Annual report of Finance Finland’s lobbying activities in 2022

Reporting period 1/2022–6/2023

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. Each year, we work on an average of 100 projects. About 20 of these are related to themes that require careful and lengthy dialogue with political decision-makers and high officials.

The names of the persons listed in the lobbying report have been published due to their significant political position. Our efforts over the past 18 months have been focused especially on the Finnish government programme for the term 2023–2027.

We support greater transparency in all lobbying that seeks to influence the preparation of legislation and the use of budgetary powers in Finland and in the EU. The previous parliamentary term culminated in the approval of the act on a statutory transparency register in February 2023. The act will enter into force at the start of 2024. The goal is to increase the openness and transparency of lobbying by obligating legal entities and sole proprietors to report all their lobbying activities and professional lobbying consultation targeted at the Parliament or the ministries.

Finance Finland has been open about its lobbying activities even before the transparency register was established: we have disclosed the names of the political decision-makers, i.e. members of the Finnish Parliament, ministers and state secretaries to the ministers, 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 2022 below. The listing discloses Finance Finland’s position on each issue and the decision-makers we met with.

General – Government programme

FFI’s position

Finance Finland’s objectives for the next government programme were approved by the Board in March 2022. They focus on three main themes: sensible regulation – less is more; moderation in taxation – bolstering growth; and money talks green – using finance and investment to turn the tide towards sustainability. The Board made further refinements to the objectives in early 2023. After the government programme objectives were confirmed, we began actively lobbying them in meetings with political decision-makers. We also held several events for various focus groups and met with personal assistants, parliamentary group staff and other ministry officials, whose names are not included in this report.

Meetings with decision-makers

Prime Minister, party leader Sanna Marin (Social Democratic Party)
Minister of Finance, party leader Annika Saarikko (Centre Party)
Minister of Justice, party leader Anna-Maja Henriksson (Swedish People’s Party)
Minister of the Environment and Climate Change, party leader Maria Ohisalo (Greens)
Minister of Education, party leader Li Andersson (Left Alliance)
Minister of Science and Culture Antti Kurvinen (Centre Party)
Minister for European Affairs Tytti Tuppurainen (Social Democratic Party)
Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
Legal Affairs Committee chair Leena Meri (Finns Party)
Social Affairs and Health Committee chair Markus Lohi (Centre Party)
Member of Parliament, party leader Petteri Orpo (National Coalition Party)
Member of Parliament, party leader Sari Essayah (Christian Democrats)
Member of Parliament Matias Marttinen (National Coalition Party)
Member of Parliament Ville Valkonen (National Coalition Party)
Member of Parliament Mari-Leena Talvitie (National Coalition Party)
Member of Parliament Elina Valtonen (National Coalition Party)
Member of Parliament Sari Multala (National Coalition Party)
Member of Parliament Sakari Puisto (Finns Party)
Member of Parliament Ville Tavio (Finns Party)
Member of Parliament Juho Eerola (Finns Party)
Member of Parliament Vilhem Junnila (Finns Party)
Member of Parliament Iiris Suomela (Greens)
Member of Parliament Mikko Savola (Centre Party)
Member of Parliament Jouni Ovaska (Centre Party)
Member of Parliament Arto Pirttilahti (Centre Party)
Member of Parliament Arto Satonen (National Coalition Party)
Member of Parliament Sofia Vikman (National Coalition Party)
Member of Parliament Inka Hopsu (Greens)
Member of Parliament Marko Kilpi (National Coalition Party)
Member of Parliament Pia Kauma (National Coalition Party)
Member of Parliament Sari Multala (National Coalition Party)
Member of Parliament Janne Sankelo (National Coalition Party)
Member of Parliament Janne Heikkinen (National Coalition Party)
Member of Parliament Esko Kiviranta (Centre Party)
Member of Parliament Antti Lindtman (Social Democratic Party)
Member of Parliament Matias Mäkynen (Social Democratic Party)
Member of Parliament Hilkka Kemppi (Centre Party)
Member of Parliament Atte Harjanne (Greens)
Member of Parliament Anders Adlercreutz (Swedish People’s Party)
Member of Parliament Saara-Sofia Sirén (National Coalition Party)
Member of Parliament Mari Rantanen (Finns Party)
MEP Sirpa Pietikäinen (National Coalition Party)
MEP Alviina Alametsä (Greens)
State Secretary to the Minister of Family Affairs and Social Services Eila Mäkipää (Social Democratic Party)
State Secretary to the Minister of Employment Ville Kopra (Social Democratic Party)
State Secretary to the Minister of Finance Timo Reina (Centre Party)
National Coalition Party leadership
Centre Party leadership
Board of the Federation of Green Youth and Students
Board of the Youth of the National Coalition Party
Board of the Swedish Youth of Finland
Board of the Finnish Centre Youth

