Annual report of Finance Finland’s lobbying activities in 2023

Reporting period 7/2023–3/2024

Transparency is the foundation of responsible lobbying. Finance Finland therefore regularly publishes a report of its lobbying activities, disclosing the political decision-makers and topics we have lobbied in Finland and in the EU.

The names of the persons listed on the lobbying report have been published due to their significant political position.

The Finnish Transparency Register Act entered into force on 1 April 2024. The new act obligates all lobbyists to provide information to the register on lobbying targeted at the parliament and ministries. Finance Finland was the first organisation to enrol in the register.

Even after the launch of the national register, we want to be open about our lobbying activities by publishing our own report disclosing the names of the political decision-makers, i.e. members of the Finnish Parliament, ministers and ministerial staff, members of the EU Parliament and Commission officials, whom we have lobbied in our key themes.

Our experts have also participated in a number of ministerial expert working groups engaged in preparing legislation that is essential to the financial sector. They have also been consulted in Finnish parliamentary committees.

We have listed our key lobbying topics for the period of July 2023 to March 2024 below. The listing discloses Finance Finland’s position on each issue as well as the decision-makers we met with.

General – Government programme

Finance Finland’s position

The Finnish government programme includes several measures that pertain to the financial sector. Finance Finland is engaged in active discussions with the governing parties to promote the implementation of these measures. We have made concrete proposals and want to make our voice heard during the relevant deliberations.

Meetings with decision-makers

• Prime Minister Petteri Orpo (National Coalition Party)
• Minister of Finance Riikka Purra (Finns Party)
• Minister of Economic Affairs Wille Rydman (Finns Party)
• Minister of Social Security Sanni Grahn-Laasonen (National Coalition Party)
• Member of Parliament Ville Valkonen (National Coalition Party)
• Member of Parliament Aleksi Jäntti (National Coalition Party)
• Member of Parliament Ville Valkonen (National Coalition Party)
• Member of Parliament Heikki Autto (National Coalition Party)
• Member of Parliament Saara-Sofia Sirén (National Coalition Party)
• Member of Parliament Susanne Päivärinta (National Coalition Party)
• State Secretary to the Minister of Social Security Laura Rissanen (National Coalition Party)
• State Secretary to the Minister of Finance Riikka Slunga-Poutsalo (Finns Party)
• State Secretary to the Minister of Justice Teija Makkonen (Finns Party)
• Special Adviser to the Minister of Social Affairs and Health Marjo Lindgren (Finns Party)

 

EU elections

Finance Finland’s position

Finance Finland wants Finland to represent a strong and unified EU while also looking after the interests of Finland and its citizens. The financial sector has considerable influence as a driver of European stability and financial security and a promoter of the dual green and digital transition. We published our own EU policy objectives on 12 March.

Meetings with decision-makers

• Member of Parliament Aura Salla (National Coalition Party)
• Member of Parliament Ville Valkonen (National Coalition Party)
• Member of Parliament Aleksi Jäntti (National Coalition Party)
• Member of Parliament Susanne Päivärinta (National Coalition Party)
• Member of Parliament Katri Kulmuni (Centre Party)
• Member of Parliament Matias Marttinen (National Coalition Party)

By March 2024, we had also participated in the EU election seminars of the following candidates:

• MEP Eero Heinäluoma (Social Democratic Party)
• MEP Henna Virkkunen (National Coalition Party)
• Member of Parliament Maria Ohisalo (Greens)
• Member of Parliament Mika Lintilä (Centre Party)
• Member of Parliament Maria Guzenina (Social Democratic Party)
• Member of Parliament Atte Harjanne (Greens)

 

Digital euro

Finance Finland’s position

In Finance Finland’s opinion, the digital euro involves too many unanswered questions and actual risks. We fail to see what additional value the digital euro would bring to the already functional and efficient monetary system. The amount that an individual citizen could hold in digital euros should be limited to as small as possible. We consider it important to ensure that no interest is paid on digital euros: the new currency must not turn into an instrument of investment. The anonymity of the currency must also be critically evaluated especially from the viewpoints of crime and grey economy. Banks must be in a key role in the development of the digital euro and in ensuring a level regulatory playing field. The launch of the digital euro must be based on a political decision.

