Reporting data to the Positive credit register

These instructions were updated 19 April 2024.

These instructions describe how to report data to the Positive credit register. The act on the Positive credit register (Laki positiivisesta luottotietorekisteristä 739/2022) entered into force on 1 August 2022. The content of the instructions may still change.

The Positive credit register will be rolled out in two stages. In the first stage, starting from 1 February 2024, data on consumer credits and comparable loans is reported to the register. In the second stage, at the end of 2025, lenders start reporting loans granted to natural persons other than consumers. These instructions describe the reporting of loans included in the first stage. Instructions on the reporting of data included in the second stage will be published closer to the second rollout.

These instructions describe the requirement to submit reports, the loans to be reported, the time limits for reporting, the data content of the reports, and the reporting procedures. They do not describe the sharing of data from the register, nor the requesting of credit register extracts. Information on those is available in the instruction document Sharing data from the Positive credit register.

Get familiar with the Positive credit register’s other instruction documents:

• Reporting data on loan contracts – API description (pdf)
• Checking loan data – API description (pdf)
• General instructions for application developers (pdf)
• Signing up to the Positive credit register as a data notifier
• Sharing information from the Positive credit register
• Instructions for lenders on how to request a data permission
• Instructions on certificates

1 Terminology used in the instructions

Party with the reporting obligation
‘Party with the reporting obligation’ refers to businesses and the Social Insurance Institution (Kela) which are required, under the act on the Positive credit register, to submit reports on loans that they grant or own to the Positive credit register. The requirement to submit reports is discussed in section 4 of these instructions.

Lender
‘Lender’ is a party that grants loans. In these instructions, ‘lender’ refers to all parties required to submit reports. The group of parties with the reporting obligation includes some parties that are not lenders, such as peer-to-peer loan brokers, Kela, debt collection agencies buying debts, and other businesses to which the lender’s rights arising from a loan contract are transferred (reassignees). For the sake of readability, the above parties are also called lenders in these instructions.

Borrower
‘Borrower’ is a person to whom a loan has been granted. The borrower is responsible for the debt to the lender. A single loan may have several borrowers, or co-debtors. The act on the Positive credit register uses the term ‘debtor’ to refer to borrowers.

Consumer
‘Consumer’ refers to a natural person who acquires a commodity—in this case a loan—primarily for a purpose other than conducting business activities. This means that the consumer usually acquires a loan for their personal needs or for their own household. A legal person cannot be a consumer.

A natural person conducting business does not act as a consumer. Business refer to business or professional activities falling within the scope of an accounting obligation, and to agriculture conducted on a professional basis.

Incomes Register Unit
A unit of the Finnish Tax Administration acting as the Positive credit register’s controller together with the Tax Administration.

API
API is an access point according to certain specifications, and it is used for sending data between an outside party and the Positive credit register. For purposes of the Positive credit register, APIs are used for reporting data on loan contracts. API specifications specify the data transmission method (protocol), and the content and format of the data to be transmitted. The use of APIs requires a certificate granted by the Finnish Tax Administration. The certificate is needed to identify the organisation reporting data and to verify the integrity of the data.

2 General principles of data reporting

Lenders submit data to the register through a technical API. For this purpose, the Positive credit register provides API services. The parties with the reporting obligation are responsible for building their own APIs and liable for the related costs. Data cannot be reported in any other way. Reporting data to the register is not subject to a charge.

The data is submitted in a batch of a specific format. The data transmission method (protocol) and the content and format of the data to be transmitted are defined in the register’s technical instructions.

The requirement to submit reports is fulfilled when the lender has successfully submitted data to the register within the time limit and the data has been successfully stored. The lender must check in the processing response sent by the register whether the data has been stored successfully. More detailed instructions on the processing response are available in the general instructions for application developers.

Loans meeting the following statutory requirements are reported to the Positive credit register:

• Borrower: A loan is granted to a person as laid down in section 4 of the act on the Positive credit register. The borrowers falling within the scope of the register are defined in greater detail in section 3 of these instructions.
• Lender: A loan is granted by a business with the reporting obligation under section 16, subsection 1 or 3 of the act on the Positive credit register. The parties required to submit reports to the register are described in greater detail in section 4 of these instructions.
• Loan: A loan is a consumer credit or comparable loan as laid down in chapter 7 or 7a of the Consumer Protection Act (38/1978). All consumer credits are reported to the register, whatever the type of the loan, the amount of the loan, and the duration of the loan contract. Promises to grant a loan or loan offers are not reported to the register. The loans to be reported to the register are described in greater detail in section 5 of these instructions.

In addition, Kela reports guarantee receivables for student loans under section 38 of the act on financial aid for students (Opintotukilaina 65/1994).

Lenders reporting loan data must submit the data content laid down in the act on the Positive credit register. The data content is discussed in section 7 of these instructions.

The time limits for reporting data are described in section 8 of these instructions.

The use of the register begins in stages:

• 2 Oct.–30 Nov. 2023 Lenders sign up as loan contract notifiers (in the lenders’ e-service or by filling in a paper form).
• 1 Feb.–31 Mar. 2024 Lenders start reporting data on loan contracts.
• 1 Apr. 2024 Sharing data from the register to lenders begins.

3 Individuals whose loans are reported to the Positive credit register

Lenders must submit data to the Positive credit register on all loans of such natural persons who have a Finnish personal identity code and a place of residence in Finland. The person’s age is irrelevant, so loans issued to minors must also be reported to the register.

The purpose is to report as comprehensive loan data as possible regarding persons who live temporarily or permanently in Finland and have a Finnish personal identity code. However, the concept of ‘residence’ is not defined in greater detail in the legislation on the Positive credit register. In other words, if a person moves to Finland and they have or they receive a Finnish personal identity code, the party with the reporting obligation must report all the person’s new and previously granted consumer credits and comparable loans falling within the scope of chapter 7 or 7a of the Consumer Protection Act.

If a person moves away from Finland after the grant of a loan, the lender can continue reporting data on the loan contract if the person has a Finnish personal identity code and had income from Finland or a special bond to Finland when the loan was granted.  If the lender does not continue reporting data on the loan contract, the loan must always be reported as ended to the register.

If a person has a Finnish personal identity code but no place of residence in Finland, the lender can report the loan data to the register if at least one of the following requirements is met at the time the loan is granted:

• The person receives income from Finland.
• The person has some other special bond with Finland.

In these situations, the lender may report the loan to the register but has no obligation to do so. ‘Other special bond with Finland’ refers to another kind of customer-relationship-based commitment that the person may have to a lender that is required to submit reports. In particular, a previously granted loan may be such a special bond.

Example: The lender has granted a home loan for permanent home to a person residing in Finland, but the person moves abroad during the loan relationship. The lender grants the same person a loan for buying a leisure house, and the borrower repays the loan with income earned abroad. Due to the previously granted loan, the person has a special bond with Finland, so the lender can also report the new loan to the register.

Loans of individuals who do not have a Finnish personal identity code are not reported to the register.  In other words, foreign personal IDs or artificial personal identity codes, for example, are not reported to the register.

4 Parties with the reporting obligation

According to the act on the Positive credit register, the businesses specified below are obliged to report data on consumer credits and other comparable loans to the Positive credit register.

1. The following businesses that are under the supervision of the Financial Supervisory Authority in accordance with the Act on the Financial Supervisory Authority (878/2008):
   1. businesses providing credit and financial services (section 4, subsection 1)
   2. Finnish branches of foreign credit and financial institutions of EEA countries subject to supervision (section 4, subsection 5)
   3. foreign credit and financial institutions subject to supervision that provide services in Finland but do not have a Finnish branch (section 4, subsection 5).
2. Lenders and loan brokers registered in accordance with the Act on the Registration of Certain Credit Providers and Credit Intermediaries (186/2023).
3. Other businesses to which the lender’s rights arising from a reported loan contract are transferred (reassignees).

In addition, Kela reports guarantee receivables for student loans to the register. The State Treasury does not report the guarantee receivables they collect.

The reporting obligation referred to in item 1 applies to such providers of credit and financial services whose operations are supervised by the Financial Supervisory Authority. A branch of a foreign EEA-supervised entity may be a branch of a credit institution located in an EEA country or a branch of a credit institution established in an EEA country by a third country. The provision of services without a branch is possible only for such EEA-supervised entities that have an operating licence in another EEA country.

The reporting obligation referred to in item 2 applies to such lenders and peer-to-peer loan brokers entered in the register maintained by the Financial Supervisory Authority whose operations are supervised by the Financial Supervisory Authority. Lenders and peer-to-peer loan brokers granting consumer credits are obliged to register and are subject to supervision, except for certain exceptions laid down in legislation. The lenders and peer-to-peer loan brokers with the reporting obligation that are referred to in this item could also be lenders established in another EEA country that provide services in Finland.

The requirement to submit reports also applies to businesses referred to in item 3 to which the lender’s rights arising from a reported loan contract have been transferred. Such reassignees include, for example, debt collection agencies to which loans have been transferred from a business that is required to submit reports. If a debt collection agency attends to a collection assignment on behalf of a lender, the reporting obligation remains with the lender.

