Finland

Licensing, Authorisation & Market Access

Finland's banking M&A and structural-change supervisory regime tightened materially on 1 October 2026 with the entry into force of a new chapter of the Act on Credit Institutions implementing CRD6. The new chapter introduces advance written notification requirements to FIN-FSA for credit institutions ahead of material asset or liability transfers reaching a 10% balance-sheet-value threshold, or 15% where the transfer is intra-group, as well as material-holding acquisitions and mergers or demergers of credit institutions. These transactions are now subject to FIN-FSA's own assessment and approval process rather than proceeding on a notification-only basis.

This is a market-access and structural-change development specifically for the bank-PSP model: a bank considering a material transfer of assets, a material-holding acquisition, or a merger or demerger must now build an advance notification and FIN-FSA approval step into its transaction timeline. The obligation does not extend to non-bank payment institutions or e-money institutions, whose authorisation and structural-change framework sits outside the Act on Credit Institutions. Separately, FIN-FSA published updated principles on 1 October 2026 for determining the size of penalty payments and administrative fines across all supervised sectors, giving more explicit weight to early and comprehensive cooperation by a responsible party; while not specific to licensing or market access, this shapes the consequences of any future non-compliance with the new notification regime.

Outlook

The practical operation of the new CRD6 notification and approval process has not yet been tested against an actual transaction, so the pace and rigour of FIN-FSA's assessment process remains to be observed. A bank-PSP planning a material asset transfer, holding acquisition, merger, or demerger should expect the advance notification and approval step to now form part of the transaction timeline from 1 October 2026 onward.

Conduct, Safeguarding & Financial Promotions

The PSD3/PSR legislative package reached final compromise text, approved by national representatives on 22 April 2026, with formal publication expected in the third quarter of 2026 and a twenty-one-month transition period to follow for member states, including Finland. The Payment Services Regulation will repeal and replace PSD2 and the second E-Money Directive across the European Economic Area, consolidating and updating the conduct and safeguarding framework that currently governs Finnish payment service providers and e-money institutions.

The single most consequential conduct-side provision is the new payee-name and IBAN verification mandate. Under the PSR, payment service providers across the EU will be required to verify that the stated payee name matches the account holder before a transfer is authorised; where a mismatch is detected, the payer must be warned before the transfer proceeds, and liability for a failure to notify the payer of a mismatch shifts to the payer's own provider. This is, in effect, an EU-wide confirmation-of-payee mandate with a built-in liability-allocation mechanism, applying uniformly rather than through fragmented national implementation, and it will require Finnish banks and payment institutions to build or adapt payee-verification infrastructure ahead of the transposition deadline.

Outlook

Watch for the formal publication of the PSD3/PSR final text, which will fix the exact start date of the twenty-one-month transition period for Finnish implementation. Watch also for any Finland-specific transposition guidance from national authorities addressing how the payee-verification and liability-shift provisions will interact with existing Finnish fraud-prevention practice.

Operational Resilience & Critical Infrastructure

Finland's payment service providers are now operating under the fully mandatory regime of Regulation (EU) 2024/886, the Instant Payments Regulation. Mandatory receipt of instant credit transfers has applied since 9 January 2025, and the second and more operationally demanding phase — mandatory sending of instant credit transfers together with free Verification-of-Payee checks — has applied since 9 October 2025. This is a confirmed finding, and it represents the completion of a phased EU-wide operational-resilience mandate rather than a discretionary national implementation choice.

The practical operational consequence for Finnish payment service providers is that instant payment infrastructure is no longer an optional value-added service but a mandatory baseline capability, with the free Verification-of-Payee requirement adding a specific anti-fraud operational obligation on top of the underlying instant-transfer-processing requirement. Because this regulation applies uniformly across the euro area, Finnish PSPs face the same operational-resilience baseline as their counterparts elsewhere in the EEA, removing any comparative advantage or disadvantage that might otherwise arise from differential national implementation timelines.

