Signing up to the Positive credit register as a data notifier

These instructions provide guidance on the lenders’ obligation to sign up to the Incomes Register Unit. The instructions describe who are obliged to sign up for the register under the Act on the Positive Credit Register, and what kind of loans they are required to report. Lender here refers to all parties required to submit reports, including peer-to-peer loan brokers and other businesses to which the lender’s rights arising from a loan contract have been transferred.

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 loans comparable to them is reported to the register. In the second stage, at the end of 2025, lenders start reporting other than consumer credits granted to private individuals. Such credits include, for example, loans that business operators have taken out for their business activities.

These instructions describe how to sign up as a party required to submit reports in the first stage of the register, starting 2 October 2023. The sign-up regarding the second stage begins on 1 August 2025, and instructions for it will be provided closer to that date.

Lenders may have a legal right to receive information from the Positive credit register. When signing up, the lender can also separately apply for a data permission needed for the purpose. Certificates are needed to report data and to request data. Instructions on how to apply for a data permission and how to retrieve and use certificates are provided in separate instruction documents:

• Instructions for lenders on how to apply for a data permission
• Instructions on certificates

Also study the Positive credit register’s other instruction documents:

• Reporting data to the Positive credit register
• Sharing data from the Positive credit register

Contact information for the Positive credit register's customer service is available on the register's website at www.positivecreditregister.fi.

1 Terminology used in the instructions

Consumer credit refers to a consumer credit or comparable loan to which the provisions of chapter 7 or 7 a of the Consumer Protection Act (38/1978) are applied.

Lender is a party that grants loans. In these instructions, ‘lender’ refers to all parties required to submit reports. The group also 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 have been transferred (reassignees). For the sake of readability, they are also called lenders in these instructions.

2 Requirement to sign up for the Positive credit register

2.1 Lenders required to sign up

Before a lender can start reporting data, they must sign up to the Incomes Register Unit. The sign-up requirement is laid down in the Act on the Positive Credit Register (Finlex).

The lenders specified below are obliged to report data on the consumer credits and comparable loans to the Positive credit register (section 16 of the Act on 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):
   • business operators providing credit and financial services (section 4, subsection 1)
   • Finnish branches of foreign EEA supervised entities (section 4, subsection 5)
   • foreign supervised entities that provide services in Finland but do not have a Finnish branch (section 4, subsection 5).

Lenders under the supervision of the Financial Supervisory Authority refer to supervised entities under section 4, subsection 1 of the Act on the Financial Supervisory Authority, i.e. authorised supervised entities, supervised entities comparable to authorised supervised entities, and other supervised entities. This group also includes Finnish branches of foreign EEA supervised entities, and foreign supervised entities that provide services in Finland but do not have a Finnish branch (section 4, subsection 5 of the Act on the Financial Supervisory Authority). A branch of a foreign EEA supervised entity may be a branch of a credit institution established in an EEA country, or a branch of a credit institution established in an EEA country by a third country. Provision of services without a branch is possible only for such EEA supervised entities that have an operating licence in another EEA country.

2. Lenders and loan brokers registered in accordance with the Act on the Registration of Certain Credit Providers and Credit Intermediaries (186/2023) and supervised by the Financial Supervisory Authority.

In other words, the sign-up requirement applies to lenders and peer-to-peer loan brokers entered in the register of lenders and peer-to-peer loan brokers maintained 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. Lenders and peer-to-peer loan brokers with the reporting obligation may also be lenders established in another EEA country but providing services in Finland.

3. Other businesses to which the lender’s rights arising from a loan contract reportable to the Incomes Register Unit have been transferred (reassignees).

Such reassignees include, for example, debt collection agencies to which loans have been transferred from another business operator that is required to submit reports. If a debt collection agency attends to a collection assignment on behalf of a lender, however, the reporting obligation remains with the lender.

If the new lender is a business with the reporting obligation (item 1 or 2 above), they must always report transferred loans. Other businesses have the reporting obligation only as regards loans that have been transferred from a business that is required to submit reports.

The reporting obligation does not apply to Kela (The Social Insurance Institution of Finland).

2.2 Consumer credits or loans comparable to them

In the first stage of the Positive credit register, the requirement to sign up applies only to lenders that grant consumer credits or loans comparable to them.