If the new lender is a business referred to in item 1 or 2, the obligation to report on the transferred loan always transfers to the new lender. As regards other businesses, the reporting obligation transfers to the new lender if the loan is transferred from a business that is required to submit reports.

 

4.1 Signing up, and a decision on establishing a connection

Lenders must sign up as loan contract notifiers with the Finnish Tax Administration’s Incomes Register Unit either in the Positive credit register’s e-service or by using a paper form. When signing up, the lender must provide information on its actual activities and submit the information required for the introduction of APIs. Kela is not required to sign up.

The Incomes Register Unit processes the lender’s sign-up request and checks its obligation to submit reports. It will then issue an appealable decision on establishing a connection for the lender. If the decision is positive, the lender is granted a certificate by which it will be identified in the API. Separate instructions are provided on how to retrieve and use the certificate.

In the Positive credit register, only a lender with the reporting obligation can sign up as a data notifier and request and receive a certificate needed to report data. The certificate of a party with the reporting obligation must always be used when data is reported to the register. The Business ID and name of the party in question are recorded in the register as the data notifier's information. The party with the reporting obligation is responsible for the certificate and the data submitted by the use of the certificate.

If data is reported on behalf of the party with the reporting obligation, the organisation acting on another's behalf must use a separate certificate. If the organisation acting on another's behalf (e.g. a system supplier) performs all the reporting, the certificate issued to the party with the reporting obligation can be handed over to them. In this case, the register must be informed of the certificate user (name and business ID) either by calling the register's customer service or by filling in the contact form.  

If the party with the reporting obligation uses their own certificate to report data but, in addition, some of their loan data is reported by an organisation acting on their behalf, an additional certificate must be requested for the organisation acting on another's behalf by calling the customer service or by filling in the contact form.  When requesting an additional certificate, the organisation must provide the name and Business ID of the organisation for which the additional certificate is requested. The party with the reporting obligation is responsible for all actions in which the additional certificate is used and for seeing that the certificate holder has the right to use the API certificate. Authorisation documents must be presented upon request.

Information on lenders that have been approved as notifiers and that have received positive decisions on the establishment of connections is available on the Positive credit register’s website. The information includes the name and Business ID or foreign business ID of each party with the reporting obligation.

Separate instructions are provided on how to sign up as a notifier of loan contract data.

 

5 Loans reported to the register

Data on consumer credits and comparable loans granted by virtue of loan contracts is reported to the Positive credit register. In addition, Kela reports data on guarantee receivables for student loans. This section of the instructions describes in greater detail what loans must be reported to the register. The data to be reported on the loan contracts is described in section 7.

5.1 Consumer credit

Consumer credits reportable to the Positive credit register mean loans laid down in chapter 7 or 7a of the Consumer Protection Act (38/1978).

According to the Consumer Protection Act, the term ‘consumer credit’ means credit which, 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 and on which interest or other charges are collected.

The lender is responsible for investigating whether a loan it grants or brokers to a natural person is a consumer credit.

Only granted loans are reported to the Positive credit register. Promised loans are not reported. A loan promise refers to the lender's unilateral commitment to lending. Credit granted by agreement and reportable to the register refers to a loan on which a loan contract approved by both parties has been concluded.

A deferred payment refers to the right granted to the borrower by agreement to pay the overdue amount either partly or fully after the due date. A deferred payment is not the same as a usual extension for payment. The usual extension for payment, i.e. an extension granted to a consumer in commodity trading, does not constitute a consumer credit within the meaning of chapter 7 of the Consumer Protection Act, so agreements on such extensions for payment are not reported to the register.

A financing agreement can also be made on a purchased commodity, in which case the buyer can pay the price of the commodity either as a one-off payment without interest and expenses or in instalments. In the latter case, interest and expenses are added to the price. Financing agreements are reported to the register only if the buyer decides to use the credit facility agreed on in the financing agreement and pays the price of the commodity in more than one instalment.

Data on credits to which the provisions of chapter 7 or 7a of the Consumer Protection Act do not apply is not reported to the register. Such credits include loans on which no interest or expenses are collected, credits granted by pawnbrokers, and social credits.

Consumer credits do not include loans that a natural person has taken out primarily for their business activities. As of 1 December 2025, loans taken out for business activities will be reported to the register.

5.2 A loan comparable to a consumer credit

Data on loans comparable to consumer credit is reported to the Positive credit register.

Under chapter 7, section 1, subsection 2 of the Consumer Protection Act, loans comparable to consumer credits refer to leases or other such contracts by which goods are transferred to a consumer’s control and according to the terms and conditions of which the cash price and loan expenses will be paid during the lease period or the consumer can otherwise become the owner of the goods at the end of the contract. The Positive credit register refers to the above contracts with the term ‘leasing contract’.

Under chapter 7, section 1, subsection 3 of the Consumer Protection Act, a loan is also comparable to a consumer credit if a party other than a lender grants or promises to grant it to a consumer as a loan, deferred payment or another corresponding financial arrangement and if a business operator brokers the credit to the consumer. In that case, the business acts as a peer-to-peer loan broker.

6 Reporting existing loans to the register

Once the lender’s sign-up request has been processed and the Incomes Register Unit has issued a decision on the establishment of a connection, the lender can start reporting data. The existing loans must be reported between 1 February and 31 March 2024. However, the Incomes Register Unit recommends that organisation should not start reporting until on 5 February 2024, so that the Incomes Register Unit can ensure sufficient support for all data notifiers. 

At first, the lender must report information on all the valid loans that fall within the scope of the requirement to submit reports. All loans of the existing credit stock that are defined in section 5 of the instructions and have been granted to persons meeting the definition in section 3 must be reported. Loans where the only debtor is a death estate will not be included when the existing credit stock is reported to the register.

When the lender has reported a loan to the register, they must start reporting on a continuous basis: any changes to loan contract data must be reported within the statutory reporting deadlines.

The lender is obliged to report all the data within the scope of the reporting obligation. All data on the existing loans that should be reported to the register may not be available to the lender with reasonable efforts if, for example, a loan has been granted a long time ago. When existing loans are reported, the following conditions apply to the data elements that are technically required in the API:

• Date of conclusion is not a technically required data element between 1 February and 31 March 2024, i.e. the period when the existing loans are being reported to the register. As regards some conditionally required data fields, whether they are required or optional depends on the date of conclusion. If the date of conclusion is omitted from the report, these conditionally required data fields are technically optional.
• One-time expenses paid when a loan contract is made are not technically required if the date of contract is before 1 February 2024.
• Information that a loan is a goods or services related credit is not a technically required data element if the date of contract is before 1 February 2024.
• Information on whether a loan is a consumer credit under chapter 7 of the Consumer Protection Act, a consumer credit related to residential property under chapter 7a of the Consumer Protection Act, or other than a consumer credit is not a technically required data element if the date of contract is before 1 February 2024.
• The information on whether the lender is a peer-to-peer loan broker is not a technically required data element if the date of conclusion is earlier than 1 February 2024.

Some loan information is technically optional in the API, such as:

• effective interest rate on the date of contract
• income data established during lending
• information that the loan was transferred from another lender.

Technically optional data may be omitted without that the report is rejected. However, even the technically optional data must be reported if it is available with reasonable efforts.

Lenders submit data on the existing loan contracts to the register through the New loans API, reporting the information as it is at the time of submittal. Past payment transactions or deferments of amortizations that have already ended are not reported for the existing credit stock.

The lender starts reporting data to the register on a continuous basis immediately after reporting the existing credit stock. This means that amortizations and changes made to loan contracts, for example, must be reported in compliance with statutory time limits. The time limits are discussed in section 8 of these instructions.

The data to be reported is described in section 7 of these instructions.

7 Data to be reported on loans

Lenders submit data on loan contracts in batches through APIs. Depending on the batch type, the lender uses one of the following API services:

• New loan
• Changes to loan contract information
• Payment transactions
• Delayed amounts
• End of loan contract

These instructions concern the data content to be reported. More detailed instructions on the technical details of reporting can be found in the API description and the general instructions for application developers.

Basic loan data with the same data content is reported on all loans. In the API description and these instructions, some information is grouped differently from the act on the Positive credit register. In the act, the information on the collateral and on the borrower forms a separate entity, whereas in these instructions and in the description of the API for reporting data on loan contracts, it is included in basic loan information. In the act, the end of a loan and the transfer of a loan are included in basic loan information, whereas in the reporting solution, i.e. in the APIs, they form a separate entity.

In addition to the basic information common to all loans, the data content defined specifically for each loan type is reported. The loan types of the Positive credit register are:

• lump-sum loan
• running-account loan
• guarantee receivable for a student loan
• leasing.

7.1 Information on the notifier must be included in the batch data

One batch may contain one or more reports. However, a batch may include only reports submitted through a single API, e.g. only data on new loans or only data on payment transactions.

The identifier of the business required to submit reports must be indicated in all the batch data submitted through the API services. For Finnish businesses, the identifier is always the Business ID. Foreign businesses that do not have a Finnish Business ID must report their foreign business ID and country code. The business’s official name does not need to be reported, because the register obtains the information from the Business Information System (BIS) based on the Business ID. Where foreign businesses are concerned, the register receives their names as they sign up as notifiers of loan contract data.