Meetings with decision-makers

• MEP Ondrej Kovarik (Renew Europe)
• MEP Henna Virkkunen (National Coalition Party)
• MEP Nils Torvalds (Swedish People’s Party)

 

Open finance and the FIDA framework

Finance Finland’s position

Finance Finland has reservations about the European Commission’s proposal for a framework for financial data access (FIDA) because of its failure to provide concrete and applicable solutions. Especially problematic are the definition and categories of customer data. The proposal has a very broad scope of application in terms of the customer data and the service providers subject to the regulation. In Finance Finland’s opinion, the proposal must be clarified and delimited considerably. We are in favour of a gradual implementation of the framework and a transition period of at least three years for establishing data sharing systems.

Meetings with decision-makers

• MEP Ondrej Kovarik (Renew Europe)
• MEP Sirpa Pietikäinen (National Coalition Party)

 

Reform of the Act on the Openness of Government Activities

Finance Finland’s position

The Finnish Act on the Openness of Government Activities is under extensive review. It has been proposed that its scope of application be extended also to public tasks, not only the exercise of public authority. Finance Finland wants to maintain the current scope of application, under which pension providers and non-life insurers are subject to the act only when they exercise public authority. EU regulation does not treat private insurance activity as the performance of a public task or exercise of public authority.

Meetings with decision-makers

• State Secretary to the Minister of Justice Terhi Mikkonen (Finns Party)
• State Secretary to the Minister of Social Security Laura Rissanen (National Coalition Party)

 

The Banking Union’s crisis management and deposit insurance (CMDI) framework

Finance Finland’s position

In April 2023, the Commission adopted a proposal for the reform of the bank crisis management and deposit insurance (CMDI) framework. The objective of the proposal is to extend the scope of the crisis resolution mechanism to small and medium banks. The proposal also aims to enhance the use of deposit guarantee funds to finance resolution.

Finance Finland does not think it wise to expand the range of covered deposits or to use deposit guarantee funds to cover banks’ losses. The assets of a deposit guarantee fund must only be used for the practical arrangements of crisis management and must be paid back in full. The superpriority of the deposit guarantee fund and the covered depositors must be ensured.

It must be clearly specified that regular insolvency measures still take priority over the CMDI resolution process. 

Meetings with decision-makers

• MEP Sirpa Pietikäinen (National Coalition Party)
• MEP Nils Torvalds (Swedish People’s Party)
• Member of Parliament Katri Kulmuni (Centre Party)
• Member of Parliament Susanne Päivärinta (National Coalition Party)
• Member of Parliament Ville Valkonen (National Coalition Party)

 

Retail Investment Strategy (RIS)

Finance Finland’s position

The legislative proposals related to the EU Retail Investment Strategy (RIS) cover all sectors of the capital markets union, various investment products and their sales practices. In Finance Finland’s opinion, cross-sectoral reforms must be implemented so that each sector’s specificities and national viewpoints are taken into account. Disclosure regulation must be clarified to improve investor protection, and existing inducements regulation must not be amended. We are not in favour of the complex value-for-money benchmarks mechanism and strongly endorse finding an alternative solution that does not turn into price regulation. The changes must not hamper functioning competition in the market. The legislative proposals are being negotiated in the European Parliament and between member states in the Council in spring 2024.

Meetings with decision-makers

• Chairman of the Commerce Committee Sakari Puisto (Finns Party)
• MEP Eero Heinäluoma (Social Democratic Party)
• MEP Sirpa Pietikäinen (National Coalition Party)

 

The financial sector’s growth strategy

Finance Finland’s position

The Finnish government programme states: “The Government will draw up a growth strategy for the financial sector, which will include conducting a comprehensive assessment of financial market regulation.” After the programme was published in autumn 2023, Finance Finland met with ministers, ministerial advisers and officials and lobbied for the appointment of a high-level working group tasked to prepare the growth strategy with financial sector representation. On 26 February 2024, the Ministry of Finance appointed a working group to work on the growth strategy. Finance Finland was given a place in the monitoring group. According to the appointment decision, the objective of the growth strategy is to assess how the financial sector could better promote sustainable economic growth while increasing the number of jobs and amount of tax revenue in Finland.

