means a power source which is reliant on Hydrocarbons.

The Arbitration Committee of the Finland Chamber of Commerce (FCC) has opened registration for the Helsinki International Arbitration Day (HIAD) conference, scheduled for 16 May 2025 at the Clarion Hotel Helsinki. The conference will examine recent legislative reforms in Finland and Europe, artificial intelligence applications in arbitration and developments in arbitration advocacy. The event brings together legal practitioners, academics and business leaders from Nordic countries and beyond, concluding with a networking reception and dinner.

The Finland Chamber of Commerce (FCC) has announced the appointment of six new members to the board of the Finland Arbitration Institute (FAI) for a three-year term commencing 1 January 2025. The new appointees, comprising legal professionals from diverse backgrounds, include partners from law firms, in-house counsel, and academics specialising in international procedural law. This refresh of the FAI Board aims to bring new perspectives to its work, as noted by FAI Secretary General Henrik Sajakorpi. The announcement also details the full composition of the FAI Board effective from the start of 2025, including both Finnish and international members, and acknowledges the contributions of six outgoing members who will conclude their terms at the end of the current period.

1. What is the applicable legislation? The subject matter is covered by the Act on the Monitoring of Foreign Corporate Acquisitions in Finland (172/2012, the MFCA). 2. Which government or other body (or bodies) reviews foreign investments? The Ministry of Economic Affairs and Employment (MEAE) and the Council of State (in case the MEAE considers it necessary to refer the matter to the Council (which is the only authority with jurisdiction to prohibit an acquisition). 3. What is the scope of the foreign investment regime? Does it only apply to specific sectors or types of investors (eg foreign or non-EU / non-WTO)? Are there specific rules for certain types of investors (eg state-owned enterprises)? The scope of the MFCA covers acquisitions whereby a foreign owner gains at least 10%, a third (1/3) or half (1/2) of the total voting rights or a corresponding control in a monitored entity, which are defined as companies: • active in the defence industry–defence sector companies are corporations or business undertakings which produce or supply defense equipment or other services or products important for

This table summarises all completed investigations by Finland’s competition authority (the Finnish Competition and Consumer Authority—FCCA) into alleged cartels, anti-competitive agreements and abuses of dominant positions (Articles 101/102 TFEU and national equivalents) since 2018. Note—only investigations that have been made public are included in this table. 2025 Investigations under Article 101 TFEU/Chapter 2, section 5 of the Competition Act The FCCA did not issue any decisions under Article 101/Section 5 in 2025. Investigations under Article 102 TFEU/Chapter 2, section 7 of the Competition Act The FCCA did not issue any decisions under Article 102/Section 7 in 2025. 2024 Investigations under Article 101 TFEU/Chapter 2, section 5 of the Competition Act The FCCA did not issue any decisions under Article 101 TFEU/Section 5 in 2024. Investigations under Article 102 TFEU/Chapter 2, section 7 of the Competition Act The FCCA did not issue any decisions under Article 102/Section 7 in 2024. 2023 Investigations under Article

NOTE—to see whether notification thresholds in Finland and throughout the world are met, see further: Where to Notify. 1. There have been recent developments regarding the Finnish merger control regime. What are the main points of interest and are any further updates/developments expected in the coming year? Are there any other ‘hot’ merger control issues in Finland? Finnish merger control rules are included in the Competition Act (No. 948/2011), which entered into force on 1 November 2011 repealing the Act on Restrictions on Competition (No. 480/1992). Merger control rules were first introduced into Finnish competition legislation on 1 October 1998. The 2011 Competition Act introduced some amendments to the merger control provisions, which mainly further harmonised the Finnish merger control rules with EU rules. The main amendments were the replacement of the dominance test with the SIEC test applied by the European Commission (Commission) and certain amendments to the procedural rules to further align the merger control process with that of the Commission. The merger notification thresholds were changed in a legislative amendment that entered into force at the beginning of