We also participated in the election seminars of parliamentary candidates.

Finance Finland's objectives for the Finnish government programme

Sustainable finance legislation

FFI’s position

We are in favour of developing science-based sustainability classifications that are aligned with the goals of the Paris Agreement. The classifications should be based on the recommendations of the Technical Expert Group (TEG) set up by the European Commission. Ideally, sustainable finance regulation increases clarity, transparency and trust in financial markets, making them more attractive and justified from the consumer perspective.

Meetings with decision-makers

MEP Sirpa Pietikäinen (National Coalition Party)
MEP Henna Virkkunen (National Coalition Party)
MEP Ville Niinistö (Greens)
MEP Eero Heinäluoma (Greens)
Minister for European Affairs Tytti Tuppurainen (Social Democratic Party)
Minister of Agriculture and Forestry Antti Kurvinen (Centre Party)

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. Finance Finland considered these changes justified. A full reform would have been unreasonably expensive for both the public and private sector.

We supported the state-led development of a digital identity and personal identifiable data. The maintenance of personal identifiable data and the digital distribution of electronic initial identification data fall under the jurisdiction of the state quite naturally.

Earlier plans also included the introduction of a new personal unique identifier that would, at first, only be used by businesses, authorities and communities and would not be disclosed to the individual it identifies. Finance Finland opposed the idea of a parallel identifier due to the heavy costs and potential confusion it would cause.

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 proposal was presented to the Parliament in September 2022. We actively lobbied against the continuation of this legislative project for a new personal identifier. The legislative proposal was eventually allowed to lapse in late February 2023.

Meetings with decision-makers

Minister of Local Government Sirpa Paatero (Social Democratic Party)
Minister of Transport and Communications Timo Harakka (Social Democratic Party)
Minister of Economic Affairs Mika Lintilä (Centre Party)
State Secretary to the Minister of Finance Timo Reina (Centre Party)
Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
Constitutional Law Committee chair Johanna Ojala-Niemelä (Social Democratic Party)
Member of Parliament Riikka Purra (Finns Party)
Member of Parliament Sakari Puisto (Finns Party)
Member of Parliament Mari-Leena Talvitie (National Coalition Party)
Member of Parliament Juha Pylväs (Centre Party)
Member of Parliament Hanna Holopainen (Greens)
Member of Parliament Hanna Huttunen (Centre Party)
Member of Parliament Tiina Elo (Greens)
Member of Parliament Eveliina Heinäluoma (Social Democratic Party)
Member of Parliament Piritta Rantanen (Social Democratic Party)

Reform of the Act on the Openness of Government Activities

FFI’s position

Pension providers and non-life insurers perform public tasks and are therefore subject to the Act on the Openness of Government Activities regarding documents related to the exercise of public authority. The Act is under extensive review, and 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. A Ministry of Justice working group is tasked with preparing a government proposal in the second half of 2023.