7.2 Data to be reported on new loans

Data on new loans is reported by using the New loans API. Loans transferred from another lender are also reported to the register through the New loans API. The reassignee reports the original loan data if it can be reported with reasonable efforts.

7.2.1 Basic loan information

The following data must be reported on all new loans:

Loan number and type of loan number
A loan number identifying the loan must be unique to the lender: two loans from the same lender cannot have the same loan number. The lender cannot assign a loan number they have used previously to a new loan if they have reported the previous loan as terminated less than 30 months earlier. The type of loan number may be an account number in IBAN or BBAN format or another loan number. A loan number of the selected type is also reported. If the loan number changes during the life cycle of the loan, the new number must be reported to the register. The reporting of changes to loan contract information is discussed in section 7.3 of these instructions.

Lender as a peer-to-peer loan broker
A peer-to-peer loan broker is a business that brokers loans granted to consumers by other consumers. In the case of a peer-to-peer loan brokered by a peer-to-peer loan broker, the value to be reported in this data field is ‘true’; otherwise, it is ‘false’.

Lender’s name for marketing purposes
The lender's marketing or auxiliary business name by which the lender has marketed the loan to the consumer. The name entered here, as well as the lender’s official name, will be displayed to private individuals in the Positive credit register’s e-service. If a separate marketing name or auxiliary business name has not been used, the lender enters its official name in this field.

Number of debtors
The lender reports the number of debtors liable for the loan. The number may not be smaller than 1. Only data on individuals who have a Finnish personal identity code is reported to the register. If a co-debtor has no Finnish personal identity code, their information is not reported to the register. However, the co-debtor in question is included in the quantity of co-debtors.

Date of contract conclusion
The date of contract conclusion reported to the register by the lender is the date on which a contract binding to the lender and the borrower was established. 

Currency code
When reporting a loan, the lender uses a 3-letter currency code according to ISO 4217. For example, EUR, USD, SEK.

One-time service fees payable when a loan contract is concluded
The lender reports any loan expenses paid by the borrower that arise from establishing a loan contract. The expenses are reported as a total amount in the same currency as the loan, and the reasons for the expenses are not specified.

One-time service fees relating to the establishment of the loan are reported to the register if they are included in the calculation of the effective annual interest rate according to chapter 7, section 6 of the Consumer Protection Act. Such loan expenses reported as one-time service fees include the expenses and other charges that the lender knows will be collected from the consumer on account of the loan relationship. Examples:

• expenses and fees charged for a loan application and conclusion of a loan contract
• fees charged for the use of a payment instrument
• fees payable to a loan broker when a loan contract is made or a credit opened
  • arrangement fees
  • service fees
  • commissions on credit
• separate charges for repayment of capital, such as additional charges for expedited processing or withdrawal.

It is also possible to collect charges and loan expenses from the borrower throughout the life cycle of the loan. If loan expenses are paid in connection with monthly repayments, for example, or otherwise in instalments, they are reported as payment transactions. See section 7.4 of these instructions.

Not all charges paid by the borrower are loan expenses that need to be reported to the Positive credit register. For example, the following charges are not reported as loan expenses:

• Account management fees for a loan management account if opening such an account is not required and if the fees are specified in the loan contract or another agreement entered into with the consumer. However, if the account management fees relate to a consumer credit relating to residential property under chapter 7a of the Consumer Protection Act, the account management fees must be reported to the register.
• Charges for breach of contract.

Loan type
One of the following must be selected as the loan type:

• running-account loan
• lump-sum loan
• guarantee receivable for a student loan
• leasing.

Running-account loan
A running-account loan is a consumer credit that is continuously available to the borrower up to a pre-defined credit limit based on a single loan decision. When the borrower makes a payment to amortize the loan they have withdrawn, the amount of available credit increases correspondingly. Running-account loans include credit cards, and accounts with credit facilities.

Data on a valid running-account loan contract is reported to the Positive credit register even if the borrower does not actively use the loan or if the borrower always repays the amount drawn by the due date.

Lump-sum loan
A lump-sum loan is a consumer credit that is not a running-account loan. Lump-sum loans include, for example, home loans and student loans.

Guarantee receivable for a student loan
Loan type ‘guarantee receivable for a student loan’ can be reported only by Kela. The data content of a guarantee receivable for a student loan is the same as that of a lump-sum loan, apart from a few separately defined exceptions.

Leasing
Lease contracts and other contracts under chapter 7 of the Consumer Protection Act must be reported to the Positive credit register if goods are transferred to a consumer’s control on the basis of the contract and if according to the terms and conditions of the contract the cash price and loan expenses of the goods are paid during the lease period or the consumer can otherwise become the owner of the goods at the end of the contract. The lender reports such contracts to the Positive credit register as leasing contracts .

Leasing contracts that involve only renting and whose terms and conditions stipulate that the ownership of the goods cannot transfer to the consumer are not reported to the register.

Loan with collateral
The lender must indicate whether collateral is agreed on in the loan contract (‘true’ or ‘false’). If the loan type is leasing, this data element is not reported.

Type of collateral
If collateral is agreed on in the loan contract, the lender selects the type of collateral from the following code values:

• residential property
• other immovable property
• hire-purchased item
• other moveable property
• other collateral
• personal guarantee
• government guarantee
• other guarantee.

If the loan has several types of collateral, the type of each collateral must be reported separately. For example, if the collateral provided for a loan includes two apartments and movable property, collateral types ‘residential property’ and ‘other movable property’ are reported. However, if the loan has several personal guarantors, collateral type ‘personal guarantee’ must be reported in accordance with the number of individuals. In addition, the Finnish personal identity code of each guarantor must be provided.

‘Residential property’ means residential property as referred to in chapter 7a, section 3, subsection 1, paragraph 1 of the Consumer Protection Act. The lender reports the type of collateral to be ‘residential property’ if the collateral is residential real estate, interest in a corporation conferring the right of possession to a residential apartment, or a residential building located in an area whose control is based on a right of use concerning a property, such as a right of tenancy. It is irrelevant whether the property or the apartment is intended for permanent use or for leisure use. The type of collateral is also ‘residential property’ if the collateral is a dwelling for investment purposes, a right-of-occupancy dwelling or part-ownership dwelling.

The type of collateral is ‘other immovable property’ if the collateral is, for example, a field, forest or non-residential real estate.

The type of collateral is ‘hire-purchased item’ if the collateral is a commodity under a contract, such as a vehicle.

The type of collateral is ‘other movable property’ if the collateral is movable property that is not residential property or a hire-purchased item. Examples of such property include various securities, such as shares other than those conferring the right of possession to a residential apartment, and art of high value and precious metals.

The type of collateral is ‘other collateral’ if the collateral is property that does not fit in any of the categories described above. Examples of such property are business mortgage or credit insurance.

If the type of collateral is personal guarantee, the lender must also state the guarantor’s personal identity code. If there are several guarantors, all their personal identity codes must be given. If a guarantor does not have a Finnish personal identity code, the lender must select ‘other guarantee’ as the type of collateral.

The type of collateral is ‘government guarantee’ if the collateral is a government guarantee.

The type of collateral is ‘other guarantee’ if the loan is guaranteed by a foreign individual or has a guarantee other than a personal guarantee or a government guarantee. Examples of such collateral include commercial guarantees and guarantees granted by parishes, municipalities or other organisations. Also, if the guarantee is provided by the Provincial Government of Åland, the type of guarantee is ‘other guarantee’.

The euro-denominated value of the collateral, the valuation date or the proportions of different types of collaterals in the total collateral are not reported.

Loan transferred from another lender
The lender reports ‘true’ if the loan has been transferred to it from another lender. More information on the transfer of loans is given in section 7.6 of these instructions.

Borrower’s identifier
The lender reports the borrower's Finnish personal identity code. If a loan has several co-debtors, the personal identity codes of all co-debtors are reported as borrowers. If the borrower's personal identity code changes, the reporting continues normally with the new personal identity code. The information on the change is received from the Population Information System, so the lender does not need to report it separately as a change to loan information.

Loan issued to the borrower is included in a payment plan in a debt arrangement
If the borrower has a debt arrangement confirmed by a court of law and the loan to be reported is included in a payment plan in the debt arrangement, the lender reports ‘true’ in this field. Voluntary debt arrangements or any other debt arrangements provided by private parties, such as combination loans, are not debt arrangements as referred to here.

When a payment plan in a debt arrangement ends, the lender reports ‘false’ in this field. The payment plan ends when its duration ends. If the debt arrangement is ordered to lapse, the lender reports ‘false’.

On loans included in a payment plan in a debt arrangement, the lender reports only the information listed in section 7.2.1 of the instructions (excluding income data established during lending), changes to the information in question, and if the loan ends. This more limited information is reported if the loan is included in a payment plan in a debt arrangement for even one debtor. In other words, if the loan has two debtors and only one of them is in a debt arrangement, only the more limited loan information is reported for both debtors, including the one who is not in a debt arrangement. If the debt arrangement lapses, the lender must report the loan information that is currently valid. After this, the reporting of all loan information continues as usual.

