Banks

Consumer credit intermediaries

Act on Certain Consumer Credit Intermediaries

The Act on Certain Consumer Credit Intermediaries (33/2026) was published on 21 January 2026. The Act applies to entities who intermediate consumer credit within the scope of chapter 7 of Consumer Protection Act and provide advisory services related to such credit.

The Act will enter into force on 20 November 2026. A consumer credit intermediary who is subject to the obligation to register under the Act must be entered in the register of the Financial Supervisory Authority (FIN-FSA) by that date in order to continue to operate after the Act enters into force.

A registered credit intermediary may also provide the advisory services referred to in the Act.

The Act does not apply to peer-to-peer loan brokers; the Act on the Registration of Certain Creditors and Credit Intermediaries (186/2023) applies to peer-to-peer loan brokerage.

Consumer credit intermediation and consumer credit advisory services

Consumer credit means credit under chapter 7 of the Consumer Protection Act that an entity (credit provider), by agreement, provides or promises to provide to the consumer in the form of a loan, deferred payment or another corresponding financial arrangement.

Consumer credit intermediation means the following activities, among others, undertaken against compensation1 by an entity other than the credit provider itself via consumer credit agreements falling within the scope of chapter 7 of the Consumer Protection Act:

  • presenting or offering such credit agreements (for example presenting or directing credit offers of credit providers in the conclusion of credit agreements,
  • otherwise assisting consumers in the conclusion of such credit agreements (undertaking credit agreement preparations or other administrative actions prior to the conclusion of an agreement, such as forwarding the consumer’s information or credit application to the credit provider or another credit intermediary for the purpose of seeking credit or requesting credit offers from the credit provider on behalf of the consumer) and
  • concluding such credit agreements with consumers on behalf of the credit provider.

If an entity only directly or indirectly introduces the consumer to the credit provider, the entity is not considered to be a credit intermediary on this basis alone.

A situation where, for example, a seller pays compensation to a credit provider in order to be able to offer various payment methods in its online store, even if these payment methods include consumer credit offered by a credit provider, is also not consider to be credit intermediation.

Advisory service means the provision of a personal recommendation to a consumer with regard to a credit agreement falling within the scope of chapter 7 of the Consumer Protection Act.

Exemptions from the obligation to register

The obligation to register does not apply to:

  • micro-enterprises and SMEs that engage in credit intermediation as a side business only to finance the purchase of the consumer goods they sell
  • Finnish or EEA credit institutions or branches of a third country credit institution

The EU definition of an SME is met by a company that employs fewer than 250 people and has an annual turnover under EUR 50 million or a balance sheet total under EUR 43 million.

Practice of activities may be prohibited by virtue of a conditional fine if the registration obligation is not complied with.

Transitional provision before the entry into force of the Act

If an entity offering consumer credit intermediation and who is subject to the registration obligation intends to continue its credit intermediation activities after the entry into force of the Act, it should submit a registration notification to the FIN-FSA by 20 May 2026 in order to ensure that, provided the registration requirements are met, its activities can continue without interruption.

The FIN-FSA will accept registration notifications from 20 March 2026.

Service provision by a Finnish entity abroad and service provision by a foreign entity in Finland

Registration as a consumer credit intermediary does not grant the right to engage in consumer credit intermediation abroad; the right depends on the applicable legislation of the country in question.

Registration as a consumer credit intermediary outside Finland does not grant the right to engage in consumer credit intermediation in Finland.

Code of conduct in consumer credit intermediation

In addition to supervising the information in the register notification, the FIN-FSA also supervises the code of conduct of credit intermediaries. Provisions related to credit intermediation are particularly to be found in chapter 7 of the Consumer Protection Act.

Contact information

kuluttajaluottorekisteroinnit(at)finanssivalvonta.fi

 

1 The concept of compensation is broad in definition, and refers to agreed consideration in the form of both monetary and other financial benefit. The definition does not limit from whom and when such consideration should come.