Meetings with decision-makers

Minister of Justice Anna-Maja Henriksson (Swedish People’s Party)
Minister of Science and Culture Antti Kurvinen (Centre Party)
Minister of Transport and Communications Timo Harakka (Social Democratic Party)
Member of Parliament Matias Marttinen (National Coalition Party)
Member of Parliament Sari Multala (National Coalition Party)
Member of Parliament Mari-Leena Talvitie (National Coalition Party)

Households’ excessive indebtedness

FFI’s position

Our objective has been to ensure that any new measures aimed at preventing 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. The draft Government proposal for measures to curb household indebtedness was submitted to the Finnish Parliament in summer 2022. Finance Finland supported some of the changes, such as introducing the loan-to-value limit to housing company loans and extending regulation to cover different creditors on a broad basis.

Some of the changes we considered problematic, especially the proposal about the Finnish Financial Supervisory Authority (FIN-FSA) being authorised to give credit institutions orders pertaining to the limits and distributions on the assessment of insolvency risk. This would practically constitute solvency supervision, which is fully harmonised in the EU.

The proposal for measures to curb the indebtedness of households was approved by the Parliament in January 2023. The FIN-FSA was granted new powers that also apply to credit institutions, as laid out in the proposal. The new legislation entered into force on 1 July 2023.

Meetings with decision-makers

Minister of Finance Annikka Saarikko (Centre Party)
State Secretary to the Minister of Finance Timo Reina (Centre Party)
Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
Member of Parliament Katri Kulmuni (Centre Party)
Member of Parliament Matias Mäkynen (Social Democratic Party)

Self-Employed Persons’ Pensions Act (YEL)

FFI’s position

From Finance Finland’s viewpoint, the question of how entrepreneur income should be assessed and confirmed has always been a key problem in the context of the self-employed persons’ pension scheme. Pension contributions and the social security they accumulate should be based on the actual amount of work the entrepreneur does, but many entrepreneurs currently pay smaller pension contributions than their income would require. This leads to small pensions and insufficient social security.

Various working groups under the lead of the Ministry of Social Affairs and Health have been working on a reform of the Self-Employed Persons’ Pension Act (YEL). A government proposal that introduced more tools for the determination and adjustment of YEL income was made in June 2022. The proposal roused much public debate, and a petition by citizens demanding changes to the proposal was submitted in September.

The Parliament approved the final version of the proposal to amend the YEL act in December. The transitional provisions, for example, were changed to slow down the act’s impact especially on small enterprises.

Meetings with decision-makers

Minister of Social Affairs and Health Hanna Sarkkinen (Left Alliance)
Social Affairs and Health Committee chair Markus Lohi (Centre Party)
State Secretary to the Minister of the Interior Akseli Koskela (Greens)
State Secretary to the Minister of the Environment Terhi Lehtonen (Greens)
State Secretary to the Minister of Economic Affairs Ann-Mari Kemell (Centre Party)
Centre Party leadership

Provision of financial services in emergency conditions

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.

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 and proposed a high-level meeting to discuss future steps. The first meeting with the authorities was held in June 2021. The matter did not otherwise progress during the year.

The idea of regulating this matter in law was raised again in spring 2022. Amendments to chapter 5, section 16 of the Act on Credit Institutions and a new act on certain backup and emergency arrangements in the financial sector entered into force on 11 July 2022. The preparation of these acts was done urgently and in secret, and Finance Finland did not get the chance to comment on their substantive content or proposals. Implementation was also started under non-disclosure agreements between the authorities and banks, which did not allow Finance Finland to participate or the sector participants to discuss the matter with each other in advance.

More preparedness regulation is to be introduced in the financial sector both nationally and on the EU level. The amendments implemented in 2022 do not set aside, restrict or otherwise affect the EU regulation that applies to credit institutions or their services.

Meetings with decision-makers

Minister of Finance Annikka Saarikko (Centre Party)
Minister of Justice Anna-Maja Henriksson (Swedish People’s Party)
Minister of Social Affairs and Health Hanna Sarkkinen (Left Alliance)

Telemarketing laws

FFI’s position

The Finnish Consumer Protection Act was revised in 2022. With the review, Finland implemented the EU Omnibus Directive and also tightened the provisions on door-to-door sales and telemarketing according to the previous government programme.