A loan issued to the borrower is included in a business restructuring program
If a loan reported is included in a business restructuring program confirmed by a court of law, the lender reports ‘true’ in this field. If the business restructuring program is ordered to lapse, the lender reports ‘false’.

On loans included in a business restructuring program, the lender reports only the information listed in section 7.2.1 of the instructions (excluding income data established during lending), changes to the information in question, and if the loan ends. This more limited information is reported if the loan is included in a business restructuring program for even one debtor. In other words, if the loan has two debtors and only one of them is included in a business restructuring program, only the more limited loan information is reported for both debtors, including the one who is not in business restructuring. If the debt arrangement lapses, the lender must report the loan information that is currently valid. After this, the reporting of all loan information continues as usual.

Income data established during lending
The lender reports the borrower’s income data established for purposes of creditworthiness assessment, i.e. information that the lender has received by asking from the borrower or in another way. The income is reported as monthly income and separated into gross income and net income. In the case of several co-debtors, income is reported separately for each borrower (debtor). The income data is always reported in euros. If only gross income or only net income is established for purposes of creditworthiness assessment, the lender reports only that information.

Loan as referred to in the Consumer Protection Act
The lender reports whether a loan is a consumer credit within the scope of chapter 7 of the Consumer Protection Act, a consumer credit related to residential property within the scope of chapter 7a of the Consumer Protection Act, or other than a consumer credit.

‘Consumer credit within the scope of chapter 7 of the Consumer Protection Act’ means a loan which the lender grants to a consumer and on which interest or other charges are collected. Such loans include student loans, investment loans, credit cards, hire-purchase transactions and various consumption loans. Loans comparable to consumer credits, such as peer-to-peer loans and rental and other contracts (leasing contracts), are also reported as falling within the scope of chapter 7.

‘Loan related to residential property within the scope of chapter 7a of the Consumer Protection Act’ means loans granted for acquiring residential property and loans for which residential property has been lodged as collateral. Such loans include, for example, home loans, loans for the purchase of investment apartments, and renovation loans. This information is reported only on loans granted after the entry into force of chapter 7a of the Consumer Protection Act (1 January 2017).

‘Loan as referred to in the Consumer Protection Act’ is technically required data only if the loan was granted on or after 1 February 2024. If the lender reports a loan that was granted before that date, the report is not rejected even if the data element is left blank.

In the Positive credit register, other than consumer credits mean guarantee receivables for student loans or loans that have been granted to natural persons for business activities. Loans granted for business activities are not reported in the first stage of the register rollout.

Goods or services related credit
In the case of a consumer credit, the lender must indicate if the loan is a goods or services related credit. A goods or services related credit is a consumer credit that a seller, a service provider or a business acting on their behalf has granted for the acquisition of a consumer commodity.

Where a goods or services related credit is concerned, the borrower does usually not have the right to withdraw cash or determine how the credit is used: the credit is to be used for the purchase of a consumer commodity. Credit cards are also reported to the Positive credit register as goods or services related credit. Cash, home loans or student loans are not reported as goods or services related credit.

Information whether the loan is a goods or services related credit is a technically required data element only if the loan was granted on or after 1 February 2024 and if the loan falls within the scope of chapter 7 or 7a of the Consumer Protection Act.

7.2.2 Data reported on lump-sum loans

In addition to the basic data listed in section 7.2.1 above, the following data must be reported on lump-sum loans.

Loan’s purpose of use
The purpose of use of a lump-sum loan is reported according to the main purpose for which the loan was granted. One of the following must be selected as the purpose of use of the lump-sum loan:

• home loan
• home loan for first home
• home loan for leisure house
• home loan for investment purposes
• student loan
• consumer credit for the purchase of a vehicle or craft
• other consumer credit
• other credit (not available in the first rollout stage)
• loan for operation of business (not available in the first rollout stage)
• guarantee receivable for a student loan.

Home loan
‘Home loan’ means a loan for acquiring residential property or retaining the right of ownership. ‘Residential property’ means residential real estate, interests in a corporation conferring the right of possession to a residential apartment, and a residential building located in an area whose control is based on a right of use concerning a property.

The retention of the right of ownership refers, for example, to a situation where in the case of distribution of matrimonial assets the party that owns the apartment takes out a loan to retain their right of ownership to the apartment. A loan taken out for paying a housing company loan may also be a home loan.

If a home loan has been taken out for the purchase of a first home, a leisure house or a home for investment purposes, the lender selects the appropriate purpose of use for the loan. Otherwise, the purpose of use is ‘home loan’.

A renovation loan that needs to be taken into account in the calculation of the maximum loan-to-value ratio is reported to the register as a home loan (chapter 15, section 11, subsection 1 of the Act on Credit Institutions 610/2014). Such loans include renovation loans where the home is used as collateral. The purpose of use for other renovation loans is ‘other consumer credit’. The purpose of use of a renovation loan with the home as collateral is ‘home loan’, ‘home loan for first home’, ‘home loan for leisure house’ or ‘home loan for investment purposes’ according to the type of residential property for which the loan was taken out.

Student loan
‘Student loan’ refers to a credit granted to a private individual for studies or, for example, for study trips. These student loans include loans where the collateral is a government guarantee under the act on financial aid for students (Opintotukilaki 65/1994) or a student loan guarantee granted by the Provincial Government of Åland. Student loans granted to minors are also reported to the Positive credit register.

Consumer credit for the purchase of a vehicle or craft
A vehicle or craft refers to a means of transport registered in the Transport Register under the Act on Transport Services (320/2017), and to any accessories associated with it. The lender reports this purpose of use if it grants the consumer a credit for buying a car or a boat, for example.

Other consumer credit
This purpose of use covers consumer credits that are not home loans, student loans, consumer credits for the purchase of a vehicle or craft, or guarantee receivables for a student loan. The purpose of consumption loans, for example, is ‘other consumer credit’.

Other loan, and loan for operation of business
These purposes of use are not available in the first stage of the register rollout.

Guarantee receivable for a student loan
Only Kela can submit reports where the purpose of use is ‘guarantee receivable for a student loan’.

Final due date according to the payment plan
The lender indicates the final due date of the payment plan agreed on in the loan contract, if the date is known. If the payment plan is changed during the loan repayment period because the borrower pays extra amortizations, for example, and the final due date changes, the lender updates the information to the register through the Changes to loan contract information API. However, if the loan has been accelerated, the last due date of a payment plan agreed on in loan recovery is not reported. More information on changes to reported data is provided in section 7.3 of these instructions.

Payment method
The lender reports one of the following payment methods for a lump-sum loan:

• fixed-size amortizations
• fixed-size payments
• annuity
• balloon
• bullet
• other.

Fixed-size amortizations is a payment method in which the loan is always amortized with equal amounts and interest is added to the instalments.

Fixed-size payments refers to a payment method in which the sum of the interest and amortization remains the same for the entire loan period. At the beginning, the proportion of interest is higher. The proportion of interest decreases as the loan principal decreases. If the interest rate goes up, the loan period is extended.

The payment method is reported to be ‘annuity’, if changes in the interest rate affect the instalment amounts rather than the loan period. In other words, an increase in the interest rate does not extend the loan period.

The payment method ‘balloon’ is reported if the last instalment of the loan is much bigger than the other instalments.

If the loan principal is repaid in one instalment, the payment method is ‘bullet’.

If the payment method has not been agreed on because the loan is in collection, for example, the payment method is ‘other’.

Amortization frequency
If the payment method is other than ‘bullet’ or ‘other’, the lender reports the amortization frequency agreed on with the borrower in months. For example, if a loan is amortized every month, the value reported is 1, and if it is amortized every other month, the value is 2.

Amount issued
The lender reports the total loan principal issued to the borrower in the loan currency. If the amount issued is updated, the lender must submit the updated amount to the register as a change to loan contract information. The lender always reports the cumulative amount.

Amount drawn
The lender reports the amount drawn by the borrower in the loan currency. If the loan is drawn in several instalments, the lender updates the information when a new instalment is drawn. The lender reports the cumulative amount, i.e. the total amount drawn, as the amount drawn. The information is updated by reporting a change to loan contract information. If the borrower does not draw an amount when the loan contract is concluded, the lender submits a report on a new loan stating that the amount drawn is 0. When the borrower draws the loan in part or in full, the lender updates the amount.

Loan balance
The lender reports the remaining amount of loan principal. The lender always updates the loan balance when reporting payment transactions for the loan. More detailed instructions on how to report payment transactions are presented in section 7.4.

7.2.3 Data reported on running-account loans

In addition to the basic data listed in section 7.2.1 above, the following data must also be reported on running-account loans.

Credit limit
The lender reports the credit limit agreed on for a running-account loan in the loan currency.

Amount of loan balance
The amount of loan balance refers to the entire amount drawn by the borrower, regardless of whether interest or expenses are collected. The amount of loan balance is the unpaid amount of debt.

The lender reports the amount of loan balance for the running-account loan according to the situation on the calendar day following the monthly due date or, if there is no monthly due date, on the last calendar day of the month. If the monthly due date for the running-account loan is, for example, the 15th day of the month, the amount of loan balance to be reported is the balance on the 16th of the month.

