Credit institutions
Applying for authorisation
An application for authorisation is made through the IMAS portal, maintained by the European Central Bank (ECB). Before submitting an official application, we recommend that the applicant go through the so-called pre-notification phase, during which the Financial Supervisory Authority (FIN-FSA) and the ECB will provide preliminary feedback on the comprehensiveness and content of the application material. The applicant is encouraged, in any case, to contact the FIN-FSA in good time before submitting an application for authorisation.
An application for authorisation can be made in Finnish, Swedish or English.
Application processing schedule
An authorisation of a credit institution is granted by the ECB, based on an application submitted to the FIN-FSA. The FIN-FSA must submit a decision proposal on the authorisation of a credit institution to the ECB within four months of receipt of the application or, in the event of a defective application, as soon as the applicant has submitted the necessary documents and clarifications.
A decision on an authorisation must always be given, however, within 12 months of receipt of the application.
Entry into register of authorisations and announcement of authorisations granted
Once authorisation is granted to a credit institution, the FIN-FSA makes the appropriate declaration for entry into the Trade Register. It is important to note, however, that a company to be established may not commence operations until the company has been entered into the Trade Register.
In addition, the FIN-FSA forwards information on granted authorisations to the Deposit Guarantee Fund (in the case of a deposit bank authorisation), the Investor Compensation Fund (authorisation to credit institutions providing investment services), the EU Commission and the European Banking Authority.
Credit institutions that have been granted authorisation can be viewed in the FIN-FSA’s list of supervised entities.
Information on authorisation conditions and application procedure:
Act on Credit Institutions, chapter 4
Commission Delegated Regulation (EU) 2022/2580 supplementing Directive 2013/36/EU of the European Parliament and of the Council with regard to regulatory technical standards specifying the information to be provided in the application for the authorisation as a credit institution, and specifying the obstacles which may prevent the effective exercise of supervisory functions of competent authorities
Commission Implementing Regulation (EU) 2022/2581 laying down implementing technical standards for the application of Directive 2013/36/EU of the European Parliament and of the Council with regard to provision of information in applications for authorisation of a credit institution
EBA Guidelines on a common assessment methodology for granting
ECB Guide to assessments of licence applications
When assessing authorisation applications, the FIN-FSA also takes into account the FIN-FSA’s Regulations and guidelines concerning authorisation requirements as well as EBA Guidelines.
EEA credit institution
Branch
A foreign credit institution whose registered office is in an EEA state may establish a branch in Finland by notifying the supervisory authority of its home member state. The supervisory authority of the credit institution’s home member state will notify the Financial Supervisory Authority (FIN-FSA) of the credit institution’s right to carry out credit institution activity and will specify the services that the branch will provide. The FIN-FSA must respond to the credit institution within two months of receiving the notification.
Before commencing its operations, the branch is requested to notify the FIN-FSA of the exact date of commencement and to submit a trade register extract, as referred to in the Trade Register Act (564/2023).
The FIN-FSA supervises branch operations to a limited extent. Supervision of operational risks and solvency falls within the competence of the supervisory authority of the credit institution’s home member state. Branches accepting deposits are required to provide information on the deposit guarantee scheme and its organisation. The deposit guarantee of the branch is determined on the basis of the deposit guarantee scheme of the credit institution’s home member state.
If a branch fulfils the assessment criteria of a significant institution as specified by the Single Supervisory Mechanism, the branch is subject to supervision by the ECB.
Foreign credit institutions providing their services via a branch can be viewed in the FIN-FSA’s list of supervised entities (Credit market entities – Branches and representative offices).
Cross-border provision of services
A foreign credit institution whose registered office is in an EEA state may provide services in Finland by notifying the supervisory authority of its home member state, which will then notify the FIN-FSA.
Supervision of direct cross-border credit institution operations is mainly the responsibility of the supervisory authority of the credit institution’s home member state. However, the FIN-FSA supervises the customer policies of credit institutions providing services cross-border and their compliance with the provisions concerning customer protection.
Foreign credit institutions providing cross-border services in Finland can be viewed in the FIN-FSA’s list of notifications (Credit market)
Non-EEA credit institution
Branch
A non-EEA credit institution intending to carry out credit institution operations in Finland must apply to the FIN-FSA for an authorisation to establish a branch in Finland. The information to be included in a branch authorisation application is laid down in more detail in a decree of the Ministry of Finance.
Foreign credit institutions providing their services via a branch can be viewed in the FIN-FSA’s list of supervised entities (Credit market entities – Branches and representative offices).
