Finance Finland (FFI) is committed to transparent lobbying. We therefore annually publish a report of our lobbying activities, disclosing the political decision-makers and topics we have lobbied.
We support greater transparency in all lobbying that seeks to influence the preparation of legislation and the use of budgetary powers in Finland or in the EU. The Finnish Government is due to publish a proposal for an act for a transparency register this spring. The act will impose a registration obligation on organisations and individuals engaged in lobbying activities.
Even before a statutory transparency register is established, Finance Finland wants to disclose its lobbying activities in key themes and the political decision-makers we have lobbied in the previous year. These include members of the Finnish Parliament, ministers and state secretaries to the ministers, members of the EU Parliament and Commission officials. The names of the persons listed on the lobbying report have been published due to their significant political position.
We also represent the interests of the Finnish financial sector in Brussels and are a long-time member in the EU Transparency Register.
Our dialogue with the various interest groups and authorities is related to legislative projects and other current financial sector themes with national or EU-wide relevance. Our experts have also participated in a number of ministerial expert working groups engaged in preparing legislation that is essential to the sector. Our experts have also been consulted in Finnish parliamentary committees.
We have listed our key lobbying topics for 2021. The listing discloses Finance Finland’s position on each issue and the decision-makers we met with.
What we lobbied
National emergency preparedness legislation
FFI’s position
In August 2018, a Ministry of Finance working group proposed enacting an obligation to have the financial sector’s key information systems and databases located in Finland. The National Emergency Supply Agency and the Ministry of Employment and the Economy supported Finance Finland’s position that such relocation should not be undertaken because the proposed preparedness obligations were disproportionate. Prime Minister Sipilä’s Government did not take the proposal forward. The idea of regulating this matter in law has now been raised again.
To offer an alternative to regulatory action, Finnish banks conducted an assessment of other ways in which key financial services could be secured under emergency conditions. Finance Finland officially submitted the final report of the assessment in December 2020.
Meetings with decision-makers
- Minister of Finance Annikka Saarikko
- Minister of Justice Anna-Maja Henriksson
- Minister of Local Government Sirpa Paatero
- Minister for European Affairs Tytti Tuppurainen
- Permanent Secretary of the Ministry of Finance Juha Majanen
- State Secretary to the Minister of Finance Maria Kaisa Aula
More about emergency preparedness
Institutional investors’ withholding tax-at-source on dividends
FFI’s position
Finance Finland participated in the Ministry of Finance expert working group’s assessment regarding a new withholding tax-at-source on dividends. The working group’s conclusion was that the planned new dividend withholding tax would not fit well into the current dividend tax system and would only make the system even more complicated. The withholding tax was overturned at the government budget session on 9 September 2021. Most of the commentators agreed with this decision.
The Government’s decision to overturn the proposal on a withholding tax on dividends supports Finnish ownership, ordinary citizens’ investment and the employee pension system.
Finance Finland appreciates the fact that the Government took the expert working group’s assessment of the adverse impacts of the tax into account in its decision making. It was also important that the withholding tax and its impacts were a subject of active public dialogue. Transparency and the broad consultation of experts lead to high-quality decisions.
The Government did, however, decide that the yields from real estate investments made into foreign funds will in Finland be subject to as extensive taxation as possible as from the start of 2023. The specific contents of this decision will not be clear until it enters the drafting process. Finance Finland will monitor the situation.
Meetings with decision-makers
- Minister of Finance Annikka Saarikko
- Minister of Justice Anna-Maja Henriksson
- Minister of Local Government Sirpa Paatero
- Minister of Economic Affairs Mika Lintilä
- Chair of the Finnish Social Democratic Party SDP Antti Lindtman
- Member of Parliament Sanni Grahn-Laasonen
Households’ excessive indebtedness
FFI’s position
Finance Finland’s objective has been to ensure that the new measures aimed at curbing the excessive indebtedness of households are targeted on those forms of credit that have caused the most problems for consumers. Targeted measures can help prevent adverse effects on the national economy, especially those related to the mobility of the workforce and the functioning of the housing market. When lending rules are tightened, the related costs from changes to data systems, for example, must be kept as small as possible.