This finding sits within the module's critical-infrastructure framing because instant-payment processing capability, once mandatory, becomes part of the baseline infrastructure a Finnish PSP must maintain continuously rather than a discretionary product feature; any operational failure in meeting the mandatory sending or Verification-of-Payee obligations would itself become a conduct and resilience issue under the broader regulatory framework.

Outlook

With both phases of the Instant Payments Regulation's mandatory requirements now in force, the item to watch shifts from implementation-timeline compliance to operational-performance monitoring: whether Finnish PSPs are meeting the Verification-of-Payee and instant-sending obligations reliably at scale, which was not independently assessed this cycle.

Payment Corridor Dynamics

Finland's instant-payments corridor runs on SEPA Instant Credit Transfer alongside the domestic Siirto product, with the two systems designed to coexist rather than compete directly. SEPA Instant carries a general scheme maximum of EUR 100,000 as of 1 July 2020, though Finnish banks have agreed to remove the upper limit specifically for domestic transfers, a national variance more permissive than the scheme-wide parameter. The Instant Payments Regulation has driven two concrete compliance milestones that are now both in effect: all payment service providers offering SEPA payments were required to be able to receive instant transfers from January 2025, and to send them from October 2025.

Siirto, operated by Automatia, is positioned to function alongside SEPA Instant rather than to replace it, and send-side interoperability between Siirto and the wider Finnish banking system is still described as evolving rather than complete. This dual-rail structure — a domestic mobile-payment product running in parallel with the EU-wide SEPA Instant scheme, now fully subject to IPR send/receive mandates — is the defining corridor-dynamics feature of the Finnish market this cycle.

Outlook

The completion of Finnish banks' removal of the domestic SEPA Instant transfer cap, and the continued evolution of Siirto's send-side interoperability across all Finnish banks, are the two concrete corridor-dynamics developments to track. The IBAN-name Verification of Payee check already mandatory on the SEPA Instant rail is expected to extend to all transfer rails once PSD3/PSR takes effect, which will be a further corridor-level change to monitor.

Legal & Litigation

The Helsinki Administrative Court accepted an appeal by Alexandria Group Oyj and annulled a EUR 1,000,000 joint penalty that FIN-FSA had imposed in June 2025, finding in the firm's favour; FIN-FSA was ordered to pay EUR 30,000 toward Alexandria Group Oyj's legal costs. The ruling is not yet final. The underlying penalty concerned an alleged failure to obtain legally required client information before making investment recommendations, a suitability and investor-protection matter rather than a payments-sector finding; Alexandria Group Oyj is a non-payments investment firm.

The relevance of this matter to the payments sector is limited to what it signals about FIN-FSA's general enforcement posture and its exposure when a penalty decision is appealed: a court has found against the regulator on a significant penalty and ordered it to bear a portion of the appellant's costs, while the matter remains open pending finality. This sits alongside FIN-FSA's separate, cross-sector update to its penalty-determination principles, published 1 October 2026, which gives greater explicit weight to early and comprehensive cooperation by a responsible party, a procedural change that would apply equally to any future payments-sector enforcement matter.

Outlook

Whether the Alexandria Group Oyj ruling becomes final, and whether FIN-FSA appeals further, remains to be observed. The episode is a data point on FIN-FSA's enforcement exposure on appeal rather than a payments-sector-specific development in its own right.

Product Innovation & Market Development

Finland's new Gambling Act (10/2026) is constructing a distinct, licence-conditioned payments surface specifically for the newly-competitive gambling vertical ahead of its 1 July 2027 market opening. Licence applicants to Poliisihallitus (the National Police Board) must submit financial-stability documentation and AML-control frameworks as part of the licensing dossier, meaning the payments dimension of gambling-operator compliance is being gated at the point of licensing rather than left to post-entry supervision. This finding is held at probable confidence, reflecting the underlying Gambling Act's confirmed provisions but a still-developing evidentiary picture of exactly how the payments-specific compliance detail will be operationalised.

