For all those that are running an online shop in Finland, there are two key changes to the Finnish Consumer Protection Act applicable from 1 October 2023. The aim of the changes is to reduce consumer debt problems and prevent credit and payment related misconducts.
The first change concerns the presentation of the payment options. When shopping online, the consumer must be presented with payment methods in the following order:
- Payment methods that do not include the possibility of applying for or using credit e.g. online payments, debit or Visa Electron cards, or benefits related to sports and culture.
- Payment methods that may include the possibility of applying for or using credit e.g. combined cards with both debit and credit features and payment applications like MobilePay.
- Payment methods that involve applying for or using credit e.g. a credit agreement, a payment application that involves the use of credit, cash on delivery or invoice.
None of the available payment methods can be pre-selected / chosen as a default – the consumer must select the payment method for each contract individually.
The other key change concerns strong identification of the consumer in case the consumer chooses to delay the payment. The consumer’s identity will have to be verified at the online checkout via strong electronic identification whenever the consumer chooses an option that means delaying the payment, such as an invoice or other extension for payment. The obligation expands the existing strong identification requirements.
There are some other changes in the reform of the Consumer Protection Act (Kuluttajansuojalaki 38/1978), but these are the ones concerning a wide range of actors in the online sphere. Note that fines are possible for not implementing these correctly.
For further information, please contact:
Tobias Bräutigam, Partner, Bird & Bird