As the register's first year comes to an end, a look at what we have learned and what improvements we can still make
12/10/2024The Positive credit register opened on 1 April 2024, which means that it has operated for approximately eight months now. The register currently contains around 12,5 million Finnish household loans. The early stages of the register have included both successes and challenges.
The Positive credit register was launched at the beginning of April. Lenders enter information on home loans, consumer loans, student loans, credit cards and instalment financing in the register. The register currently contains around 12,5 million loans, totalling approximately EUR 151 billion. The lenders must use the credit register extract they have requested from the register when assessing the creditworthiness of loan applicants. Approximately 550,000 extracts are requested each month. An extract is always requested when the individual:
- applies for new credit
- increases their credit limit
- applies for an amendment to the terms of credit that requires a creditworthiness assessment
- the lender accepts a guarantee or third-party security as collateral for a loan.
Loan decisions are not made in the register itself. Instead, we provide the lender with a credit register extract that contains details of the applicant’s loans and income. The lender is responsible for how they process the data they receive from the register and for the loan decision they make on the basis of the data.
Positive and negative feedback on the register
We have received positive feedback on the register from both stakeholders and private individuals. Stakeholders feel that the data in the register improves the quality of credit decisions and speeds up the credit process. Private individuals have praised the fact that the register’s e-service provides a comprehensive view of their own loans, which makes it easier to plan their own finances and improves their overall view of their situation. The accessibility of our customer service and our e-service and the free-of-charge voluntary ban on credits have also emerged in our positive customer feedback.
Erroneous information or misunderstandings?
As is often the case with the introduction of new information systems, we too have faced challenges since the introduction of the Positive credit register. Private individuals have been active and contacted us about their observations on possible errors. We have received an abundance of feedback on such issues as missing information in the register on debt adjustments and so-called mutualised loans. We have added clarifications and more information to our website on how and why the aforementioned cases are visible in the register.
In addition, our clients have been in contact with us if they have seen loans in our e-service that they are not aware of: They can see, for example, credit cards, expired loans, or loans that they are not aware of in our e-service.
"We receive loan data directly from lenders, i.e. if there are errors or shortcomings in the loan data, the lender must correct the data without delay. We welcome observations and notifications by private individuals, as they have allowed us to also improve our own activities and the quality and instructions concerning the register data," says Marjaana Ohralahti, the register's operating officer.
As a rule, lenders correct incorrect data without delay after the client has contacted them, but sometimes the client has been unable to reach the lender or they have not corrected the error despite being notified of it. In such situations, the client can submit a claim for correction to the register. So far, there have been relatively few claims for correction (approximately 900) compared to the total number of loans listed in the register.
Lack of data on entrepreneurial income in credit register extracts
We have also received an abundance of media coverage and feedback on the lack of income data from private entrepreneurs. The income data of entrepreneurs and grant recipients is missing from the credit register extract, as this data is not reported to the Incomes Register, from which we receive all income data. We have published a news item and more detailed instructions on the income data in credit register extracts on our website.
"In situations where income data is not visible on the credit register extract, clients should also have the opportunity to supplement their loan application with additional information, such as income data. We will continue to do our part and improve our own guidelines,” says Ohralahti.
Incorrect data in data content have been corrected quickly
Due to technical challenges encountered in data transfer, the register’s data contained partly erroneous benefit and pay data from the Incomes Register. We detected this error internally and fixed it quickly immediately after the observation. From October to November, some pay data had also not been entered in the register, which as a rule, caused a shortage of one-month's pay data in the credit register extracts of some individuals. This problem, too, was caused by a technical error in data transfer, and was resolved quickly after the observation.
"We will now monitor data transfers between the registers more closely to prevent similar situations from arising. We also believe that the difficulties we have faced have helped improve the register. We have been able to experience how well cooperation with various public authorities and our stakeholders works. Of course, it would be ideal if there were no errors in the register. We sincerely apologise for any damage and distress caused to clients by incorrect information,” says Ohralahti.
The more detailed investigation of possible errors is often time-consuming: Although an error may be fixed quickly, the potential impacts on private individuals or on the extracts supplied to lenders may last longer. The analysis of impacts requires the processing and cross-reference of large amounts of data, which is why it will take time to assess them in more detail.
A notification of requested credit register extracts may reveal the misuse of data
The aim of the register is to improve the opportunities of private individuals to manage their own finances and prevent the over-indebtedness of households. Our e-service provide private individuals access to comprehensive information about their own loans. Approximately 5,500 individual people log in to the e-service every day.
In the e-service, client can set a voluntary ban on credits free of charge. A ban on credits protects private individuals from over-indebtedness and helps e.g. victims of identity theft. More than 37,400 bans on credit have been set so far. The most common reason for the ban has been the “risk of identity theft”. The number of bans increases regularly whenever the media reports on various data breaches or data leaks: For example, the City of Helsinki’s data breach and related news coverage resulted in a significant peak in the number of visits to the e-service and the number of credit bans set.
"In October, we introduced a new functionality: A notification is sent to the client via Suomi.fi Messages whenever a credit register extract has been requested for their data," says Ohralahti.
In addition to a voluntary ban on credit, notifications are an important tool for private individuals to protect and monitor the use of their own data and to detect potential deficiencies.
Entrepreneurs’ loans and housing company loans to be added to Positive credit register
We are developing the Positive credit register in cooperation with our clients and stakeholders. The data content of the register will also be expanded in the future. In the first phase, consumer credits and similar loan data were reported to the register. In the second phase, lenders will report loans granted to private individuals other than consumers, i.e. business-related loans to private individuals. Lenders will be able to utilise this data starting 1 April 2026.
Finland's Parliament has also decided to provide funding for the register's third development phase, during which data on a shareholders share of debt in a housing company loan will be entered in the register. The timetable for reporting and utilising housing company loans will be specified as legislative drafting progresses.
The purpose of adding housing company loans to the register is to improve the scope of the data content of the register, as housing-related debt accounts for the largest share of the loan burden for households.
Further reading
- "Zero income" in the credit register extract – why don't grants and the earned income of self-employed persons show up in the extract?
- Second phase of register progressing - lender interface descriptions have been published
- Housing company loans will also be reported to the Positive credit register in the future
- Activate Suomi.fi Messages - receive a notification when a loan is applied for in your name
- Deficient wage information on credit register extracts between October and November
- The error that generated false benefits payment data on credit register extracts has been corrected
- Incorrect benefit income data on credit register extracts
- Wrongful requests for credit register extracts for 1,800 persons submitted
- Credit register extracts requested from the Positive Credit Register without relevant grounds
- Incorrect customer data causing unjustified dates of death on credit register extracts have been corrected
- Unjustified dates of death on some customers’ credit register extracts