Representative office
A non-EEA credit institution may open a representative office in Finland by notifying the FIN-FSA of this. The notification must mention the address of the representative office, the person responsible for the activities of the representative office, and the nature and scope of the activities.
According to chapter 17, section 6, subsection 2 of the Act on Credit Institutions (610/2014), a representative office may not carry on activities referred to in chapter 5, section 1 of the Act. A representative office may therefore be established for the purpose of establishing business relationships and presenting services. The activities of a representative office may include, for example, so-called brand marketing or marketing research. A representative office may promote the creation of customer relationships, but cannot enter into business or customer relationship agreements that are binding on the credit institution.
The representative offices of foreign credit institutions operating in Finland can be viewed in the FIN-FSA’s list of supervised entities (Credit market entities – Branches and representative offices).
Cross-border provision of services
A non-EEA credit institution may not provide services directly to Finland cross-border.
Operations in another EEA state
Branch
Establishment of a branch in another EEA state requires prior notification to the Financial Supervisory Authority (FIN-FSA). The notification must include the information in accordance with Annex I of European Commission Implementing Regulation 2022/193 (establishment of a branch or changes in branch particulars). The notification procedure is described in more detail below under the heading Submission of a notification.
The FIN-FSA must, within three months, process the matter and assess whether there is an impediment to the establishment of a branch. If the FIN-FSA has nothing to comment on the matter, it will notify the supervisory authority of the state where the services are to be provided (host member state). If a branch cannot be established, the FIN-FSA issues a decision which is subject to a right of repeal. The authority of the host member state must, within two months, process the FIN-FSA’s notification and respond to the party making the notification. The branch can commence its activities when it has received a response from the host member state or if no response has been received from the host member state within two months.
Before opening a branch, the credit institution is requested to submit to the FIN-FSA any notification that the supervisory authority of the host state may have given to the supervised entity regarding the public interest conditions under which operations must be carried out. In addition, the credit institution is requested to provide notification of the date of opening of the branch.
For credit institutions under the direct supervision of the European Central Bank (ECB), the notification is submitted to the FIN-FSA but is processed and the final decision made by the ECB.
Cross-border provision of services
A credit institution that wishes to provide its services directly on a cross-border basis without the establishment of a branch must notify the FIN-FSA of this. The notification must include the information in accordance with Annex V of European Commission Implementing Regulation 2022/193. The notification procedure is described in more detail below under the heading Submission of a notification.
The FIN-FSA will notify the supervisory authority of the future host member state about the provision of services within one month of receiving the credit institution’s notification. An exception to this is notifications involving crypto-asset services, where the corresponding processing time is 10 working days. Activities can be commenced immediately after the FIN-FSA has made this notification.
For credit institutions under the direct supervision of the ECB, the notification is submitted to the FIN-FSA but is processed by the ECB.
The notification procedure is described in more detail below under the heading Submission of a notification.
Submission of a notification
New notifications, changes to notifications and withdrawals (cross-border services and branches) should be made via the ECB’s IMAS portal (significant and domestic banks):
Notifications are made in English.
In the case of a new, first notification, please contact AUT.Banks(at)finanssivalvonta.fi before sending the notification.
See also
Commission Implementing Regulation (EU) No 2022/193
Credit institutions providing their services from Finland to EEA states can be viewed in the FIN-FSA’s list of notifications.
Operations in a non-EEA state
Branch
Establishment of a branch in non-EEA state requires an authorisation granted by the Financial Supervisory Authority (FIN-FSA). The Ministry of Finance has issued a decree specifying the attachments that must be submitted to the FIN-FSA along with the application for authorisation. The decree can be found behind the link below. The FIN-FSA must make a decision on the authorisation within 12 months of receiving the application.
When assessing the conditions for granting authorisation, the FIN-FSA pays particular attention to the following:
- that the governance of the branch meets the same requirements as the governance of the credit institution
- that no foreign operating unit remains outside effective control
- that supervisory cooperation between the FIN-FSA and the host state is effective.
For credit institutions under the direct supervision of the European Central Bank (ECB), the notification is submitted to the FIN-FSA but is processed and the final decision made by the ECB.
Cross-border provision of services
If a credit institution intends to provide cross-border services in a non-EEA country without the establishment of a branch, it must make prior notification to the FIN-FSA of this in good time. With regard to services provided to non-EEA countries, the credit institution must ascertain before making the notification whether the cross-border provision of services is permitted in accordance with the legislation of the non-EEA country and the interpretations of the local supervisory authority.
Within three months of receiving a notification, the FIN-FSA may prohibit the activity if there are serious grounds for doing so.