pc
nid 91804
Apr 09, 2026
tojuri@vixio.com
Finland
Financial Supervisory Authority
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2100 charsFinland's Financial Supervisory Authority Publishes Thematic Assessment on Consumer Creditworthiness Evaluation
On April 8, 2026, the Financial Supervisory Authority (Finanssivalvonta) published a thematic assessment examining how domestic and selected foreign credit institutions operating in Finland evaluate consumer creditworthiness for unsecured consumer loans. The assessment, conducted during 2025, evaluated whether credit institutions' practices comply with consumer protection regulations.
The assessment identified that credit institutions generally meet regulatory requirements, though deficiencies vary across institutions. Key findings include: all institutions use positive credit registers, though utilisation rates vary significantly; most institutions verify payment defaults, but not all adequately assess loan justification for consumers with default records; not all institutions ensure accuracy of financial data provided by consumers; many institutions fail to consider all material expenses when assessing repayment capacity; some institutions do not account for potential interest rate increases or income continuity factors; documentation deficiencies exist regarding record retention periods; and some institutions have not assessed whether their credit scoring models comply with equality legislation and discrimination prohibitions.
The assessment notes that consumer protection requirements will be clarified in November 2026 when amendments implementing the Consumer Credit Directive (CCD2) take effect. Key regulatory changes include: credit institutions must define and maintain creditworthiness evaluation procedures; minimum requirements for data sources and accuracy verification will be explicitly specified; loan rejection reasons must be communicated promptly to consumers, with written explanations provided upon request; documentation retention periods will extend to five years from full loan maturity; and customer identification requirements when accessing positive credit registers will be mandatory.
The Financial Supervisory Authority will use assessment findings to direct ongoing supervision and requires credit institutions to correct identified deficiencies.
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2487 charsFinland's Financial Supervisory Authority Publishes Thematic Assessment on Consumer Creditworthiness Evaluation
On April 8, 2026, the Financial Supervisory Authority (FIN-FSA) published a thematic assessment examining how domestic and selected foreign credit institutions operating in Finland evaluate consumer creditworthiness for unsecured consumer loans.
The assessment, conducted during 2025, evaluated whether credit institutions' practices comply with consumer protection regulations. The assessment identified that credit institutions generally meet regulatory requirements, although deficiencies vary across institutions.
The key findings are as follows:
All institutions use the positive credit information register when assessing consumers' creditworthiness. However, the extent to which the register's data is utilised varies significantly between different credit institutions.
All credit institutions have properly implemented the use of income data, but not all utilise data on the amounts of existing loans.
All credit institutions check default records as part of the creditworthiness assessment, and the majority of credit institutions will not grant new credit to consumers with default records. However, the FIN-FSA was unable to ensure that all credit institutions properly assess the justification for granting new credit to customers with default records.
Not all credit institutions take all of a consumer's essential expenses into account in their liquidity calculations when assessing their solvency. In addition, liquidity calculations do not always take into account a possible increase in interest rates or factors affecting the continuity of a consumer's income.
There were shortcomings in the documentation regarding the retention period of documents. Not all credit institutions retain documents related to the assessment of a consumer's creditworthiness for at least the duration of the credit relationship.
FIN-FSA notes that consumer protection requirements will be clarified in November 2026 when amendments implementing the revised Consumer Credit Directive (CCD2) take effect. The key regulatory changes will include:
The requirement for lenders to define and maintain creditworthiness evaluation procedures.
The requirement that loan rejection reasons must be communicated promptly to consumers, with written explanations provided upon request.
The extension of documentation retention periods which will extend to five years from full loan maturity.
The FIN-FSA requires credit institutions to correct the deficiencies identified in the assessment.