 6 regions and more than 25 government agencies, universities and university colleges.
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