Finland's Financial Supervisory Authority (FIN-FSA) is mapping the operating models of companies offering employment services and related invoicing as a platform service, after identifying cases where the activity appears to be organised as payment facilitation between the work orderer and the person performing the work. The authority indicated that these arrangements may include payment services that require a licence under the Payment Institutions Act. FIN-FSA highlighted that a typical licensable payment service involves receiving funds belonging to other parties for onward transfer, unless the payment service activity has been outsourced so that the firm does not hold funds belonging to others. Where payment services are provided, firms must meet requirements on safeguarding client funds, anti-money laundering and counter-terrorist financing controls, operational risk management and the reliability of company management. Over the next weeks, FIN-FSA will contact invoicing service companies operating in the market with requests for clarification to assess their operating models and potential need for licensing.
Finanssivalvonta 2025-01-15
Finland's Financial Supervisory Authority to request clarifications from invoicing service platforms on potential payment services licensing
Finland's Financial Supervisory Authority (FIN-FSA) is examining companies offering employment services and invoicing as platform services for potential licensable payment services under the Payment Institutions Act. FIN-FSA stressed that firms must comply with safeguarding client funds, anti-money laundering, counter-terrorist financing controls, operational risk management, and management reliability. The authority will contact invoicing service companies to assess their models and licensing needs.