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title: "Finland Crypto Regulation Monitor | cryptoassets.gi"
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description: "Finland crypto asset regulation: 8 categories, 37 sourced findings, updated 2026-11-02. Licensing, token classification, stablecoins, tax treatment."
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# Finland Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/finland/), [World Payments](https://payments.gi/jurisdictions/finland/)

Last updated 2026-11-02 · 8 categories · 37 sourced
findings · 35 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-02 · Position last changed: 2026-11-02 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

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Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority Finanssivalvonta (FIN-FSA) Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) None scheduled No dated future statutory milestone on record

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 5 Open gaps 37 Findings

7 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

Law made at European Economic Area (Bloc) level that applies in Finland is covered once, on the [European Economic Area (Bloc)](/jurisdictions/european-economic-area-bloc/) page. This page covers Finland’s own layer: implementation, national authorities, national options and local enforcement.

## Jurisdiction lead brief

###### Latest update · 2 November 2026

#### Lead Signal

Finland's crypto-asset regime has completed its transition to the EU's harmonised framework, with the Financial Supervisory Authority (FIN-FSA) now operating as the primary authorisation and supervisory body for crypto-asset service providers under the Markets in Crypto-Assets Regulation. Providers that previously operated under Finland's national Virtual Currency Provider regime faced a transitional deadline of 30 June to submit their applications for authorisation under the new framework, and FIN-FSA received eight such applications by that date. This closes one of the shorter national transition windows seen across the EU and leaves FIN-FSA working through a defined, bounded pipeline of legacy applicants rather than an open-ended stream. For any firm providing regulated crypto-asset services in Finland, the operative fact is now straightforward: authorisation is required regardless of where the provider is based, and operating without it exposes a firm to enforcement action by FIN-FSA.

#### Other Developments

On the stablecoin side, Membrane Finance Oy, issuer of the EUROe token, has carried its existing Finnish e-money institution licence forward into the new e-money-token category under the harmonised framework, placing it under FIN-FSA's continuing supervision. This is best read as continuity rather than a new entrant: a firm that was already licensed and supervised in Finland has repositioned its existing authorisation to fit the new categorisation rather than seeking licensing from a standing start. No other stablecoin-specific development has surfaced alongside this.

#### Cross-Monitor Connections

No cross-monitor overlap has been identified in the material behind this update.

#### Outlook

With the transition window closed and FIN-FSA holding a known set of legacy applications, the near-term question for Finland is one of processing: how FIN-FSA works through the eight pending applications from firms that operated under the prior national regime, and what approach it takes to any applicant that fails to secure authorisation. The EUROe transition is likely to be treated by FIN-FSA as a template for other Finnish e-money institutions considering the same move, since it demonstrates that an existing licence can be carried forward rather than replaced. Firms operating in or into Finland should expect FIN-FSA's enforcement posture toward unauthorised crypto-asset activity to sharpen now that the formal application window has closed, since the authority's practical tolerance for operating during the transition period no longer applies to new entrants.

5 earlier updates not shown here.

###### Standing brief · as of 3 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Finland's crypto-asset regulatory perimeter has completed its transition to the EU's Markets in Crypto-Assets Regulation (MiCA), with Finanssivalvonta (FIN-FSA) confirmed via ESMA's published list of competent authorities as the national body responsible for authorising and supervising crypto-asset service providers (CASPs) operating in the country. ESMA's own statements record that the EU-wide transitional/grandfathering backstop for legacy providers closed on 1 July 2026, after which any entity providing crypto-asset services to Finnish or wider EU clients without full MiCA authorisation is in breach of EU law; ESMA has separately and publicly called on unauthorised providers to cease operations in the Finnish market and elsewhere in the bloc. This closes out the multi-year run-in period during which providers registered under Finland's now-superseded national Act on Providers of Virtual Currency (572/2019) could continue operating on a transitional basis.

One important caveat sits underneath this otherwise settled picture. A dispute has surfaced over whether 1 July 2026 is the correct closure point for Finland specifically, or whether Finland exercised an option to shorten its own transitional window to six months, closing legacy cover as early as 30 June 2025 -- a full year earlier than the EU-wide backstop. The shorter-window assertion rests only on lower-tier commentary sources, against a directly-sourced ESMA statement for the later date, and the discrepancy has been escalated for human/regulatory confirmation rather than resolved in this cycle. Because the underlying compliance question -- whether a legacy Finnish provider was already unauthorised for up to a year before it believed itself to be -- is binding and materially consequential, this record is held pending confirmation rather than published as fully resolved.

#### Other Developments

Beneath the headline licensing story, Finland's broader crypto framework is now substantially harmonised at EU level. Token classification under MiCA -- covering asset-referenced tokens, e-money tokens, MiFID-II-qualifying security tokens, NFTs, and other crypto-assets -- applies directly in Finland with no material national gold-plating identified. The stablecoin regime (MiCA Titles III-IV) is fully in force, requiring ART and EMT issuers to obtain FIN-FSA authorisation, maintain asset reserves and own-funds buffers, honour holder redemption rights, and publish approved white papers -- though a thin-evidence-sourcing concern has pulled confidence on these specific obligations down from Confirmed to Probable pending Finland-specific corroboration beyond generic MiCA text. Consumer protection obligations -- custody segregation, complaint handling, and fair, clear, non-misleading communication with holders -- are similarly in force and enforceable by FIN-FSA, alongside a standing joint warning from the European Supervisory Authorities urging retail holders to verify a provider's MiCA authorisation before investing.

Two areas remain structurally underdeveloped. First, on-chain activity such as staking, DeFi lending, DEX operation, mining and validator activity has no dedicated Finnish or MiCA-level licensing category; coverage is incidental, arising only where an identifiable legal person happens to fall within a MiCA-defined CASP service category, and further EU-level rulemaking is anticipated but not yet delivered. Second, tax treatment and cross-border transfer detail rest more heavily on secondary commentary than on primary Vero.fi or Finlex text this cycle. Finland taxes crypto trading gains as capital income under the progressive scale -- among the highest effective crypto tax burdens identified in the EU -- and a 2014 Central Board of Taxes ruling (034/2014) treats bitcoin purchases as a VAT-exempt financial service, consistent with the later CJEU position, though the VAT claim's confidence was downgraded after a review noted that a directly on-point primary vero.fi source exists but was not cited this pass. On cross-border transfers, the EU crypto travel rule applies with a zero de minimis threshold to CASP-to-CASP transfers; a separate claim that had asserted a EUR 1,000 threshold in this context was found to self-contradict the module's own narrative and has been corrected to clarify that the EUR 1,000 figure in Finnish AML implementation applies only to conventional fiat occasional transactions and unhosted-wallet due diligence, not the general crypto travel-rule threshold -- the correction itself is capped at Uncertain confidence pending primary confirmation. Third-country providers remain barred from soliciting Finnish/EU clients outside the narrow, client-initiated reverse-solicitation exemption, and Finland-specific sanctions-nexus guidance for crypto transfers has not yet been independently retrieved.

#### Cross-Monitor Connections

Two overlap surfaces are flagged for other monitors in this fleet. Financial-integrity owns the detailed illicit-finance analysis of Finland's AML/CFT obligations for crypto actors -- the 2017 anti-money-laundering act as amended in 2024, and the EU crypto travel rule's originator/beneficiary information requirements -- with this record retaining only disambiguation context per the fleet's module-subscription doctrine rather than duplicating that analysis. World-payments has an adjacent interest in the payments-instrument framing of Finland's ART/EMT stablecoin regime and in the jurisdiction's comparatively high effective crypto tax burden, both of which sit at the boundary between crypto-native regulation and mainstream payments and tax policy.

#### Outlook

The near-term picture for Finland is one of a maturing, EU-harmonised regime with one open compliance-date dispute and several sourcing gaps still to close. Resolution of the Finland-specific transitional-closure date -- whether 1 July 2026 or 30 June 2025 governs legacy-provider grandfathering -- is the single highest-priority open item, given its direct bearing on whether specific providers have already been operating without authorisation. Beyond that, primary-source retrieval from Finlex and Vero.fi, clarification of FIN-FSA's position on staking-as-a-service classification, and confirmation of Finland-specific sanctions-nexus guidance are the main items likely to sharpen this record's confidence levels in a subsequent research pass, without changing the overall direction of travel toward a fully MiCA-anchored national regime.

Read full brief · 1306 words

Key regulatory facts for Finland Regulatory Dimension Finland Standing Position

Jurisdiction Finland (FI)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 37 sourced findings)

Crypto Licensing MiCA is fully in force in Finland, with FIN-FSA confirmed as the designated competent authority for CASP authorisation.

Token Classification MiCA's ART/EMT/security-token/NFT/other taxonomy applies directly in Finland without material national gold-plating.

On-Chain Activity Regime No dedicated Finnish or MiCA-level licensing regime exists for staking, DeFi lending, DEX operation, or mining/validator activity; coverage is incidental via MiCA CASP service categories only, and further EU...

Stablecoin Regime MiCA's ART/EMT authorisation, reserve, redemption and disclosure regime (Titles III-IV) is fully in force under FIN-FSA supervision.

Primary Instruments Cited Finanssivalvonta (FIN-FSA), MiCA Article 143(3) transitional regime, ESMA, Act on Providers of Virtual Currency (572/2019), CASP authorisation (Finland)

Last Confirmed / Updated 2026-11-02 (35 sources in cumulative register)

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### Finland: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable▾

MiCA is fully in force in Finland, with FIN-FSA confirmed as the designated competent authority for CASP authorisation. The EU-wide transitional/grandfathering backstop for legacy Act 572/2019 registrants closed on 1 July 2026 per ESMA, and ESMA has publicly called on unauthorised providers to cease operations. A Finland-specific closure date is disputed against a lower-tier source asserting an earlier 30 June 2025 closure; this discrepancy is under human review and is the substantive basis for this jurisdiction's held publication status. Finland's now-superseded national Act on Providers of Virtual Currency (572/2019) has been effectively replaced by direct MiCA applicability and the 2024 AML Act amendment (414/2024).

Open gap — crypto-int-3 Specific own-funds/prudential-capital figures required by FIN-FSA of named Finnish CASPs beyond the MiCA Annex IV formula not located. no under-indexing note recorded

Open gap — crypto-int-4 National transposition pinpoint and figures for MiCA Article 111 penalties not confirmed. no under-indexing note recorded

#### Crypto Licensing

Finland's crypto-asset licensing regime has moved decisively onto the EU's harmonised Markets in Crypto-Assets Regulation (MiCA) track. Finanssivalvonta (FIN-FSA) is confirmed, via ESMA's published list of competent authorities notified under MiCA, as the designated national authority responsible for authorising and supervising crypto-asset service providers (CASPs) operating in or into Finland. That designation establishes FIN-FSA as the body to which any entity wishing to offer custody, exchange, execution, advice, portfolio management, or related crypto-asset services to Finnish clients must apply for authorisation, and against which MiCA's conduct and prudential requirements are enforceable.

The regime's transitional architecture has now closed at EU level. ESMA's statement on the end of transitional periods under MiCA sets 1 July 2026 as the EU-wide backstop date after which entities providing crypto-asset services to EU clients without a MiCA licence are in breach of EU law, superseding the earlier national registration-based regimes that member states, including Finland, operated during MiCA's phase-in. ESMA has followed that statement with a further, direct public call on unauthorised crypto-asset service providers to cease operations, applicable to the Finnish market under FIN-FSA's supervisory remit as much as to any other EU member state. Together these mark the definitive end of the grace period during which a provider could rely on legacy national authorisation, rather than full MiCA authorisation, to continue serving Finnish or EU clients.

Underneath this generally settled trajectory sits a live and unresolved dispute that materially affects compliance timing for at least some Finnish-facing providers. The EU-wide 1 July 2026 backstop is the position taken by the highest-tier, directly-sourced ESMA material relied on in this research pass. Separately, however, lower-tier commentary -- law-firm and industry-newsletter sources -- asserts that Finland exercised a national option to shorten its own transitional window to six months, which would have closed legacy-provider cover as early as 30 June 2025, a full year earlier than the EU-wide date. This is not a trivial difference: it is a binding, high-materiality question about exactly when a legacy Act-572/2019-registered provider ceased to have any lawful basis to continue operating without full MiCA authorisation. Because the higher-tier source supports the later date and the earlier date rests only on secondary commentary, the claim recording the 1 July 2026 backstop has been retained rather than overwritten, but the discrepancy has been escalated for human and regulatory confirmation rather than resolved definitively in this pass. This dispute is the specific reason the published record for Finland currently carries a held status rather than an unconditional publication.

Separately from the transitional-date question, Finland's own pre-MiCA national framework -- the Act on Providers of Virtual Currency (572/2019), which had required registration with FIN-FSA for virtual currency exchange and custodian wallet providers -- has now been effectively superseded by the combination of direct MiCA applicability and the 2024 amendment to Finland's anti-money-laundering act (414/2024), which brings MiCA-authorised CASPs within the existing obliged-entity AML/CFT framework rather than maintaining a separate parallel licensing track. This is treated as a non-normative historical fact describing the transition between regimes rather than a currently binding rule in its own right.

#### Outlook

The most consequential open item for Finland's licensing module is resolution of the Finland-specific transitional-closure date. Whichever date is ultimately confirmed by FIN-FSA or Finnish implementing legislation, the direction of travel is unambiguous: Finland now operates a single, EU-harmonised CASP authorisation regime under FIN-FSA supervision, with no further national registration route available to new entrants and no remaining lawful basis for legacy providers to operate outside full MiCA authorisation. A secondary, lower-materiality gap is confirmation of the exact title and number of any Finland-specific MiCA-implementing legislation beyond the 2024 AML Act amendment, which has not yet been independently retrieved from Finlex. Neither item is expected to alter the fundamentally settled, green-rated character of this module, but both are expected to sharpen the precision of the record in a subsequent research pass.

Read full sub-brief · 645 words Periodic update · new data 2026-11-02

#### Crypto Licensing

Finland now operates crypto-asset licensing through the EU's harmonised Markets in Crypto-Assets Regulation, with the Financial Supervisory Authority (FIN-FSA) acting as the primary regulatory and supervisory authority for crypto-asset service providers in the country. Authorisation from FIN-FSA is required before a firm may provide regulated crypto-asset services, and this requirement applies irrespective of where the provider is physically located: a firm serving Finnish customers or operating within Finland's market is expected to hold the authorisation regardless of its home base. A provider operating without the required authorisation is exposed to enforcement action by FIN-FSA.

The practical transition story this period concerns the firms that had been operating under Finland's prior national regime for virtual currency providers. Those firms were given until 30 June to submit their applications for authorisation under the new EU framework. FIN-FSA received eight such applications by that deadline. This was one of the shorter national transitional windows offered across EU member states implementing the same framework, which put legacy Finnish providers under tighter time pressure than counterparts in some other jurisdictions to either complete their application or cease operating.

What this means operationally is that FIN-FSA's current licensing caseload for crypto-asset service providers is now, at least with respect to legacy conversions, a closed and countable set: eight applications from firms transitioning out of the old regime, rather than an open stream of national licence holders still working toward authorisation. New entrants to the Finnish market, separately, apply for authorisation under the same EU framework from the outset rather than through any transitional mechanism, since that mechanism was only available to firms already operating under the prior national licence.

#### Outlook

The immediate question for Finland is how FIN-FSA processes the eight pending applications from firms transitioning out of the prior national regime, including whether any of those firms fail to secure authorisation and what happens to their Finnish operations if so. Because the transitional application deadline has now passed, FIN-FSA's tolerance for crypto-asset service providers operating in Finland without current authorisation should be expected to narrow: the grace period associated with the transition from the old national regime to the new EU framework no longer has force for any firm that did not use it. Firms that did not apply by the deadline, and new entrants to the Finnish market generally, face the EU framework's standard authorisation pathway without benefit of any transitional accommodation. Market participants dealing with Finnish-licensed counterparties should treat authorisation status under the new framework, rather than any reference to the old national licence, as the relevant marker of good standing going forward.

5 earlier distinct update(s) Periodic update · new data 2026-10-25

#### Crypto Licensing

Finland's crypto-asset licensing framework rests on Regulation (EU) 2023/1114 (MiCA) together with the national Act on Crypto-Asset Service Providers, with FIN-FSA (Finanssivalvonta) as the supervisory authority. No in-window change to the licensing framework itself was identified. The one development bearing on licensed entities is FIN-FSA's publication, on 1 October 2026, of updated principles for determining the size of penalty payments and administrative fines, which give more explicit and precise weight to early and comprehensive cooperation by a responsible person. This framework applies across all FIN-FSA-supervised sectors, which includes authorised crypto-asset service providers alongside banks, investment firms, and other regulated entities; it is not a crypto-specific instrument, but it is directly relevant to any CASP facing a future FIN-FSA enforcement or sanctions process, since it sets out more precisely how cooperative conduct during an investigation would reduce the eventual penalty.

No new CASP authorisation, revocation, or licensing-condition development was identified for Finland. The supervisory relationship between FIN-FSA and its authorised population of CASPs continues on the standing MiCA framework, with the updated penalty principles representing an incremental but cross-sector procedural change rather than a shift in substantive licensing requirements.

#### Outlook

The near-term question for Finland's licensing position is whether FIN-FSA applies its updated, more explicit cooperation-weighted penalty principles in any forthcoming CASP enforcement matter, which would be the first visible test of the new framework in a crypto-specific context. No such matter has been identified as pending.

Periodic update · new data 2026-10-18

#### Crypto Licensing

Finland's crypto-asset licensing framework rests on Regulation (EU) 2023/1114 (MiCA) together with the national Act on Crypto-Asset Service Providers, with FIN-FSA (Finanssivalvonta) as the supervisory authority. No in-window change to the licensing framework itself was identified this cycle. The one development bearing on licensed entities is FIN-FSA's publication, on 1 October 2026, of updated principles for determining the size of penalty payments and administrative fines, which give more explicit and precise weight to early and comprehensive cooperation by a responsible person. This framework applies across all FIN-FSA-supervised sectors, which includes authorised crypto-asset service providers alongside banks, investment firms, and other regulated entities; it is not a crypto-specific instrument, but it is directly relevant to any CASP facing a future FIN-FSA enforcement or sanctions process, since it sets out more precisely how cooperative conduct during an investigation would reduce the eventual penalty.

No new CASP authorisation, revocation, or licensing-condition development was identified for Finland this cycle. The supervisory relationship between FIN-FSA and its authorised population of CASPs continues on the standing MiCA framework, with the updated penalty principles representing an incremental but cross-sector procedural change rather than a shift in substantive licensing requirements.

#### Outlook

The near-term question for Finland's licensing position is whether FIN-FSA applies its updated, more explicit cooperation-weighted penalty principles in any forthcoming CASP enforcement matter, which would be the first visible test of the new framework in a crypto-specific context. No such matter has been identified as pending.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Finland's national virtual-currency provider regime has been fully repealed. FIN-FSA confirmed that the national transition period for virtual-currency providers ended 30 June 2025, and the prior registration act (the Act on Virtual Currency Providers, 2019) is repealed in favour of the European Markets in Crypto-Assets Regulation. MiCA CASP authorisation from FIN-FSA is now the exclusive route for any entity seeking to actively offer or market crypto-asset services in Finland.

A transitional mechanism permitted legacy Finnish virtual-currency registrants who filed a complete MiCA application by 30 October 2024 to continue operating under national law until 30 June 2025 or a FIN-FSA authorisation decision, whichever came first. Only seven companies met this filing deadline, a strikingly small number given the size of the prior registered population, and this figure has not been updated in the evidence reviewed with how many of those seven have since received full authorisation. Legacy registrants who did not file, or whose applications were not granted, are legally required to have ceased Finnish operations. This is a tightening development: the exclusivity of MiCA authorisation, combined with the low transitional filing count, points to a materially smaller authorised operator base in Finland than existed under the light-touch national registration regime, with outcomes for the seven 2024 filers still unconfirmed.

#### Outlook

The principal open question is how many of the seven legacy applicants have since secured full MiCA CASP authorisation, and whether any operators continued serving Finnish clients past 30 June 2025 without a finalised decision. Until this is confirmed, the true size of Finland's lawfully authorised crypto-asset-service population remains uncertain, which has direct implications for both consumer access and supervisory capacity at FIN-FSA.

Periodic update · new data 2026-09-14

#### Crypto Licensing

Finland's crypto-asset licensing regime has moved decisively past its transitional phase. The pre-MiCA national VASP registration regime, previously administered by FIN-FSA under Finnish virtual-currency-provider rules, closed its grandfathering window on 30 June 2025. From that date, any entity wishing to provide crypto-asset services in Finland has required full authorisation as a crypto-asset service provider under Title V of Regulation (EU) 2023/1114, the Markets in Crypto-Assets Regulation. Five CASPs are now authorised under this regime, and the practice-guide research reaching this cycle names Coinmotion Oy as the first entity to secure MiCA authorisation in Finland, in July 2025, alongside other named authorised providers including Kvarn Capital Oy and NorthCrypto Oy.

The supervisory authority for this regime is FIN-FSA, the same body that supervised the predecessor national regime, giving the transition institutional continuity even as the substantive legal basis shifted from national law to directly-applicable EU regulation. Because MiCA is directly applicable across the European Economic Area, Finland's implementation carries no material national divergence from the EU baseline in the areas reached by this cycle's research: the licensing criteria, ongoing prudential requirements and supervisory expectations for a Finnish CASP are essentially those set at Title V of MiCA itself, applied by FIN-FSA as the competent national authority.

This settled position is reflected in the confidence and durability of the underlying finding: the closure of the grandfathering window and the resulting five-CASP population are treated with confirmed confidence, resting on a Tier-2 industry practice-guide source. That said, no direct FIN-FSA primary-source bulletin was independently retrieved this cycle to corroborate the specific five-CASP count, so while the structural fact of the completed transition is solid, the precise population figure carries a residual sourcing gap that a future cycle's retrieval of FIN-FSA's own public register would close.

#### Outlook

Barring a MiCA-level amendment at the EU level, Finland's crypto-licensing regime is now in a stable, fully operative state, with FIN-FSA continuing to supervise the CASP population under Title V. The principal item to watch is direct regulator-sourced confirmation of the CASP register, which would upgrade the current five-CASP figure from an industry-practice-guide citation to a primary-source finding.

Periodic update · new data 2026-08-25

#### Crypto Licensing

Finland's crypto-asset service provider licensing regime completed its transition to full Markets in Crypto-Assets Regulation authorisation this cycle. The national VASP grandfathering period, which had permitted continued operation under Finland's pre-MiCA national regime, expired 30 June 2025; from that date, every CASP operating in Finland has been required to hold full MiCA authorisation issued by FIN-FSA (Finanssivalvonta). Five CASPs are reported authorised as of this cycle, including Kvarn Capital Oy, NorthCrypto Oy and Coinmotion Oy, though this figure rests on a secondary Tier-3 source rather than a direct citation to FIN-FSA's own authorisation register, which was not independently queried this cycle.

The regime is assessed as settled: the traffic-light status is green, reflecting that the framework is fully in force with a hard transition deadline already passed, rather than pending or provisional. For an operator or counterparty assessing Finland as a crypto-asset jurisdiction, the practical implication is that there is no longer any national-licence alternative to MiCA authorisation -- FIN-FSA's MiCA authorisation is the sole legal gateway to providing crypto-asset services from or into Finland.

#### Outlook

The principal item to verify next cycle is the exact, current FIN-FSA-authorised CASP count and register listing, independently confirmed against finanssivalvonta.fi rather than secondary commentary. Absent a material regulatory change, Finland's crypto-licensing regime should be expected to remain in its current settled, fully-transitioned state.

Sources and findings (6)
- T1 · European Securities and Markets Authority (ESMA)[Finanssivalvonta (FIN-FSA)](https://www.esma.europa.eu/sites/default/files/2024-12/List_of_Competent_Authorities_notified_to_ESMA_under_MiCA.pdf) — CASP authorisation for crypto-asset service providers operating in Finland
- T1 · European Securities and Markets Authority (ESMA)[MiCA Article 143(3) transitional regime](https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf) — 1 July 2026; entities providing crypto-asset services to EU clients without a MiCA licence after this date are in breach of EU law
- T1 · European Securities and Markets Authority (ESMA)[ESMA](https://www.esma.europa.eu/sites/default/files/2026-06/ESMA75-113276571-1710_Public_Statement_MiCA_transitional_period_ends.pdf) — the Finnish market under FIN-FSA supervision following the 1 July 2026 transitional expiry
- T1 · Finlex / Finnish Ministry of Justice[Act on Providers of Virtual Currency (572/2019)](https://www.finlex.fi/fi/laki/ajantasa/2017/20170444) — MiCA authorisation and the 2024 AML Act amendment (414/2024) bringing MiCA-authorised CASPs within the obliged-entity framework
- T3 · Chambers Practice Guides[CASP authorisation (Finland)](https://www.licentium.io/hub/finland) — MiCA
- T3 · Helsinki Times[Legacy VCP-Act providers (Finland)](https://www.eduskunta.fi/sv/arenden-och-omrostningar/riksdagsarenden/handlingar/edktunnus/EDK-2024-AK-15460) — 2026-06-30

### Finland: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable▾

MiCA's ART/EMT/security-token/NFT/other taxonomy applies directly in Finland without material national gold-plating. ART and EMT issuance requires FIN-FSA authorisation; MiFID II-qualifying security tokens remain under existing securities-markets supervision; NFTs are generally excluded absent large-series fungible-like issuance; other crypto-assets fall under MiCA Title II public-offer requirements.

Periodic update · new data 2026-10-25

#### Token Classification

EUROe, issued by Finland's Membrane Finance Oy (now operating as Paxos Issuance Europe Oy) under a Finnish e-money institution authorisation, was the first stablecoin to receive authorisation under MiCA, in June 2024. According to the issuer's own notice, EUROe has now been placed into redemption-only mode, meaning no new units are being minted and no new trading in the token is occurring, while redemption of existing holdings continues to be available to holders. The exact date on which this decision was taken has not been confirmed; the issuer's notice does not state it, and no independent regulatory confirmation of the status or its timing was located.

This is a material status change for a token that had stood as the flagship example of a MiCA-authorised euro-denominated e-money token issued from Finland. Because the underlying authorisation was granted as an e-money token under MiCA Title III/IV, a move to redemption-only status would ordinarily reflect a decision by the issuer to cease active issuance while preserving holder redemption rights, but the precise regulatory characterisation of this status, and whether FIN-FSA has taken or will take any supervisory position on it, is not established on the present record.

#### Outlook

The key open item is confirmation of the date EUROe was placed into redemption-only mode and whether this reflects a permanent wind-down or a temporary pause in issuance; neither has been confirmed by the issuer or by FIN-FSA as. Clarification from either source would materially sharpen Finland's token-classification picture, given EUROe's position as the first MiCA-authorised stablecoin.

Periodic update · new data 2026-10-18

#### Token Classification

EUROe, issued by Finland's Membrane Finance Oy (now operating as Paxos Issuance Europe Oy) under a Finnish e-money institution authorisation, was the first stablecoin to receive authorisation under MiCA, in June 2024. According to the issuer's own notice, EUROe has now been placed into redemption-only mode, meaning no new units are being minted and no new trading in the token is occurring, while redemption of existing holdings continues to be available to holders. The exact date on which this decision was taken has not been confirmed; the issuer's notice does not state it, and no independent regulatory confirmation of the status or its timing was located this cycle.

This is a material status change for a token that had stood as the flagship example of a MiCA-authorised euro-denominated e-money token issued from Finland. Because the underlying authorisation was granted as an e-money token under MiCA Title III/IV, a move to redemption-only status would ordinarily reflect a decision by the issuer to cease active issuance while preserving holder redemption rights, but the precise regulatory characterisation of this status, and whether FIN-FSA has taken or will take any supervisory position on it, is not established on the present record.

#### Outlook

The key open item is confirmation of the date EUROe was placed into redemption-only mode and whether this reflects a permanent wind-down or a temporary pause in issuance; neither has been confirmed by the issuer or by FIN-FSA as at this cycle. Clarification from either source would materially sharpen Finland's token-classification picture, given EUROe's position as the first MiCA-authorised stablecoin.

Periodic update · new data 2026-09-14

#### Token Classification

Token classification in Finland is governed entirely by the directly-applicable EU framework set out in Titles III and IV of Regulation (EU) 2023/1114, the Markets in Crypto-Assets Regulation, with no FI-specific supplementary classification regime identified in this cycle's research. What distinguishes this cycle for Finland is a concrete instance of that classification framework being used commercially: Paxos Issuance Europe Oy, an electronic-money institution licensed in Finland, has launched USDG, a USD-denominated stablecoin issued under the MiCA-compliant electronic-money-token or asset-referenced-token regime.

This development is significant less as a novel legal finding and more as evidence that Finland's MiCA implementation is functioning as a live issuance base rather than a purely dormant framework. The classification of USDG under MiCA's token-type taxonomy determines the specific prudential, reserve-backing, and redemption obligations that apply to Paxos Issuance Europe Oy as issuer, and the fact that a licensed Finnish EMI chose Finland as its issuance base for a USD-denominated token is itself a signal of confidence in the jurisdiction's MiCA implementation, albeit one drawn from a single Tier-2 practice-guide citation and therefore held at probable rather than confirmed confidence.

No FI-specific gap or ambiguity in the underlying classification framework was identified this cycle: the applicable law is the same directly-applicable EU regulation that governs token classification across the European Economic Area, and FIN-FSA is the supervisory authority responsible for applying it to Finnish-based issuers and service providers.

#### Outlook

The most useful signal to track going forward is whether additional issuers follow Paxos Issuance Europe Oy's example and use a Finnish EMI licence as an EEA issuance base, which would corroborate this cycle's single-source finding with a broader pattern and would justify upgrading confidence from probable toward confirmed.

Periodic update · new data 2026-08-25

#### Token Classification

MiCA Titles III and IV establish the classification framework for asset-referenced tokens and e-money tokens applicable directly in Finland, without any national derogation identified this cycle. This direct-application structure means Finnish-based token issuers work against a single EU-wide classification framework rather than a nationally-variable one, reducing classification-divergence risk relative to earlier, non-harmonised national regimes. The most concrete evidence of this framework's operability this cycle is the issuance of USDG, a MiCA-compliant USD stablecoin, by Paxos Issuance Europe Oy, a Finnish e-money institution, passported across the European Economic Area under the e-money-token provisions.

The traffic-light status for this module is green, reflecting direct EU regulation application with no national derogation identified. FIN-FSA (Finanssivalvonta) is the supervisory authority for token-classification matters as for crypto licensing generally.

#### Outlook

Continued monitoring of whether further token issuers, particularly asset-referenced-token issuers, establish a Finnish base following Paxos's e-money-token launch is warranted, as is confirmation of USDG's practical EEA-wide passporting uptake in subsequent cycles.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-02

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### Finland: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

No dedicated Finnish or MiCA-level licensing regime exists for staking, DeFi lending, DEX operation, or mining/validator activity; coverage is incidental via MiCA CASP service categories only, and further EU rulemaking is anticipated.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-02

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### Finland: C4 Stablecoin RegimeGreenEnacted in forceModule confidence: Probable▾

MiCA's ART/EMT authorisation, reserve, redemption and disclosure regime (Titles III-IV) is fully in force under FIN-FSA supervision. Confidence on four claims (authorisation, reserve requirement, redemption right, disclosure) was downgraded from Confirmed to Probable per a thin-evidence-module sourcing-bar review requiring FI-specific corroboration beyond generic MiCA text.

Periodic update · new data 2026-11-02

#### Stablecoin Regime

Membrane Finance Oy, issuer of the EUROe stablecoin, has carried forward its pre-existing Finnish e-money institution licence into the e-money-token category created under the EU's harmonised crypto-asset framework. The effect is that a firm already licensed and supervised in Finland as an e-money institution has repositioned that existing authorisation to sit within the new stablecoin-specific category, rather than seeking an entirely new licence from a standing start. Membrane Finance continues under FIN-FSA's supervision in this capacity.

This is best understood as a continuity event rather than a new market entry: EUROe was already operating under Finnish e-money regulation before the harmonised EU framework took effect, and the transition reflects the issuer's existing regulatory footprint being reclassified to match the new category rather than any change in the underlying business or a fresh supervisory relationship being established. No other Finland-specific stablecoin development has surfaced alongside this transition, and the broader shape of Finland's stablecoin regulatory environment beyond this single issuer's repositioning has not been independently re-examined.

#### Outlook

The EUROe transition is likely to function as a reference point for any other Finnish e-money institution weighing whether to move into e-money-token issuance under the new framework, since it demonstrates a path that preserves an existing licence rather than requiring a fresh authorisation process. Whether other Finnish-licensed e-money institutions follow the same path, and whether FIN-FSA's supervisory approach to e-money-token issuers evolves as more licensees make the same transition, are the open questions to watch. Because this update rests on a single issuer's transition and has not been corroborated against FIN-FSA's own published register of authorised entities, the detail should be treated as provisional until confirmed against a primary regulatory source.

Periodic update · new data 2026-09-14

#### Stablecoin Regime

Finland's stablecoin regime is the fully operative MiCA electronic-money-token and asset-referenced-token framework set out in Titles III and IV of Regulation (EU) 2023/1114, which entered into force on 30 June 2024 and has been in live operation since. The regime is directly applicable EU law, applied and supervised in Finland by FIN-FSA, and this cycle's research confirms it is not merely a paper framework: Paxos Issuance Europe Oy, a Finland-licensed electronic-money institution, is an active issuer under this regime, having launched USDG, a USD-denominated stablecoin.

The presence of an active issuer operating from a Finnish licence is the clearest available evidence that the stablecoin regime is functioning as intended rather than sitting dormant pending market entrants. This finding carries confirmed confidence for the general statement that the regime is fully operative, resting on the directly-applicable and already-in-force status of MiCA Titles III-IV, with the specific Paxos/USDG detail held at the probable confidence appropriate to a single Tier-2 industry source.

No FI-specific stablecoin rule beyond the EU baseline was identified this cycle — Finland has not layered additional national requirements onto the MiCA stablecoin regime as far as this cycle's research reached, meaning an issuer's compliance obligations in Finland track the EU-wide EMT/ART requirements directly, supervised locally by FIN-FSA.

#### Outlook

The regime itself is settled; the item to watch is issuer-level activity — specifically, whether Paxos Issuance Europe Oy's USDG launch attracts further stablecoin issuance activity to Finland, or whether it remains an isolated instance. Either outcome would be a useful signal for assessing Finland's competitive position as an EEA stablecoin-issuance base relative to other MiCA member states.

Periodic update · new data 2026-08-25

#### Stablecoin Regime

Finland's stablecoin regime, governed by MiCA Titles III and IV and directly applicable across the EU including Finland since 30 June 2024, has this cycle produced its first concrete operative demonstration: USDG, a MiCA-compliant USD stablecoin issued by Paxos Issuance Europe Oy, a Finnish e-money institution, passported across the European Economic Area. The launch confirms that Finland's stablecoin framework functions in practice, moving the jurisdiction from a state of regulatory readiness to one of demonstrated operability.

The traffic-light status is green, reflecting that the regime is fully in force with an active market entrant demonstrating its operability. FIN-FSA (Finanssivalvonta) supervises stablecoin issuance under this framework. For counterparties or issuers assessing where to base EEA-passported stablecoin issuance, Finland's completed regulatory transition and now-demonstrated operability are relevant comparative factors.

#### Outlook

Whether additional stablecoin issuers follow Paxos's example in choosing a Finnish e-money-institution base, and how USDG's EEA-wide passporting performs operationally, are the principal items to watch in coming cycles.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-02

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### Finland: C5 Consumer ProtectionGreenEnacted in forceModule confidence: Probable▾

MiCA's conduct-of-business rules -- custody segregation, complaint handling, and fair/clear/non-misleading communication -- are in force and enforceable by FIN-FSA. The European Supervisory Authorities, including FIN-FSA, have jointly warned consumers of residual crypto-asset risk and limited legal protection even where a provider is MiCA-authorised.

Open gap — crypto-int-1 Finnish statutory pinpoint transposing MiCA Article 75 custody duties for Finnish-authorised CASPs not located. tax_treatment is a structurally thin-coverage module across the estate per BIAS CORRECTIONS.

Open gap — crypto-int-2 No FIN-FSA-specific guidance on MiCA Title VI market-abuse surveillance expectations located. no under-indexing note recorded

#### Consumer Protection

Finland's crypto-asset consumer protection framework is anchored in MiCA's conduct-of-business rules, which are fully in force and enforceable by FIN-FSA against any CASP authorised in Finland. MiCA-authorised CASPs must keep clients' crypto-assets and funds segregated from the CASP's own assets and are prohibited from using client assets for their own account -- a custody-segregation safeguard directly analogous to client-asset protection rules in conventional financial services regulation. CASPs authorised in Finland must also establish and maintain effective and transparent procedures for handling client complaints promptly, fairly, and consistently, giving Finnish consumers a defined internal escalation route before any recourse to FIN-FSA or ombudsman-type mechanisms. Beyond internal process obligations, crypto-asset offerors and CASPs operating in Finland are subject to a substantive communications standard: all communication with holders must be fair, clear and non-misleading, and holders must be treated equally unless any preferential treatment is expressly disclosed.

Sitting alongside these binding CASP-level obligations, Finland's consumer protection posture also includes a broader risk-awareness dimension. The European Supervisory Authorities, including FIN-FSA as one of the national authorities jointly issuing the statement, have publicly warned consumers that crypto-assets can be risky and that legal protection may be limited even where a provider is MiCA-authorised, and have recommended that consumers verify a provider's MiCA authorisation status before investing. This warning is not itself a binding rule but functions as a standing supervisory communication reinforcing the message that MiCA authorisation, while a meaningful protective threshold, does not eliminate market and product risk for retail holders.

#### Outlook

This module's core legal architecture is settled and unlikely to shift materially absent a broader MiCA amendment cycle. The main developments likely to affect this record going forward are enforcement-level: FIN-FSA complaint-handling statistics, any published enforcement actions concerning custody-segregation breaches, or updated ESA risk warnings, none of which have yet been located in Finland-specific form in this research pass.

Read full sub-brief · 309 words Periodic update · new data 2026-09-28

#### Consumer Protection

MiCA CASP authorisation introduces consumer-protection requirements in Finland that did not exist under the prior national virtual-currency registration regime. Authorised CASPs must maintain segregated custody of client crypto-assets, meet defined capital requirements, provide pre-trade fee transparency, and operate a formal complaints path for clients. None of these obligations were mandatory under Finland's previous light-touch national registration model, making this one of the more substantive consumer-facing changes accompanying the MiCA cutover.

Because MiCA authorisation passports across the EEA, a CASP authorised in Finland can serve clients across the bloc without separate national licensing, and conversely a CASP authorised elsewhere in the EEA can serve Finnish clients under the same consumer-protection floor. This means the consumer-protection uplift is not a Finland-specific enhancement so much as Finland's adoption of the harmonised EU standard, replacing what had previously been a nationally-determined and comparatively lighter registration regime. The practical benefit to Finnish consumers depends on how quickly the authorised-CASP population stabilises following the transition-period cutover; with only seven legacy applicants having filed by the 31 October 2024 deadline, the near-term population of CASPs actually subject to these protections in a Finnish context may be smaller than the prior registered population, even as the per-provider protection standard rises.

#### Outlook

The consumer-protection gains from CASP authorisation will only be realised for Finnish users to the extent that authorised providers, whether Finland-domiciled or passporting in from elsewhere in the EEA, actually serve the Finnish market at scale. Tracking the resolution of the seven legacy applicants' authorisation status will clarify whether Finland retains a domestically-supervised CASP presence or shifts toward reliance on passported providers.

1 earlier distinct update(s) Periodic update · new data 2026-09-14

#### Consumer Protection

The completion of Finland's transition to full MiCA CASP authorisation carries a direct and well-evidenced consumer-protection consequence: crypto-asset customers of FIN-FSA-authorised CASPs now benefit from a structurally uplifted protection regime compared with the prior national virtual-currency-provider registration framework. MiCA authorisation brings with it segregated custody requirements for client crypto-assets, minimum capital requirements for the CASP itself, fee-transparency obligations toward customers, and a formal complaints-handling path that did not exist in comparable form under the pre-MiCA national regime.

This is treated as a probable-confidence finding: the structural uplift is well evidenced by the shift in the underlying legal framework itself — from a lighter-touch national registration regime to a harmonised EU authorisation regime carrying substantive prudential and conduct obligations — even though no single Finland-specific enforcement action or consumer complaint outcome was surfaced this cycle to illustrate the uplift in concrete operation.

The practical effect for a Finnish crypto-asset customer is that dealing with a FIN-FSA-authorised CASP today carries meaningfully different protections than dealing with a virtual-currency provider did under the pre-2025 national regime: segregation of client assets from the CASP's own balance sheet, capital buffers intended to reduce the risk of provider insolvency, and a defined path for raising and escalating complaints are now baseline features of the authorised market rather than optional good practice.

#### Outlook

The consumer-protection uplift is now a structural feature of the Finnish market rather than a pending change. The item to watch is whether FIN-FSA or the CASP population generate concrete enforcement or complaints-handling case data in future cycles that would allow this finding to move from a structural, framework-level assessment toward a confirmed, evidenced operational one.

Sources and findings (4)
- T2 · EUR-Lex / European Union[MiCA-authorised CASPs](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=legissum:4626998) — clients' crypto-assets and funds segregated from own assets and not use client assets for own account
- T2 · EUR-Lex / European Union[CASPs authorised in Finland](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=legissum:4626998) — effective and transparent procedures for handling client complaints promptly, fairly and consistently
- T1 · EUR-Lex / European Union[Crypto-asset offerors and CASPs operating in Finland](https://eur-lex.europa.eu/legal-content/FI/ALL/?uri=CELEX%3A32023R1114) — fair, clear and non-misleading, treating holders equally absent disclosed preferential treatment
- T1 · European Banking Authority (EBA)[European Supervisory Authorities (incl. FIN-FSA)](https://www.eba.europa.eu/publications-and-media/press-releases/eu-supervisory-authorities-warn-consumers-risks-and-limited-protection-certain-crypto-assets-and) — crypto-assets can be risky and legal protection may be limited, recommending verification of provider MiCA authorisation before investing

### Finland: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

Verohallinto taxes crypto trading gains as capital income under the progressive scale, among the highest effective crypto tax burdens in the EU. A 2014 Central Board of Taxes ruling (034/2014) treats bitcoin purchases as VAT-exempt, aligned with the CJEU Hedqvist position; confidence on the VAT claim was downgraded to Probable after a review noted an uncited but existing primary vero.fi source. Reporting-obligation mechanics including DAC8/CARF implementation remain unverified.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-02

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### Finland: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾

The EU crypto travel rule (Reg 2023/1113) applies with a zero de minimis threshold to CASP-to-CASP transfers; a self-contradictory EUR 1,000-threshold claim was corrected this cycle, with confidence capped at Uncertain pending primary confirmation. Third-country providers are barred from soliciting Finnish/EU clients outside the client-initiated reverse-solicitation exemption. Finland-specific sanctions-nexus guidance remains unretrieved.

Periodic update · new data 2026-09-14

#### Cross-Border Transfer

A Finnish MiCA authorisation functions as an EEA-wide passport for crypto-asset services, under the passporting mechanism set out in Title VI of Regulation (EU) 2023/1114. A CASP that has obtained authorisation from FIN-FSA can provide crypto-asset services across the European Economic Area without needing to seek separate national authorisation in each additional member state where it wishes to operate. This finding is held at confirmed confidence, reflecting the well-evidenced and directly-applicable nature of the MiCA passporting regime itself.

For cross-border transfer purposes specifically, this means that a crypto-asset service provider based and authorised in Finland is not confined to the Finnish market: its authorisation carries legal effect across the EEA, materially lowering the compliance cost of EEA-wide expansion compared with the pre-MiCA landscape, in which national VASP registrations typically had to be sought and maintained separately in each jurisdiction of operation.

This passporting capability is directly relevant to Finland's positioning as a potential EEA base for crypto-asset operations: the five CASPs already authorised by FIN-FSA, and issuers such as Paxos Issuance Europe Oy operating a stablecoin from a Finnish licence, are each in a position to extend their authorised activities into other EEA member states on the strength of their Finnish authorisation, without incurring the cost of a fresh national licensing process in each target market.

#### Outlook

The passporting mechanism itself is settled EU law and not subject to material near-term change. The item to watch is empirical: whether Finnish-authorised CASPs actually exercise passporting rights into other EEA markets at scale, which would corroborate Finland's positioning as a genuine cross-border issuance and service base rather than a purely domestically-focused licensing jurisdiction.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-02

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### Finland: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾

AML/CFT content for Finnish crypto-asset actors is a subscribed surface owned by financial-integrity per fleet module-subscription doctrine; this record retains disambiguation context only (Act 444/2017 as amended by 414/2024) and carries no independent claims this cycle.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-02

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