Thematic review on the assessment of consumers’ creditworthiness

In 2025, the Financial Supervisory Authority (FIN-FSA) carried out a thematic review examining the procedures applied by domestic credit institutions and selected foreign credit institutions granting consumer credit in Finland in the assessment of consumers’ creditworthiness. The objective of the review was to determine, in particular, the extent to which credit institutions’ practices meet the requirements set by consumer protection regulation. The review concerned unsecured consumer credits.

Overall, the procedures applied by credit institutions were found to correspond fairly well to the requirements set by regulation. However, the review also identified shortcomings, which varied across the institutions. The findings are based on responses provided by the credit institutions.

Key findings

Information sources used in the assessment of creditworthiness

Based on the thematic review, the FIN-FSA found that all the credit institutions examined make use of the Positive Credit Register in the assessment of consumers’ creditworthiness. However, the extent to which the data in the register is utilised varies significantly across the credit institutions. The FIN-FSA finds that, as a minimum requirement for the types of credit covered by the review, institutions should use data from the register concerning the consumer’s income over the past 12 months and the amounts of credit previously granted to and drawn by the consumer. All credit institutions used income data appropriately, but not all of them utilise information on the amount of outstanding credit.

All credit institutions check payment default entries as part of the creditworthiness assessment, and the majority do not grant new credit to a consumer who has such entries. However, the FIN-FSA was not able to verify that all credit institutions appropriately assess the justifiability of granting new credit to a customer with payment default entries. A payment default entry is not an absolute barrier to granting credit, but the creditor must assess the number and background of any defaults and their impact on the consumer’s creditworthiness.

It was found in the thematic review that not all credit institutions verify to a sufficient degree the accuracy of the financial information requested from the consumer for the purpose of creditworthiness assessment.

Assessment of the consumer’s repayment capacity 

Based on the responses received in the thematic review, not all credit institutions take into account all of the consumer’s essential living expenses in their repayment capacity assessments. In addition, a potential increase in interest rates or factors affecting the continuity of the consumer’s income are not always considered in the financial margin calculations. The FIN-FSA emphasises the importance of taking into account changes that may affect repayment capacity, particularly in large or long-maturity credits.

Shortcomings were identified in documentation and retention periods: not all credit institutions retain documents related to the assessment of the consumer’s creditworthiness for at least the duration of the credit relationship.

Furthermore, it was found in the thematic review that some credit institutions have not assessed the lawfulness of the assessment criteria used in their credit scoring models from the perspective of equality legislation and the prohibition of discrimination.

Creditors’ procedures must be updated to comply with new regulation

The requirements concerning the assessment of creditworthiness in chapter 7 of the Consumer Protection Act will be further specified in November 2026 when the amendments required by CCD2 enter into force.¹ The FIN-FSA draws the attention of all lenders granting consumer credit in particular to the following changes in regulation:

• Going forward, creditors will be obliged to define and maintain the procedures used in the assessment of creditworthiness. These procedures refer not only to the concrete measures used to assess the consumer’s creditworthiness but also to the methods used to verify the accuracy of the information employed in the assessment.
• The provision concerning the information and data sources to be used in the assessment of creditworthiness (Consumer Protection Act, chapter 7, section 14, subsection 1) will be clarified, and its rationale will set out the minimum requirements for the assessment in a more precise manner than before.

The new provision emphasises the consideration of the consumer’s interests and the proportionality of the assessment. It also explicitly requires appropriate verification of the accuracy of the information used in the creditworthiness assessment.

• If a credit application is rejected, the consumer must be informed of the rejection without delay and, where necessary, directed to financial and debt counselling services. As a rule, the grounds for rejection must be provided in writing if requested by the consumer.
• The time limits for documenting the measures taken in the creditworthiness assessment will be extended. Going forward, the information must generally be retained for five years from the date on which the credit has fully fallen due for payment.

In addition, the FIN-FSA reminds creditors of their obligation to verify the customer’s identity when using the Positive Credit Register. As a result of the legislative amendment that entered into force in November 2025, creditors are required to identify and, where necessary, verify the customer’s identity before obtaining data from the Positive Credit Register for the purpose of creditworthiness assessment. At the time the thematic review was conducted, not all credit institutions yet met this requirement.

Subsequent measures by the FIN-FSA

The findings of the thematic review will be used as a basis for directing future supervision. The FIN-FSA requires that the credit institutions remediate the shortcomings identified in the review.

For further information, please contact

• Anu Dahlström, Senior Legal Advisor, anu.dahlstrom(at)fiva.fi or telephone + 358 9 183 5309
• Timiikka Tommiska, Senior Legal Advisor, timiikka.tommiska(at)fiva.fi or telephone + 358 9 183 5578

¹Act Amending the Consumer Protection Act, 31/2026.