FINE Annual report 2023

”FINE's advisory and dispute resolution model saves consumers, businesses and society time, effort and money.”

CEO Anu Koskenvuo

1. Conciliator of disputes

FINE's role as a pioneer in alternative dispute resolution was strengthened. We received a record number of contacts, and the need for our expertise was on the increase. We dealt with nearly 11,000 contacts. The biggest increase was in insurance. In banking, the number of contacts remained broadly at the same level as in the previous year but, on the other hand, the cases were more challenging. In investment, the situation remained stable.

The cases we deal with are often increasingly complex: the world is undergoing rapid digitalisation, and the problems are more extensive and diverse. This is reflected in customer contacts, which, in addition to the actual subject matter question, often also include questions of a general nature concerning services. That is why it is important for us to continuously develop our operations and expertise.

Our aim is for FINE to represent the strongest expertise in the field. Monitoring and anticipating changes in the operating environment and actively responding to changes will be even more important in the future. Fortunately, we have a highly knowledgeable and committed staff, and our complaints boards include top experts from service providers, the judiciary, public authorities, universities and consumer organisations.

Personally, I have been able to observe FINE's activities from the CEO's point of view for over a year now. During this time, my perception of a reliable, independent and genuinely caring organisation has only grown stronger. FINE's work is of great societal importance in promoting good practice in the financial sector and empowering customers. At FINE, we serve customers, financial service providers and a wide network of stakeholders.

An effective and independent alternative to litigation

Throughout FINE's more than 50 years of history, the cornerstone of our operations has been to benefit the customer. We provide help with insurance and financial issues free of charge, quickly, efficiently and out of court. We are an impartial and independent expert organisation, trusted by service providers, as well.

Customers appreciate the personal service they get from FINE: we are easy to reach by phone or other channels. In many cases, when people approach us, the issue is difficult and multifaceted. The problem is usually caused by a negative experience, and the situation is unique to the customer. It is important for people to feel that they are heard and treated fairly.

Often, FINE's role is to act as a conciliator, for example between an insurance company and a customer. Of the customer contacts we received last year, 90% of cases were resolved through advice aimed at reconciliation. It is perhaps fair to say that our role as a dispute resolver and mediator grew in importance.

Our work helps individual citizens, but it also has a wider societal impact. FINE's advisory and dispute resolution model saves consumers, businesses and society time, effort and money. Our independence ensures that customers are generally more likely to accept FINE's advice and interpretations than those of banks or insurance companies – even when the interpretation is the same as that of the service provider.

The customer can be confident that issues will be resolved

The year 2023 was the first year of our new strategy. In this annual report, we summarise our main findings on the topics of counselling and dispute resolution.

Although each customer case is unique, many themes recur in the contacts. In banking, for example, the number of cases involving scams and card fraud continued to rise. The current rules on money laundering provide protection, but also create situations that are difficult to resolve for customers, service providers and dispute resolution providers alike. Some people find it difficult to manage their affairs online, and financial matters are becoming increasingly complex for customers to understand.

We embrace the challenges of digitalisation in the financial sector and respond to customer needs in line with our strategy. We will continue to make sure that people can also reach us in person and that it is easy to do business with us. The broad expertise of our staff, as well as a good working atmosphere and maintaining well-being at work, are important to us. We will continue promoting the development of best practices in the financial sector. To this end, cooperation and smooth communication with the various stakeholders is of paramount importance. FINE also contributes to the drafting of legislation in the financial sector. Our approach is internationally recognised and serves as an example to others.

FINE has a strong mentality of innovation and openness. Going forward, we want to continue to be agile in helping our customers within the framework of the law. We have a strong culture of accountability, and we do not shy from addressing difficult issues, always respecting the parties involved. Customers can be confident that their issues will be resolved at FINE. My appreciative thanks to the FINE staff for this!

We also see in our work how service providers are increasingly focusing on customer service when developing their digital services – even if it doesn't always seem that way to customers. I feel that we are moving in the right direction in the sector in general.

Our work is based on mutual trust and a strong commitment by the parties to respect our judgment. I would like to thank the service providers and other partners, such as the authorities, for their cooperation.

Helsinki, 26 March 2024

Anu Koskenvuo

2023 In Figures

Customer contacts




compared to the previous year


resolved through counselling


ended up as disputes

2. Working for awareness and impact

FINE's core work is helping customers: providing advice and resolving disputes in banking, insurance and investment matters. We investigate the customer's case free of charge and, if necessary, negotiate it with the bank, insurance company or other service provider. We handle disputes and provide recommendations for their resolution, which have been well followed by the financial sector. However, we do not work alone. We work together with the whole financial sector, so half of the credit belongs to our stakeholders, with whom we work to promote and develop the best practices in the financial sector.

The year 2023 was the first year of our new strategy period, 2023–2025. The vision for this strategy period is to be visible and impactful. Visibility refers to publicity, recognition and visibility both in society and in the media. It can be achieved through effective and impactful work.

The vision "visible and impactful FINE" was extensively pursued in the news coverage. Visibility was boosted by the presence of FINE experts in around 250 news stories. Our experts were interviewed mainly on topics related to insurance and claims, but also on banking issues, especially scams. FINE's role as an advisor and mediator was strongly conveyed in the media. News coverage included interest rate hedging, scams, accidents, and various types of insurance claims. Opinions and statements were also issued on natural disasters, pharmaceutical injuries and the promotion of economic literacy. 

The number of visitors to the website increased by 30%. The website was accessed about 370,000 times. The most searched for topic on the website was information about recommended resolutions, but visitors were also interested in guides, podcasts and FINE's activities.

The increase in the number of visitors to the website is certainly at least partly due to the work done to make FINE easier to find. This has been done, for example, with the help of search engine optimisation.There is also a clear need for independent information.

For discoverability, it is important that banks and insurance companies refer customers to independent advice and dispute resolution through redress.

Awareness was also boosted by FINE's IhanFINE (JustFINE) podcast series. Its eight episodes covered topics ranging from identifying internet scams to the compensability of slip-and-fall accidents and managing insurance and banking affairs for an estate. In particular, the episodes highlighted the issues that customers should pay attention to when choosing insurance cover and managing their banking affairs.

FINE's webinars on problem areas in liability insurance and motor insurance developments, as well as a seminar on strengthening practical cooperation and smooth processes, reached a wide audience of company experts.

Mission: good practices

FINE's mission for the 2023–2025 strategy period is to promote the development of good practices and customer empowerment in the financial sector. The organisation's activities and their impact were studied through a stakeholder survey, customer feedback and a staff survey.

Respondents to the stakeholder feedback survey consider FINE to be a competent, independent and cooperative dispute resolution service that benefits customers. FINE communicates its activities sufficiently and openly, and its activities are considered effective and objective. Areas for improvement included increasing visibility and awareness, especially among customers, and speeding up dispute resolution.

Customers who responded to the customer satisfaction surveys gave positive feedback, particularly on the friendliness, impartiality and clarity of customer service. They would like faster processing of their cases and information on the progress of the processing.

The results of the personnel survey aimed at FINE staff, which have been good in the past, now improved even further. As a proof of this, in autumn 2023, we were honoured with recognition as one of the Most Inspiring Workplaces in Finland. This reflects the commitment of staff and the long-term collective development of the organisation. The Most Inspiring Workplaces in Finland award is given annually to the best organisations participating in the Eazy Flown PeoplePower survey.

90% of customer contacts are resolved in counselling

FINE employs 29 people, and its activities consist of counselling, dispute resolution and communication. The core of the work is helping customers: giving advice and resolving disputes in banking, insurance and investment issues.

Customer advice is offered in a variety of ways by telephone, chat and written correspondence. The main aim of the counselling is to identify the client's problem and find a solution. The customers' questions may relate to issues such as insurance claims, scams or investment advice. While customers often want an immediate response on the phone, there are many situations where further clarification is needed before advice can be given.

FINE's experts provide easy-to-understand information on legislation and contract terms. The service is not limited to providing information, but aims to help prevent disputes and find amicable solutions between the parties. Thanks to counselling, hundreds of contentious cases can be resolved. As many as 90% of customer contacts are resolved successfully in the counselling phase.

In most cases, the service provider's decision is perfectly appropriate, and the customer can accept it after receiving an expert assessment of their case from FINE.

If the customer's case cannot be resolved through counselling, FINE may settle it through dispute resolution, using either the office procedure or the complaints board procedure, and issue a written recommendation for resolution.

Influencing and collaborating

An important part of FINE's activities is to promote financial literacy and to contribute to the drafting of legislation by giving opinions and participating in working groups.

During 2023, FINE continued collaboration with a wide network of stakeholders on a number of projects, with the ultimate aim of increasing people's knowledge in insurance, banking and investment matters. We helped to organise the Talousguru (Financial Guru) competition for secondary school students and participated in the Financial Literacy Advisory Board. We produced content for the information materials on guardianship and death in the family, coordinated by the Digital and Population Data Services Agency, and for the Omissa Käsissä campaign, as well as updating our own materials on these matters.

We retained good contacts and strong participation at international level, both in the European Commission's FIN-NET Steering Committee and in the global International Network of Financial Services Ombudsman Schemes (INFO Network).

In addition, we contributed to the drafting and development of legislation in various ministries, the preparation of EU directives and official guidance by submitting opinions and written comments, and by participating in working groups and consultations. We expressed our views on issues such as: out-of-court dispute resolution, the adequacy, availability and quality of basic banking services; the organisation of activities to comply with sanctions regulation and freezing orders; the amendment of the law on share savings accounts; the amendment of the ADR directive and the repeal of the ODR regulation; the small claims procedure; investor protection; the provisions on fraud; the framework for the use of financial data; and the single currency package.

Customer contacts

Insurance issues
2021 5876
2022 6399
2023 7765


Banking issues
2021 2425
2022 2769
2023 2825


Investment issues
2021 505
2022 409
2023 385


3. Cybercrime is here to stay

Banking-related customer contacts with FINE have increased in recent years, mainly due to an increase in scamming and phishing cases. There were less than 200 contacts of this type in 2020 and more than 500 in 2023.

The majority of online incidents reported to FINE are phishing incidents based on fake websites.

"Phishing is when a customer thinks they are logging into an online bank or government service, for example, but in reality the information they enter on a fake site ends up in the hands of criminals. The victim may have landed on the fake website through a search engine or through a link in a text message or email fraudulently sent in the name of a genuine operator," explains Tuomas Hidén, Head of Division at FINE.

Phishing attempts can be so sophisticated that victims may not notice anything out of the ordinary. It may even take some time for the victim to discover that funds have disappeared from their bank account, and they cannot tell when and where the phishing took place.

"Being a victim of a scam is a traumatic experience for most customers. Their emotions range from shock to disbelief, grief and anger. Many also feel ashamed for falling for a scam. The amounts lost to scammers have ranged from a few hundred to tens of thousands of euros, up to a hundred thousand euros, which may have spelled financial disaster for the customer."

”Being a victim of a scam is a traumatic experience for most customers.”

Tuomas Hidén
Tuomas Hidén Tuomas Hidén

First, contact the bank

In scam cases, the first thing customers should do is contact their own bank.

Head of Division Tuomas Hidén points out that it is of paramount importance for banks to invest resources in the handling of customer complaints. Complaints should be processed as quickly as possible, and efforts should be made to ensure that customers receive a proper and well-justified decision on their complaint.

A customer who is dissatisfied with a bank's decision can turn to FINE for advice or bring the matter before FINE as a dispute.

Improving trend

Although the number of disputes has increased, the trend has shown signs of improvement this year. The Banking Complaints Board has issued rulings and guidelines on the misuse of payment instruments online, which has helped to avoid unnecessary disputes.

Several operators and the entire financial sector, including FINE, are working hard to prevent scams.Efforts are being made to teach people how to recognise scams. At the same time, advice is given on what kinds of messages should be ignored.

FINE's guides "Scam detection and FINE resolution procedure (published in Finnish) Huijausten selvittäminen ja ratkaisukäytännöt FINEssä and "How to spot a scam" (published in Finnish) Miten tunnistat ja vältät huijauksen provide useful information on scam-related issues. The podcast (published in Finnish) "JustFINE" IhanFINE  delves into the identification of online scams and instructions on how to proceed if you get scammed. The FINE counselling team answers customers' questions free of charge.

2023 In Figures

Banking contacts

2 825



Cases involving scams and handling of data


Scam cases ended up as disputes


Number of scam-related disputes compared to the previous year

4. When taking out a loan, financial literacy is key

As the economic situation deteriorates, people often become more cautious and careful in their financial affairs. 

In a tighter economy, they may be more cautious in their use of money and take a closer look, for example, at the content and cost of their insurance cover.This is also reflected to some extent in the content of contacts with FINE. 

Last year, the rise in interest rates was mainly reflected in the number of contacts about interest rate hedging on loans. Many customers were unsure about the impact of rising interest rates on the monthly instalments due, especially on annuity loans, and how interest rate hedging works in such a situation. Some customers had been led to believe, on the basis of marketing information, that a rise in interest rates would not affect the monthly instalments to be paid.

"This highlights the need for financial literacy," says Elina Antila, Communications Manager at FINE. She points out that borrowing can be a useful tool to achieve financial goals, but it requires careful planning and consideration.

"Customers should understand the terms of the loan, be able to assess their own financial situation, and ensure that the loan can be repaid even if their circumstances change. When it comes to financial matters, customers' decisions can affect their lives and finances for decades to come."

Verbal negotiations can pose challenges

The importance of financial literacy is highlighted, for example, in situations where you are about to take out a large mortgage for the first time and the negotiation is verbal. You should understand things at once and be able to ask questions and clarify things that are not clear. 

Conflicts may arise over what was actually agreed. Customers trust the professional providing the service and think they understood what was said, although in reality it may have remained unclear. 

Therefore, before taking out a loan, the customer should receive clear and easy-to-understand information on the terms of the loan, including repayments, interest rates, charges and other matters affecting the loan. It is equally important that the customer carefully studies the information received and asks for more information if there is something they do not understand. The same applies, of course, to other banking and insurance matters.

Elina Antila points out that the growing number of offered financial services also necessitates better financial literacy. Products and services are intensively marketed, but they are difficult to compare. Replacing a personal service with online services creates difficulties for some customers. In particular, solving problem situations without a personal service can be difficult.

”When it comes to financial matters, customers' decisions can affect their lives for decades to come.”

Elina Antila
Elina Antila Elina Antila

FINE contributing to better financial literacy

In addition to giving advice and resolving disputes, FINE's mission is to increase customers' understanding and skills in banking, insurance and investment matters. This task is written into the FINE statutes and is also reflected in our mission statement. The aim is to promote customers' interest and confidence in financial activities, improve consumers' financial literacy, and otherwise improve day-to-day practices in the financial sector.

The task is a challenging one. In the light of current research, the financial literacy of Finns is very close to the international average. The data comes from the Organisation for Economic Co-operation and Development's (OECD) 39-country International Survey of Adult Financial Literacy. Finland is well above the average for all countries in digital financial literacy.

"Financial literacy and digital skills must be developed hand in hand. In order to be able to use financial services, you usually need to have good digital skills," says Elina Antila.

In the field of insurance, financial literacy means being able to choose insurance according to your needs, and understanding what insurance covers and what it does not. In banking and investment, it translates into making wise saving, investment and borrowing decisions, managing your finances in a balanced way, and being prepared for changes in the operating environment.FINE helps customers in these areas by producing a range of materials, guides, podcasts and news for the media. This work is carried out together with a wide network of stakeholders.

"With good financial skills, you can better manage your finances and make informed decisions about borrowing, saving, spending and investing. Good financial information helps you make smart and sensible decisions about spending, such as buying a home, investing and planning for retirement," Elina Antila points out.

5. Increase in contacts concerning money laundering and due diligence

During 2023, there was an increase in the number of contacts received by FINE concerning the sudden suspension of a customer's banking services. In the past, customers contacted FINE about the need for banks to ask their customers questions about issues such as political influence. Now, the contacts increasingly concern the limitation or termination of a customer's services.

"With regard to banking services in particular, FINE has received a lot of contacts on these issues, recently almost daily. The customer's bank account may have been frozen or a payment stopped," says Tuomas Siirala, Senior Legal Counsel at FINE.

For insurance, such contacts have been less frequent in the past, but they, too, seem to be slowly becoming more common.

”If you are unable to use your bank account ID, it is impossible to manage your affairs.”

Tuomas Siirala
Tuomas Siirala Tuomas Siirala

The effect of anti-money laundering laws

Customers contact FINE when their banking services have been terminated or restricted. 

If a bank or insurance company is unable to take the steps required to know the customer, it may be obliged to refuse to carry out a transaction or maintain the business relationship at all. In practice, this means, for example, refusing to make transfers without further information, freezing a customer's account funds, or terminating an insurance contract or a contract for non-basic banking services.

Tuomas Siirala explains that the actions of a bank or insurance company are usually motivated by anti-money laundering and counter-terrorism laws, which require banks and insurance companies to know their customers. This obligation applies for the entire duration of the customer relationship.

"Compliance with the law is particularly important in the current situation of war in Europe and the need to effectively prevent sanctioned entities from doing business."

Service providers must obtain sufficient information to assess the risks associated with the customer relationship and to determine the customer's individual level of risk. If necessary, information must be obtained on, among other things, the origin of the funds. In practice, this leads to the need to ask questions of the customer. The situation will not be resolved until the customer answers the service provider's questions.

The situation becomes more difficult when the answers to the questions are not sufficient and services are restricted or terminated altogether.

"When the use of an online banking ID is prevented, it becomes impossible to manage many daily affairs. The problem is exacerbated by the fact that the current regulation takes little account of the possibility that a well-intentioned restriction or termination of services may, in individual cases, be excessive or completely unjustified," Siirala says.

For example, if a dispute arises over the termination of services, the question is whether there were proper grounds for the termination. However, in the case of suspected money laundering, the law does not allow the service provider to disclose the suspicion to the customer. This means that the service provider cannot justify, for example, why the insurance contract has been terminated at the end of the insurance period.

"In such a situation, FINE or another dispute resolution body may also have no way of knowing the real reasons for the termination. As it is, it may be impossible to reliably assess whether the termination was justified, which may result in FINE not being able to process the case at all or otherwise assist the customer."

Right now, because of the stricter regulation on money laundering and counter-terrorism and updated guidelines from the supervisory body, FINE is receiving quite a lot of cases related to money laundering and customer due diligence.

"Financial services companies are complying more closely with legislation and guidelines, which is a good thing," says Tuomas Siirala.

He says that among service providers, these issues are gradually becoming part of normal customer service. This also means that problematic situations can usually be resolved quickly and smoothly, without unnecessary interruptions to services.

The problems faced by financial consumers are essentially linked to legislation and guidelines from the authorities. This issue is currently under discussion in the EU, where the so-called money laundering package aims to reform and clarify the regulation on money laundering. FINE, as an expert organisation, has participated in the drafting of the legislation.

"It is to be hoped that the new regulation will also take better account of the position of the ordinary financial consumer," Siirala says.

6. Health insurance gains popularity – it's important to stay informed

In recent years, there has been a clear increase in the number of contacts with FINE concerning health insurance. Last year, 697 health insurance contacts were made, compared to 493 in 2022 and 356 in 2021.

Growth can be seen both in health insurance covering medical expenses and in other health insurance, such as disability insurance.

"Part of the increase is due to policy terminations and premium increases, which have been the subject of an increasing number of enquiries to FINE's advisory service. In a typical termination situation, a certain insurance stock has become unprofitable for the insurance company. Companies often offer customers a new policy to replace the terminated one. It may differ from the old insurance in terms of conditions and fees," says Kaisa Laine, Head of Division.

Enquiries to the FINE advisory service include whether the insurance company has the right to cancel a policy, or whether the customer has other options than to take out a new policy.

However, most of the health insurance contacts that come to FINE concern compensation issues.

For policyholders, financial literacy is key

If you are taking out a completely new insurance policy or need to take out a new one after the old one has been terminated, financial literacy is a must. 

"Financial literacy involves being aware of risks and weighing up what risks you can bear with your own wealth or the support provided by society, and what risks you might want to insure," Kaisa Laine explains.

Personal insurance always covers the financial risk associated with a change in health: the cost of treatment for an illness or injury, loss of earnings due to incapacity for work, permanent disability, the financial consequences of a serious illness or the financial losses caused by the death of a family member.

Laine points out that when choosing insurance cover, you should carefully read the sales material. Insurance needs are individual, which is why it pays to compare the contents of insurance policies.

”No two policies are the same, and you should never buy insurance on the basis of the name alone – it doesn't tell you anything about the contents of the policy. In particular, it is worth reading the insurance terms and conditions to find out what is covered and what is not, so that there are no surprises later on about the coverage," says Laine.

The health declaration must be completed carefully – it does not pay to cheat

In recent years, disputes concerning the policyholder's or insured's obligation to provide information have occupied the FINE Insurance Complaints Board more than before. The obligation to provide information means the duty to provide correct and complete answers to the questions asked by the insurer in connection with an insurance application.

If the insured has provided false or incomplete information, and the correct information would have been relevant to the insurer's decision on the choice of liability, the policy may be cancelled or an individual exclusion clause may be attached to it.

Most of the disputes that come before FINE concern these issues. Then it needs to be determined whether the insured was negligent in providing the information, the degree of negligence, if any, and whether the insurer was entitled to cancel the policy, make changes to it or recover any compensation previously paid.

"It is therefore very important to complete the insurance application and health declaration honestly and in detail," Kaisa Laine emphasises.

On the other hand, insurance companies have a responsibility to ensure that the questions asked in the health declaration form are clear and unambiguous enough to make it as easy as possible to give correct and complete answers. This will help curb the increase in the number of disputes relating to the granting of personal insurance.

Insurance policy cover is not always what the customer expected

Last year's customer contacts included questions concerning various health insurance compensation issues. Customers wanted to know whether a certain treatment, for which compensation was claimed, is in line with generally accepted medical opinion, meaning established medical practice, and whether the insured was incapacitated in the way required for coverage.

"Treatment disputes reflect customers' high expectations of the insurance they take out. For example, people want quick access to treatment, the possibility to continue their sporting activities without interruption, or the continuation of an established doctor–patient relationship. Many assume that insurance will give them faster access to treatment and better or more comprehensive care,” Kaisa Laine says.

She says it comes as a big surprise to many of the insured that the insurance does not cover all the proposed treatment: an operation or procedure may not be considered a necessary treatment under the terms of the policy.

Disputes concerning incapacity for work typically involve cases where the treating physician has assessed the customer to be completely incapable of their usual work, but the insurance company considers that the medical reports do not show a functional deficiency that causes complete incapacity for work. In this case, the insurer usually refuses compensation. The required degree of incapacity for work is indicated in the terms and conditions of the insurance policy, along with the deductible and maximum benefit period.

In recent years, contacts concerning disability insurance have focused particularly on mental incapacity for work, that is, the length of the period or the degree of incapacity for work due to mental health problems. Insurance for temporary incapacity for work always has a maximum benefit period for the entire policy period. The maximum benefit period available may vary from insurer to insurer and may affect the premium.

Claims disputes are resolved at the FINE office and the Insurance Complaints Board. Typically, FINE will obtain an expert medical opinion for the processing of the case. 

Contacts regarding Health insurance

Health insurance
2021 356
2022 493
2023 697


7. Contacts related to insurance and banking

The articles in this annual report highlight phenomena and contacts that have particularly characterised the year 2023. This chapter also contains information on other contacts that have been topical in terms of quantity or the extent of discussion. Of the types of insurance, home insurance accounted for the highest number of contacts, while in banking, scams were the most prevalent topic. In the field of insurance, for example, FINE experts have drawn attention to the increase in contacts related to health insurance. 

Home insurance and animal insurance

Home insurance is the most common type of property insurance for consumers and the one that causes the most customer contacts at FINE. Last year, the number of contacts related to home insurance increased by 35%. However, there is no single explanatory factor behind the rise; it is the sum of multiple factors. 

With regard to home and real estate insurance, there have been enquiries about damage caused by damp, its compensability and the amount of possible compensation. Damage is often linked to the failure or absence of waterproofing or pipe supports. Other topics include faulty construction and installation, damage by rainwater, fire damage, deduction of depreciation, the suddenness and unpredictability of damage, and lost, missing or stolen property. 

Customers have raised questions about the fairness of premium increases and whether the insurance company was entitled to terminate the policy for non-payment. The issue of burglary and theft and their compensability in ambiguous situations has also been raised. Questions are also often raised about evidence in cases of damage to movable property: what kind of evidence there is relating to the property or the damage that has occurred. Customers also often complain that they do not receive written claims decisions from the insurance company (on request). Reasons given over the phone may not be remembered by the customer, and written reasons are needed for possible further action. 

Damage caused by natural phenomena, such as storms, floods and power surges, has also been a frequent topic.The associated property damage can be extensive, and customers often wonder why such damage is not covered at all, for example, if there is insufficient evidence that the damage was caused by a storm or that the rainfall exceeded the limit specified in the terms and conditions.

The number of customer contacts concerning pet insurance remained at the same level as in previous years. Recurring questions included the compensability of veterinary examination costs and whether the pet had a structural defect subject to an exclusion clause. 

What were the disputes about? 

  • In cases of damage caused by leakage, disputes were typically about whether the damage was caused by a construction or installation fault, such as with the fixing of a drainage pipe or the waterproofing of the floor. 
  • In cases of fire damage, disputes were typically about the impact of the customer's conduct on the compensation payable by the insurance company. 
  • In pet insurance, disputes were typically about latent defects or the conditions for compensation for sterilisation. 

Voluntary motor vehicle insurance and motor liability insurance

In voluntary motor vehicle (so-called kasko) and motor liability insurance issues, a frequent question concerns the amount of compensation, which the customer considers to be too small. With regard to kasko insurance, enquiries often concerned the termination of insurance due to non-payment of the premium. 

For kasko, questions about the causal link between the damage to the vehicle and the incident described have been somewhat more prevalent than usual. The customer and the insurer disagree as to whether the damage to a part of the vehicle was caused by the (alleged) collision, or whether the damage was of a compensable nature at all, or whether it was, for example, a normal circumstance on the road that the car should have withstood, such as damage to the wheel suspension when driving into a pothole. 

In vehicle claims, the issue of damage assessment often arises, where the roles of the insurance company and its partners, such as repair shops, may not be clear to the customer. 

In cases of kasko theft and vandalism cover, the onus is on the claimant to prove that the damage was caused by theft or intentional vandalism. Customers often feel that this obligation to provide evidence is unfair. If the cause of the damage remains unclear on the basis of visible signs of damage and other evidence, compensation is usually conditional on the existence of collision or parking insurance. 

The number of motor liability insurance disputes handled by FINE is very limited. In kasko insurance cases, there were recurring ambiguities related to the incident details of theft and vandalism claims, often involving an assessment of the evidence presented by the parties rather than an interpretation of the terms and conditions.

Liability insurance

In liability insurance, a large number of the contacts were about personal injuries, such as filing a claim and the amount of compensation in slip-and-fall accidents. Contacts concerning damage to property were slightly fewer.

