Technology companies operating digital services in Finland face a tightening regulatory environment. Finland's implementation of EU digital services legislation, combined with domestic supplementary rules under Finnish information society law, has introduced new compliance obligations that took effect in early 2025. International businesses that fail to act risk enforcement proceedings, administrative penalties, and – in the most serious cases – suspension of service access in the Finnish market.
Finland's digital services regulatory regime now requires technology companies offering intermediary services, online platforms, and AI-enabled digital products to satisfy obligations covering algorithmic accountability, content moderation, software liability disclosure, and technology licensing conditions. Businesses meeting defined user-volume or systemic-risk thresholds must complete compliance assessments and appoint local points of contact by the deadlines set out in the applicable EU and domestic rules. Companies that have not yet mapped their obligations under this regime should treat the matter as urgent.
This alert identifies which business categories are caught, the key threshold criteria, the compliance deadlines that apply, and the immediate steps international companies should take now.
What has changed and when it takes effect
The regulatory shift in Finland stems from two converging developments. First, the EU Digital Services Act became fully applicable to all providers of intermediary digital services across the Union. Second, Finland's domestic supplementary legislation – enacted through Finnish information society and electronic communications law – imposed additional national requirements on providers established in or targeting Finnish users.
The obligations that concern most international technology companies fall into three clusters. The first covers transparency and algorithmic accountability: providers of recommender systems and automated decision-making tools must publish clear disclosures about how their systems operate and offer users meaningful alternatives where technically feasible. The second cluster addresses software liability: companies distributing software products or digital services into Finland must maintain updated documentation of known vulnerabilities and demonstrate a structured incident-response process. The third cluster concerns technology licensing conditions for businesses whose digital products involve third-party intellectual property or data assets licensed under Finnish or EU rules.
Full applicability for very large online platforms and very large online search engines has been in force since mid-2023 at EU level. For all other providers – including the mid-sized and emerging technology companies that form the majority of international entrants – the obligations under Finnish implementing legislation applied from February 2025. Businesses that have not yet audited their position are already operating in a period of potential non-compliance.
For AI-enabled services specifically, the EU AI Act compliance timeline introduces a parallel layer. Prohibited AI practices became unenforceable from February 2025. High-risk AI system requirements will apply in phased stages through 2026 and 2027. Finnish regulators – operating under the authority of the Traficom (Finnish Transport and Communications Agency) and sector-specific bodies – have signalled active interest in early enforcement action against providers that lack documented compliance programmes.
For a broader analysis of how AI Act compliance intersects with technology licensing and platform obligations across Nordic markets, see our practice coverage of AI and technology law in Finland.
Who is affected: threshold criteria and business categories
The new requirements are not limited to large platforms. They apply across a wider range of business categories than many international companies assume.
The primary categories caught by the Finnish digital services regulatory regime include the following:
- Online intermediary platforms connecting buyers and sellers, including marketplaces, app distribution services, and B2B software-as-a-service platforms with Finnish user bases
- Providers of recommender systems, algorithmic content curation tools, or automated profiling services directed at Finnish consumers or businesses
- Companies deploying high-risk AI systems in areas such as recruitment, creditworthiness assessment, biometric identification, or access to essential services
- Software vendors and digital product distributors subject to software liability obligations under Finnish consumer and commercial legislation
- Technology companies holding technology licensing arrangements that involve Finnish-law intellectual property or data-sharing agreements with Finnish counterparties
Threshold criteria vary by obligation. For Digital Services Act purposes, the key thresholds are defined by average monthly active users in the EU. Platforms exceeding defined user-volume levels face heightened due-diligence, transparency, and audit requirements. Below those thresholds, lighter obligations still apply – including terms-of-service transparency, single-contact-point designation, and annual reporting to the competent national authority.
For AI Act compliance, the threshold is risk classification rather than user volume. Any company deploying a system that falls within the high-risk categories set out in the AI Act's annexes must satisfy conformity assessment, registration, and human-oversight requirements – regardless of company size or market share.
A common error among international technology companies is to assume that Finnish rules do not apply because the company is established outside Finland. Under both EU-level and Finnish domestic rules, the determining factor is where the service is offered or where its effects are felt – not where the provider is incorporated. A technology company based in the United States, Singapore, or Brazil that targets Finnish users or operates through Finnish distribution partners is subject to these requirements.
For companies whose digital products also raise questions around technology licensing and intellectual property protection in Finland. Our coverage of intellectual property law in Finland addresses the intersection of software protection, licensing obligations, and enforcement options.
To receive an expert assessment of your company's exposure under Finland's digital services regulatory regime, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies operating digital services in Finland should take the following steps without delay.
Map your obligations now. Conduct a structured review of all digital products and services offered to Finnish users. Identify which regulatory category each product falls into – intermediary service, online platform, AI system, or software product – and confirm which specific obligations apply. This mapping exercise should cover both EU-level and Finnish domestic rules.
Appoint a legal representative in Finland. Providers established outside the EU that offer services in Finland must designate a legal representative within the Union. This representative serves as the point of contact for Finnish regulatory authorities and bears responsibility for coordinating compliance submissions. Failure to designate a representative is itself a ground for enforcement action.
Document algorithmic accountability measures. For any service using recommender systems or automated decision-making, prepare and publish the required transparency disclosures. Ensure that internal documentation supports these public statements. Regulators in Finland have indicated that they will examine whether public disclosures are substantiated by actual system architecture.
Review software liability documentation. Compile records of known software vulnerabilities, patch histories, and incident-response procedures for all products distributed in Finland. Under Finnish information society legislation and EU product safety rules, software vendors bear liability for foreseeable harm caused by undisclosed deficiencies. Gaps in documentation increase both regulatory and civil liability exposure.
Audit technology licensing arrangements. Review all technology licensing agreements that involve Finnish-law intellectual property, Finnish data sources, or Finnish counterparties. Confirm that licence terms remain consistent with applicable Finnish and EU rules on data use, interoperability, and fair dealing. Where agreements were entered into before 2024, consider whether updated contractual terms are required to reflect the current regulatory position.
Companies that address these five areas promptly will be substantially better positioned to engage with Finnish regulatory authorities from a position of documented good faith. Those that delay risk not only financial penalties but reputational damage that is disproportionate to the cost of early action.
A parallel regulatory alert addressing digital services obligations in another EU member state is available in our analysis of digital services regulation in Portugal, which covers comparable implementation dynamics in a civil law jurisdiction.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising technology companies, institutional investors. Additionally, in-house legal teams on AI Act compliance. Algorithmic accountability, software liability, technology licensing. Additionally, digital services regulation across 46 jurisdictions. As an international law firm in Finland and across the Nordic region. We combine Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions for technology businesses entering or operating in European markets. Engaging a lawyer in Finland with experience across multiple EU regulatory regimes is essential for companies navigating the current period of accelerated digital regulation. Our team includes practitioners with experience before Finnish regulatory authorities and in EU-level proceedings. To discuss your company's specific situation under Finland's digital services requirements, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.