Presently, Finland holds the record with respect to the number of users of on-line banking services. Almost every Finnish bank offers a service of invoice payments through the Internet. In fact, a customer of a bank can do almost everything on-line that can be done through more traditional service channels. This includes, inter alia, making deposits, applying for a loan, transferring funds between accounts or giving commissions on stock purchase.

However, development in electronic banking services is fast. Wired banking is going wireless. The largest bank in Finland, Merita-Nordbanken, released recently as a first bank in the world its mobile banking service system based on WAP application.

Mobile phones based on wireless application technology make certain banking services available over the Internet to those who have access to the net system of Merita-Nordbanken, the Solo system. Thus, a customer of the Bank is no longer limited to use only his personal computer when he needs to use banking services. He can, by using his WAP mobile phone, for example check the balance in his account and pay bills.

In addition to the variety of banking services also so called mobile commerce is available to a WAP customer of Merita-Nordbanken. The net system of the Bank gives a WAP customer access to the shopping sites of given shopkeepers. After ordering needed commodities he can pay for his purchases in the Bank´s net system.

From the legal point of view, the on-line service system is based on general contractual law and specific contracts between the parties involved viz. the bank, customers and service providers. Presently, there is no specific legislation or regulation governing on-line banking services in Finland.

Finnish consumer authorities follow closely developments in on-line banking, although no official statements have been issued by the Finnish Consumer Administration in this respect. So far, the consumer authorities have not been contacted by dissatisfied consumers.

The Financial Supervision Authority (FSA) has, in turn, particularly emphasised the importance of adequate non-face-to-face identification of clients using on-line banking services. Problems in customer identification arise especially when new customers are offered a possibility to subscribe shares, purchase unit trust units or other securities via the Internet. These problems will eventually be mitigated by future digital identification methods. The digital identification card has been available as of 1 December 1999 to everyone having his permanent domicile in Finland. This card issued by Population Register Centre for using governmental on-line services represents the first step in such digital identification.

The intention of the FSA is to contribute to identification and limitation of risks related to the use of new technology in on-line banking. The FSA has already addressed certain issues which should be taken into account when shares are offered to the public via the Internet such as integrity of the prospectus available on the Internet, data protection issues and adequate information management systems.

In future, the Internet banking services in Finland need to comply, among others, with the national legislation implementing the proposed EC electronic commerce directive and the directive on distance marketing of financial services.

This article contains general information on the subject matter and shall not be relied upon for a specific case. Specialist advice should be sought with respect to any specific circumstances.