Finland and six other EU member states, have not been able to implement NPL-Directive, which was supposed to be implemented already on 29th of December 2023.

European Commission has decided to refer Finland and six other member states to Court of Justice of EU for failing to transpose and implement NPL-Directive. Other six member states being, Austria, Bulgaria, Hungary, Netherlands, Spain and Portugal. All other European Union’s member states have communicated their full transposition measures to EC.

According to some sources minimum penalty for Finland has been set into 1 237 000 EUR, which shall be followed by a daily penalty if infringement continues. Finland shall reply on its behalf to the Court of Justice no later than 30th of May 2025.

As we at WOW WORKS are mainly serving Clients within Nordics, here’s a brief overview on the open matter in Finland, which is the only Nordic country who has not transposed the directive yet.

What is NPL-Directive?

NPL-directive is an initiative to improve secondary market of Non-Performing Loans, establishing rules for the authorisation and supervision of credit purchasers and servicers and enabling a framework for Buyers and Sellers to operate on European wide scale.

What are the roles of different stakeholders in NPL-Directive?

According to Government’s proposal, supervisory authority shall be FIN-FSA. Cost estimation for implementation in FIN-FSA is 1 FTE and cost shall be covered by Supervision Fees
Sellers of NPL’s (Credit Institutions such as banks and other type of lenders)
Buyers of NPL’s (Credit Purchasers such as Debt Collection Agency’s central NPL-investment unit or separate NPL-investors)
Credit Servicers (Debt Collection Agencies central NPL-investment units)
Credit Service Providers (Debt Collection Agencies).

What is the status of NPL-Directive’s implementation in Finland?

NPL-Directive was set on 24th of November 2021 by EC and supposed to be transposed by 29th of December 2023.
Commission sent formal letter of notice to Finland on 24th of January 2024.
EC informed Finland on 25th of July that it has two months to implement the directive.
Ministry of Finance started the implementation on 4th of September 2024.
Governments proposal was drafted on 13th of September 2024 and distributed for commenting round the same day. Commenting round was open until 18th of October 2024.
Government distributed the subject to Parliament for preliminary debate on 19th of December 2024 and subject was sent to committee hearing. Debate included no major comments for the committee work (except minimizing the effects for the businesses)
Parliament’s Commerce Committee has started the committee hearing on Government’s proposal to Parliament on 19th of February 2025 and decided to hear stakeholders.
Commerce Committee has closed the hearing of stakeholders on 6th of March 2025.
Commerce Committee is currently preparing and finalizing Government’s proposal on implementing an Act on Credit Purchasers and Credit Servicers. No dates have been communicated publicly.