Loan market and developments Please provide a brief overview of the current state of the loan markets in your jurisdiction and any significant recent market developments. Reflecting the slow market in investments as well as leveraged and real estate transactions in recent years, the activity in the Finnish loan markets has been subdued, mainly focusing on refinancings and amendments/extensions. The number of project financings has also been low due to the heavy expansion of wind energy investments in the early 2020s and the overcapacity created in the sector thereby. However, we have seen an increasing number of investments in energy storage systems and data centers. We expect this activity to keep expanding together with investments across different themes from energy and infrastructure to growth companies and defense. We also expect the overall market to pick up as activity increases in the real estate and leveraged markets and we have also seen signs of this in early 2026. On the supply side, the Finnish market has so far only seen limited activity from private credit players, partly

The European Data Protection Board has reported that the Finnish Supervisory Authority (SA) has imposed a €2.4m fine on Posti for unlawful processing of personal data. The SA found violations of EU General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR) Articles 5, 6.1, 13, and 25, including automatic creation of electronic mailboxes without consent and inadequate customer information. Posti received a reprimand for informational shortcomings and was ordered to rectify its unlawful practices, particularly focusing on data protection by design in its electronic services.

The Finnish Supervisory Authority (SA) has fined S-Bank EUR 1.8m and issued a reprimand for breaches of the EU General Data Protection Regulation (EU) 2016/679 (EU GDPR) after investigating a personal data breach reported in August 2022. The breach occurred when a new login function introduced in April 2022 contained a software flaw allowing customers to access others’ online banking accounts using strong authentication, leaving the vulnerability exploitable for more than three months and affecting a significant number of users. The SA found that S-Bank had failed to implement adequate safeguards, properly test the software, or respond appropriately to customer reports of login anomalies, violating Articles 5(1)(f), 25(1), 32(1), and 32(2) of the EU GDPR. The penalty reflected the seriousness of the breach, the protection of individuals’ rights, a prior reprimand, and consideration of a related EUR 7.67m fine imposed by the Finnish Financial Supervisory Authority in May 2025 for negligence in managing operational risks.

A wide range of activities in which companies use technology to make financial services, enable financial services or drive technological innovation of financial services. This could be in the areas of banking, insurance, investing and can be in relation to both retail and corporate markets.

This Practice Note considers IP issues specifically in relation to fintech. It covers fintech and intangible assets, fintech IP strategy, copyright, open source software, brand protection, trade secrets, impact of artificial intelligence (AI) and practical steps. Fintech is technology used in the provision of financial services and may include, for example: • software for electronic payments using conventional currency, such as software which implements protocols for atomicity, consistency, isolation, durability (ACID) transactions (where ‘ACID’ is a set of properties of the transaction) • software for making transactions using a blockchain distributed ledger • quantum equipment and software for implementing ‘quantum money’ • trained machine learning systems for making automated-lending decisions for loans to individuals or businesses • trained machine learning systems for assisting with pension fund management • software for automated trading of securities and/or derivatives • software used by an enterprise, for automated price setting of goods or services sold by the enterprise in particular markets • autonomous, rule-based systems for providing financial advice to individuals • trained machine learning software for anti-money laundering

Innovation and new technologies have had an impact on most industries. The evolution of technology is largely driven by a desire to reduce costs and increase efficiency. Within the debt capital markets, the level of technology and innovation disruption has been minimal, largely because of the high barriers to entry including capital requirements and regulatory scrutiny. However, new technologies are increasingly being embraced within the debt capital markets. What is fintech? There is no universal definition of ‘fintech’, but it is a term that is broadly used to describe innovation in financial services that is enabled by technology. Examples of such innovation include: • cryptocurrencies/cryptoassets (eg bitcoin) • blockchain or distributed ledger technology (DLT) • artificial intelligence (AI) and machine learning (ML) • crowd funding platforms • ‘telematics-based’ insurance (eg where data is collected to monitor driving), and • mobile banking Why is fintech being explored for the debt capital markets? There are three main reasons why the debt capital markets are being increasingly subject to technological innovation. These include: • a drive for cost efficiency