FIN-FSA has mapped invoicing service companies’ operating models and assessed potential need for authorisation during 2025

During 2025, the Financial Supervisory Authority (FIN-FSA) has examined the operating models of invoicing service companies active on the markets and assessed whether they necessitate authorisation or registration as referred to in the Payment Institutions Act (297/2010). The FIN-FSA has sent requests for clarification to companies in the sector, with the aim of examining the nature of the companies’ activities relative to payment services legislation. The purpose of the review conducted by the FIN-FSA was to map first whether certain operators need to apply for the aforementioned authorisation and then to monitor how these operators proceed in the matter.

In the mapping exercise, the FIN-FSA has been in contact with approximately 60 invoicing service companies operating on the markets and examined their business models. The FIN-FSA identified significant differences between the companies’ operating models. According to the review, 35% of the companies engaged in activities that require authorisation or registration entitling them to provide payment services. Of the companies covered by the mapping, approximately 45% were assessed as either operating in a way that does not require authorisation, or they changed their operations so that no authorisation is needed. For one fifth, the review is ongoing, and the need for authorisation for these operators is still being assessed.

Approximately 10% of all invoicing service companies covered by the review have so far applied to the FIN-FSA for authorisation or registration in accordance with the law. The FIN-FSA will continue its dialogue with operators in the sector.

For further information, please contact:

Head of Division Jussi Terho, +358 9 183 5573,  jussi.terho(a)finanssivalvonta.fi