Registration of debt collectors

Debt collection activities may only be carried out by companies that are registered in the Regional State Administrative Agencies’ debt collection register. If you plan to engage in debt collection activities, you must submit a notification to be entered into the register. 

Unregistered debt collectors violate the law. We prohibit the debt collection activities of unregistered debt collection companies.

Companies are not required to register in the following cases:

• the creditor collects debts owed personally to them
• the creditor collects outstanding debts for a corporation belonging to the same group
• the debt collection is occasional and has not been marketed
• the supervision of the debt collection activities is arranged in some other manner. This applies to credit institutions, fund management companies, insurance companies and lawyers, among others.

The preconditions for being registered in the debt collectors’ register are:

• The applicant has the right to engage in trade in Finland.
• The applicant has not been declared bankrupt. 
• If the applicant is a natural person: the applicant is of age and legally competent and has not been appointed a legal guardian.
• The applicant is trustworthy.
• The applicant is financially sound.
• The applicant has declared a person who is in charge of the debt collection activities and who meets the requirements set out in legislation.
• The applicant is capable of taking care of client funds.
• The applicant is capable of appropriately protecting the data of the client and the debtor.

The applicant must submit documents and information that we cannot obtain otherwise to the Regional State Administrative Agency in order to assess whether the conditions listed above are met.

You should notify us if the information entered into the register changes. 

If the person in charge of debt collection activities changes, you need to notify us within one month of the termination of the previous person’s post. You should also notify us of the termination of operations.

 The target time for processing registration notifications is two weeks. 

Registration decisions by debt collection agencies as well as changes in the register data are subject to a fee. Decision fees for registration notifications submitted for processing in the online service (notification to start business operations and register data change notifications) are cheaper than for registration notifications submitted on paper. 

For more information on our fees, visit page Fees and charges.

To enter the debt collectors’ register, you need to submit a notification using our online service. For the moment, you can only sign into our online services with a private individual’s online banking credentials. Other authentication methods, such as company authentication, cannot be used to sign into the service.

State the following information in the application:

1. Private entrepreneurs

• full name of the private entrepreneur
• personal identity code or, in the absence thereof, date of birth
• business name and possible auxiliary business names used for debt collection 
• company ID or similar ID 

2. Legal persons  

• legal person’s business name and possible auxiliary business names used for debt collection 
• company ID or similar ID 

3. Contact information

• visiting addresses for the offices 
• postal address
• telephone number and e-mail address for communication with authorities
• website address

4. Invoicing information

• billing address or e-invoicing details
• invoice reference data

5. Contact person

• name of the contact person
• contact person’s telephone number and e-mail address

You should state the following information concerning the person responsible for debt collection:

• full name of the person 
• personal identity code or, in the absence thereof, date of birth 
• the responsible person’s consent along with the person’s signature, name in block letters and date
• statement clarifying the responsible person’s position in the debt collection agency. State whether the person in charge of debt collection activities is an employee of the debt collection agency or a member in one of its bodies.

You need to submit information on the following persons:

• CEO and deputy CEO
• board member and deputy board member
• member and deputy member of the supervisory board or an equivalent administrative body
• general partner 
• other person holding a position in senior management.

You also need to state the persons who

• directly or indirectly hold more than 25 percent of the shares in the limited liability company 
• directly or indirectly hold more than 25 percent of votes conferred by shares
• have equivalent holding or control in another type of company.

For these persons, you should state the following information:

• role
• full name 
• personal identity code or, in the absence thereof, date of birth. 

If the same person holds more than one position in the company (e.g. both as a CEO and as a board member), enter the person’s information in all relevant fields in the online form. All information regarding the person’s position must be stated in the notification.

You need to provide two documents as attachments:

• a diploma demonstrating that the person knows the relevant debt collection legislation 
• proof of the person’s employment relationship with the debt collection agency, such as an employment contract, unless the responsible person is a member in one of the debt collection agency’s bodies.