Customers were given advice on the causal link between the injuries and the incident and the degree of impairment caused by the injury. Questions from claimants typically concerned the amount of compensation and how to determine and calculate compensation for temporary or permanent impairment. A large proportion of the calls concerned questions about the establishment of liability (for personal injury and damage to property) and how to file a liability claim. Customers were unclear about who reports the incident to the insurance company, how to initiate the processing of the claim at the insurance company, and how the matter proceeds. There were also complaints about the long processing times of insurance companies: decisions take a long time, you can't get hold of the person responsible, and you can't get the decision in writing. There was also an increase in enquiries about reimbursement of expenses in the private health care sector and compensation for loss of earnings. 

The lack of written decisions from insurance companies results in the customer having to contact various parties multiple times. The customer is called by phone from the insurance company and told that the loss will not be compensated. In these situations, the customer often fails to make a note of the reason for the rejection. The customer contacts FINE because they cannot reach anyone at the insurance company. However, it is difficult to take a position on the matter in the absence of a written decision, and FINE will have to ask the customer to contact the insurance company and request a written decision and then contact FINE again. 

Questions about how to claim on liability insurance also led to contacts with FINE. These concerned situations in which the injured party calls and asks how to get their case to the liability insurer of the party who caused the injury or damage, when the party who caused the injury or damage refuses to use their liability insurance or to provide the additional information requested by the insurer. 

What were the disputes about? 

  • Whether the loss or damage was attributable to the insured, that is, whether it was caused by negligent acts or omissions. 
  • Causal relationship with medical expenses, reimbursement of expenses, amount of compensation, assessment of loss of earnings. 
  • Liability in various property damage: leakage, fire. 

Pharmaceutical injury insurance

Pharmaceutical injury insurance cases continue to account for a very small proportion of FINE's customer contacts, but the number of disputes remained high for Covid-19 vaccine-related cases.

Compared to 2022, the number of contacts and disputes related to pharmaceutical injuries remained similar, with the majority of them concerning harm and injuries related to Covid-19 vaccines. However, based on the number of contacts with FINE, the number of adverse events and the number of disputed compensation decisions appears to be very small in relation to the number of Covid-19 vaccine doses administered in Finland. In Finland as a whole, 78% of the population had received at least one Covid-19 vaccine dose by November 2023. The number of pharmaceutical injury cases other than those related to Covid-19 vaccines has been smaller than normal.

What were the disputes about? 

  • In most cases, the dispute was about the causal relationship between the injury and the vaccine received.

Business insurance

As in previous years, FINE received few business insurance cases compared to the more popular types of insurance. Typically, FINE was contacted especially in relation to businesses' property loss and liability cases. Among the less common forms of insurance, cases concerning consultants' liability insurance and construction defects insurance under the Housing Transactions Act were also filed during the reporting year. 

In property insurance, the ambiguities were related to what was covered by the policy, the exclusions and the property insured. The disputes were also characterised by the fact that in many cases, the problem was whether the insurer had fulfilled its obligation to provide information about the contents of the policy when it was taken out or when its scope was subsequently amended. Unfortunately, FINE's findings show that the situation in this respect does not seem to have improved substantially in recent years. 

Liability insurance cases have mainly concerned various types of damage and injuries in connection with construction, maintenance and repair services. In most cases, these are losses that are generally excluded from general liability insurance coverage. These include, for example, damage to the customer's property under the insured entrepreneur's duty to protect and prevent damage, or situations involving non-performance of a contract or re-doing work that has been performed incorrectly. Disagreements have also arisen over who is the right party to be held liable for damage when there are several parties involved in the contracting chain of a construction site. 

What were the disputes about? 

  • Liability insurance for entrepreneurs and companies, in particular with regard to the scope of the limitation of liability clauses in the insurance terms and conditions. 
  • The scope of recoverable losses and the property insured in business property insurance. 


2023 In Figures

Distribution of insurance issues


Insurance issues


Compensation issues




Contractual issues


Obligation to inform


Cheating, causing losses


In banking, the total number of contacts remained high at around 2,700. As in previous years, a major theme was scams and phishing, with around 500 contacts.  The vast majority of disputes, around ¾, also concerned various cases of online misuse of bank IDs and bank cards. However, the total number of disputes fell to less than half of the previous year, as the guidelines issued by the Banking Complaints Board on the most typical scamming cases have guided counselling and helped to resolve cases already at the advisory and mediation stage.

A wide range of money laundering-related issues, from knowing the customer to limiting and suspending services, increased in counselling. In practice, such situations can be challenging for the customer, especially if the customer considers that they have provided the clarifications requested by the bank, but the handling of the matter is stalled and the customer is unable to manage their normal banking affairs.

Changes in the business environment, such as high interest rates, had only a limited impact on banking advice. In individual cases, the rise in interest rates made the customer realise that there was no interest rate hedging on their loan, even though they had been under the impression that there was. Some contacts were also received about interest-hedged annuity loans, mainly about how a rise in interest rates affects the monthly instalments to be paid and how interest-hedging works in such a situation.

Another issue raised was banking for older people in situations in which they are no longer able to manage their own affairs, but there is not yet a guardianship scheme in place. Other issues raised included estate issues, such as questions from estate shareholders about why it takes an inordinate amount of time for the bank to check documents. Visitors to the website are also interested in questions relating to how to manage the affairs of an estate. Banking and insurance in an estate – advice for estate shareholders has been FINE's most widely read guide for several years.

What were the disputes about?

  • Phishing and various online scams.
  • Disputes over individual mortgages, such as those concerning the absence of interest rate hedging.
Asia­jakauma vakuutus­asioissa 2023
  Compensation issues Other Contractual issues Obligation to inform Cheating, causing losses
% 56 30 12 2 1


8. Tighter regulation has reduced the number of investment-related contacts

In 2023, there were a lot of changes and events in the stock and interest rate markets that could have been expected to generate a lot of contacts with FINE. The transition from zero to 4% rates was rapid, and the stock market had steep up and down days in addition to various corporate events. 

However, there was no increase in the number of investment-related contacts; instead, the year was even quieter than previous record-breakingly quiet years. This is despite the fact that from 2018 onwards, insurance-based investments are also counted as investment-related contacts. 

"If you exclude insurance-related contacts and complaints from the overall figures, the figures related to investment issues are astonishingly low," says Vesa Sainio, Head of Division at FINE. 

He goes on to point out that most of the contacts are about issues or products that are not even within FINE's remit. These include, for example, issues related to various investment scams and cryptocurrencies. 

Sainio also draws attention to the almost complete absence of the usual issues of so-called ordinary investors. 

"The majority of contacts come from either fairly novice or very experienced investors. Novice investors contact us because of their general interest in different products. Experienced investors, on the other hand, contact us about issues such as an interpretation of a detail in a complex entity, which may have an impact on the performance of an investment, for example."

