Fintech & payments regulation in Finland (2026)
Fintech and digital payments in Finland: licensing regime.
Finland operates a full, in-force licensing regime for payment institutions (PIs) and electronic money institutions (EMIs) under the PSD2-based Act on Payment Institutions (297/2010) and Payment Services Act (290/2010), with the Financial Supervisory Authority (FIN-FSA) as sole competent authority. Open banking (PISP/AISP) is authorised under PSD2; SEPA Instant Credit Transfers are widely adopted and reinforced by the EU Instant Payments Regulation, and BNPL is being tightened under CCD II transposition. Preparations for PSD3 / the Payment Services Regulation are ongoing at EU level.
Legal framework
Act on Payment Institutions (297/2010) and Payment Services Act (290/2010), implementing PSD2, supervised by the Finnish Financial Supervisory Authority (Finanssivalvonta / FIN-FSA). Instant payments follow the EU Instant Payments Regulation (Regulation (EU) 2024/886); consumer credit / BNPL comes under national law aligned with the EU Consumer Credit Directive II.
How to get an EMI license in Finland
To provide electronic-money or payment services in Finland you need authorisation as an Electronic Money Institution (EMI), supervised by the Finnish Financial Supervisory Authority (FIN-FSA), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Finnish Financial Supervisory Authority (FIN-FSA)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Finland covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
Step by step: getting an EMI license in Finland
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
Deposit and evidence the €350,000 initial capital.
Submit the application to the national competent authority.
The authority has three months from a complete application to grant or refuse.
On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Finland
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
Ongoing obligations in Finland
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
Key points: digital payments & fintech in Finland
Regulator & core statutes
FIN-FSA (Finanssivalvonta) is the sole competent authority for authorising and supervising payment institutions and e-money institutions under the Act on Payment Institutions (297/2010) and the Payment Services Act (290/2010).
PI and EMI licensing thresholds
Minimum initial capital is EUR 125,000 for a payment institution and EUR 350,000 for an EMI (with own funds of at least 2% of average e-money in issue); FIN-FSA can register 'small' payment service providers below activity thresholds (approx. EUR 3 million/month for legal persons, EUR 50,000/month for natural persons) without full authorisation.
Open banking / PSD2
PSD2 was transposed on 13 January 2018 via amendments to the Payment Services Act and Payment Institutions Act, licensing Payment Initiation Service Providers (PISPs) and Account Information Service Providers (AISPs); FIN-FSA is the National Competent Authority overseeing access to accounts.
Instant-payment rails
Finnish banks operate on the SEPA Instant Credit Transfer scheme; under the EU Instant Payments Regulation, euro-area banks have been required to receive instant payments since January 2025 and to send them since October 2025. Bank of Finland statistics show 79 million instant credit transfers (12.3% of total) in H2 2025.
BNPL / consumer credit
BNPL products are governed by the Finnish Consumer Protection Act and are being tightened as Finland transposes EU Consumer Credit Directive II (CCD II) — required national transposition by 20 November 2025, taking effect from 20 November 2026 — bringing invoice-style BNPL into scope with mandatory creditworthiness assessments and disclosure duties.
PSD3 / PSR pipeline
Finnish PSPs are preparing for the forthcoming PSD3 Directive and the directly-applicable Payment Services Regulation (PSR), which are progressing through the EU legislative process in 2026 and will tighten fraud, safeguarding and open-banking rules once adopted.
EMI license in Finland: FAQ
Do you need a license to run an e-money business in Finland?
Yes. To provide electronic-money or payment services in Finland you need authorisation as an Electronic Money Institution (EMI), supervised by the Finnish Financial Supervisory Authority (FIN-FSA), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
Which authority issues EMI licenses in Finland?
The Finnish Financial Supervisory Authority (FIN-FSA).
How much does an EMI license cost in Finland?
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
How long does it take to get an EMI license in Finland?
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
What documents do you need for an EMI license in Finland?
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
What is the application process for an EMI license in Finland?
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Does an Finland EMI license work in other EU/EEA countries?
Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Timeline of decisions
- Guidance · officialCrypto-asset service providers brought formally under FIN-FSA AML supervision
Revised FIN-FSA AML regulations and guidelines took effect, formally placing MiCA-authorised crypto-asset service providers (exchanges, custodians, wallet providers, token issuers) within the anti-money-laundering supervisory perimeter. This aligned crypto licensing obligations with the rest of the regulated financial sector.
FIN-FSA
- Decision · officialFIN-FSA grants Finland's first MiCA crypto-asset service provider authorisation
Coinmotion became the first company authorised by FIN-FSA as a crypto-asset service provider under MiCA, establishing the template for licensed crypto operations in Finland. FIN-FSA also warned consumers that many platforms still operated without authorisation.
FIN-FSA
- Enforcement · officialFIN-FSA fines money remittance providers for AML failures
FIN-FSA imposed penalty payments of EUR 25,000 on Roble Services Oy and EUR 15,000 on Alami Services Oy for failing to report to the Financial Intelligence Unit payments of at least EUR 1,000, illustrating active enforcement of AML duties on payment-services firms.
FIN-FSA
- Guidance · officialStrong Customer Authentication requirement enters into force
The PSD2 obligation to apply strong customer authentication (two-factor) for online payments and account access became effective in Finland, reshaping how banks and payment service providers secure electronic transactions.
FIN-FSA
- Law · officialSecond E-Money Directive (2009/110/EC) transposition
The EU's second E-Money Directive deadline shaped Finland's regime for licensing electronic money institutions (issuing e-money), folded into the Act on Payment Institutions framework supervised by FIN-FSA, with proportionate authorisation thresholds.
EUR-Lex (EU)
- Law · officialPayment Services Act (290/2010) and Act on Payment Institutions (297/2010) enter into force
Finland's foundational payments framework transposed the original Payment Services Directive (PSD1), creating the licensing/registration regime for payment institutions under FIN-FSA and the conduct rules for executing payment transactions that still anchor the sector.
Finlex (Finland)
Sources
- finanssivalvonta.fi/en/financial-market-participants/banks/payment-service-providers/
- dittmar.fi/insight/articles-di-finance-capital-markets-alert-15-jan-2018/
- nordiclaw.fi/en/news/how-to-be-an-emi
- nordiclaw.fi/en/news/how-to-be-a-payment-institution
- suomenpankki.fi/en/statistics/statistical-news/payments/2026/instant-payments-became-
- finanssiala.fi/en/topics/sepa-services/
- openbankingtracker.com/regulator/finland
- fondia.com/en/en/insights/articles/psd3-new-payment-services-directive
- powens.com/blog/bnpl-europe-france-regulation/
- fticonsulting.com/insights/articles/buy-now-pay-later-preparing-new-regulatory-era
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 5 Sept 2026. Methodology & how to cite · State of Technology Regulation 2026