Meetings with decision-makers
- Minister of Finance Annikka Saarikko
- Minister of Justice Anna-Maja Henriksson
Review of the Act on the Openness of Government Activities and the regulation of automated decision-making
FFI’s position
In 2021, a Ministry of Justice working group worked on a draft general act on the use of automation in decision-making and the processing of administrative matters. Finance Finland had a representative in the working group. The new act will also apply to statutory insurance business. Each year, insurance companies process a massive amount of claims from statutory insurance alone. Regulation should permit automation (including the use of artificial intelligence) that takes into account the special characteristics of private operators. It should also permit automated decision-making as extensively as possible also when it comes to public administrative tasks.
The ministerial working group’s work progressed in a balanced fashion, and the eventual proposals will therefore likely enable sufficient flexibility in automation from the viewpoint of insurance service providers. Some challenges were posed by the fact that under the Ministry of Finance, another working group led by public officials is currently active with a partially overlapping mandate to prepare the review of information system regulation in public administration.
The working group appointed by the Ministry of Justice to review the Act on the Openness of Government Activities continued its work in 2021. The working group is tasked to review and assess the adequacy and currency of the act’s scope of application. Finance Finland has a representative in the working group.
Meetings with decision-makers
- Minister of Justice Anna-Maja Henriksson
Positive credit register
FFI’s position
The basic purpose of the positive credit register is to prevent excessive indebtedness. The register will contain the full credit information of private persons, and its use will be mandatory for all credit institutions. Finance Finland had a representative in the steering group and the subgroup tasked with preparing the establishment of the register. Finance Finland’s goals concerning the positive credit register are to have it implemented it in a way that supports lending as well as possible and to have the register in place already by the time the regulation required to utilise the register in practice enters into force. The Government proposal will be issued to the Parliament in early 2022. The aim is to have the register in use as of 1 April 2024.
Meetings with decision-makers
- Minister of Justice Anna-Maja Henriksson
Anti-money laundering legislation and its effects on the banking of associations and companies
FFI’s position
Finance Finland has given several proposals for the improvement of money laundering prevention and has called for tighter cooperation between banks and the various authorities. Many of the proposals were approved by the Ministry of Finance working group tasked to deliberate a partial reform of anti-money laundering legislation. Finance Finland had a representative in the working group. The partial reform is aimed at fixing deficiencies and inconsistencies in the implementation of EU anti-money laundering directives and the Financial Action Task Force’s (FATF) recommendations. These shortcomings have been brought up by national authorities and Finance Finland.
Finance Finland greatly contributed to the outcome of the review. The GDPR-compliant handling of criminal records and other similar information related to the customer is now enabled, the definitions of PEPs were further specified, the Financial Intelligence Unit was not granted direct access to sector participants’ internal money laundering risk assessments, and the establishment of a national PEP register is continued as a separate project.
In July 2021, the European Commission presented an ambitious package of legislative proposals to strengthen the EU’s anti-money laundering rules.
Meetings with decision-makers
- Commissioner Jutta Urpilainen
- MEP Eero Heinäluoma
- MEP Sirpa Pietikäinen
- MEP Henna Virkkunen
- Member of Parliament Johannes Koskinen
- Member of Parliament Hussein al-Taee
- Member of Parliament Antero Laukkanen
- Permanent Representative of Finland to the EU Markku Keinänen
More about the prevention of money laundering
Reform of personal identity codes in Finland
FFI’s position
The plan was to implement the redesign of Finnish personal identity codes with a partial reform that would have adequately fixed the issues related to the sufficiency of unique codes and gender neutrality. The reform was to enter into force in January 2023. The majority of commentators, Finance Finland included, considered the transitional period too short.
Although the partial reform would have been adequate, the full reform was pushed forward. Finance Finland underlined that a full reform would be too expensive, without clear benefits in return. Finance Finland participated in the reform’s working group, which ended up proposing the implementation of a fully redesigned personal identity code. Finance Finland entered a dissenting opinion. The redesigned personal identity code is to be introduced in the internal use of the population information system, and organisations can voluntarily use it as an identifier in their systems. Unlike the current personal identity codes, the new personal identity code will not be disclosed to or be usable by the person it identifies.
