FINLAND Law and Practice Contributed by: Jon Hautamäki, Max Atallah and Mikael Huhtala, Nordic Law
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain The past 12 months have been a defining period for blockchain in Finland, shaped primarily by the full application of MiCA from 30 December 2024 and DORA from 17 January 2025. These instruments have replaced the fragmented national VASP registration regime with a harmonised EU-wide authorisation framework. 1.1.1 Evolution of Uses of Blockchain Development Over the Past 12 Months Finland’s transitional period ended on 30 June 2025, by which date all previously registered VASPs were required to obtain CASP authorisation from the FIN- FSA or cease operations. Finland counts five author- ised CASPs, including Kvarn Capital Oy, NorthCrypto Oy and Coinmotion Oy. A notable development was the launch of USDG, a MiCA-compliant USD-denominated stablecoin issued by Paxos Issuance Europe Oy, a Finnish EMI. This was among the first regulated USD-denominated stable- coins issued under MiCA in the EU and is passported across the EEA. The FIN-FSA also updated its AML/ CFT guidance in June 2025 to bring CASPs within its supervisory scope, while the revised Transfer of Funds Regulation extended the travel rule to all crypto-asset transfers regardless of value. Current Use Cases The primary use cases are exchange and execution services, as well as the custody and transfer of crypto- assets. The EBA’s June 2025 no-action letter on the MiCA/PSD2 interaction has introduced a practical compliance consideration: while exchange services involving EMTs fall solely within MiCA, custody and transfer of EMTs on behalf of clients constitutes a payment service, requiring authorisation under both frameworks. CASPs are therefore having to obtain a PSD2 licence or partner with a PSD2-licensed pro- vider. Smart contracts are increasingly relevant, particularly following the EU Data Act becoming applicable in September 2025, which imposes mandatory termina-
tion and suspension mechanisms on smart contracts within its scope. Automated investing and algorithmic trading are permitted under the Investment Services Act. DeFi protocols that are genuinely decentralised remain outside MiCA’s scope, though those with an identifiable central operator are likely to be treated as CASPs. Issues Likely to Impact the Next 12 Months PSD3 and the Payment Services Regulation will be significant near-term developments, given their impli- cations for CASPs handling EMTs. DORA compliance will continue to require attention, particularly regard- ing ICT risk management and contractual oversight of outsourced or sub-contracted services. The European Digital Identity Wallet may also open new use cases for blockchain-based identity and credential verifica- tion. Interaction With Intellectual Property Law There is no blockchain-specific IP regime in Finland. Innovations are protectable by patent through the Finnish Patent and Registration Office or the European Patent Office, and brands through the EUIPO for EU- wide protection. The technology-neutral principle that underpins Finnish regulatory thinking applies equally to IP: the nature of the underlying technology does not alter the availability of protection. No significant tensions between blockchain business models and existing IP law have been reported in Finland. 1.1.2 Regulatory Sandbox Finland does not operate a formal or dedicated nation- al regulatory sandbox specifically geared towards blockchain-based projects. Instead, the FIN-FSA gen- erally engages with firms through the authorisation and registration process and may provide non-binding guidance on regulatory interpretation; this can func- tion as an innovation-facilitation approach, but it is not a sandbox framework offering regulatory exemptions. At EU level, the DLT Pilot Regime established under Regulation (EU) 2022/858 provides the closest sand- box-like framework, focused specifically on market infrastructures for tokenised financial instruments. It enables eligible participants to operate DLT-based multilateral trading facilities, settlement systems or combined trading and settlement systems under time-
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