Tightening the Finnish laws on telemarketing as proposed by the Government was not justified in Finance Finland’s opinion. Financial services, especially insurance and investment services, should have been left outside the scope of application. We also noted that the 12-month period during which a consumer should plead that the contract is non-binding if they wish to prevent its entry into force is too long from the viewpoint of the consumer’s legal protection. There have not been any problems associated with telemarketing in the financial sector. The requirement to send a written confirmation hampers sales processes especially for insurance companies, as the policies will not enter into force until the customer confirms the details in writing. In written confirmations sent via text message, it should be enough to include the essential details of the offer.

The proposal was approved by the Parliament with only a few minor amendments, and the new laws entered into force at the start of 2023. If a product or service is sold to a customer during a telemarketing call, the company may no longer close the deal over the phone but must submit its offer to the customer in writing, and the contract enters into force only after the customer has confirmed the offer in writing. These requirements do not apply to loans and credits.

Meetings with decision-makers

State Secretary to the Minister of Justice Mikaela Nylander (Swedish People’s Party)
Minister of Science and Culture Antti Kurvinen (Centre Party)
Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
Member of Parliament Hanna Kosonen (Centre Party)

Automated decision-making and the public information management act

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 also applies to statutory insurance business. 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 proposals therefore enable sufficient flexibility in automation from the viewpoint of insurance service providers.

The Parliament made some necessary changes to the government proposal before it was approved. Had the proposal been approved as it was, it would have put insurance companies in a difficult position and obstructed the progress of digitalisation. The issues with the original reform were first brought up by the Constitutional Law Committee and then by the Administration Committee, which offered many sensible solutions in its memorandum.

Meetings with decision-makers

Minister of Local Government Sirpa Paatero (Social Democratic Party)
Minister of Transport and Communications Timo Harakka (Social Democratic Party)
Legal Affairs Committee chair Leena Meri (Finns Party)
Constitutional Law Committee chair Johanna Ojala-Niemelä (Social Democratic Party)
Member of Parliament Heikki Vestman (National Coalition Party)
Member of Parliament Sakari Puisto (Finns Party)
Member of Parliament Mari-Leena Talvitie (National Coalition Party)
Member of Parliament Mari Rantanen (Finns Party)
Member of Parliament Eveliina Heinäluoma (Social Democratic Party)
Member of Parliament Piritta Rantanen (Social Democratic Party)

Investment funds’ derogation from the place of effective management provisions

FFI’s position

Investment funds’ derogation from the provisions on the place of effective management will end at the end of 2023. When the act on income tax was amended in 2021, one of the aims was to address the problem of effectively Finland-based businesses registering their domicile abroad to evade taxation.

However, many foreign investment funds are managed from Finland, and it was not desirable that their position should also be affected. They were therefore granted a temporary derogation (which in the Netherlands and Ireland was put forward as permanent), during which the Ministry of Finance and the European Commission were to discuss whether or not the derogation could be treated as state aid.

Discontinuing the fund derogation would enable Finland to consider funds that are effectively managed from Finland to also be domiciled in Finland. However, treating the entities as resident taxpayers would not increase tax income for Finland because the majority of the funds in the scope of the derogation would be comparable to Finnish investment funds, which enjoy full or partial exemption from income taxes. The funds could, however, incur such significant tax implications in their home states that their operations could instantly become unprofitable.

Meetings with decision-makers

Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
State Secretary to the Minister of Finance Timo Reina (Centre Party)
Member of Parliament Matias Marttinen (National Coalition Party)
Member of Parliament Ville Valkonen (National Coalition Party)

Price regulations of consumer credits

FFI’s position

We were in favour of the specifications added to good lending practice as lined out in the government proposal HE 218/2022. The specifications and the related penalty fees enable the authorities to effectively intervene in the improper marketing of consumer credits. The provisions are also appropriately targeted in that their most significant impact focuses mostly on the entities whose operating policies are deficient, not on all lenders in general.