Meetings with decision-makers
- Minister of Local Government Sirpa Paatero
- Minister of Finance Annikka Saarikko
- Permanent Secretary of the Ministry of Finance Juha Majanen
Basel III
FFI’s position
Finance Finland underlines the importance of implementing the reform in a way that ensures that capital requirements accurately reflect risks and that their increase is kept as low as possible. The financial sector considers it important that banks’ capacity to finance the economy is protected in the implementation of the regulation and that the regulation takes into account the special characteristics of Finnish mortgage lending. Finance Finland gave statements to Parliamentary committees regarding the draft government position and sought to ensure that Finland’s official position in EU negotiations better acknowledges the needs of the financial sector and the economy.
Meetings with decision-makers
- Minister of Finance Annikka Saarikko
- Minister of Local Government Sirpa Paatero
- Member of Parliament Hanna Kosonen
- Member of Parliament Eeva Kalli
- Member of Parliament Sanni Grahn-Laasonen
- Member of Parliament Antti Lindtman
- Member of Parliament Riitta Mäkinen
- Member of Parliament Matias Marttinen
- Member of Parliament Jouni Ovaska
- MEP Ville Niinistö
- MEP Sirpa Pietikäinen
- MEP Eero Heinäluoma
- State Under-Secretary for European Affairs to the Prime Minister Jari Luoto
- State Secretary to the Minister of Finance Maria Kaisa Aula
- State Secretary to the Ministry of the Interior Akseli Koskela
- Commissioner Jutta Urpilainen
- Head of Commissioner Urpilainen’s Cabinet Taneli Lahti
- Commissioner Mairead McGuinness
- Member of Commissioner McGuinness’s Cabinet Tommy De Temmerman
- Permanent Representative of Finland to the EU Markku Keinänen
Lotteries Act
FFI’s position
In December 2021, the Parliament approved the reform of the Finnish Lotteries Act. The reform introduces payment blockades to curb the adverse effects of gambling. Finance Finland endeavoured to prevent the adoption of such blockades because they are an inefficient and very costly way to prevent gambling problems. Finance Finland issued statements on the Lotteries Act and took part in Parliamentary hearings.
Meetings with decision-makers
- Minister of Science and Culture Antti Kurvinen
- Member of Parliament Riikka Purra
- Member of Parliament Mari-Leena Talvitie
- Member of Parliament Juha Pylväs
- Member of Parliament Mikko Kärnä
- Member of Parliament Joonas Könttä
Sustainable finance
FFI’s position
Sustainable finance plays a major part in the transition towards climate-neutral economy. Finance Finland is in favour of developing a science-based taxonomy and improving the transparency of ESG evaluations. However, it is important to steer clear of overregulation and excessive administrative burden. The sustainability disclosures regulation, for example, is being prepared under a very strict schedule, which may lead to hasty decisions and insufficient impact assessment.
Meetings with decision-makers
- Minister for European Affairs Tytti Tuppurainen
- Commissioner Jutta Urpilainen
- MEP Sirpa Pietikäinen
- MEP Eero Heinäluoma
- MEP Ville Niinistö
- MEP Nils Torvalds
- MEP Mauri Pekkarinen
- Member of Parliament Pia Kauma
- Permanent Representative of Finland to the EU Markku Keinänen
More about sustainable finance
Deepening the Banking Union and economic policy setting
FFI’s position
EMU membership, the single currency and the Banking Union form a stable operating environment, and Finland should therefore stay close to the heart of the EMU. Emphasis must be placed on each member state’s responsibility for its own finances and the role of market discipline. If joint debt becomes a perpetual phenomenon, there will be a need for mechanisms that enhance the effectiveness of market discipline and thereby compensate for the weakening effect that joint debt has on it. Any decisions to expand risk sharing must be carefully deliberated and justified. The present problems of each member state’s banks must be solved and risks reduced before risk sharing is deepened in the Banking Union.
If a common deposit guarantee scheme is implemented, it must be based on lending and have strict conditions.