If the borrower draws an amount of the running-account loan when the loan contract is concluded, the lender reports the amount of loan balance in the report on a new loan. If the borrower does not draw the running-account loan until later, the amount initially reported to the register is 0.

Value date for the amount of loan balance
The lender reports the date when the amount of loan balance was checked.

7.2.4 Interest information

In addition to the basic loan data and data on lump-sum and running-account loans listed above, interest information must also be reported on lump-sum loans and running-account loans. Kela does not report interest information on guarantee receivables for student loans.

Only expenses that are included in the calculation of the effective annual interest rate are reported to the Positive credit register. Expenses resulting from a breach of contract, such as late-payment interest, are not included in the reportable expenses.

Total interest rate
The lender reports the total effective interest collected from the borrower as percentage. For example, if a 1% margin is collected on a loan, plus the bank’s reference rate, which on the date of loan contract is 1%, the lender reports 2% as the total interest rate. If the loan is interest-free, the lender reports that ‘Total interest’ is 0.

If the borrower can select different payment options with different interest rates, i.e. the agreed interest rate may vary, the maximum amount of interest that may be payable on the basis of a loan contract will be reported.

If only late-payment interest is collected after the loan has been accelerated, total interest will not be reported on the loan. This is done by leaving out Total interest from the report.

Margin interest
The lender reports the margin interest agreed on for the loan as percentage. The margin interest is the part of the interest rate that the lender specifies for the customer in the loan contract, for example.

Interest type
The lender reports one of the following types of interest:

• Euribor rate
• reference rate determined by the bank
• other variable rate
• fixed interest
• interest-free.

The Euribor rate (Euro Interbank Offered Rate) is the rate generally used as a reference rate for loans and savings in the financial markets of the euro zone.

The bank's own reference rate refers to a reference rate that the bank or group of banks can decide to change. The bank's own reference rate is often called the primary interest rate.

The lender reports ‘other variable rate’ as the type of interest if the interest rate is other than the Euribor, the bank's own reference rate, or fixed interest.

Fixed interest refers to an interest rate that remains the same throughout the agreement period or for the duration of the loan.

The reported type of interest may be ‘interest-free’ only if no interest is collected on the loan according to the loan contract.

Period for interest determination
Required if the interest type is ‘Euribor rate’. The period is reported in months.

End date of the period for a fixed interest rate
If a fixed interest rate period is initially agreed on for the loan, the end date is reported here. When the period ends, the lender must report valid interest information on the loan. If the end date of the period for a fixed interest is in the past, it is not reported.

Type of linkage to a benchmark interest rate after the period for a fixed interest rate
If the loan period continues after the end of the fixed interest rate period, and if some other interest type has already been agreed on for that period, the other interest type is reported in this field. The interest types available are the Euribor rate, the bank's own reference rate and other variable rate.

Lower limit of the interest rate corridor
If an interest rate corridor has been agreed on for the loan, its lower limit is reported as percentage. The lender reports the lower and upper limits of the interest rate corridor if both the lower limit and the upper limit have been agreed on for the interest charged on the loan.

Upper limit of the interest rate corridor
If an interest rate corridor has been agreed on for the loan, its upper limit is reported as percentage.

Interest rate cap
If an interest rate cap has been agreed on for the loan, it is reported as percentage. The lender reports the interest rate cap if only the upper limit has been agreed on for the interest charged on the loan.

End date of interest rate restriction
If an interest rate restriction has been set for the loan, the lender reports the end date of the interest rate corridor or the interest rate cap. If the interest rate restriction does not end before the loan ends, the final due date according to the payment plan is reported here.

Effective interest rate on the date of contract
The lender reports the effective annual interest rate on the date of loan contract as percentage. In the Positive credit register, ‘effective annual interest rate’ means the effective annual interest calculated in accordance with the Consumer Protection Act and specified for the borrower in the loan contract.

If the borrower can select different payment options with different interest rates, i.e. the agreed interest rate may vary, the maximum amount of interest that may be payable on the basis of a loan contract will be reported.

7.2.5 Deferment of amortizations

In addition to the basic loan data and data on lump-sum and running-account loans listed above, data on any agreed deferments of amortizations must also be reported on lump-sum loans and running-account loans.

If a deferment of amortizations is a basic component of the loan contract and under the borrower’s control and if no separate agreement is made on it, it is not reported to the register. Only separately agreed deferments of amortizations and their start and end dates are reported to the register.

Several deferments of amortizations can be reported for a loan. When a new deferment of amortizations is agreed on for a loan, the lender reports all current and future deferments of amortizations for the loan in question.

Due to the API’s technical limitations, no more than 64 separate deferment periods can be reported for a loan in one go. A lender needing to report more than 64 deferments of amortizations in one go should contact the Positive credit register's customer service.

If a deferment of amortizations is agreed on when the loan contract is concluded, data on the deferment can be reported at the same time as other data on the new loan contract. Otherwise, data on the deferment of amortizations must be reported as changes to loan contract information no later than on the second business day following the date of agreement on the deferment period. More detailed instructions on how to report changes to loan contract information are presented in section 7.3.

Example: On 1 September 2024, the lender and the borrower agree on a new deferment of amortizations, which will begin on 1 December and end on 31 December 2024. The borrower has previously agreed on a deferment of amortizations for 1 March to 31 March 2025. The lender submits the new deferment of amortizations to the register by 3 September 2024, reporting two deferments of amortizations for the loan: 1 to 31 December 2024, and 1 to 31 March December 2025.

7.2.6 Data reported on leasing

The basic loan data listed in section 7.2.1 is reported on leasing contracts, with the exception of the information on collateral. In addition, the following information must be reported on leasing contracts.

Start date of contract period
The lender reports the start date of the leasing contract, which may also be the same as the date of contract conclusion. The start date of the contract period is the date that the lender and the borrower agree to be the start date of the contract period. If the start date has not been agreed on, the start date of the contract period is the date when the contractual rights and obligations of the lender and the borrower become effective.

Monthly instalment
The lender reports the monthly instalments of the leasing contract in the loan currency. The lender reports the entire amount collected from the borrower on a monthly basis, i.e. the principal, interest and expenses.

Interest included in the instalment
The lender reports the amount of interest included in the monthly instalment in the currency of the leasing contract.

Other expenses included in the instalment
The lender reports the other expenses included in the monthly instalment. The other expenses include, for example, expenses paid for supplementary services falling within the scope of the leasing contract. Interest is not included in the amount.

Transaction price
If the leasing contract requires that the borrower should purchase the leased item at the end of the contract period, the lender reports the agreed transaction price in the currency of the contract. If the borrower has the option of redeeming the leased item but is not obliged to do so, the transaction price is not reported.

7.3 Reporting changes to loan contract information

The Changes to loan contract information API is used to report changes made after the lender reported a new loan to the register. Changing the loan information is not the same as correcting an error in the loan information. More information on how to correct errors is presented in section 9.2 of these instructions.

The lender must report changes to any information on new loans listed in section 7.2. Exceptions include changes in the loan balance and total interest rate, which can also be reported by using the Payment transactions API. For more detailed instructions, see section 7.4 below. Other exceptions include the date of conclusion and changes to the borrower's personal identity code: The date of conclusion should not be changed but the original date of conclusion should be reported to the register. Similarly, changes to the borrower's personal identity code do not need to be reported to the register separately, because the data is updated automatically from the Population Information System.

When loan information changes, the lender must report any previously submitted data that does not change in addition to the changed data. This means that when loan contract information changes, the lender cannot report only changed data: the report must be complete, containing all the data. Exceptions include certain information related to the time when the loan was granted: income data established during lending, one-time service fees payable when the loan contract is concluded, and the actual annual interest rate on the date of conclusion. The lender can report that these details have not changed, in which case they do not need to be entered in the report.

If new debtors are added to the loan, the lender must also submit the loan's up-to-date balance in the ‘Changes to loan information’ report.

If the loan number changes, the old loan number is reported in addition to the new loan number.

The lender reports all changes to individual items made during the day. If several changes are made to the same loan item within a 24-hour period, the lender can report the data valid at the end of the day. For example, if the credit limit of the borrower's running-account loan is changed more than once in a 24-hour period, the lender can submit a report on changes to loan contract information where the credit limit is indicated as it is at the end of the day.

Changes to loan data are reported through the Changes to loan contract information API. The report type to be used is ‘new report’.

The reportable changes to loan contract information include:

• a change to the payment plan: for example, the final due date of the payment plan changes
• a change to the credit limit
• income data established during lending if the borrower’s creditworthiness is re-assessed
• a change to collateral: for example, collateral is released and, as a result, the loan no longer has collateral
• a new deferment of amortizations: the lender and the borrower agree on a new deferment of amortizations after the conclusion of the loan contract at any stage of the loan life cycle
• a change to the number of debtors: for example, only one debtor remains, in which case the personal identity code of only this individual is reported in the borrower information
• changes to interest: for example, the interest information that is valid when the fixed interest rate period ends.