Consumer credits reportable to the Positive credit register refer to loans within the scope of chapter 7 or 7 a of the Consumer Protection Act (38/1978). Loans comparable to consumer credits include

• lease contracts or other contracts under which goods are handed over to the consumer. According to the terms and conditions of the contract, the cash price of the goods and the loan expenses must be paid during the lease period, or the consumer can otherwise become the owner of the goods at the end of the contract.
• a credit that a party other than a lender grants to a consumer as a loan, deferred payment or another corresponding financial arrangement, if some other business operator brokers the credit to the consumer (peer-to-peer loan).

Data on credits to which the provisions of chapter 7 or 7 a of the Consumer Protection Act do not apply is not recorded in the register. Such credits include

• consumer credits on which no interest or other charges are collected
• credits based on agreements according to which a consumer has the right to pay the price of a continuously supplied commodity in instalments during the period of validity of the agreement
• credits granted by pawnbrokers
• credits granted on the basis of the act on social crediting (Laki sosiaalisesta luototuksesta 1133/2002)
• loans that a natural person has taken out primarily for their business activities.

Further, granting a usual time of payment to a consumer in commodity trading does not constitute a consumer credit under chapter 7 of the Consumer Protection Act.

3 Sign-up process

3.1 Sign-up period

Lenders must sign up to the Incomes Register Unit between 2 October and 30 November 2023. New parties with the reporting obligation must sign up to the Incomes Register Unit on their own initiative no later than 1 month before starting to report data to the Positive credit register.

3.2 Sign-up channels

You can sign up as a data notifier in the Positive credit register’s e-service. The e-service can be used if

• the lender has a Finnish Business ID, and
• the person acting in the lender’s name can identify themselves in the Suomi.fi service using strong identification. In Suomi.fi, users identify themselves with their Finnish e-bank codes, mobile certificates or certificate cards.

If the lender cannot use the e-service, they can sign up with a paper form. They can request the form from the Positive credit register’s customer service as of 2 October 2023. The form will be sent to the address specified by the organisation either by post or by email. You can find the customer service’s contact information on the Positive credit register's website at www.positivecreditregister.fi.

The completed form and its attachments can be returned to the Incomes Register Unit by post to the address below:

POSITIVE CREDIT REGISTER

P.O. BOX 2

FI-00055 INCOMES REGISTER

Read about the attachments to the paper form in chapter 3.4.

3.3 Who can sign up a lender?

Individuals who are recorded to have any of the official roles listed below in the Trade Register or the Business Information System (BIS) can act in the lender’s name in the e-service:

• managing director
• managing director’s substitute
• Chair of the Board
• general partner (limited partnership)
• partner (general partnership)
• business operator
• holder of procuration who is authorised to sign alone
• individual who is authorised to sign alone (authorised individual)

In addition to individuals with the official roles listed above, individuals or companies that have been granted the ‘Registering as a credit information reporter and user’ authorisation can perform the sign-up in the e-service. Lenders can grant and change authorisations as needed in the Suomi.fi e-authorisation service.

The Suomi.fi e-authorisation `Registering as a credit information reporter and user’ always applies both to applying for a data permission and to signing up as a data notifier. If the lender wants to authorise different persons to make a data permission application and a request to sign up as a data notifier, a paper form must be used.

Read more about granting authorisations (Suomi.fi)

An individual acting in the lender’s name identifies themselves in the Positive credit register’s e-service with their personal e-bank codes, mobile certificate or certificate card. Only individuals with a Finnish personal ID can identify themselves in the e-service.

The sign-up request can be submitted on a paper form by an individual who is authorised to sign for the lender or has the required authorisation, see section 3.4.

3.4 Attachments to the paper form

If the lender signs up with a paper form, various attachments must be enclosed with the form to verify the company and the right to represent the company. The documents must be certified and original. The attachments are sent to the Incomes Register Unit by post.

The documents may be in Finnish, Swedish or English.

Documents needed if the company is registered in Finland:

• Documents proving the right of representation (unless indicated in authorities’ registers).

In the case of Finnish organisations, the Incomes Register Unit checks in authorities’ registers, such as the Trade Register, who has the right to represent the organisation. If the right of representation is not indicated in Finnish authorities’ registers, documents proving the right of representation, such as the rules of the organisation, must be enclosed with the form.

• Enclose an authorisation, if necessary.

The sign-up with a paper form can also be performed by an individual or a company authorised by the lender. In that case, an authorisation must be enclosed with the form. The authorisation must state at least the authorising party’s information (lender’s name and Business ID), the authorised party's information (name and Finnish or foreign personal identity code), and what the authorisation concerns. The authorisation must be signed by someone who is authorised to sign for the lender.