Attach the following information:

• proof that the client funds are kept in an account intended only for client funds 
• information on the bank account used for storing client funds 
• a document declaring that the account is intended for client funds, such as a client fund account agreement, its terms and conditions or a statement from the bank
• proof of other methods used to prevent the intermixing of client funds with the applicant’s funds.

You should attach evidence of how your company plans to ensure that the data of the client and the debtor are adequately protected. Provide information on the following aspects: 

1. Protection of personal data by technical and other methods from

• unlawful access 
• accidental or unlawful destruction
• alteration
• disclosure
• transfer.

2. Permissions to use and process personal data

• access rights to personal data 
• safety precautions (such as passwords) ensuring that only authorised persons can access the data.

If you need more detailed information on data protection, consult the office of the Data Protection Ombudsman.

Under the Finnish Act on the Registration of Debt Collectors, we must assess the trustworthiness and solvency of foreign persons in charge of debt collection activities. We also need this information on Finnish citizens who are living abroad.

You should provide the following documents:

• a criminal records extract (may not be more than three months old)
• an extract from the reg­is­ter of business prohibitions
• an extract from the insolvency register
• a certificate from enforcement authorities
• a copy of the credit report
• tax decision

If any of these documents are unavailable, we will assess the need for that document on a case-by-case basis. We will assess the person’s trustworthiness and financial standing based on the documents and information we have received.

If you need more information, you can contact us by e-mail: [email protected] 

The Positive Credit Register is a new register that collects information on private individuals’ credit and income. The Act on the Positive Credit Register entered into force on 1 August 2022. 

The aim of the register is to:

• combat the over-indebtedness of households
• improve credit providers’ ability to assess applicants’ creditworthiness
• help private individuals manage their finances
• provide reliable information about the credit market
• facilitate the monitoring and supervision of credit markets. 

The Positive Credit Register will be introduced in stages. 

• Credit providers will register with the Incomes Register Unit as obliged entities between 2 October and 30 November 2023.
• After that, the first stage is for credit providers to disclose information on consumer credits and comparable credits to the register starting 1 February 2024.
• The use of credit register extracts will begin on 1 April 2024.
• In the second stage, credit providers will disclose non-consumer credit granted to private individuals to the register starting 1 December 2025. Using credit register extracts for these records will begin on 1 April 2026.

Debt collection agencies as recipients of transfers

The obligation to notify the Positive Credit Register does not apply to debt collection agencies when they only manage debt collection orders on behalf of the lender and are not transferees of the credit agreement itself. If a loan has been transferred (sold) to a debt collection agency that meets the conditions concerning the lender, the credit and the borrower set out below, the debt collection agency is obliged to register in the Positive Credit Register maintained by the Incomes Register Unit of the Finnish Tax Administration and notify it of loans, credit transactions and their changes.  

Conditions applicable to the lender

Information disclosed to the Positive Credit Register will include the credit providers, credits and persons obtaining credit that meet the requirements laid down in the related Act.

In the first stage, credit providers that will be obliged entities are

• traders providing credit and financial services supervised by the Financial Supervisory Authority
• Finnish branches of foreign EEA supervised entities
• foreign supervised entities that provide services in Finland without the establishment of a branch.

Obliged entities will also include credit providers and credit intermediaries entered in the register of creditors and peer-to-peer loan intermediaries.

Credit conditions

In the first stage, the information disclosed to the Positive Credit Register will be consumer credit granted to private individuals and other comparable credit. Consumer credit include loans that fall within the scope of Chapter 7 or 7a of the Consumer Protection Act (38/1978). Consumer credit means credit that, by agreement, is granted or promised to the consumer by a business in the form of a loan, deferred payment or another corresponding financial arrangement.

A consumer credit is comparable to a lease or other contract under which the goods are transferred to the possession of the consumer and under which the cash price and credit costs of the goods are paid during the lease period or under which the consumer may otherwise become the owner of the goods when the contract ends. In addition, credit granted by a party other than the lender to the consumer as a loan, deferral of payment or other similar financial arrangement is treated as a consumer credit if another trader passes the credit to the consumer (peer-to-peer loan).