The lender must report to the register if a loan is transferred to a payment plan in a debt arrangement or a business restructuring program confirmed by a court of law. Payment transactions, delayed amounts or information about acceleration is not reported on loans included in a debt arrangement or a business restructuring program. If delayed amounts or acceleration has been reported for the loan, the data does not need to be deleted separately when the loan is reported to be included in a debt arrangement or a business restructuring program. The only changes that need to be reported on loans included in a debt arrangement or a business restructuring program are changes to the basic loan data listed in section 7.2.1, changes to collateral information, and the end of a loan contract. If an error is detected in the data on a loan included in a debt arrangement or a business restructuring program, the notifier is obligated to correct it.

If the debt arrangement or business restructuring program lapses, the lender must report it to the register. In this situation, the lender must check that all loan information (basic information, delayed amounts and payment transactions) is up to date and, if necessary, update the information to match the current situation. After this, the reporting of all loan information continues as usual. When the duration of a payment plan in a debt arrangement ends, the lender reports ‘false’ at The loan is included in a payment plan in a debt arrangement.

7.4 Data reported on payment transactions

The payment transactions reported to the register include amortizations of lump-sum loans, and other payment transactions related to lump-sum loans and running-account loans. Other payment transactions include the payment of loan-related expenses or interest. The amount of loan balance is reported on running-account loans on a monthly basis. No payment transactions are reported on leasing contracts. The payment transactions are reported through the Payment transactions API.

If the borrower has incorrectly made a payment that is not a repayment of the loan principal and not allocated to interest or expenses, the incorrect payment or refunding of the payment to the borrower is not reported to the register. If, however, the incorrectly made payment has been reported to the register, the data must be corrected. More information on how to correct payment transaction data is presented in section 9.2.2 of these instructions.

If several payment transactions relating to the same loan are made during a 24-hour period, the lender can add them together and submit a single report containing the sum of all the payment transactions of the day. For example, if the borrower pays €100 in the morning and another €100 later during the day, the lender can submit a single report at the end of the day, indicating €200 as the amount repaid.

The following information is reported on payment transactions of both lump-sum loans and running-account loans.

Loan number and type of loan number
A unique identifier assigned to the loan in the lender’s system. The type of loan number may be an account number in IBAN or BBAN format or another loan number. The loan number is reported according to the type selected.

Loan type
The lender reports whether the loan is a lump-sum loan, a running-account loan or a guarantee receivable for a student loan. If the loan type is ‘leasing’, payment transactions are not reported.

7.4.1 Payment transactions of a lump-sum loan

In addition, the following information must be reported on payment transactions of lump-sum loans.

Total interest rate
The lender reports the total interest on the loan as percentage. Kela does not report total interest on guarantee receivables for student loans. If the lender reports the total interest rate in connection with a payment transaction, the amount to be reported is the total interest rate on the date the payment is made.

If only late-payment interest is collected after the loan has been accelerated, total interest will not be reported on the loan. The late-payment interest rate is irrelevant, i.e. late-payment interest is not reported, not even if it is equivalent to the original interest on the loan. In other words, the ‘Total interest’ field must be omitted from the report.

Amortization paid
The lender reports an amortization of the loan principal in the loan currency.

Interest paid
The lender reports the interest included in the payment transaction in the loan currency. Late-payment interest is not reported.

Other loan expenses paid
The lender reports any other loan expenses paid by the borrower. Interest is also a loan expense, but it is reported separately from other expenses. The total amount of other loan expenses paid is reported in the loan currency. In other words, the expenses are not itemised in the report.

Loan expenses that are included in the calculation of the effective annual interest rate (chapter 7, section 6 and chapter 7a, section 3, subsection 2 of the Consumer Protection Act) are reported to the register. Such loan expenses include the expenses known to the lender and other charges collected from the consumer on account of the loan relationship. The loan expenses also include expenses for an insurance policy or other additional service related to the loan contract if the conclusion of a contract on the additional service is required in order that the borrower could obtain the loan on the terms and conditions on which it was marketed to them. For example, the loan could be available only on weaker conditions without the additional service or it could be completely unavailable without the additional service.

Other loan expenses paid include, for example, the following:

• expenses related to loan withdrawal, regardless of how or how often the consumer draws loan amounts
• separate charges for the processing of a loan application or the repayment of capital, i.e. additional charges for expedited processing or withdrawal
• expenses for the lender’s guarantee service and the associated text message service subject to a separate charge if the borrower must use the service in order that they could obtain the loan on the terms and conditions on which it was marketed to them. In general, loan expenses include all service fees related to the loan relationship, and it is not significant, for example, whether the lender distributes part of the expenses to third parties.

Expenses may arise at any stage of the loan life cycle. The lender reports the expenses collected in conjunction with establishing the loan when submitting a report on a new loan (see section 7.2.1 of these instructions). Other expenses are reported to the register through the Payment transactions API whenever the borrower pays them.

Not all charges paid by the borrower are loan expenses that need to be reported to the Positive credit register. For example, the following charges are not reported as loan expenses:

• Account management fees for a loan management account if opening such an account is not required and if the fees are specified in the loan contract or another agreement entered into with the consumer. However, if the account management fees relate to a consumer credit relating to residential property under chapter 7a of the Consumer Protection Act, they must be reported to the register.
• Charges for breach of contract.

Date of payment
The lender reports the date of payment, i.e. the date on which the borrower made the payment.

Loan balance
The lender reports the remaining loan principal in the loan currency. The loan balance must always be reported, even if the payment transaction does not contain an amortization but only interest or other expenses.

7.4.2 Payment transaction for a running-account loan

The payment transactions for a running-account loan reportable by the lender include the amount of loan balance, the interest paid and the other loan expenses paid. The amount of loan balance is reported once a month. If the interest and other loan expenses were paid on the same due date, they can be reported in the same report. If the monthly due date (amount of loan balance) and the due date for the interest and expenses are different, the lender reports the data separately.

If the borrower repays the running-account loan in such a manner that the repayment is fully attributable to the loan principal and does not include any expenses or interest, the lender does not submit a report to the register.

Total interest rate
The lender reports the total interest on the loan as percentage. 

If only late-payment interest is collected after the loan has been accelerated, total interest will not be reported on the loan. The late-payment interest rate is irrelevant, i.e. late-payment interest is not reported, not even if it is equivalent to the original interest on the loan. In other words, the ‘Total interest’ field must be omitted from the report.

Amount of loan balance
The lender reports the amount of loan balance as it is on the calendar day following the monthly due date. The amount of loan balance refers to the amount that the borrower has drawn, including both the interest-bearing and the interest-free balance. If a monthly due date has not been separately agreed on, the amount of loan balance is reported as it is on the last calendar day of the month.

If the borrower exceeds the credit limit, this is not reported to the register separately, but the amount exceeding the limit is included in the amount of loan balance. If, on the other hand, the borrower makes a repayment that is more than the amount of loan they have drawn, the lender reports the amount of loan balance to be 0.

If a running-account loan has been accelerated and only the remaining part of the debt is being collected, the lender reports the remaining debt as the month-to-month amount of loan balance.

Value date for the amount of loan balance
The lender reports the date when the reported amount of loan balance was checked.

Interest paid
The lender reports the paid amount of interest in the loan currency. Late-payment interest is not reported.

Other loan expenses paid
Other loan expenses paid are reported on running-account loans on the same principle as on lump-sum loans. Read ‘Other loan expenses paid’ in section 7.4.1 of the instructions.

Date of payment
The lender reports the payment date of the payment transaction.

7.5 Information to be reported on delayed amounts and loan acceleration

The lender reports certain delayed amounts to the Positive credit register, as well as information that the loan has been accelerated.

7.5.1 Delayed amounts

If a payment transaction for a loan is 60 days late from the original due date, the lender reports it to the register as a delayed amount for the loan in question. If more than one amount relating to the same loan is 60 days late, they are all submitted in the same report. The lender removes a delayed amount from the register after the borrower has paid off the instalment in full. Delayed amounts are also reported on leasing contracts.

Example: The borrower fails to pay an instalment of €200 due on 31 July 2024. The instalment will be 60 days late on 29 September 2024. The lender reports the delayed amount to the register by 1 October 2024. The borrower also fails to pay the next €200 instalment of the loan, due on 31 August 2024. This instalment will be 60 days late on 30 October 2024. The lender must report both the delayed amounts to the register by 1 November 2024.

In the example, the lender must report the following data on the first delayed amount to the register by 1 October 2024:

• The unpaid instalment of €200, and the original due date of the delayed instalment, i.e. 31 July 2024

In the example, the lender must report the following data on both the delayed amounts to the register by 1 November 2024:

• The unpaid instalment of €200, and the original due date of the delayed instalment, i.e. 31 July 2024
• The unpaid instalment of €200, and the original due date of the instalment, i.e. 31 August 2024

If the borrower pays part of a delayed amount reported to the register, the lender updates the information by submitting a new report on delayed amounts. The lender must also report a separate payment transaction for the loan. On a payment transaction report, the lender reports the payment transaction data (see section 7.4 of these instructions) and updates the loan balance, for example. The register will not change the loan balance on the basis of a change reported to a delayed amount. 