Documents needed if the company is not registered in Finland:

• A certified extract from a foreign business information register. Register documents of organisations not registered in Nordic countries must be validated (e.g. Apostille).
• If the organisation's rights of representation are not shown in the foreign register extract, the organisation must provide sufficient, certified documentation to show the rights of representation.
• Enclose an authorisation, if necessary.

The sign-up with a paper form can also be performed by an individual or a company authorised by the lender. In that case, an authorisation must be enclosed with the sign-up request. The authorisation must state at least the authorising party’s information (lender’s name and foreign business ID), the authorised party's information (name and Finnish or foreign personal identity code), and what the authorisation concerns. The authorisation must be signed by someone who is authorised to sign for the lender.

3.5 Processing of the sign-up request, and notification channel

When signing up, the lender must provide the Incomes Register Unit with information on their actual activities and submit the information required for the introduction of APIs.

The Incomes Register Unit processes the sign-up request and may ask the lender for additional information. If possible, the request for additional information is emailed to the sign-up contact person, specified by the lender, and a response must be submitted within a certain time limit. The lender may request an extension to the time limit, if needed.

When the sign-up has been processed and any additional information considered, the lender receives a decision from the Incomes Register Unit on establishing connections. The decision is sent by post or email to the address indicated at ‘Notification channel’ in the request. You can also see in the e-service whether the sign-up request has been accepted or rejected.

If the sign-up is accepted, the lender is granted a certificate. The lender will need the certificate to identify themselves to use the APIs for reporting data. Separate instructions are available on how to retrieve and use the certificate. You can find a link to the instructions at the beginning of this document.

The decision can be appealed. Instructions for appeal are enclosed with the decision.

The lenders whose reporting obligation has been verified and that have received a positive decision on establishing connections are listed on the Positive credit register’s website. The lenders’ names and Business IDs or foreign business IDs are listed on the website.

The Incomes Register Unit processes sign-up requests as of 2 October 2023. The sign-up requests are processed within 14 days on average. If the service is congested, the processing time may be longer. However, a decision on the sign-up request will be provided at the latest by the time the reporting of data begins on 1 February 2024.

4 How to fill in the sign-up form

This chapter provides detailed instructions on how to fill in the sign-up form. The form asks for information about the lender and its business activities. The form refers to lenders as organisations, and the word organisation is therefore also used in this chapter.

The form available in the e-service cannot be saved as unfinished, and you cannot continue to fill it in later. The electronic form times out after 4 hours, so if the form is open in the browser for longer than that without being submitted, the session will close and the information you have filled in will disappear.

4.1 Description of activities

Select on what grounds the organisation is obliged to report data to the Positive credit register. You can select only one option.

Credit or financial service provider: According to the Act on the Financial Supervisory Authority (878/2008), the organisation is an entity, institute or private entrepreneur under the supervision of the Financial Supervisory Authority (section 4, subsection 1), a Finnish branch of a foreign EEA supervised entity (section 4, subsection 5) or a foreign supervised entity providing services in Finland without a branch (section 4, subsection 5).

Lender or peer-to-peer loan broker: The organisation is a lender or a peer-to-peer loan broker entered in a register according to the act on the registration of certain lenders and loan brokers (Laki eräiden luotonantajien ja luotonvälittäjien rekisteröinnistä 186/2023).

Reassignee: The reassignee is a business to which the lender’s rights arising from a loan contract have been transferred. The reassignee’s credit stock contains loans within the scope of chapter 7 or 7 a of the Consumer Protection Act, or loans comparable to them, and the loans in question have been transferred from another business that is required to submit reports.

Select ‘reassignee’ only if neither of the first two options is applicable. Then select whether the organisation is in the register under section 3 of the Act on the Registration of Debt Collectors (411/2018).

Other: The organisation is required to submit reports for a reason other than any of the above. Give additional information about the activities of the business you represent and state the reason why the business is covered by the reporting obligation.

Does the organisation grant consumer credits or comparable loans, or are such loans included in the organisation’s credit stock? (Loans within the scope of chapter 7 or 7 a of the Consumer Protection Act; see item 1.2 in this document)

The options available are ‘yes, at present’, ‘yes, but only in the future’, and ‘no’.

If you select ‘yes, but only in the future’, you will be asked to enter the date when the organisation plans to start granting loans, or when the organisation’s credit stock will include such loans. New organisations entering the market after the sign-up period of 2 October 2023–30 November 2023 must sign up to the Incomes Register Unit on their own initiative no later than 1 month before starting to report data to the Positive credit register.