However, data on credits that are not subject to the provisions of Chapters 7 or 7a of the Consumer Protection Act are not stored in the register. These include consumer credit

• for which no interest or other payments are charged
• loans covered by contracts under which the consumer is entitled to pay the price of the commodity to be continuously delivered in instalments during the term of the contract;
• loans granted by pawnbrokers
• loans granted under the Social Loans Act (1133/2022)
• loans that a natural person has borrowed mainly for the operation of their business.

In addition, granting a normal payment period to a consumer in a commodity transaction is also not considered a consumer credit within the meaning of Chapter 7 of the Consumer Protection Act.

Conditions applicable to the borrower

A credit must be entered in the register if the person obtaining the credit is a private individual who has a Finnish personal identity code and is habitually resident in Finland at the time of granting the credit. If the person is not habitually resident in Finland but has a Finnish personal identity code and income from Finland or other particular ties to Finland, the credit can be disclosed to the register.

If the debt collection agency is obliged to register, register with the Incomes Register Unit of the Finnish Tax Administration before you start acquiring credit claims.

Information disclosed to the Positive Credit Register will include credits, credit events and their changes as stipulated in the related Act. Changes to credits include paid instalments, changes to the credit agreement and payment delays. Information on new credits must be reported no later than the calendar day following the date of concluding the contract, and information on changes in credits must be reported on the second business day following the change in the information. Payment delays are reported to the register when a payment has been delayed by 60 days. The information is disclosed via the interfaces provided by the Positive Credit Register.

When a private individual applies for a loan, the credit provider has an obligation to check the applicant’s creditworthiness. To this end, the credit provider requests an extract from the Positive Credit Register. The extract contains up-to-date information on the applicant’s credits reported to the register and the applicant’s income. An extract from the credit register is subject to a fee for the credit provider.

Private individuals can view their personal credit details in the register’s e-service. In addition, everyone can impose a voluntary credit ban on themselves free of charge.

The Financial Supervisory Authority is the main supervisory authority for credit providers. 

However, the Regional State Administrative Agency for Southern Finland supervises the obliged entities that purchase receivables from credit companies and are obliged to register in the register of debt collection agencies maintained by the Regional State Administrative Agency for Southern Finland. 

The controller is the Incomes Register Unit of the Finnish Tax Administration.

Inquiries: Positive Credit Register – The Positive Credit Register (vero.fi)

 

Companies must be registered as debt collectors if they intend to collect debts on behalf of another party or purchase debts for collection. 

There are some exemptions from the registration obligation. These exemptions are specified in the Finnish Act on the Registration of Debt Collectors.

Registration is not mandatory in the following cases: 

1. the debt collection is occasional and has not been marketed
2. the organisation or foundation is under the control of the state, a municipality or a church and carries out debt collection activities on behalf of another organisation in a similar position in accordance with the Accounting Act
3. the company collects the outstanding debts of a company belonging to the same group, or the client and the creditor are operating under the control of the same person
4. the debt collection agency is under the supervision of the Finnish Financial Supervisory Authority
5. the debt collection activities are carried out by a lawyer or a lawyer’s assistant
6. a party to an estate of a deceased person or the administrator of an estate collects debts due to the estate
7. the administrator of an bankruptcy estate collects debts due to the estate
8. the company operates in another European country and is only temporarily engaged in debt collection in Finland.

However, the operators mentioned in points 3, 6 and 7 must register if they have obtained the outstanding debts solely for the purposes of debt collection.

Creditors are allowed to collect debts owed personally to them. Debts due to a creditor who belongs to the same group may be collected without registration. Lawyers are supervised by the Finnish Bar Association, which means that they are not required to enter the Regional State Administrative Agencies’ register. Death estates and bankruptcy estates do not have to register if they are collecting debts due to the estate.

You do not need to get registered if you wish to collect outstanding debts through the court or through an enforcement process (so-called legal collection). The supervision of legal collection does not fall within the authority of the Regional State Administrative Agency.