Notifying of missing data
According to section 19 of the Act on the Positive Credit Register, data covered by the reporting obligation and changes to such data must be reported to the register insofar as the data is reasonably accessible to the party that is required to submit reports.
The instructions on Reporting data to the Positive credit register 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.
If data is missing, i.e. if some data covered by the reporting obligation is not reasonably accessible to the party that is required to submit reports, the Incomes Register Unit has to be informed of this in writing. A free-form notification can be submitted by filling in the register's contact form.
In the case that data is missing from your current credit stock, please inform us by 31 March 2024. As of 1 April 2024, we recommend that you should notify us of any missing data within two weeks of reporting the loans.
In the notification, state what information is not accessible and why not, and what kind of loans the omission concerns. The free-form notification is general in nature. It may not include any identifying details of the loans that the omission concerns, such as personal data or loan numbers.
The notification helps the Incomes Register Unit to focus its control measures on actually missing data.
Examples
- Example 1: The lender’s system does not contain data element ‘Effective interest rate on the date of conclusion’ for old loans. This piece of information can be found only on original loan contracts that are in paper form or have been scanned. In the lender's view, it is not possible to report this information on old loans with reasonable measures, and the information is therefore not included in the reports on old loans.
- The lender notifies the Incomes Register Unit that they have not reported ‘Effective interest rate on the date of conclusion’ on loans issued before dd.mm.yyyy, because the information has not been reasonably accessible. In addition, the lender explains why this is so.
- Example 2: Before the introduction of the Positive credit register, the lender has not indicated in their systems if a particular loan falls within the scope of chapter 7 or 7a of the Consumer Protection Act. In the lender's view, it is not possible to report this information on old loans with reasonable measures, and the information is therefore not included in the reports on old loans.
- The lender notifies the Incomes Register Unit that they have not reported whether a loan falls within the scope of chapter 7 or 7a of the Consumer Protection Act on loans issued before dd.mm.yyyy, because the information has not been reasonably accessible. In addition, the lender explains why this is so.
When is a notification of missing data not needed?
A notification of missing data need not be submitted if the data does not exist for the loan reported.
- Example 3: If no deferment periods have been agreed on for a loan, no information about deferments of amortizations will be reported and no notification of missing data needs to be submitted.
- Example 4: If no interest rate cap or interest rate corridor has been agreed on for a loan, the related data fields will not be filled in and no notification of missing data needs to be submitted.