FINLAND Law and Practice Contributed by: Jon Hautamäki, Max Atallah and Mikael Huhtala, Nordic Law
At EU level, Finnish crypto-asset businesses may engage through organisations such as the Europe- an Crypto Initiative (EUCI), which contributes to EU policy and implementation discussions, including by submitting consultation responses on MiCA-related measures. Blockchain for Europe performs a simi- lar advocacy role as a Brussels-based membership organisation, facilitating dialogue with EU institutions and promoting a European regulatory framework that supports blockchain-based innovation. In practice, firms operating in Finland can engage directly with FIN-FSA through authorisation and supervisory processes, and the MiCA regime has introduced a harmonised EU baseline for govern- ance and conduct requirements across the regulated crypto-asset sector. 2. Regulation 2.1 Regulators and International Alignment The Finnish Financial Supervisory Authority (FIN-FSA) is the primary regulatory and supervisory authority for blockchain and crypto-asset businesses in Finland. It grants and oversees CASP authorisations under MiCA, supervises payment institutions and EMIs, and enforces AML compliance. The FIN-FSA is known for its technology-neutral supervisory approach, making Finland one of the more accessible jurisdictions in the EU for fintech and crypto-asset businesses seeking regulatory engagement. The Finnish Tax Administration is increasingly relevant following the introduction of mandatory reporting obli- gations requiring crypto-asset exchanges to submit detailed customer transaction data, and following the comprehensive updated guidance on crypto-asset taxation issued in December 2025. Finland’s regulatory alignment with international standards is primarily achieved through EU-level implementation rather than direct bilateral engage- ment with international bodies. MiCA, DORA and the revised Transfer of Funds Regulation collectively reflect the FATF’s recommendations on virtual asset service providers, including the travel rule, customer due diligence and AML obligations. The FIN-FSA’s
updated AML/CFT guidance of June 2025 explicitly incorporates CASPs within its scope, replacing the former national category of virtual currency providers, aligning Finnish supervisory practice with FATF stand- ards. Finland participates in EU-level engagement with IOSCO and BIS through the European Bank- ing Authority and European Securities and Markets Authority, which develop binding technical standards under MiCA. 2.2 Crypto-Asset Regulatory Frameworks Crypto-assets in Finland are classified primarily under MiCA, which defines them as digital representations of value or rights transferable and storable electronically using distributed ledger technology. MiCA recognises three categories: • EMTs, referencing one official currency; • ARTs, referencing other values or rights (or their combinations); and • other crypto-assets, including utility tokens, gov- ernance tokens, bitcoin and ethereum. EMTs and ARTs face more stringent requirements, reflecting their potential systemic significance. ESMA’s guidelines of December 2024 provide further criteria for determining when a crypto-asset qualifies as a financial instrument under MiFID II and therefore falls outside MiCA’s scope entirely. No crypto-assets have to date been classified as securities or financial instruments in Finland. For tax purposes, the Finn- ish Tax Administration treats crypto-assets as assets, with EMTs and ARTs treated similarly to conventional currency. MiCA constitutes the principal regulatory framework governing crypto-asset issuance and services in Fin- land. It became fully applicable on 30 December 2024, and Finland’s grandfathering regime for previously registered VASPs expired on 30 June 2025. All opera- tors must now hold CASP authorisation from FIN-FSA, of which five have been granted to date. Alongside MiCA, CASPs are subject to the AML Act, the revised Transfer of Funds Regulation extending the travel rule to all crypto-asset transfers regardless of value, and DORA’s operational resilience requirements applicable from January 2025.
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