For example, if the borrower pays €100 of the first delayed instalment in the above situation, the lender must report the following information to the register no later than on the second business day following the change:

• The unpaid instalment of €100, and the original due date of the delayed instalment, 31 July 2024
• The unpaid instalment of €200, and the original due date of the instalment, i.e. 31 August 2024

If the lender and the borrower agree on a new payment plan for the payment of a delayed amount, the lender removes the delayed amount from the register. If the instalments according to the new payment plan are delayed, they are reported to the register in the same way as delayed amounts under the original payment plan.

7.5.2 Accelerated loans

The lender reports to the register that the loan has been accelerated due to delayed payments, i.e. the entire loan has fallen due for payment in accordance with the loan contract. Acceleration of a leasing contract must also be reported if the reason for acceleration is delayed payments. When reporting a loan as accelerated, the lender must also remove any delayed amounts reported to the register. If a loan has been accelerated, delayed amounts related to the loan are no longer reported to the register.

Payment transactions related to the accelerated loan are reported as usual. Also, changes other than those resulting from payment transactions are reported normally.

In addition, the lender reports up-to-date information regarding the accelerated loan. The information is reported through the Changes to loans API. For example, if a payment plan according to the loan contract on a lump-sum loan is no longer complied with, the payment method to be reported for the accelerated lump-sum loan is ‘other’. In addition, the amortization frequency and final due date of the payment plan will be omitted. If only late-payment interest is collected on the loan after acceleration, the type of interest is to be reported is ‘other variable rate’. In this case, you must also submit the margin interest rate, which can be stated to be zero.

If an accelerated loan is reported to have been transferred from another lender and if only late-payment interest is collected on it, the interest type can be left out from the report.

The late-payment interest collected on the accelerated loan is not reported to the register. If only late-payment interest is collected on the loan, the lender removes the total interest rate from the loan information. The information is removed by reporting all other loan information except Total interest rate through the Changes to loans API. The total interest rate cannot be removed from the loan information through the Payment transactions API.

When a leasing contract is reported as accelerated, the lender does not need to change any other contract data already reported on the leasing contract, such as the monthly instalment amount. The information on the monthly instalment of the leasing contract and any final transaction price reported to the register are left unchanged so that the information in the register shows what the situation was prior to the acceleration.

If the lender accelerates the loan before an individual instalment is 60 days late, the delayed amounts are not reported to the register. In this case, the lender directly reports the acceleration of the loan to the register.

7.5.3 Data to be reported in the API

The following information is reported on the delayed amounts and acceleration through the Delayed amounts API:

Loan number and type of loan number
A unique identifier assigned to the loan in the lender’s system. The type of loan number may be an account number in IBAN or BBAN format or another loan number. The loan number is reported according to the type selected.

Delayed amount
The lender reports ‘true’ if there is a delayed amount relating to the loan.

Unpaid amount of an instalment
The amount that fell due on the original due date is reported in this field. The lender updates the unpaid amount only if the borrower pays part of it. The amount is updated by submitting a new report on the delayed amount, so that the new information replaces the previously reported information.

Original due date of a delayed instalment
The original due date of a delayed instalment remains the same even if the borrower pays part of the instalment.

Loan has been accelerated
The lender reports ‘true’ if the loan has been accelerated, i.e. if the lender collects the full loan from the borrower as a single payment. However, the loan is not reported as accelerated if it is accelerated for a reason other than delayed amounts. In that case, the reporting continues as usual until the end of the loan contract.

When reporting a loan as accelerated, the lender must also remove any delayed amounts reported to the register. To remove delayed amounts from the register, the lender reports ‘Delayed amount: false’. If a loan has been accelerated, delayed amounts related to the loan are no longer reported to the register.

Date of acceleration
The lender reports the date on which the entire loan falls due for payment on account of delayed amounts.

7.6 Reporting the end and transfer of a loan

The lender reports to the register when a loan ends or is transferred to another business operator. The end and transfer of a loan are reported through the API for reporting the end of a loan.

A loan is reported as ended when the loan relationship between the lender and the borrower ends and the parties no longer have any obligations towards each other. Often a loan ends when the borrower repays it in full, but it can also end for other reasons. For example, if the lender accelerates the loan and terminates the contract, the loan is not reported as ended until after the borrower’s obligations towards the lender have ended. Similarly, if the loan principal has already been paid but collection costs or interest payments still remain, the loan cannot be reported as ended until all the liabilities have ended. Also, if collection is deferred but payments are still expected from the borrower, the loan cannot be reported as ended.

If the borrower dies, the loan is not reported as ended until it actually ends. If the loan does not end on account of the borrower's death, the lender can continue to report the loan information as usual until the loan ends. If the lender does not continue reporting data on the loan contract, the loan must always be reported as ended to the register.

Before reporting the loan as ended, the lender must submit a report on the loan's last payment transaction, if any, through the Payment transactions API. The lender must report the loan as ended by submitting a report on the end of the loan: the loan is not terminated in the register just because the loan balance is 0, for example. If for some reason the last payment transaction has been reported incorrectly or if the transaction is not known to relate to the loan until after the loan has been reported as ended, it is possible to report payment transactions or changes to the payment transactions for the loan for two years from the date when the loan is reported as ended.

The loan is also reported as ended if the borrower exercises their right under the Consumer Protection Act to cancel the contract within 14 days from the date of contract.

The loan is reported as transferred if the loan is transferred to another lender. Transfer refers to situations in which the lender's rights based on the loan contract are transferred to a new party. An example is a situation where the lender sells the loan to another lender or the loan is transferred within a group of companies in such a way that the legal person acting as the lender changes (different Business ID). Instead, if the loan is transferred to a collection agency for collection, the transfer of the loan is not reported but the reporting obligation remains with the same lender.

The reassignee reports the data on the transferred loan to the register in accordance with the data content of new loans (see section 7.2 of these instructions).

If the loan is transferred on the borrower’s initiative, the transfer is not reported to the register. Examples of such transfers are situations where the borrower changes banks, transfers their ASP loan to another bank or takes out a combination loan. In these cases, the previous lender reports the loan as ended and the lender that granted the new loan reports the information on the new loan to the register.

If the loan ends because the borrower is unable to pay the debt and it is therefore transferred to the guarantor for payment, the loan is reported as ended but not transferred. This is done, for example, when a student loan is transferred to Kela for recovery based on the State guarantee liability.

No reason is reported for the end of a loan. The lender reports the end of a loan and the transfer of a loan with the same data content, regardless of the reason.

The following information is reported on the end of a loan:

Loan number and type of loan number
A unique identifier assigned to the loan in the lender’s system. The type of loan number may be an account number in IBAN or BBAN format or another loan number. The loan number is reported according to the type selected.

Loan contract has terminated
When the loan has ended, the lender reports ‘true’.

End date
The lender reports the date on which the loan ended or was transferred to another business operator.

Loan transferred to another lender
If a loan is transferred to another lender, ‘true’ is reported.

In addition, the lender reports the following information on the reassignee:

Reassignee's identifier type and identifier
The lender reports the identifier type – a Business ID or a foreign business ID – and the actual identifier.

Reassignee's name
The lender reports the reassignee’s name if the identifier type is ‘foreign business ID’.

Reassignee's country code
The lender reports the country code if the identifier type is ‘foreign business ID’. The country code is reported as a 2-letter country code according to ISO 3166.

7.6.1 The end of a loan included in a payment plan in a debt arrangement

When the duration of a payment plan in a debt arrangement ends, the lender reports the loan to the register as ended if the loan has been paid in accordance with the payment plan during the debt arrangement. If the duration of the payment plan ends before the borrower has paid the confirmed debt included in the payment plan, the lender continues to report data on the loan until the debt has been paid off. However, the entry saying that the loan is included in a payment plan in a debt arrangement must be removed immediately as the duration of the payment plan ends, even if payments are still reported to the register. ​

If the loan has been paid in accordance with the payment plan during the duration of the plan, the lender also reports the loan as ended even though liability for additional payments may still be looked into.

After the payment plan has ended, if a court of law confirms the borrower’s liability for additional payments or if additional payments are agreed on with the borrower, the lender re-reports the loan to the register by submitting an Error correction report to cancel the end of the loan. This must be done within two years from the end date reported for the loan in a report saying that the loan has ended. If the loan is re-reported to the register more than two years later, it must be reported as a new loan but with the same loan number. When reporting the loan, the lender submits the loan data available to them. The loan balance to be reported is the confirmed or payable amount of the liability for additional payments. Payment transactions regarding such loans are reported normally, and the reporting of loan data continues until the debt has been paid off and the borrower has no further liability for the debt towards the lender.​

7.6.2 Transferred loan

The reassignee reports data on the transferred loan through the New loans API. The reassignee is required to submit reports, so it must report all loan data covered by the reporting obligation (the data listed in sections 7.2–7.5, depending on the loan type).

There are some exceptional rules for required/optional data in the reporting of a transferred loan. They are presented in the description of the API for reporting data on loan contracts. When a transferred loan is reported, certain information required for a new loan can be omitted without that the report is rejected. The information can be left unreported only if the lender cannot report it with reasonable efforts. For example, a loan may have been granted a long time ago and some information may therefore be missing.

If the type of the transferred loan is not known, the loan type to be reported is ‘lump-sum loan’.

8 Reporting time limits

The act on the Positive credit register lays down the time limits for reporting. New loans and changes to loan contract information have slightly different time limits.

