Stablecoin issuer / redeemer in Finland

Official MiCA Text: Regulation (EU) 2023/1114

FIN-FSA Information on MiCA: FIN-FSA - MiCA Regulation (in Finnish) (While primarily in Finnish, it confirms their role and the regulation's importance).

a) E-money Tokens (EMTs):

Definition: Crypto-assets that purport to maintain a stable value by referencing the value of one single fiat currency that is legal tender (e.g., a token pegged 1:1 to EUR or USD).

Regulatory Basis: These are essentially electronic money under MiCA. They are primarily regulated by Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions (E-money Directive), as implemented into Finnish law by the Act on Payment Institutions and Electronic Money (Laki maksulaitoksista ja sähkörahasta 297/2010). MiCA adds specific rules for crypto-asset aspects.

Finnish E-money Act: Laki maksulaitoksista ja sähkörahasta (297/2010) (in Finnish)

b) Asset-Referenced Tokens (ARTs):

c) Other Crypto-Assets (not directly stablecoins under MiCA definitions):

For EMTs (Articles 52-54 MiCA):

Issuers must hold the funds received in exchange for EMTs in a segregated account with a credit institution or invest them in secure, low-risk assets.

The proceeds from the investment of these funds must be managed in a way that provides for sufficient liquidity.

The assets must be fully liquid, meaning they must be redeemable at par at any time.

They must be invested in assets denominated in the same currency as the EMT.

For ARTs (Articles 35-39 MiCA):

Issuers must establish and maintain a reserve of assets that is separate from their own assets, and segregated in the interest of the holders of ARTs.

The reserve assets must be managed in an "effective and prudent manner," aiming to ensure that the ART can meet redemption requests.

A portion of the reserve must be held in highly liquid financial instruments.

The reserve assets must be managed in an "effective and prudent manner," aiming to ensure that the ART can meet redemption requests.

Specific rules apply to the investment of reserve assets to ensure minimal market, credit, and operational risks.

For EMTs (Article 51 MiCA):

Issuers of e-money tokens must be authorized as a credit institution (bank) or an electronic money institution (EMI) in accordance with the E-money Directive and relevant national law (Finnish Act on Payment Institutions and Electronic Money).

They also need to publish a crypto-asset white paper and obtain approval from the FIN-FSA (or relevant national competent authority).

Financial Supervisory Authority (FIN-FSA): The primary regulator responsible for authorizing and supervising all crypto-asset service providers, ensuring compliance with anti-money laundering (AML), consumer protection standards, and operational requirements.

Issuance of licenses for providers offering stablecoins and other crypto assets.

2026: Full enforcement across all covered activities.

2024-2025: Gradual rollout affecting broader categories of crypto service providers.

2023: Initial compliance measures for stablecoin issuers.

Evidence fact fi.aml.tesseract-finance-oy not found (may have been renamed).

Evidence fact fi.aml.coinmotion-oy-a not found (may have been renamed).

The applicant must be a Finnish limited liability company (osakeyhtiö) or a branch of a limited liability company incorporated in an EEA country.

The management of the applicant must be located in Finland. This includes the CEO and at least one other member of the board of directors.

Capital Requirements (Professional Indemnity Insurance):

Capital Gains Tax Rates (Pääomatulon verokanta): Finland has a progressive capital income tax rate:

Acquisition Cost Method: Finland primarily applies the FIFO (First-In, First-Out) method by default. This means that the first crypto units acquired are considered the first ones sold. Taxpayers can sometimes use other methods if consistently applied and justifiable, but FIFO is the standard expectation.