Chapter 7 and enacted Finnish CCD2 reform
Finland regulates ordinary consumer credit through Chapter 7 of the Consumer Protection Act, kuluttajansuojalaki 38/1978. Chapter 7a addresses certain consumer credits relating to residential property and has its own distinctions. The CCD2 implementation includes Act 31/2026, published in January 2026. The consolidated Finlex text expressly states that the Chapter 7 and 7a amendments in Act 31/2026 enter into force on 20 November 2026, while changes to other chapters entered into force on 19 June 2026. A lender should not treat the whole Act as having one commencement date. Use the Finnish statutory version applicable to the contract and product, and keep a reference to the consolidated text and original amending act.
Transitions for continuous credit
The transition clause in Act 31/2026 generally preserves the law in force at commencement for contracts made before the new provisions. It also applies specified new Chapter 7 sections to existing continuous-credit agreements. Finlex identifies sections 24, 25, 30, 32, 46, 46a and 47 among those selected provisions. An older revolving facility and a newly signed fixed-term loan can therefore need distinct rule configurations after 20 November 2026. Record the original contract date, whether the account is jatkuva luotto, continuous credit, and which new provisions reach the existing agreement. This is a legal classification, not simply a servicing-system migration task. Do not broadly apply every new disclosure or creditworthiness requirement to older contracts without checking the transitional clause.
Finnish information and identity verification rules
Finland's Chapter 7 addresses information and creditor conduct, with specific national statutory terminology such as kuluttajaluotto, luotonantaja and luotonvälittäjä. The 2026 reform introduces or modifies definitions relating to credit intermediation and advice services. A separate Act 835/2026 amended provisions concerning verification through electronic identification methods and entered into force on 1 October 2026. It should not be confused with the main CCD2 commencement. Electronic lending processes must map any identification duty to the currently operative statute and the product type, rather than assume every electronic-signature event is equivalent to legally adequate customer identification. Keep evidence of the method used and the consumer's agreement and disclosures as required.
Authorities and lender oversight
Kilpailu- ja kuluttajavirasto, the Finnish Competition and Consumer Authority (KKV), is a key institution for consumer rights and fair commercial practices. Finanssivalvonta, the Finnish Financial Supervisory Authority, oversees financial institutions and certain regulated credit-market activities within its remit. Different consumer-credit obligations may also involve the Consumer Ombudsman and other designated authorities under Finnish law. Clarify which organisation supervises advertising, contract provisions, credit-provider registration and banking conduct for the actual firm. Maintain Finnish- and Swedish-language customer information where applicable and verify statutory presentation requirements. A foreign lender entering Finland should not assume that a licence check in another EU Member State addresses all Finnish conduct duties.
Positive Credit Register and underwriting
Finland's Positive Credit Register, positiivinen luottotietorekisteri, is a national arrangement for reporting and access to relevant credit information. It is administered by the Finnish Tax Administration's Incomes Register Unit, not simply by a private bureau. A lender should verify reporting and access obligations for the institution and product, including corrections and data-quality controls. Credit register evidence can inform a borrower's existing obligations but does not automatically answer questions about living costs or repayment capacity. Use lawful sources and proportionate assessment methods under the applicable regime. Document when data were obtained and how stale or disputed entries were handled. Integrate register reporting and consumer-credit underwriting while keeping their distinct legal bases and regulator responsibilities clear.
Pricing, marketing and agreement controls
Finnish consumer-credit law includes rules affecting interest, fees, marketing, agreement information and repayment rights that should be checked against the precise operative statutory version. The lender should test its advertised annual percentage rate, charges, payment schedule and ancillary services for each product. A zero-interest instalment offer may still involve credit-law obligations depending on the domestic definitions and transitional rules. Provide information in a manner the consumer can retain when required, and keep the version of the agreement actually accepted. Update servicing notices, default and hardship procedures where provisions change in November 2026. A standardised European product catalogue should not conceal Finnish national details, including credit reporting and any mandatory identification procedures.
Scenario: new loan and existing card account
Consider a Finnish instalment loan agreed in December 2026 and an older continuous-credit account entered in 2024. The new loan generally falls under the updated Chapter 7 measures, while the older revolving facility may remain under prior law except for the enumerated provisions extended to it by Act 31/2026. The lender should configure its decision engine accordingly and preserve the contract dates and versions of legal documents. Check whether identity verification and the Positive Credit Register trigger separate duties for the relevant products. The historical agreement should not be overwritten to give the impression that the consumer accepted an entirely new contract. Document the exact statutory basis for each customer-facing disclosure, rate-change notice or servicing action. The 2026 Finnish amendments should be mapped provision by provision, with explicit testing for both new agreements and continued accounts established before commencement.
Frequently asked questions
When do new CCD2 rules generally apply in Finland?
The common application date is 20 November 2026, subject to the enacted national statute and transitional conditions.
Is the original national consumer credit law still relevant?
Yes. The contract date, product and operative national provisions determine requirements.
Can the same rules be used across all three countries?
No. Their statutes, supervisory arrangements and transition provisions differ.
Primary sources
Directive (EU) 2023/2225 ↗Finland Consumer Protection Act Finlex consolidated ↗Finland amendment 31/2026 legislative record ↗Finland separate Act 835/2026 ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.
Related research
CCD2 and Consumer Credit Regulation Across EU Member States ↗