This is a genuinely new product-access regulatory development distinct from a structural market-analysis trend (which would sit under industry-structure-and-commercial-dynamics) or a discrete commercial event such as an M&A deal or product launch (which would sit under commercial-intelligence-and-fintech): it is a thematic, regulation-driven reshaping of how payments access to the Finnish gambling vertical will be gated going forward. The financial-stability and AML-control documentation requirements together suggest that Finnish regulators are treating payments integrity as a first-order licensing criterion for the newly-competitive gambling market, rather than a secondary compliance matter addressed only after market entry.

For payment service providers and payment-facilitation businesses considering involvement in Finland's newly-licensed gambling vertical, this represents a concrete new compliance surface to track: engagement with a Finnish gambling operator licensee will likely require visibility into that operator's own financial-stability and AML-control standing as established through the Poliisihallitus licensing process.

Outlook

The item to watch is the specific content of the financial-stability and AML-control documentation requirements as licences begin to be granted, expected by end-2026 ahead of the 1 July 2027 market opening, which would clarify the precise payments-compliance bar for the gambling vertical.

Correspondent Banking, Settlement & Access

Finland's correspondent-banking and settlement-access picture this cycle is defined by a structural bank/non-bank asymmetry playing out in two directions at once. On the access side, the Eurosystem's TARGET access policy, in effect since October 2025, allows non-bank payment service providers that meet TARGET Guideline requirements to access the T2 and TIPS settlement systems directly, extending a form of settlement-system access previously reserved to banks to qualifying non-bank providers. This is a harmonised, Eurosystem-level policy rather than a Finland-specific measure, but it directly affects the settlement options available to Finnish non-bank payment institutions and e-money institutions.

On the compliance side, FIN-FSA's 12 February 2026 sanctions risk assessment found that payment service providers have the most room for improvement in complying with sanctions and national freezing-order obligations, identifying non-bank payment providers specifically as the segment of greatest supervisory concern. The juxtaposition is analytically significant for this module: the same non-bank PSP segment now gaining direct access to Eurosystem settlement infrastructure is also the segment identified as carrying the weakest sanctions-compliance controls, meaning expanded settlement access and a documented compliance gap are advancing simultaneously rather than sequentially. This is a single Tier-1 source this cycle, not yet independently corroborated, which bars the finding from a Confirmed rating and holds it at High/Assessed pending a second anchor.

Outlook

Watch for whether FIN-FSA's sanctions-compliance finding produces a specific supervisory follow-up directed at non-bank payment service providers, particularly given their simultaneous gain of direct T2/TIPS access. Watch also for further Eurosystem guidance on TARGET Guideline compliance requirements for non-bank PSPs seeking direct settlement access.

Commercial Intelligence & Fintech

Finland's fintech and insurtech sector now comprises more than two hundred firms operating across payments, wealthtech, regtech, digital lending, and embedded finance. Investment conditions in the sector have become more selective, consistent with the broader European venture-capital slowdown, meaning new commercial activity is likely to be more concentrated among better-capitalised or later-stage firms than in prior growth cycles.

Within the buy-now-pay-later category specifically, the Finnish market is forecast to grow 17.1 percent year-on-year to reach USD 4.74 billion in 2026, led by Klarna and Walley. Separately, the European Central Bank invited payment service providers to apply to participate in the digital euro pilot programme, with applications due by 14 May 2026; this is a cross-cutting, EEA-wide product-development opportunity directly relevant to Finnish payment service providers' roadmap planning, distinct from the BNPL market-growth figure and from the sector-scale statement, in that it represents a specific, dated commercial call to action rather than a general market observation.

Outlook

Watch for whether Finnish payment service providers participate in the digital euro pilot programme following the 14 May 2026 application deadline, and for BNPL market performance against the 17.1 percent growth forecast as the year progresses. No Finland-specific private funding-round or M&A detail was available this cycle; this is flagged as an under-indexed gap for prioritisation next cycle.