Financial Supervisory Authority identified deficiencies in the marketing of crypto-asset services and products

In autumn 2025, the FIN-FSA carried out a thematic review targeting then-authorised crypto-asset service providers on the marketing of crypto-asset services and products. The review also covered the prior information to be provided under the Consumer Protection Act before entering into an agreement.

- Markets in crypto-assets have grown strongly, and services are being marketed extensively to new client groups that do not necessarily have prior experience with crypto-assets. From the perspective of customer and investor protection, it is essential that marketing complies with regulation and that clients receive balanced and clear information on the benefits and risks of the services and products, says Tytti Tanninen, Senior Supervisor at the FIN-FSA.

Crypto-asset operators must provide their clients a true and fair view of the products and services. Clients must also always be given, well in advance of the provision of the service, with the pre-contractual information required under the Consumer Protection Act¹.

Key findings of the thematic review

• The companies did not describe the risks associated with crypto-assets and crypto-asset services in a sufficient and balanced manner. In addition, to familiarise themselves with the risks and other information, clients were often required to take their own initiative. The risk descriptions gave the impression that all crypto-assets are subject to the same risks.
• Much of the information relevant to clients was often difficult to find.
• Not all of the companies that participated in the survey had internal guidelines relating to marketing. One company altogether lacked an approval process for the social media channels used by it.
• Only one of the companies that responded to the survey had defined competence requirements for persons engaged in marketing.
• Marketing placed particular emphasis on the ease and speed of onboarding, although especially consumer clients should have the opportunity to familiarise themselves with information on the service without haste and with due care.
• In addition, marketing appealed to the fact that the company is Finnish and supervised by the FIN-FSA. The companies also played on the notion of investing in crypto-assets safely.
• Some of the information provided on crypto-assets contained clear errors.
• In some cases, the distinction between matters presented as facts about crypto-assets and impression-creating narrative was unclear.
• Differences across crypto-assets and different types of crypto-assets were not apparent from the information on the websites. On the basis of the information provided, a potential client would not, for example, have been able to distinguish well-established crypto-assets from new crypto-assets with weaker liquidity (e.g. meme coins).
• The thematic review identified deficiencies concerning the predictability and comprehensiveness of pricing information. In some cases, pricing information was not easy to find.
• Some companies failed to provide their clients with the statutory prior information personally as required by the Consumer Protection Act.
• Some companies provided a significant part of the prior information under the Consumer Protection Act (for example the risk disclosure) only in the terms of use. It was also made easy to bypass the terms when onboarding the service, without requiring clients to study them.
• Some companies failed to provide all prior information required by the Consumer Protection Act. Information had been made available across different website sections or documents.

The application of the EU Regulation on Markets in Crypto-Assets² (MiCA) began on 30 December 2024, and since then the provision of crypto-asset services and products has required authorisation. In Finland, there was a national transitional period of six months, ending on 30 June 2025.

- The FIN-FSA requires crypto-asset service providers to consider the findings of the thematic review and to take the necessary corrective measures to ensure regulatory compliance, emphasises Tytti Tanninen.

For further Information, please contact

Tytti Tanninen, Senior Supervisor, and Pasi Åkerfeldt, Senior Inspector. Requests for interviews are coordinated by FIN-FSA Communications, tel. +358 9 183 5030, Mon-Fri 9:00–16:00.

Appendix

Report: Thematic review: Marketing of crypto-asset services and products (in Finnish)

¹ Consumer Protection Act (38/1978), chapter 6 a. The chapter will be amended as from 19 June 2026. Crypto-asset service providers must also take the new requirements into account in their activities.

² Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937.