Payment service providers

Authorisation and registration of payment institutions and electronic money institutions

Authorisation of a payment institution and registration of an entity providing a payment service without authorisation

Provision of payment services or issuance of electronic money refers to activity mentioned in the Act on Payment Institutions the Act on Payment Institutions (297/2010, in Finnish), which, as a rule, requires authorisation. The term payment service refers to, for example, execution of a payment transaction, issuance of payment instruments, and transmission of money.

This page contains information about seeking authorisation or registration of:

  • payment institutions
  • natural and legal persons providing payment services without authorisation
  • electronic money institutions
  • persons providing issuance of electronic money without authorisation
  • payment service providers within a limited network.

 

Authorisation of a payment institution or electronic money institution

Authorisation is required when:

  • the total value of completed transactions exceeds an average of EUR 3 million per month (authorisation of a payment institution)
  • the total value of issued electronic money exceeds EUR 5 million (authorisation of an electronic money institution)
  • providing a payment initiation service (PIS)
  • the payment institution or electronic money institution intends to operate in another EEA member state.

The clarifications to be appended to the application for authorisation are provided for by a Decree of the Ministry of Finance (1040/2017, in Finnish). The FIN-FSA requires that all the information listed in the Decree of the Ministry of Finance is appended to the application for authorisation. The FIN-FSA also recommends that entities applying for authorisation comply with the European Banking Authority EBA's Guidelines on Authorisation of Payment Institutions EBA/GL/2017/09 (in Finnish).

Key requirements regarding the content of the application for authorisation

  • a list of intended payment services and adequate information on the applicant
  • information on minimum capital:
    • payment institutions, no less than EUR 125 000
    • payment initiation service provider, no less than EUR 50 000
    • provider of transmission of money (exclusively), no less than EUR 20 000
    • electronic money institutions, no less than EUR 350 000
  • information on most important shareholders and
  • information that verifies the fitness and propriety of the company’s management and board of directors (see below Fit & proper)
  • information on the company’s financial qualifications and possible accounts data for previous years
  • information on the acceptance of deposits, payment transfers, and protection of customer assets
  • a description of internal control, risk management, and information management systems
  • information on customer identification and customer due diligence procedures and the prevention of money laundering and terrorism financing
  • information on management of operational and security risks and reporting of incidents and fraud
  • information on the payment initiation service provider's indemnity insurance or other comparable guarantee against liability.
Provision of payment services or issuance of electronic money without authorisation (registration)

These services may be provided without authorisation when:

  • the monthly average of the preceding 12 months’ total value of payment transactions executed by a natural person does not exceed EUR 50 000; or
  • the monthly average of the preceding 12 months’ total value of payment transactions executed by a legal person does not exceed EUR 3 million; and
  • the payment service is not offered in another member state of the EEA
  • the total value of the electronic money issued by the issuer of electronic money does not exceed EUR 5 million
  • providing only account information service.

Submission and content of registration notification:

Provisions on appendices to the registration notification are laid down in section 8 of the Act on Payment Institutions (in Finnish) and in paragraph 6 in FIN-FSA Regulations and guidelines 8/2016 (in Finnish). FIN-FSA requires that all the information as required by regulation listed above is appended to the registration notification.

Key requirements regarding the content of the registration notification

  • a list of intended payment services and adequate information on the applicant
  • information that verifies the fitness and propriety of the company’s management (see below Fit & proper)
  • a business plan, including but not limited to the following information: description of procedures, processes and information systems related to the provision of services
  • information on the protection of customer assets
  • information on customer identification and customer due diligence procedures and the prevention of money laundering and terrorism financing
  • information on management of operational and security risks and reporting of incidents and fraud
  • information on the account information service provider's indemnity insurance or other comparable guarantee against liability.
Payment services offered within a limited network or for a very limited range of goods and services – Obligation to notify FIN-FSA

Payment service legislation excludes certain payment services from the scope the law. Payment service legislation does not apply to services based on specific payment instruments that can be used only in a limited way, when

  1. the payment instrument allows the holder to acquire goods, services or other commodities only in the premises of the issuer or within a limited network of commodity providers under direct agreement with the issuer 
  2. instruments which can be used only to acquire a very limited range of goods, services or commodities or
  3. instruments provided at the request of an undertaking or a public sector entity that are valid only in a single member state of the European Economic Area and regulated by a national or regional public authority for specific social or tax purposes to acquire specific goods services or commodities from suppliers having a commercial agreement with the issuer.

Pursuant to section 8 a of the Payment Institutions Act, service providers excluded from the scope of the law are obligated to submit a notification to the FIN-FSA on the provision of payment services within a limited network or for a very limited range of commodities (as referred to in section 2, subsection 4, paragraphs 1 and 2 of the Payment Institutions Act). A notification is required only when the total value of payment transactions executed over the preceding 12 months exceeds the amount of EUR 1 million.

The notification shall contain a description of the services offered and specify under which exclusion provided in paragraphs 1 or 2 the service is excluded from the scope of the Payment Institutions Act. The notification shall be sent to the Financial Supervision Authority's registry office (kirjaamo(at)fiva.fi) in electronic form, making it possible to copy and publish the description on the FIN-FSA’s website. The notification shall be filed with the FIN-FSA form titled Ilmoitus rajoitetusti käytettävään maksuvälineeseen perustuvan palvelun tarjoamisesta (in Finnish). 

The FIN-FSA will either grant approval of registration or refuse registration based on a decision that the service does not meet the requirements for a limited network.

Service providers within a limited network that exceed the above-mentioned limits are entered into a public register of payment institutions, as well a description of the service and the legal basis for the exclusion of the service outside the scope of the law. These details will also be forwarded to the public register of payment institutions maintained by the European Banking Authority EBA.

Authorisation or registration process of a payment service provider

Upon receiving the application or notification of registration, the FIN-FSA will assess whether the payment service provider meets the legal requirements and put forward a decision. If the application is incomplete, the FIN-FSA will ask the applicant to submit further documentation before resolving the matter. Applications for authorisation shall be processed within no more than 3 months and notifications of registration within no more than 1 month. The processing time does not start until the FIN-FSA has received all required documentation. The total processing time is highly dependent on the quality and detail of the submitted application.

Withdrawal of authorisation and registration

A payment institution may apply for withdrawal of authorisation, in which case said institution shall submit to the FIN-FSA the documentation listed in section 5.14 of FIN-FSA Regulations and guidelines 8/2016 (in Finnish).

A registration may be withdrawn by informally notifying FIN-FSA of the reason for ceasing the activity.

Use the following form to report fit & proper assessment to FIN-FSA

Fit & proper form (rtf, in Finnish)

The application shall be appended with the FIN-FSA fit & proper form and additional documentation regarding reliability and suitability as provided in the Decree of the Ministry of Finance on the Information to be Appended to the Authorisation Application of a Payment Institution. In addition, see FIN-FSA Regulations and guidelines 8/2016 (in Finnish) for information on reporting of the fitness and propriety of persons providing services without authorisation.

Payment institution or electronic money institutions with authorisation from the FIN-FSA are allowed to provide payment services in other EEA Member States on a cross-border basis. Detailed instructions are included in FIN-FSA Regulations and guidelines 8/2016, chapter 7 (in Finnish).

Foreign service providers operating in other EEA Member States are correspondingly allowed to provide payment services in Finland. This requires the service provider to contact the competent authority of its home Member State.

The application forms: