Name
Global FinTech Guide
Country _ Name
Finland
SectionTitle
Asset and portfolio management
Body
FinTechs belonging to this category offer asset and portfolio management services via an internet platform or software programs and usually manage and dispose of the assets of their customers long or short term according to their specifications without actually holding the property or the possession of those assets. FinTechs, which provide information about and access to overnight or time deposit accounts at national and foreign banks and which execute the transactions to these accounts, also belong to this category. Some FinTechs however only act on request of the customer.

Aside from that some FinTechs offer software or internet solutions enabling users to manage and plan their personal finances on their own by providing graphics, overviews and compilations of their financial data and sometimes indicating financial risks or opportunities, but without actually managing the assets.

Introduction

Attitude of the country towards modern asset and portfolio management services

Finland has a structured and regulated approach to modern asset and portfolio management services, governed by the Investment Services Act (747/2012). The act defines investment services broadly to include investment advice, portfolio management and the execution of financial instruments. Only entities with specific authorisations, such as banks with a credit institution licence, authorised investment firms, or licensed management companies, may provide these services.

The Finnish Financial Supervisory Authority (FIN-FSA) supervises these entities to ensure they operate reliably and transparently. It requires that investment firms manage business risks effectively, maintain robust internal controls, and ensure business continuity. 

The FIN-FSA also monitors the profitability and capital adequacy of investment firms, imposing limitations to prevent excessive risk-taking that could endanger financial stability. Compliance with ethical codes of conduct and the protection of investors' interests are essential aspects of regulation. In addition, tied agents, acting on behalf of investment firms, must be registered and operate transparently under the supervision of the FINFSA.

Overall, Finland's strict regulatory framework aims to maintain a high standard of integrity and reliability in the provision of asset and portfolio management services.
The growing interest of Finns in investing, coupled with their positive attitude towards technology, suggests significant potential for modern asset and portfolio management services in Finland.


Legal affairs

Obligations and requirements to provide asset and portfolio management, or ancillary services described above

In Finland, providing asset and portfolio management services, along with other investment-related activities, requires specific authorisation under the Act on Investment Services (747/2012). This authorisation is mandatory for all entities, irrespective of the extent or frequency of services offered. Authorised entities include investment firms, fund management companies, alternative investment fund managers, and credit institutions that possess the necessary licenses.

Certain exemptions to this requirement exist. For example, services provided within the same corporate group or activities carried out incidentally during other professional services, such as legal or audit functions, may not fall under the Act. Furthermore, firms that engage in trading solely on their own account, without offering additional investment services—except in specified cases like trading commodity derivatives—are also exempt.

Investment firms are limited to conducting activities covered by their authorisation. However, they may also participate in other legally permissible activities, such as serving as insurance agents, bondholders’ representatives, or custodians, provided they obtain the necessary separate authorisations as stipulated by relevant EU or national legislation.
Additionally, investment services may be offered by credit institutions, fund management companies, and alternative investment fund managers, given that they hold the appropriate authorisation. This structured regulatory framework ensures that only authorised entities can provide asset and portfolio management services.

The provision of these services is further regulated by the MiFID II Directive (2014/65/EU) as implemented by the Act on Investment Services (747/2012). Investment firms are authorised to provide services not only in financial instruments but also in other investments, such as loan agreements. When engaging in such investments, firms must adhere to the same provisions outlined in the Act on Investment Services as they would for financial instruments. Notably, services for these investments cannot be offered under the notification procedure to other EEA member states.

Portfolio management services share a consistent nature regardless of whether they involve financial instruments or other investments. The core focus of these services is to manage a client’s portfolio by making investment decisions and executing related transactions on the client’s behalf. However, it is important to note that portfolio management does not extend to broader management tasks, such as extensive property management for real estate investments.

Additional comments regarding the legal situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

Sales and marketing of asset and portfolio management services is also regulated by the FIN-FSA. Regulation related to the provision of investment services must be complied with in the sales and promotion (marketing) of investment service.

Therefore, an investment service may only be marketed, in addition to the investment firm itself, by tied agents appointed by it. When a social media influencer cooperates with an investment firm, this may lead to circumstances where the influencer promotes, with the content produced, the investment services in a way only allowed for a tied agent.


Economic conditions

Market size for asset and portfolio management services and biggest companies in this business area

There are currently 44 investment firms under the supervision of the Financial Supervisory Authority (FIN-FSA).

Additional comments regarding the economic situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

In legislation, investment services refer to, for example, investment advice, portfolio management and the reception, transmission and execution of orders relating to financial instruments.

Investment services can be provided only by a bank that has received a credit institution authorisation, an investment firm that has received an investment service authorisation and, in the case of portfolio management and investment advice, an authorised management company or alternative investment fund manager.

FinTech companies entering this sector must either obtain a sufficient license or authorisation from the FIN-FSA or partner with an established credit institution to legally provide these services.



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