If you select ‘no’, you will be asked to check whether the organisation has the reporting obligation under the Act on the Positive Credit Register. If the organisation does not have the reporting obligation, it should not be signed up as a data notifier. If the organisation has the reporting obligation, you will be asked to specify what kind of loan contracts the organisation intends to report to the Positive credit register.

4.2 Details of contact persons

When signing up, the organisation must give the following information:

• details of the contact person for sign-up
• details of the contact person for content
• details of the technical contact person
• details of the contact person for certificates
• details of the notification channel.

The details of all other contact persons except the technical contact person for certificates can include a second email address, such as a distribution list or a shared mailbox, as well as a personal email address. All messages sent to such contact persons will also be sent to the second address.

You can enter the details of the same person in multiple fields, if needed. After the sign-up, you can edit the details of the technical contact person and the contact person for content on the Invoicing and contact information page in the e-service. If you want to update other contact information provided in connection with the sign-up, please contact the Positive credit register’s customer service. You can find the contact information on the Positive credit register's website at www.positivecreditregister.fi.

Contact person for sign-up

The contact person for sign-up gives additional information regarding the sign-up request, if needed. Requests for any additional information needed for the processing of the sign-up will be sent to the contact person by email.

The Incomes Register Unit will also be in touch with the contact person regarding the reporting of the existing credit stock. The decision on establishing connections will be sent to the notification address stated at the end of the form.

The contact person must be in the service of the organisation signing up.

Contact person for content

The contact person provides additional information about the content of the reports submitted by the organisation. They are familiar with the register’s data content and APIs. The Incomes Register Unit sends the contact person requests for additional information regarding the controlling of the signing up.

The contact person must be in the service of the organisation signing up.

Contact person for technical matters

The contact person answers questions about the information security and technical functionality of reporting and provides additional information in case of technical problems. The contact person must be in the service of the organisation signing up.

Technical contact person for certificates

The Incomes Register Unit grants a certificate for the use of APIs to each organisation reporting data to the register. The technical contact person for certificates receives the information and instructions for retrieving the certificate. Their telephone number must be a number to which text messages can be sent: the number is needed to receive the secure email message regarding the retrieval of the certificate. The number should preferably be a Finnish number so as to ensure the successful arrival of the text message. Once the certificate has been retrieved, the number will not be contacted again.

Notification channel

Select how you want the decision to be delivered: by secure email or by post. You can select only one of the two options. The decision will not be delivered to the e-service.

If you select delivery by secure email, enter the email address to which you want us to send the decision. The secure email sent to the address will include a link through which you can download the decision.

If you select delivery by post, enter the postal address to which you want us to send the decision.

You can find more information about the decision and appeal in item 3.4 of this document.

4.3 Submitting the sign-up request

Before you can submit your sign-up request, you will be taken to a summary view, where you can see the information you have entered on the sign-up form. At the end of the summary, you can enter additional information about the organisation’s sign-up or, for example, the contact persons. You do not need to give any additional information if all the relevant information is found on the form.

Check the information you have entered. If you want to edit the information you have entered on previous pages, click Previous.

The information entered on the form is not saved in the e-service. If you need the information later, save it before you submit the sign-up request.

When you have filled in and checked all the information, send the sign-up request to the Incomes Register Unit by clicking Submit.

4.4 Sign-up status

When the sign-up request has been successfully submitted, the status in the e-service changes to Received. If the status does not change within a few seconds, the sign-up request has not arrived.

When you have sent a sign-up request, you cannot submit a new sign-up form in the e-service, nor supplement or edit the form you have submitted. If you need to submit a new sign-up request, supplement or edit the sign-up information you have sent, or cancel the sign-up, please contact the Positive credit register’s customer service. You can find the contact information on the Positive credit register's website at www.positivecreditregister.fi. Additions and changes must always be made in writing.

When the Incomes Register Unit accepts the sign-up request, the status in the e-service changes to Accepted. The sign-up status changes to Rejected if the Incomes Register Unit rejects the sign-up request or decides not to examine the sign-up, or if you cancel the sign-up request yourself.

4.5 Updating the contact information

The organisation must check their contact information regularly and update the details as needed.

The organisation can edit the following contact information in the Positive credit register’s e-service:

• contact person for content
• contact person for technical matters.

Other contact information provided in connection with the sign-up can be updated by contacting the Positive credit register’s customer service. The customer service can also update the contact information if the organisation cannot use the e-service. You can find the customer service’s contact information on the Positive credit register's website at www.positivecreditregister.fi.