Meetings with decision-makers

• Prime Minister Petteri Orpo (National Coalition Party)
• Minister of Economic Affairs Wille Rydman (Finns Party)
• Member of Parliament Matias Marttinen (National Coalition Party)
• State Secretary to the Ministry of Finance Juha Majanen

 

Pension reform and Self-Employed Persons’ Pensions Act (YEL)

Finance Finland’s position

Finance Finland’s objective is to ensure that the views of pension providers are taken sufficiently into account when decisions on the pension reform are made. Finance Finland’s members can contribute to matters related to investment operations and solvency. Equity risk must not be increased any more than necessary. The pension reform must be implemented responsibly: the level of contributions must be sustainable and benefits adequate. The pension system must incentivise employment and take into account intergenerational fairness.

The development of the self-employed persons’ pension system (YEL) must continue. The implementation of YEL must remain with earnings-related pension providers.

Meetings with decision-makers

• Minister of Social Security Sanni Grahn-Laasonen (National Coalition Party)

 

Private ownership and wealth creation

Finance Finland’s position

Saving and investing can help prepare for the future and fulfil long-term goals. Saving and investing are available to everyone – nearly anyone can become a saver, investor and owner. Personal savings also improve society’s carrying capacity. In Finance Finland’s opinion, saving through retail investment must be promoted. Personal wealth can be increased by investing in funds, insurance, equity, bonds and other investment products.

In its government programme, the Government promised to explore the possibility of creating an equity savings account for newborns, where the State will grant each newborn Finnish child an initial investment as part of the maternity pack. Finance Finland supports the idea but considers it important to assess the inclusion of other instruments in addition to equities.

As regards the promotion of voluntary pension saving, Finance Finland supports lowering the minimum age limit of withdrawals to the age of retirement. 

Meetings with decision-makers

• Prime Minister Petteri Orpo (National Coalition Party)
• Minister of Finance Riikka Purra (Finns Party)
• Minister of Economic Affairs Wille Rydman (Finns Party)
• Member of Parliament Ville Valkonen (National Coalition Party)
• Member of Parliament Aleksi Jäntti (National Coalition Party)
• Member of Parliament Matias Marttinen (National Coalition Party)

 

Prudential regulation of the insurance sector (Solvency II)

Finance Finland’s position

Solvency II provided a prudential framework that harmonises insurers’ solvency provisions, calculation of technical requirements and supervision of solvency in the EU.

In autumn 2021, the Commission adopted a proposal for an amending directive to review the Solvency II directive. Finance Finland’s position on the proposal was that insurers’ existing solvency requirements must be eased and simplified. Insurers’ reporting burden is currently excessive.

In late 2023, the Council, the Parliament and the Commission reached an agreement on the amending directive in their tripartite negotiations. The negotiation result does not meet Finance Finland’s objectives; instead, it will significantly increase insurers’ reporting burden. The principle of proportionality will be automatically applied, but the number of Finnish insurance companies in the scope of application will be very small. Positive aspects of the Solvency II review include certain reductions in insurers’ capital requirements.

Meetings with decision-makers

• MEP Eero Heinäluoma (Social Democratic Party)

 

Insurance companies’ crisis recovery and resolution

Finance Finland’s position

The Solvency II directive already regulates insurance companies’ solvency and risk management. It works well and would meet the Commission’s key objectives after a few minor amendments. The problem with the proposed Insurance Recovery and Resolution Directive (IRRD) is that it is copied straight from the Bank Recovery and Resolution Directive (BRRD) although the business models of the two sectors differ significantly.

Tripartite negotiations on the directive were finalised at the end of 2023. The negotiation result does not solve the fundamental problems of the IRRD – instead, the directive will only drive failing insurance companies deeper into trouble. Finance Finland is especially disappointed with the resolution funding arrangements and the Commission’s obligation to look into the harmonisation of national insurance guarantee schemes. We consider them poor additions to the Commission’s original proposal. 

Meetings with decision-makers

• MEP Eero Heinäluoma (Social Democratic Party)