Contacts on investment issues 2019–2023
  Total Telephone counselling Advice Dispute
2019 610 430 155 25
2020 700 220 457 23
2021 505 283 205 17
2022 405 226 164 15
2023 385 234 141 8


Several reasons for the calm

Head of Division Vesa Sainio believes that there are several reasons for the exceptional calm. First, he cites a number of regulatory changes that have come into force since the 2008 financial crisis, which have increased the obligations of service providers and thus improved investor protection. 

"The improvement of financial literacy in general probably also has an impact. However, it is clear from the contacts that knowledge and its increase are not necessarily evenly distributed." 

Investors' financial preparedness for both short- and long-term changes also tends to reduce investment-related contacts. 

"In the short term, this preparedness is reflected in the fact that people have not wanted to tie up their savings in investments, but have kept a larger than usual cash balance. Or perhaps, after the increase in the cost of living, there are no more funds left to invest," Sainio says.

"On the other hand, the public debate about the adequacy of future pensions and proposed cuts in various benefits may have influenced the choice of investments. People have chosen to invest their money either in low-risk products that have performed as expected or in longer-term, but higher-risk products where the risk has not yet materialised." 

Sainio believes that at some point – because of the increased number of investors, if nothing else – the number of contacts will also increase. When that change will happen, he does not want to predict.

”"Preparedness is reflected in the fact that people have not wanted to tie up their savings in investments." ”

Vesa Sainio
Vesa Sainio Vesa Sainio

9. Dispute resolution

In dealing with disputes, FINE respects the principles of a fair trial, such as the independence and impartiality of the dispute resolvers and both parties' right to be heard.

FINE resolves disputes both through office proceedings and at complaints boards. The insurance and financial advisory service acts as the secretariat for the complaints boards. The office procedure is used for cases that are well established in terms of interpretation or that are otherwise legally straightforward. In 2023, these disputes accounted for 43% (46%) of all disputes resolved. The board procedure is used for difficult and complex cases that call for policy-setting solutions. In the year under review, these accounted for 57% (54%) of all disputes.

The proportion of complaints board-handled disputes has continued to rise in recent years. In 2023, as in the previous year, the exceptionally high proportion of these cases is explained by the large number of phishing disputes, which accounted for the majority of cases in the banking sector. These disputes are primarily about the weighing of evidence. The number of disputes involving extensive medical evidence in pharmaceutical injury insurance and personal insurance has remained high. As the weighing of evidence is key to the resolution of these disputes, the proportion of cases decided by the Insurance Complaints Board has increased accordingly. Disputes concerning the insured's obligation to provide information, which typically require a board hearing, have also continued to increase, especially in the area of personal insurance. In all sectors, disputes are increasingly complex and extensive.

Over the last couple of years, the strengthening of FINE's advisory service and the seeking of amicable settlements rather than starting a dispute process have led to a reduction in the overall number of dispute cases and, in particular, the number of simple disputes handled through the office procedure. The trend continues. In 2022, the number of disputes showed a slight increase, but in the reporting year, it dropped back to 2021 levels. Disputes decreased most in banking matters, although the number of contacts received by FINE was at a record high in these areas, as well. It seems that disputes in the making, especially in banking matters, have been solved to a greater extent by means of counselling.

Dispute resolution ends with a recommendation for a solution in favour of the customer or service provider, a settlement between the parties, a decision not to process the matter or a suspension of the proceedings. A settlement between the parties in a dispute means that the service provider pays compensation to the customer on a voluntary basis. Recommendations for a solution in favour of the customer ranged from recommending a small additional compensation to a complete change in the outcome.

FINE's core role is to act as a low-threshold, independent dispute resolution alternative to the court process, with a lighter procedure and no charge for customers. Effective dispute resolution can contribute to public confidence in good practice in the financial sector and improve the customer experience in problematic situations. Due to the nature of the procedure, the decisions of FINE and its boards are of a recommendatory nature.

However, the commitment of financial actors to comply with the recommendations is essential for the achievement of the objectives set for FINE. Throughout FINE's history, the compliance rate has been very high, between 96% and 100%. In the year under review, the compliance rate was 97% (96%). In fact, it can be said that the sector is quite committed to complying with the decisions. The few cases of non-compliance concern four insurance cases and one banking case. It is important for the responsible development of the financial sector and customer protection to ensure that the current high level of compliance with the decisions is maintained.

The banking case concerned online phishing, and was part of the same set of events as the recommendations from 2022 that were not complied with (5 cases in total). In one of these cases, the Consumer Ombudsman assisted the customer in the district court and the case was resolved in the customer's favour, as had been the case with the FINE Banking Complaints Board. At the time of writing, the case decided by the district court is in the process of being reviewed by a court of appeal. The case is pursued in court for a precedent.

The non-compliant insurance cases concerned the insurer's obligation to ascertain the insurance needs of the applicant and the insurer's right to terminate non-life insurance at the end of the insurance period on the grounds that it had not been possible to carry out the know-your-customer measures in a sufficiently reliable manner. These cases involved novel questions concerning the interpretation of the law and contractual terms, on which there is as yet no case law. Two other insurance cases of non-compliance concerned the limitation of the right to compensation for missing the deadline for notification of a claim and the insurer's right to change the policy terms and conditions at the end of the premium period.

Of the 783 (824) disputes resolved during the year under review, 85% (87.5%) were insurance cases, 13% (10%) banking cases and 2% (2.5%) investment cases.

All disputes in 2023

Concluded disputes in 2023
Final outcome Banking Investment Insurance Total
In favour of the service provider 49 11 377 437
In favour of the customer 19 3 171 193
Settlement 14 2 99 115
Dismissed, total 7 1 11 19
- Not suitable for resolution procedure 6 1 4 11
- No financial interest     1 1
- No competence     4 4
- Deadline to bring action expired     1 1
- Pending kor processed elsewhere 1   1 2
Processing suspended 9   11 20
Total 98 17 669 784
Breakdown by sector 13% 2% 85% 100%
Recommendations not complied with 1   4 5
Complicated issue 5 4 10 19
Processing time from completion of
correspondence (days)
44 78 91 85
Päättyneet riita-asiat 2021 - 2023
  2021 2022 2023
Yhteensä 793 824 783
Vakuutus 713 723 668
Pankki 60 81 98
Sijoitus 20 20 17


Disputes arrived 2023

Type of insurance Compensation issues Contractual issues Oblication to inform Cheating, causing losses Total
Personal accident insurance 162   1 3 166
Liability insurance 69   2 31 102
Home insurance 69   1 4 74
Health insurance 44 1 17   62
Pharmaceutical injury insurance 52       52
Legal expenses insurance 40   2   42
Voluntary motor vehicle insurance 30 3 2 4 39
Real estate insurance 33 1   2 36
Travel insurance 27 1   1 29
Business insurance 11 1 2   14
Animal insurance 8 2 2   12
Boat insurance 7       7
Farm insurance 5     1 6
Sickness fund 6       6
Loan insurance 2 1 2   5
Risk life insurance 1 1 3   5
Group pension insurance 3 2     5
Other non-life insurance 3       3
Motor liability insurance   1 1   2
Supplementary pension insurance 1       1
Cargo insurance 1       1
Total 574 14 35 46 669
Category Quantity
Credit issues 13
Other 4
Account access and payments 46
Total 63