8.1 New loans

Information on new loan contracts must be reported to the register no later than on the calendar day following the date of contract conclusion. If a loan contract is signed on a Friday, for example, the contract data must be reported to the register on Saturday at the latest.

8.1.1 Date of contract conclusion

The time limit for reporting a new loan starts when the loan contract is concluded. The date of contract conclusion is the date when a contract binding to the lender and the borrower is concluded.

8.2 Loan transactions and changes

After the conclusion of the contract, loan transactions and changes to loan contract information must be reported within two business days. Transactions and changes to be reported include the following:

• changes to loan contract information (e.g. a change to the payment plan, a change to the interest rate, deferments of amortizations, a change to the number of debtors; more information in section 7.3 of these instructions)
• payment transactions related to the loan (e.g. amortizations)
• delayed amounts
• acceleration of a loan
• the end of a loan and the transfer of a loan to a reassignee.

The lender submits a report within two business days from the date on which it obtained information on the payment transaction or another change. For example, information on an amortization of a lump-sum loan must be reported to the register no later than on the second business day following the date of payment. If the amortization is paid on Friday, the time limit for reporting expires on next Tuesday at 11.59 p.m. Midweek holidays are not regarded as business days.

If a loan is being recovered by enforcement, a payment made by the debtor must be reported no later than on the second business day after the lender has received the payment and information on what debt the payment relates to. The reassignee reports on the transferred loan within two business days from the date when the lender’s rights arising from the loan contract were transferred to it.

An exception to the reporting period of two business days is the reporting of total interest. The lender must report if the total interest on the loan changes due to a change in the Euribor rate, for example. This change must be reported at the latest when a new payment transaction or deferment of amortizations is reported for the loan in question.

8.3 Payment transactions for a running-account loan

The lender reports the amount of loan balance for a running-account loan once a month, giving the balance of the calendar day following the monthly due date. The report must be submitted even if the loan has not been drawn. If a monthly due date has not been agreed on, the amount of loan balance is reported as it is on the last calendar day of the month. If the due date of a running-account loan is the 15th day of the month, the amount of loan balance to be reported is the balance on the 16th of the month. The lender must submit the report by the end of the 18th day of the month. More detailed instructions on how to report payment transactions of a running-account loan are presented in section 7.2.3.

The lender reports the interest and expenses paid on the running-account loan no later than on the second business day after the day when the lender was informed of the payment transaction. If the monthly due date (amount of loan balance) and the due date for the interest and expenses are different, the lender reports the data separately.

8.4 Leasing contracts

There are no specific time limits for reporting leasing contracts. The lender reports information on a new leasing contract to the register no later than on the calendar day following the date of contract conclusion, and information on changes to the loan contract no later than on the second business day after the change. Delayed amounts are reported on leasing contracts in the same way as on other loans. Payment transactions are not reported on leasing contracts.

8.5 Delayed amounts and acceleration

The lender reports a loan-related delayed amount to the register if the payment is delayed by 60 days from the due date. Delayed amounts are reported within two business days of the date when 60 days have passed since the original due date of the instalment. If the original due date was 31 July 2024, the payment is 60 days late on 29 September 2024. The delay must be reported by 1 October 2024, 11.59 p.m.

The lender reports to the register if a loan is accelerated due to delayed amounts. Acceleration must be reported to the register within two business days of the date of acceleration. The date of acceleration refers to the date on which the loan actually falls due for payment.

8.6 Correcting incorrect data

The lender must correct any errors detected in the registered data without delay. Only the most recent, or valid data can be corrected. There is no separate deadline for error correction.

9 Checking and correcting submitted data

Parties that are required to submit reports are responsible for the accuracy of the data they report. The lender is obliged to see that the data they report is complete and to correct any incorrect or incomplete data without delay. The lender can check whether the reported data is correct, i.e. corresponds to the data in the lender's own system. Such a need may arise, for example, if the borrower requests that incorrect data in the register should be corrected or if the lender itself detects an error.

9.1 Checking data

Lenders can check the data they have reported by submitting a request relating to a specific loan number through the Checking loan data API. The response message will list the data registered on the loan in question.

The Checking loan data API is designed for spot checks and investigation of suspected errors, and it is not used for checking data on each loan granted by an individual lender, for example.

9.2 Correcting errors

Data is incorrect if, for example, the purpose of use reported for the loan is ‘home loan’, even though the loan is actually a student loan. Data is incomplete when a piece of information is left unreported even though it should have been reported (for example, information on all debtors associated with the loan).

9.2.1 Correcting loan contract data

Corrections to data reported through the New loans API and the Changes to loans API can be made through the Changes to loans API. The data content is nearly the same as when a new loan is reported. When loan data needs to be corrected, the lender must submit not only the changed data but also the previously submitted data that remains unchanged. In other words, the lender cannot correct data only by reporting changed data: the report must be complete and contain all the data. The lender indicates an error correction in the Type of report field in the API. Error correction can thus be distinguished from the reporting of changes to loan contract information.

9.2.2 Correcting errors in payment transactions

If there is an error in a payment transaction, the lender reports a payment transaction where correct information is given on the most recent payment transaction. In the API, you can correct only the most recent payment transaction reported to the register. The corrected payment transaction is not allocated to the previously reported payment transaction. Instead, the lender indicates an error correction in the Type of report field. Error correction can thus be distinguished from the reporting of a new payment transaction.

A payment transaction of a lump-sum loan is an individual transaction indicating the balance of the lump-sum loan, the amortization paid, and the interest and expenses paid. Only the most recent payment transaction can be corrected. The most recent payment transaction is shown in the credit register extract and in the e-service provided for borrowers. An error detected in the balance of a lump-sum loan can be corrected either through the Changes to loans API or the Payment transactions API.

As regards running-account loans, it is possible to separately correct the amount of loan balance and its value date, and the interest and expenses paid and their date of payment. If there is an error in the amount of loan balance, it is corrected by submitting a new report through the Payment transactions API. The report must contain the amount drawn against a running account, the value date of the amount drawn, and the total interest on the running-account loan. If, on the other hand, interest or expenses paid on a running-account loan or the date of payment need to be corrected, the lender reports the data of the report to be corrected through the Payment transactions API. Both the above data groups can be corrected in the same report.

If a payment transaction has been incorrectly reported for a loan although in fact no payment transactions have been made yet, the error is corrected by submitting an Error correction report through the Payment transactions API. In the report, give the correct loan balance and enter 0 in the ‘Amortization paid’ field. Enter the error correction date as the payment date.

9.2.3 Correcting errors in delayed amounts

A new delayed amount and loan acceleration are reported, updated and corrected through the Delayed amounts API. The lender updates and corrects a delayed amount by submitting a new report. The new report replaces the previously reported data. If an error in the previously reported data is being corrected, the lender indicates this in the Type of report field. In this way, error correction can be distinguished from the updating of data.

9.2.4 Correcting data on the end and transfer of a loan

The lender reports the end of a loan and the transfer of a loan to another lender through the End of loan contract API. When a loan is reported as ended or transferred, it is no longer shown in the borrowers’ e-service or in the credit register extract. The lender can correct data on the end and transfer of a loan through the End of loan contract API.

If the lender has incorrectly reported a loan as ended even though it is still active, the data can be corrected by submitting a new report through the End of loan contract API. The report type to be selected is ‘Error correction’. After that, changes can again be reported for the loan. The loan will also be shown again in the credit register extract and in the e-service. The loan data shown is the data that was valid before the incorrect report on the end of the loan was submitted. Exceptions include information that the loan is included in a payment plan of a debt arrangement or in a business restructuring program, information that the loan has been accelerated, and delayed amounts. The above data is deleted from the register 30 days after the loan has been reported as ended. In other words, if a correction to the end of the loan is reported after more than 30 days, then information that the loan is included in a payment plan of a debt arrangement or in a business restructuring program, information that the loan has been accelerated, and delayed amounts must be reported for the loan again.

9.2.5 Cancellation of a loan

If the lender has reported an invalid loan whose data must be removed from the register, the loan can be cancelled by selecting ‘Cancellation of a loan’ in the Type of report field. The report is submitted through the End of loan contract API. The cancellation of a loan is used if a loan that has never existed has been reported to the register: for example, if a loan has been reported for a wrong personal identity code. If a loan contract is cancelled after it has been concluded and reported to the register, the loan is not removed from the register by reporting a cancellation; instead, the loan is reported as ended.

Cancellation of a loan is also used in situations where the loan type or currency reported for the loan in the New loans API is wrong. It is not possible to correct the loan type or currency in the Changes to loans API, so the loan must be cancelled and reported to the register again through the New loans API.

It is not possible to correct or cancel a report on the cancellation of a loan.

The number of a loan reported as cancelled cannot be used again to re-report the loan to the register until after 30 months from the submission of the cancellation report.

If it is necessary to re-use the number of the loan to be cancelled sooner, another loan number must be reported for the loan to be cancelled in the Changes to loans API before the cancellation. The number can be an artificial number. When a new number is assigned to the loan to be cancelled, the original loan number becomes free to be used again, because the original number is no longer assigned to a loan at the time of cancellation.