Meetings with decision-makers
- Commissioner Jutta Urpilainen
- Head of Commissioner Urpilainen’s Cabinet Taneli Lahti
- Commissioner Mairead McGuinness
- Member of Commissioner McGuinness’s Cabinet Tommy De Temmerman
- Member of Commissioner Dombrovskis’s Cabinet Andrea Beltramello
- MEP Sirpa Pietikäinen
- MEP Eero Heinäluoma
- MEP Ville Niinistö
- MEP Nils Torvalds
- MEP Mauri Pekkarinen
- MEP Henna Virkkunen
- State Secretary to the Minister of Finance Maria Kaisa Aula
- Permanent Representative of Finland to the EU Markku Keinänen
- President of the Eurogroup Working Group Tuomas Saarenheimo
EU digital finance
FFI’s position
The EU digital single market needs a single rulebook. Finance Finland calls for durability and long-term focus in the design of the rules. The regulatory treatment of new participants entering the market must be equal to that of traditional financial companies. In 2021, Finance Finland issued statements concerning digital finance projects to Parliamentary committees and the European Insurance and Occupational Pensions Authority (EIOPA). Finance Finland is in favour of the plans to develop a national digital identity but has reservations when it comes to the European electronic identification, authentication and trust services (eIDAS) proposed by the Commission.
Meetings with decision-makers
- MEP Henna Virkkunen
- MEP Eero Heinäluoma
- Minister for European Affairs Tytti Tuppurainen
- MEP Ondřej Kovařík
- Deputy Head of Unit at DG FISMA Mattias Levin
Prudential regulation of the insurance sector (Solvency II)
FFI’s position
The Commission proposal for Solvency II was published in September 2021. With the proposal, the Solvency II review is headed in the right direction. The regulatory package is massive, and the review has not made it much lighter. Finance Finland lobbies for changes that would improve proportionality in the reporting requirements.
The insurance sector commended the Commission on its wise decision not to propose a harmonised insurance guarantee schemes directive. Solvency II already protects policyholders and other beneficiaries quite effectively in the event of an insurer’s insolvency or bankruptcy. Moreover, different member states have very different insurance systems, and unlike in banking, in the insurance sector the difficulties of an individual company are not likely to spread to the entire sector. Finance Finland has discussed the proposal with government officials, the Commission and MEPs on a regular basis.
Meetings with decision-makers
- MEP Eero Heinäluoma
- MEP Sirpa Pietikäinen
- Commissioner Mairead McGuinness
- Member of Commissioner McGuinness’s Cabinet Tommy De Temmerman
- Member of Commissioner Dombrovskis’s Cabinet Andrea Beltramello
- Head of Insurance and Pensions Unit Didier Millerot
Insurance companies’ crisis management
FFI’s position
The Commission published a directive proposal for an insurance recovery and resolution framework in September 2021. The proposal requires insurance companies to formulate pre-emptive recovery plans. It also grants national authorities powers to guarantee an orderly resolution of failing insurers. The directive proposal is modelled after its equivalent in the banking sector and as a result is not entirely suited to the insurance sector. Finance Finland’s minimum objective is that the proposal is amended to better account for the characteristics of insurance business.
Meetings with decision-makers
- MEP Eero Heinäluoma
- MEP Sirpa Pietikäinen
ASP bonus for home savers
FFI’s position
The Ministry of the Environment has proposed changes to the state-backed ASP savings and loan scheme designed for young first-time homebuyers. If the proposals go through, the maximum age of ASP savers will be raised from 39 to 44 years, a person will be able to apply for an ASP loan for an apartment they already live in, and two ASP savers can get an interest-subsidised loan that is up to 50% larger compared to a single homebuyer. In addition, the state loan guarantee will be raised to €60,000. Banks will be required to report all ASP loans to the State Treasury, which will be responsible for compliance supervision. Finance Finland is in favour of the amendments but points out that the effects may remain lesser than desired unless other regulation is also amended.
Meetings with decision-makers
- Minister of the Environment and Climate Change Krista Mikkonen
- Member of Parliament Pia Kauma
More about saving and investing
Securities market regulation in the EU
FFI’s position
In November 2021, the Commission adopted a proposal for the reform of MiFID/R. The proposal will especially review the transparency of share and derivative trading. It will also establish a single access point for trade information, i.e. a consolidated tape. The impacts on the structures of different EU markets and both corporate and retail customers must be taken into account when the proposal enters deliberations. The Nordic capital markets function very well, and the new regulation must not set any obstacles for them.
Meetings with decision-makers
- MEP Eero Heinäluoma
- Member of Commissioner McGuinness’s Cabinet Florian Denis
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