Category Quantity
Compensation issues 3
Investment funds 1
Contractual issues 1
Oblication to inform 3
Total 8

Statistics by service provider (all disputes)

Non-life insurance companies
Non-life insurance companies Decisions Compensation recommendations Compenstion recommendations % Compliance %
AIG Europe S.A. 7 0 0 % 100 %
AXA (Genwortd Financial, vahinko) 1 1 100 % 100 %
Chubb (ACE European Group Limited) 4 2 50 % 100 %
Fennia Keskinäinen Vakuutusyhtiö 103 37 36 % 100 %
Försäkringsaktiebolaget Agria 16 12 75 % 100 %
Försäkringsaktiebolaget Alandia 1 0 0 % 100 %
HDI Global Specialty SE 3 1 33 % 100 %
If Vahinkovakuutus Oyj, Suomen sivuliike 115 31 27 % 94 %
LähiTapiola Keskinäinen Vakuutusyhtiö 104 25 24 % 100 %
Nordea Vakuutus Suomi Oy 1 0 0 % 100 %
Pohjantähti Keskinäinen Vakuutusyhtiö 16 3 19 % 100 %
Pohjola Vakuutus Oy 153 29 19 % 100 %
Protector Forsikring ASA 6 3 50 % 100 %
Suomen Keskinäinen Lääkevahinkovakuutusyhtiö 45 9 20 % 89 %
Suomen Vahinkovakuutus Oy 4 2 50 % 100 %
Tokio Marine Kiln Insurance Ltd (DUAL Finland) 1 0 0 % 100 %
Turva Keskinäinen Vakuutusyhtiö 30 8 27 % 100 %
Ulkomainen vahinkovakuutusyhtiö 1 0 0 % 100 %
Ålands Ömsesidiga Försäkringsbolag 2 2 100 % 100 %
Total 613 165 27 % 98 %
Life insurance companies
Life insurance companies Decisions kpl Compensation recommendations Compensation recommendations % Compliance %
Aktia Henkivakuutus Oy 7 3 43 % 67 %
AXA (Genworth Financial, henki) 2 1 50 % 100 %
Chubb (ACE Europe Life Limited) 2 0 0 % 100 %
Kaleva Keskinäinen Vakuutusyhtiö 11 0 0 % 100 %
LähiTapiola Keskinäinen Henkivakuutusyhtiö 19 1 5 % 100 %
Mandatum Henkivakuutusosakeyhtiö 6 0 0 % 100 %
Nordea Henkivakuutus Suomi 2 1 50 % 100 %
Total 49 6 12 % 83 %
Employee benefit funds and pension funds
Employee benefir and pensions funds Desicions Compensation recommendations Compensation recmomendations % Compliance %
Sairauskassat 1 0 0 % 100 %
Vakuutuskassat 5 0 0 % 100 %
Eläkesäätiöt 1 0 0 % 100 %
Total 6 0 0 % 100 %
Banks Decisions Compensation recommendations Compensation recmmendations % Compliance %
Aktia Pankki Oyj 2 0 0 % 100 %
Danske Bank A/S, Suomen sivuliike 5 0 0 % 100 %
Handelsbanken 1 1 100 % 100 %
Nordea Bank Oyj 10 1 10 % 100 %
Oma Säästöpankki Oyj 4 0 0 % 100 %
Osuuspankki 12 4 33 % 75 %
POP Pankki 3 1 33 % 100 %
S-Pankki Oy 54 9 17 % 100 %
Säästöpankki 4 0 0 % 100 %
Ålandsbanken Abp 3 2 67 % 100 %
Total 98 18 18 % 97.50%
Investment service providers and other investment matters
Investment service providers and oter investment matters Decisions Compensation recommendation Compensation rcommendation % Compliance %
Danske Bank A/S, Suomen sivuliike 1 0 0 % 100 %
Front Capital Oy 1 1 100 % 100 %
Mandatum Henkivakuutusosakeyhtiö 3 1 33 % 100 %
LähiTapiola Keskinäinen Henkivakuutusyhtiö 2 1 50 % 100 %
Nordea Henkivakuutus Suomi Oy 5 1 20 % 100 %
OP-Henkivakuutus Oy 3 1 33 % 100 %
SEB Life 2 0 0 % 100 %
Total 17 5 29 % 100 %

ADR disputes in 2023

The obligation to report ADR disputes is based on a decree of the Ministry of Justice issued on the basis of the ADR Directive. This share of FINE disputes consists of cases in which a consumer who has bought a financial product claims compensation from their service provider.

Concluded disputes, ADR

Concluded disputes, ADR
Final outcome Banking Investment Insurance Total
In favour of the serice provider 41 5 196 242
In favour of the customer 17 2 88 107
Settlemnt 13 2 54 69
Dismissed 7   1 8
- Not suitable for resolution prodedure 6     6
- Pending or processed elsewhere 1   1 2
Processing suspended 8   6 14
Total 86 9 345 440
Breakdowng by sector 20 % 2 % 78 % 100 %
Recommendations not complied with 1   2 3
Complicated issue 5 4 10 19
Processing time from completion of correspondence (days) 41 104 65 62

Incoming consumer disputes, ADR

Type of insurance Compensation issues Contractual issues Obligation to inform Causing losses, cheating Total
Personal accident insurance 120   1 2 123
Home insurance 61   1 4 66
Health insurance 21 1 10   32
Voluntary motor vehicle insurance 25 1 1 4 31
Legl expenses insurance 20   1   21
Travel insurance 18     1 19
Animal insurance 7 1 2   10
Liability insurance 3   1 3 7
Boat insurance 6       6
Loan insurance 2       2
Motor liability insurance   1 1   2
Risk life insurance 1       1
Total 284 4 18 14 320
Category Quantity
Credit issues 12
Other 2
Account access and payments 40
Total 54
Category Quantity
Compensation issues 1
Obligation to inform 2
Total 3

10. Organisation

The Supervisory Board of FINE oversees and directs the activities of the organisation. The Supervisory Board approves FINE's strategy, budget and financial statements, and appoints members of the committees and FINE's management. The Supervisory Board is chaired by Astrid Thors, M.LL. The members of the Supervisory Board represent the Finnish Competition and Consumer Authority, the Financial Supervisory Authority and Finance Finland FFI, which are the parties to the agreement that is the basis of FINE's activities. In addition, the Supervisory Board had invited members representing the Ministry of Social Affairs and Health and the Ministry of Finance.

