Instructions for changes in business activities
Changes in business activities, such as selling of the organisation’s credit stock, merger or termination of business activities, can have an impact on the right to access the Positive credit register’s APIs. The changes can affect both the reporting of data and the requesting of credit register extracts.
On this page, you will find instructions on what organisations that are required to submit reports and have data permissions should do if their business activities change. If your organisation has both reported data to the register and requested credit register extracts from the register, read the instructions both for parties with the reporting obligation and for data permission holders.
The instructions also describe what reassignees should do if loans or lending activities are transferred to them.
Instructions for parties with a reporting obligation
Changes in business activities can have an impact on the reporting of data, i.e. the right to use the reporting APIs. Such changes include selling of the organisation’s credit stock, change of company form, merger, or termination of actitivies, for example.
If a party with the reporting obligation terminates its business activities but the Business ID remains valid and the credit stock still includes loans subject to the reporting obligation, the party must continue to report data on the loans to the Positive credit register as before.
If a party with the reporting obligation terminates its business actitivies and the Business ID ceases to be valid, the reporting APIs will function to a limited extent starting from the moment when the Business Information System BIS (YTJ) shows that the Business ID is no longer valid. For example, if a limited liability company is merged, its Business ID ceases to be valid when the merger is registered in the Trade Register. The Incomes Register Unit receives information on the termination of a Finnish company’s Business ID directly from the Business Information System. Access to the APIs will be closed permanently when a party with the reporting obligation ends the reporting of data and, for example, reports that the loans in the register have been transferred to another party.
If loans are transferred, what should the reassignee do?
If the reassignee has already signed up as a data notifier
If the reassignee has a valid right to access the reporting APIs, it does not need to sign up again. The reassignee reports loan data to the register in accordance with the instructions and within the time limit prescribed by law.
If the reassignee has not signed up as a data notifier yet
If the reassignee is required to submit reports, it must sign up to the Incomes Register Unit no later than one month before starting to report data. The reporting obligation is prescribed by law (Act on the Positive Credit Register 739/2022).
Read the instructions: Signing up to the Positive credit register as a data notifier
Instructions for data permission holders and organisations qualifying for a data permission
Changes in business activities may affect the data permission, i.e. the right to receive data from the register and access the API for requesting credit register extracts. Such changes include the change of company form or termination of activities, for example.
The credit register extract API stops working after the Incomes Register Unit has received information that the activities have been terminated, for example when the Business ID recorded in the Business Information System has ceased to be valid.
If lending activities are transferred, what should the reassignee do?
If the reassignee has a valid data permission
It is not necessary to request changes to the data permission if the reassignee’s activities do not change in a way that would affect the data permission. If the reassignee’s activities change in a way that affects the data permission, changes to the data permission must be requested from the Incomes Register Unit by submitting an application for changing the data permission.
Changes affecting the data permission mean, for example, changes to the purposes for which the data is used. The allowed purposes of use of the register’s data are listed in chapter 3.2 in Sharing information from the Positive credit register.
If the reassignee does not have a data permission yet
If the reassignee, i.e. a business operator to which a credit stock is transferred, is obliged to test the consumer's creditworthiness or if it wants to use the register’s data for purposes related to loans granted to natural persons other than consumers, it must apply for a data permission from the Incomes Register Unit in good time. Data cannot be requested from the register without a valid data permission. For example, if a lender reorganises its business activities in such a way that the lending activities continue but the Business ID changes, a new data permission must be requested for the new Business ID in good time.
Read more: Instructions on how to request a data permission.
What kind of changes must be reported?
Changes to the reporting of data
Report future changes to business activities to the Incomes Register Unit as early as possible. Report at least the following information:
- How will your business activities change and when?
- Are you requesting that your access to the reporting API should be closed? In principle, API access can be closed only at the request of a party entitled to sign for the organisation or at the request of the Managing Director.
- What will happen to the loans that are subject to the reporting obligation when the change takes place?
- Will the loans be transferred to another party with the reporting obligation? If so, what is the plan or schedule for the transfer?
- Is another operator involved with the change? If yes, state the operator’s name and Business ID.
If a company has merged and its credit stock has been transferred to another operator and the activities of the certificate holder have terminated, revocation of the certificate must be requested. The revocation of a certificate issued to a terminated company must be requested from the Incomes Register Unit. The request to revoke the certificate must be submitted by a representative of the reassignee (i.e. the receiving company), unless otherwise agreed in the merger agreement.
Read more about organisations with the reporting obligation and about the loans to be reported in the instructions below. If your business activities change in a way that affects your data reporting, please notify the Incomes Register Unit.
- Signing up to the Positive credit register as a data notifier
- Reporting data to the Positive credit register
Changes to the use of data
Report future changes to business activities as early as possible. Report at least the following information:
- How will your business activities change and when?
- How will the changes affect the data permission or the purposes of use specified in the permission?
- Are you requesting that the data permission should be cancelled? In principle, a data permission can be cancelled only at the request of a party entitled to sign for the organisation or at the request of the Managing Director.
- Is another operator involved with the change? If yes, state the operator’s name and Business ID.
Read more about organisations with the right of access to data and about the purposes of use of the data in the instructions below:
How should changes be reported?
Changes to business activities are reported in the e-service for organisations, which you can find on the Positive credit register’s website. If an organisation cannot use the e-service, changes can be reported on a paper form, which can be requested from the Positive credit register's customer service.
If a change affects the reporting obligation, the notification of changes to sign-up must be submitted.
In the case of a change where the grounds for the purposes of use specified in a previously granted data permission have changed, the organisation must fill in the application for changing the data permission. Other changes to the use of data are reported on the contact form for data permission matters.