FINLAND Trends and Developments Contributed by: Rosa Lång and Joona Linner, Lieke Attorneys Ltd
Looking Ahead: Finland’s Cybersecurity Landscape
tional damage. Clear internal allocation of responsibili - ties, defined escalation paths, and integration of legal and communications functions into response planning are necessary to ensure coherent management of incidents and regulatory reporting. Engagement with competent authorities and sector peers may further support co-ordinated responses in high-impact situ - ations. Regulatory preparedness has assumed increased importance as European cybersecurity frameworks become fully operational in Finland. Supervisory expectations extend beyond formal compliance and require demonstrable effectiveness. Organisations should therefore maintain comprehensive documen - tation of risk management measures, ensure timely and accurate incident reporting mechanisms, and evi - dence board-level oversight and continuous review of cybersecurity practices. Cyber risk also has significant contractual implica - tions, particularly in ICT and outsourcing arrange - ments. In the Finnish market, unlimited liability often applies to breaches of confidentiality, raising the criti - cal question of when a cybersecurity incident con - stitutes unauthorised disclosure triggering uncapped liability. The interaction between confidentiality, infor - mation security and data protection clauses must therefore be carefully structured, especially in ransom - ware scenarios involving data exfiltration. Without pre - cise drafting, organisations may face materially higher exposure than anticipated. Finally, resilience depends on third-party risk manage - ment and workforce awareness. Structured vendor due diligence, contractual cybersecurity safeguards and assessment of supply chain dependencies are essential to mitigating cascade effects. At the same time, targeted employee training and cross-functional crisis exercises reinforce organisational preparedness and clarify accountability. In Finland’s evolving regulatory landscape, cyberse - curity has become a core legal and governance con - sideration that permeates commercial risk allocation and strategic decision-making at board level.
Finland’s digital ecosystem continues to evolve rap - idly. For organisations operating in or into the Finnish market, cybersecurity must be assessed as a dynamic regulatory, geopolitical and transactional variable rath - er than a static compliance obligation. Key develop - ments to monitor include: • the final designation of entities under the CER, clarifying which organisations will face enhanced resilience and continuity obligations as critical enti - ties; • ongoing implementation of the CRA, and how product security requirements intersect with national supervisory expectations and market surveillance; • growing regulatory scrutiny, with authorities increasingly benchmarking sector preparedness, governance maturity and the quality and timeliness of incident reporting; • the integration of AI and automation in both defensive and offensive cyber operations – a trend expected to accelerate and to influence both risk exposure and regulatory responses; and • deepening cross-border co-operation and public- private partnerships, particularly within the EU and NATO frameworks, aimed at streamlining threat intelligence exchange and strengthening collective resilience. An additional example of the expanding regulatory perimeter is the treatment of dual-use technolo - gies. Certain cybersecurity tools – such as advanced encryption, intrusion software or surveillance-related technologies – may qualify as dual-use items under EU export control rules. For Finnish technology com - panies, this means that exporting such solutions out - side the EU, or engaging in cross-border transactions involving sensitive technologies, can trigger licensing requirements and enhanced due diligence obliga - tions. Cybersecurity strategy therefore increasingly intersects with export control and national security considerations. To thrive in the Finnish jurisdiction, organisations will need to adopt forward-looking cybersecurity strat - egies that integrate regulatory compliance, export
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