According to FINE's statutes, FINE's administration also includes an Executive Committee. The Executive Committee appoints members of the complaints boards and prepares FINE's budget and action plan for approval by the Supervisory Board.

The complaints boards are made up of representatives of service providers, business, the judiciary, public authorities, universities, the social and health sectors and consumer organisations. In total, there are more than 70 members on the complaints boards, in addition to our own staff.

In 2023, the FINE office had an average of 29 employees, and its activities consisted of counselling, dispute resolution and communication. Since 23 January 2023, Anu Koskenvuo has served as Chief Executive Officer, and Tuomas Siirala, Senior Legal Counsel, continues as her deputy.

FINE is not a public authority, but an independent and impartial organisation founded on an agreement between the Finnish Competition and Consumer Authority, the Finnish Financial Supervisory Authority and Finance Finland FFI (the main contracting parties). In securities-related issues, the Finnish Shareholders’ Association is also a party to the agreement, while Eläkesäätiöyhdistys ry (Association of Pension Funds) and Vakuutuskassat ry (Association of Employee Benefit Funds) participate in the activities related to the insurance sector. The contracting parties have also invited representatives of the Consumers’ Union of Finland to participate in the FINE administration.

The costs of FINE are mainly borne by Finance Finland FFI. The auditor is Oy Tuokko Ltd, APA, with Juho Leinonen, Authorised Public Accountant, as the responsible auditor.

Supervisory Board

Astrid Thors, M.LL., Chairperson
Managing Director Arno Ahosniemi, Finance Finland FFI
Director Tero Kurenmaa, Finnish Financial Supervisory Authority FIN-FSA
Director General Katri Väänänen, Finnish Competition and Consumer Authority FCCA
Director Jaana Rissanen, Ministry of Social Affairs and Health
Financial advisor Risto Koponen, Ministry of Finance

Deputy Members

Director Hannu Ijäs, Finance Finland FFI
Senior Advisor Sonja Lohse, Financial Supervisory Authority FIN-FSA (until 30 June 2023)
Head of Legal Unit Janne Häyrynen, Financial Supervisory Authority (from 1 July 2023)
Director Paula Hannula, Finnish Competition and Consumer Authority FCCA

Presenting Officers of Supervisory Board
CEO Anu Koskenvuo, FINE
Senior Legal Counsel Tuomas Siirala as the secretary of the Supervisory Board

Executive Committee


Representatives of public authorities and organisations:
Armi Taipale, Chair, Head of Department, Financial Supervisory Authority FIN-FSA
alternate: Berndt Hertsberg, Head of Office, Financial Supervisory Authority FIN-FSA
Juha Beurling-Pomoel, General Secretary, Consumers’ Union of Finland
alternate: Tiina Vyyryläinen, Head of Advocacy, Consumers' Union of Finland
Paula Hannula, Director, Finnish Competition and Consumer Authority FCCA
alternate: Maija Puomila, Director, Finnish Competition and Consumer Authority FCCA
Professor Timo Rothovius, University of Vaasa
alternate: Victor Snellman, Managing Director, Finnish Shareholders' Association

Representatives of Finance Finland FFI:
Mari Koikkalainen, Director, OP Financial Group
alternate: Pirjo Kuusela, Head of Community and Employee Engagement, Nordea Bank plc
Riikka Laine-Tolonen, CEO, S-Pankki
alternate: Janne Lassila, Director, Danske Bank
Ritva Makkonen, Director, LocalTapiola Services Ltd
alternate: Pekka Luukkanen, CEO, Nordea Life & Pension Finland
Hannu Ijäs, Director, Finance Finland FFI
alternate: Taina Ahvenjärvi, Director, Finance Finland FFI

Persons in charge of dispute resolution at FINE

FINE Finnish Financial Ombudsman's Bureau
Anu Koskenvuo, LL.M., CEO, (from 23 January 2023)
Harri Isokoski, LL.M., Senior Legal Counsel
Tuomas Siirala, LL.M., Senior Legal Counsel
Emilia Hanén, M.Sc. (Law), Head of Division
Tuomas Hidén, M.Sc. (Law), Head of Division
Jussi Korpelainen, B.Sc. (Law), Head of Division
Kaisa Laine, M.Sc. (Law), Head of Division
Vesa Sainio, LL.M., Head of Division
Oona Sternhufvud, M.Sc. (Law), BA (until 28 May 2023)
Jenni-Maria Pippola, M.Sc. (Law), Head of Division (from 29 May 2023)

As regards the composition of the complaints boards, the FINE Supervisory Board appoints the complaints board chairpersons and members with their alternates on the basis of nominations made according to the provisions in the statutes. The dispute resolution experts are independent specialists and in this role do not represent their respective employers.


Appendix 1. Opinions submitted

  1. Commerce Committee of the Finnish Parliament: HE 44/2023 Government bill to Parliament to amend section 5 of the Act on Equity Savings Accounts
  2. Regulations and guidelines of the Financial Supervisory Authority: Knowing your customer in relation to complying with sanctions and freezing orders
  3. Ministry of Justice: Need for changes to the Code of Real Estate, working group report
  4. Ministry of Finance: Need for changes to the legislation on basic banking services and credit institutions
  5. Ministry of Social Affairs and Health: National implementation of the Motor Insurance Directive, working group report
  6. Finnish Competition and Consumer Authority: Consumer Ombudsman's guideline: good practice in consumer debt collection
  7. Ministry of Justice: Request for an opinion on a report on the development of out-of-court dispute resolution and mediation
  8. Ministry of Justice: Public body liability for damages, working group report
  9. Ministry of Social Affairs and Health: Investment Funds Directive, section consultation
  10. Commerce Committee of the Finnish Parliament: U 22/2023 vp Letter from the Government to Parliament on the Commission proposal for a Directive of the European Parliament and of the Council amending the Directives and Regulation in order to establish a Retail Investment Strategy
  11. Ministry of Justice: PSD3 Directive and PSR Regulation (Third Payment Services Directive and related regulation), discussion paper
  12. Ministry of Justice: Draft U paper, amending the ADR Directive (Directive on alternative dispute resolution for consumer disputes) and repealing the ODR Regulation (Regulation on online dispute resolution for consumer disputes)

Appendix 2. Breakdown of enquiries by insurance type and banking issues

Insurance - top ten Quantity
Home insurance 1644
Other non-life insurance 1120
Personal accident insurance 728
Voluntary motor vehicle insurance 720
Health insurance 695
Liability insurance 550
Motor liability insurance 401
Travel insurance 382
Real estate insurance 185
Statutory accident insurance 178


Banking - top ten Quantity
unauthorised use of banking ID 430
basic banking services 229
account agreement 159
other 152
mortgage 132
know your cutomer 128
false alarm 123
consumer credit 116
international payment 101
interest 95


Investment issues - top ten kpl
investor protection 52
validity and termination 31
safe custody 25
scam 25
redemption 21
other 21
euro amount 17
online banking 12
transfer 11
false alarm 10