We consider it important that the need to lower interest rate caps is assessed with care, that its likely impact is investigated and that the progress of the other measures to curb over-indebtedness is monitored first. Retroactive legislation that affects existing contractual relationships is concerning as a matter of principle.

In the future, the necessity of all measures to curb the over-indebtedness of consumers must be evaluated in a comprehensive and coordinated manner that also takes into account the overall impact of both existing and upcoming regulation.

Meetings with decision-makers

Member of Parliament Atte Harjanne (Greens)
Member of Parliament Eeva Kalli (Centre Party)
Member of Parliament Katri Kulmuni (Centre Party)

Basel III

FFI’s position

The purpose of the Basel III reform is to improve risk calculation and increase comparability between banks. The Basel Committee’s mandate in the reform was to avoid a significant increase in capital requirements for banks. The Finnish financial sector considers it important to implement the reform in a way that takes into account the special characteristics of the EU financial market. Capital requirements should accurately reflect risks, and their increase should be kept as low as possible.

Finance Finland lobbied on many fronts when the Finnish position in the Basel III negotiations was being prepared. We actively lobbied MEPs in the European Parliament’s ECON committee both on our own and in cooperation with other Nordic banking associations.

In their statements on Finland’s negotiation objectives, the Finnish Parliament’s Commerce Committee and the Grand Committee both proposed some solutions that would secure economic growth and access to lending in Finland. Their stances were mostly in line with Finance Finland’s objectives. According to the Grand Committee, the outcome of the negotiations must not endanger access to low-risk corporate and mortgage funding. The final stages of the negotiations are currently underway.

Meetings with decision-makers

Minister of Finance Annikka Saarikko (Centre Party)
State Secretary to the Minister of Finance Timo Reina (Centre Party)
Grand Committee chair Satu Hassi (Greens)
Commerce Committee chair Sanni Grahn-Laasonen (National Coalition Party)
Member of Parliament Antti Lindtman (Social Democratic Party)
Member of Parliament Jouni Ovaska (Centre Party)
Member of Parliament Hanna Kosonen (Centre Party)
Member of Parliament Eeva Kalli (Centre Party)
Member of Parliament Johannes Koskinen (Social Democratic Party)
Member of Parliament Katri Kulmuni (Centre Party)
Member of Parliament Matias Mäkynen (Social Democratic Party)
MEP Eero Heinäluoma (Social Democratic Party)
MEP Sirpa Pietikäinen (National Coalition Party)
MEP Ville Niinistö (Greens)
MEP Henna Virkkunen (National Coalition Party)
MEP Jonas Fernandez (Progressive Alliance of Socialists and Democrats)
MEP Othmar Karas (European People’s Party)

EU digital finance

FFI’s position

The EU digital single market needs a single rulebook. Finance Finland calls for 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 2022, 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 regarding the European digital identity scheme (eID) proposed by the Commission. The Commission’s proposal for European electronic identification, authentication and trust services (eIDAS) regulation would obligate member states to both issue and recognise EU digital identity wallets, which must also be usable for payment authorisation.

We also have reservations when it comes to the development of a digital euro. The European Central Bank’s (ECB) project and the European Commission’s legislative proposal must not endanger the stability of the banking system or sideline healthy private business. Finance Finland and the Nordic banking sector established a joint group for background discussion to support the work of the ECB’s market advisory group.

Meetings with decision-makers

MEP Henna Virkkunen (National Coalition Party)
MEP Miapetra Kumpula-Natri (Social Democratic Party)
Head of Unit Jan Ceyssens, European Commission, DG FISMA B5
Deputy Head of Unit Mattias Levin, European Commission, DG FISMA B5

Prudential regulation of the insurance sector (Solvency II)

FFI’s position

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

In Finance Finland’s opinion, the existing solvency requirements must be eased and simplified for insurers. The reporting burden must be reduced and the principle of proportionality purposefully applied. Further development of insurers’ solvency and crisis management regulation must avoid overlap. The review must not result in stricter solvency regulations that could hamper insurers’ ability to promote sustainable finance, for example. The final negotiations on the directive proposal are currently underway.

