Regulatory AlertsFinland: fintech & payments regulation
RegulatedFIN-FSA regulates payments under EU PSD2; E-money via EMD2; P2P lending registration
- Lead regulator
- Finnish Financial Supervisory Authority (FIN-FSA)
- Also involved
- FSA (AML via NFIU) · Data Protection Ombudsman (GDPR)
- Core law
- Act on Payment Services (2010/521) · Act on Payment Institutions (2010/522)
- Entry capital
- EUR 20,000 (Payment Institution)
- Approval timeline
- 3-6 months for payment institution license
- Customer assets
- Segregated accounts required; no deposit guarantee
- Data protection
- GDPR · Finnish Data Protection Ombudsman
- Sandbox
- Yes - FIN-FSA Regulatory Sandbox
Finland implements EU payment directives (PSD2, EMD2) via national acts. The FIN-FSA supervises payment institutions and e-money institutions. P2P lending intermediaries require FIN-FSA registration under the 2023 framework. No standalone 'VASP' crypto license exists; crypto assets are generally unregulated unless they qualify as financial instruments or payment services.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicencePayment Institution Licence[1] Requires authorization under Payment Institutions Act | EUR 20,000 | 3-6 months | FIN-FSA |
| E-money & wallet issuance | LicenceE-money Institution Licence Authorized under EMD2 via national act; higher capital than payment institutions | EUR 350,000 | 3-6 months | FIN-FSA |
| Domestic money transfer | LicencePayment Institution Licence[1] Domestic transfers fall under payment service authorization | EUR 20,000 | 3-6 months | FIN-FSA |
| Cross-border remittance | LicencePayment Institution Licence[1] Cross-border payments require same payment institution license | EUR 20,000 | 3-6 months | FIN-FSA |
| Agent network | LicencePayment Institution Licence[1] Agents must be appointed by licensed payment institution | EUR 20,000 | — | FIN-FSA |
| Open banking / account information | LicenceAIS/PIS Provider Registration Account Information and Payment Initiation Service providers must register with FIN-FSA | — | — | FIN-FSA |
| Foreign-exchange services | LicencePayment Institution Licence[1] FX services are payment services; requires authorization | EUR 20,000 | 3-6 months | FIN-FSA |
New — what changed recently
- 2023-07-01Registration of Credit Grantors and P2P Loan Intermediaries — FIN-FSA mandated registration for specific credit grantors and P2P lending intermediaries, enhancing consumer protection in unsecured lending.[2]
- 2025-01-01Acquisition of Control from Outside EEA — New notification requirements established for financial entities acquiring control over non-EEA entities, strengthening supervisory oversight.[3]
- 2026-04-13CCP Licensing Requirements Notification — Mandated notification of substantial changes to licensing requirements for central counterparties of credit institutions.[4]
Market-entry checklist
- 1Secure FIN-FSA Payment LicenseApply for Payment Institution Licence with EUR 20,000 initial capital and approved business plan.
- 2Register P2P Intermediary if ApplicableIf operating P2P lending, register with FIN-FSA under the 2023 credit grantor framework.
- 3Implement AML/CFT ComplianceRegister with the Finnish Financial Intelligence Unit (NFIU) and establish robust AML procedures.
- 4Establish Segregated AccountsSet up dedicated client money accounts to comply with payment institution asset protection rules.
- 5Prepare Technical Security MeasuresDemonstrate compliance with PSD2 strong customer authentication and operational resilience standards.
Sources
- Regulations and Guidelines 8/2016: Payment Institutions and Persons Providing Payment Services Without a License
- Registration of Certain Credit Grantors and Peer-to-Peer Loan Intermediaries
- Acquisition of Control over a Company Located in a Country Outside the European Economic Area · 2025-02-14
- Notification of Substantial Changes to the Requirements for the Licences of Central Counterparties of Credit Institutions and Deposit Banks