Banks

Credit purchasers and credit servicers

The Act on Credit Purchasers and Credit Servicers (adopted by the Parliament 2^nd of April 2025), provides for the supervisory role of the Financial Supervisory Authority (FIN-FSA), the role of the FIN-FSA as the authorisation authority and the notifications to be made to the FIN-FSA.

Supervisory role of the FIN-FSA

The Financial Supervisory Authority (FIN-FSA) supervises the conduct of credit purchasers and credit servicers. Credit purchasers and credit servicers must act fairly and professionally towards the debtor. They must notify the debtor of the transfer of non-performing credit and ensure that no incorrect or unclear information is given to the debtor. In consumer relations, the Consumer Protection Act (38/1978) also applies to purchased credits and credits serviced on behalf of the purchaser.

The FIN-FSA’s supervisory tasks include, among other things, ensuring that the credit servicer complies with the requirements for the retention of client funds and credit servicing information and that it also has appropriate procedures for handling customer complaints.

Regulations regarding credit managers are, in principle, only mandatory when servicing of credit institutions’ non-performing consumer credit is involved. If, however, credit purchaser’s registered office or headquarters is outside the EEA, the appointed performer of credit servicing activities must also comply with the regulations regarding non-performing credit granted to micro, small and medium-sized enterprises (SMEs).

Credit servicer authorisation to be applied for from the FIN-FSA and notifications to be made to the FIN-FSA

More information on the application for credit servicer authorisation to be submitted to the FIN-FSA, notification of changes to the information in the application for authorisation, and on notifications to be submitted by credit institutions, credit purchasers and credit servicers to the FIN-FSA can be found here: Credit purchasers' and credit servicers' Authorisations, registrations and notifications page.

Background information

General

The legislation on credit purchasers and credit servicers implements the so-called NPL Directive (EU) 2021/2167 on credit servicers and credit purchasers. The scope of the Directive, and therefore also of the new Act on Credit Purchasers and Credit Servicers, is limited to the purchase and servicing of non-performing credits of credit institutions.

Credit servicers must have an authorisation granted by the FIN-FSA. In addition to this obligation, the FIN-FSA supervises the conduct of credit purchasers and credit servicers activities.

Obligations of a credit purchaser

Credit purchaser refers to a natural person or legal entity that, in the course of their business activities, purchases non-performing credits granted by a credit institution.

According to the Act, credit purchasers that do not have the right to engage in credit servicing activities themselves must appoint a performer of credit servicing activities for non-performing credit granted to consumers. Such a performer of credit servicing activities may be:

an authorised credit servicer
a credit institution
an authorised consumer credit provider

For credit other than consumer credit, there is no obligation to use a performer of credit servicing activities; credit purchasers may carry out credit servicing activities themselves. However, if the credit purchaser’s registered office or headquarters is not located in an EEA state, credit purchaser must also appoint a performer of credit servicing activities for non-performing credit granted to micro, small or medium-sized enterprises (SMEs).

Operating as a credit purchaser does not require authorisation or registration as a credit purchaser, but regulations also impose obligations on credit purchasers. The FIN-FSA receives information on credit purchasers from credit institutions, which are obliged to notify the FIN-FSA of the information of the credit purchasers to whom non-performing credit is transferred. The FIN-FSA supervises credit purchasers with regard to these obligations.

Credit purchasers are charged an annual supervision fee of EUR 3,500 under the Act on the Supervision Fees of the Financial Supervisory Authority unless the credit purchaser is already obligated to pay a higher fee based on other supervision.

Obligations of a credit servicer

A performer of credit servicing activities is a service provider that handles the rights and obligations related to non-performing credit and performs one or more of the following credit servicing activities on behalf of a credit purchaser:

recovery of non-performing credit and collection of credit-related payments from debtors
renegotiation of the terms of non-performing credit with the debtor
handling of debtors’ complaints concerning non-performing credit
informing debtors of payments related to non-performing credit and any changes to them.

Engaging in credit servicing activities is subject to authorisation. In addition to credit institutions and consumer credit providers, credit servicing activities may only be carried out on behalf of a credit purchaser by a credit servicer authorised by the FIN-FSA. The FIN-FSA shall prohibit credit servicing activities that are carried out without authorisation.

A credit servicer’s authorisation may be granted to a legal person whose registered office is located in Finland. Applications for authorisation can be submitted to the FIN-FSA immediately after the Act has entered into force.

The Act also contains provisions for the supervision of EEA credit servicers providing cross-border services to Finland. A Finnish credit servicer may provide credit servicing services in another EEA country either by establishing a branch or by providing cross-border services.

More information on the activities of a Finnish credit servicer in another EEA country and the activities of an EEA credit servicer in Finland can be found here: Credit purchasers' and credit servicers' Authorisations, registrations and notifications page.

A Finnish credit servicer is obliged to report customer complaints it receives to the FIN-FSA as soon as EBA/GL/2024/12 begins to be applied: Customer complaints notifications (in Finnish).