Meetings with decision-makers

MEP Eero Heinäluoma (Social Democratic Party)
MEP Sirpa Pietikäinen (National Coalition Party)
Head of DG FISMA’s Insurance and Pensions Unit Didier Millerot

Insurance companies’ crisis management

FFI’s position

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. 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 proposals made by the Commission, the Council and the EU Parliament would only speed up the problems of failing insurance companies. The changes proposed by the Council and the Parliament would increase resolution funding requirements and the use of this funding to pay shareholders and debtors, which the insurance sector is opposed to. The insurance sector is especially against the Parliament’s proposal to use harmonised national insurance guarantee schemes to finance resolution.

Tripartite negotiations on the directive will begin in autumn 2023, and the final directive is expected to be ready by the end of the year.

Meetings with decision-makers

MEP Eero Heinäluoma (Social Democratic Party)
MEP Sirpa Pietikäinen (National Coalition Party)
Head of DG FISMA’s Insurance and Pensions Unit Didier Millerot

Retail Investment Strategy

FFI’s position

The European Commission has been preparing a proposal aimed at improving retail investor protection. The planned changes concern, among other issues, the offering of investment services, securities investments and insurance-based investment products to retail investors. They also concern the practices that banks, investment firms, insurance companies and other brokers apply when they offer these products to their clients, as well as the disclosure requirements that apply when selling the products.

Finance Finland advocates for effective investor protection and clear rules for the sale of investment products. We believe an effective regime maintains retail investors’ confidence in the functioning of the financial market and encourages them to invest. This area is already heavily regulated at EU level, which has enhanced investor protection in many ways.

Meetings with decision-makers

MEP Heidi Hautala (Greens)
MEP Eero Heinäluoma (Social Democratic Party)
MEP Sirpa Pietikäinen (National Coalition Party)
MEP Ville Niinistö (Greens)
MEP Alviina Alametsä (Greens)
Minister for European Affairs Tytti Tuppurainen (Social Democratic Party)

Securities market regulation

FFI’s position

During the reform of EU securities market regulation, Finance Finland has lobbied in close cooperation with the Nordic Securities Association and met with European Commission officials, Nordic ministers of finance and key MEPs. In addition to the many meetings, we have also been active in producing our own negotiating proposals. Most of the discussions have concerned the proposed amendments to the Markets in Financial Instruments Directive and Regulation (MiFID/R).

In Finance Finland’s opinion, the impacts on the structures of different EU markets and both corporate and retail customers must be taken into account when the proposals enter deliberations. The Nordic capital markets function very well, and the new regulation must not set any unnecessary obstacles for them. We have therefore found the proposed MiFID/R amendments to be supportable in their aims of increasing transparency in trade and establishing a consolidated tape.

Meetings with decision-makers

DG FISMA Head of Securities Market Unit Tilman Lueder
EU presidents France and Czechoslovakia
Attachés of the Finnish, Swedish, Danish and Baltic permanent representations to the EU
MEP Eero Heinäluoma
MEP Sirpa Pietikäinen
MEP Danuta Hübner (European People’s Party)

Corporate Sustainability Reporting Directive (CSRD)

FFI’s position

Finance Finland considers the Corporate Sustainability Reporting Directive (CSRD) a responsible and welcome change that will help create a level playing field in the EU. However, we find some of the technical aspects and substantive solutions in the directive to be concerning. The due diligence provisions of the CSRD must be examined especially in the context of the other directives on market manipulation and insider dealing. In addition, when obligations are imposed on asset managers, the mandates granted by the client must also be taken into account.