FINLAND Trends and Developments Contributed by: Jon Hautamäki, Max Atallah and Mikael Huhtala, Nordic Law
between MiCA and the Payment Services Directive (PSD2) for crypto-asset service providers dealing with electronic money tokens (EMTs). The EBA distinguish- es between different types of services: crypto-asset exchange services involving EMTs fall solely within the scope of MiCA, whereas the custody and transfer of EMTs on behalf of clients constitute payment services, requiring authorisation under both PSD2 and MiCA. As most CASPs provide custody or transfer services for EMTs, the guidance effectively requires these provid- ers either to obtain a PSD2 licence in addition to their MiCA authorisation, or to structure their operations in co-operation with a PSD2-licensed payment service provider. In practice, the impact on Finnish CASPs was limited, as FIN-FSA’s consistently strict supervi- sory approach had already led most Finnish operators to hold or actively pursue dual authorisation prior to the EBA’s clarification – what had initially been per- ceived as a demanding regulatory burden ultimately proved to be a competitive advantage: Finnish CASPs were among the first in the EU to meet the EBA’s dual- authorisation expectations without material disruption to their operations. Stablecoins Finland has not only preserved but actively fostered innovation in the stablecoin sector. Far from being a deterrent, the rigorous nature of Finnish regulation laid a strong legal and operational foundation for early adoption and compliance. Even prior to the full enforcement of MiCA, Finland had already emerged as one of the most progressive jurisdictions in the EU for the development of compliant stablecoin solutions. A notable example is Paxos Issuance Europe Oy (formerly Membrane Finance Oy), a licensed Finnish electronic money institution (EMI), which in late 2022 launched the world’s first euro-denominated stable- coin designed to meet the requirements of both the Electronic Money Directive 2 (EMD2) and the MiCA framework. Paxos Issuance Europe Oy was acquired by the global Paxos Group in 2024 and serves as one of the issuing entities of USDG, the US dollar-pegged stablecoin of the Paxos group. During 2025, Paxos launched USDG, a fully regulated US dollar-based stablecoin now available across the European Union. Issued by Paxos Issuance Europe
Oy and compliant with MiCA, USDG provides trusted and transparent stablecoin solutions to millions of consumers across the EEA. Under MiCA, USDG is classified as an e-money token (EMT), a type of sta- blecoin that maintains a stable value by referencing an official fiat currency, in this case the US dollar. Cru- cially, only EMIs and credit institutions are authorised to issue EMTs within the EU. A further transformative shift followed the repeal of the VASP Act in the legal treatment of crypto-asset transactions. Previously, the exchange of goods for crypto-assets, including stablecoins, could trigger registration requirements under the VASP Act. Online retailers accepting payments in stablecoins were required to register as VASPs, facing administrative burdens that discouraged adoption. With the repeal of that Act, such transactions are no longer subject to licensing or registration obligations, lowering the regulatory threshold for merchants to accept crypto- assets as payment and expected to accelerate the mainstream integration of stablecoins in everyday commerce. Taxation of Crypto-Assets in Finland General framework Taxation in Finland is primarily governed by the Income Tax Act and the guidance issued by the Finnish Tax Administration. While the Tax Guidance does not con- stitute binding law, it plays a central role in interpret- ing tax matters related to crypto-assets, reflecting the considered views of the tax authorities and ensuring consistent application of tax rules. Under the Income Tax Act and supported by Finnish case law, crypto-assets are classified as property. As a result, transactions involving the disposal of crypto- assets typically fall within the scope of capital gains taxation. Income derived from crypto mining, such as through Proof of Work consensus algorithms, is gen- erally classified as earned income and taxed progres-
sively under personal income tax rules. Updated tax guidance: December 2025
The Finnish Tax Administration issued comprehensive- ly updated guidance on crypto-asset taxation on 18 December 2025 (reference VH/3057/00.01.00/2025), replacing previous guidance on virtual currencies and
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