A working group set up by the Ministry of Justice issued in January 2025 a report including a legislative proposal for the implementation of the Consumer Credit Directive (Directive (EU) 2023/2225 on credit agreements for consumers and repealing Directive 2008/48/EC and the Consumer Rights Directive (Directive (EU) 2023/2673 amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC). The report outlines significant legislative amendments and their expected impact on financial institutions and consumer protection. The proposed amendments include changes to the Finnish Consumer Protection Act (38/1978) and other consumer protection legislation. The legislative changes aim to enhance protection of consumer rights by introducing stricter compliance requirements for financial institutions, requiring them, for example, to reassess their credit policies and consumer protection mechanisms.
Amendments to consumer rights in distance selling of financial services and products
The proposed amendments introduce substantial revisions to the Finnish Consumer Protection Act. One of the most notable changes is the introduction of a withdrawal functionality applicable in distance selling of consumer financial products and services. Businesses will be required to offer consumers a clear and cost-free method to withdraw from financial agreements concluded at distance. This withdrawal functionality must be provided as an easily accessible tool, ensuring that consumers can exercise their right of withdrawal during the assigned 14-day withdrawal period.
The amendments also strengthen protections against misleading online interface practices — often referred to as dark patterns — that could direct consumer behaviour, obscure withdrawal rights or misrepresent financial terms. Businesses will be required to provide clear, accessible and sufficient information on financial products and agreements to ensure consumers fully understand their commitments.
Widening the regulatory scope of consumer credits and disclosure obligations
Another key change proposed by the working group is the expansion of the scope of the Finnish Consumer Protection Act to cover interest-free and cost-free consumer credits previously excluded from the applicability of the act. These (typically BNPL) loans will be subject to compliance requirements, including mandatory information disclosures.
Additionally, the amendments introduce stricter rules on disclosure and credit marketing practices. Mandatory general information and pre-contractual information about credit agreements must be made available in a clear and comprehensible form. Regarding marketing practices, it will be explicitly prohibited to create an impression that taking out a loan leads to an increase in financial resources, replaces savings, or improves a consumer’s standard of living. Furthermore, marketing must not downplay the impact of existing credit obligations or imply that outstanding loans or recorded credit history have minimal or no effect on future credit assessments.
The legislative amendments also introduce contractual consequences for creditors failing to properly assess creditworthiness, ensuring a more robust regulatory framework. Creditors will be required to thoroughly evaluate a consumer’s creditworthiness before extending credit, and failure to comply could result in financial penalties and legal repercussions. The amendments also emphasize responsible lending and referring consumers to appropriate debt counselling services if deemed appropriate.
Enhancing regulatory supervision through registration requirements
To improve oversight, registration requirements for certain creditors and credit intermediaries will be expanded, further tightening compliance and reinforcing consumer protection measures. In addition, the right to provide consumer credit advisory services will be restricted to certain market participants and their right to charge for such advisory services will be regulated by law.
The establishment of stricter registration and operational requirements is intended to ensure higher standards within the financial sector, increasing accountability among creditors and intermediaries. Institutions will be expected to implement adequate training programmes and comprehensive risk assessment mechanisms and adapt their business practices accordingly.
The regulatory developments will also necessitate enhanced supervision and co-operation by consumer and financial authorities to ensure that institutions comply with the new framework.
Implementation timeline and industry implications
A government proposal based on the working group report is expected to be submitted to Parliament this autumn. The amendments stemming from the Consumer Rights Directive are proposed to enter into force on 19 June 2026, while the Consumer Credit Directive provisions will take effect on 20 November 2026.
Financial services and consumer credit providers are encouraged to act proactively and to ensure compliance with the new regulations on registration, disclosure and marketing. The amendments are likely to necessitate a review of the operational framework, a reassessment of credit assessment processes as well as advertising strategies and consumer protection measures. As the implementation deadline approaches, institutions must evaluate and adapt their compliance frameworks by reviewing applicable regulatory licenses and registrations, updating terms and conditions, lending policies, enhancing customer communication, and ensuring staff training aligns with new regulatory expectations.
To navigate these regulatory changes, collaboration with legal and compliance experts is essential. Our Financial Regulatory team at Waselius is ready to assist businesses with drafting of amendments to the terms and conditions as well as any other compliance assessments, regulatory strategy adjustments, and licensing matters you may have.