Obligation to provide information in online stores

These guidelines are intended as a tool for online stores. The purpose of these guidelines is to

• help online stores to ensure that the order-related information required by law has been provided to the consumer
• reduce complaints arising from incomplete information
• increase trust in online stores.

The guidelines do not cover all possible methods of implementing online stores, and therefore they may not provide an answer that works in all cases.

During a purchasing process, an online store must provide the consumer with various information specified by law. Such information includes the contact details of the online store and information on the right of withdrawal. All advance information must be provided before the contract is concluded, that is, before the consumer places the order.

Where and at which stage information must be provided is only specified for some types of information in the legislation. The Consumer Ombudsman has also outlined the presentation of information in its past rulings.

• Some of the information must be provided at a certain point in the purchasing process. For example, just before placing an order, the most important information for the purchase decision must be provided.
• Product-specific information must also include relevant information about the products or services to be purchased.

To streamline the consumer’s service experience and increase the reliability of the online store, an online store should invest in the accessibility of information.

The purchasing process must also be clear and predictable. Consumers must be aware of the stage in the process they are currently in and of the remaining steps.

Note! These guidelines do not consider data protection requirements for online stores. Information and tools for data protection can be found on the website of the GDPR2DSM – Data Protection for SMEs project and the website of the Office of the Data Protection Ombudsman.

Provide the consumer with the following information:

1. Company name

A company name refers to the official name by which the company is entered in, for example, the Business Information System (BIS).

If the company acts as an agent or representative of another company, the company acting as an agent or representative of the other company must also provide the principal’s name and geographical address. The address for complaints must also be provided separately if it differs from the geographical address.

2. Geographical address of the company’s head office

If the address differs from the address for complaints, also provide the address for complaints.

3. Email address for consumer contacts and, where appropriate, certain electronic means of communication

Indicate if there are any other means of electronic communication that are quick and efficient to use and allow the consumer to record correspondence. Such means of communication include a feedback form, a chat or a discussion channel in an application.

4. Phone number

Also indicate the cost of calling.

When a customer contact concerns a previously concluded sale or contract, customer service must be provided from a basic-rate number. You can also offer a differently priced number for other customer service situations.

It must be clearly indicated which of the phone numbers in use is intended for matters related to previously concluded contracts, which are intended for other situations and what are the prices of these numbers.

5. Company’s business ID and register entry

Information on which trade register or other similar public register the online store has been entered and the business ID or other similar identifier for the online store in the register in question.

6. Processing of customer complaints, if different from usual

If necessary, the consumer must be informed of how the online store processes customer complaints.  If there is no specific practice, there is no need to mention this separately.

7. Customer support information and other after-sales customer services, if available

An online store must have functional customer service. In addition to customer service, an online store may also offer customer support and other after-sales customer services. If such services are available, they must be indicated, as must the terms and conditions of the services if they differ from common practices.

8. Code of conduct

The consumer must be informed of the existence of a code of conduct (for example, an ethical code for a particular sector), that is, whether any codes of conduct will be applied. How to obtain a copy of them must also be indicated.

9. Out-of-court dispute resolution body that is competent in a potential dispute

The website address of the dispute resolution body must be indicated in addition to the name of the dispute resolution body. In e-commerce, the dispute resolution body is the Consumer Disputes Board.

Read more useful examples on the page Information on dispute resolution bodies on companies’ websites and standard terms and conditions.

10. Link to the European Online Dispute Resolution platform

The website must provide a link to the European Commission’s Online Dispute Resolution platform.

Read more

Online dispute resolution on the European Commission’s website
Customer services subject to charge
Consumer Ombudsman’s guidelines and the legislation

Inform the consumer of the necessary information on right of withdrawal:

When the consumer has the right of withdrawal, indicate

• conditions and time limits for exercising the right of withdrawal and information on how the consumer can withdraw from a purchase.
• the situations in which the right of withdrawal may be lost.
• whether the consumer bears the cost of returning the products. Also indicate the amount of return costs unless the products can be returned in the usual way by mail due to their nature.
• instructions for submitting a notice of withdrawal, and provide a form for withdrawal from purchase.

In the case of service concerning a delivery of non-digital content, also provide:

• information on the obligation to pay compensation if the consumer cancels a service whose performance has begun at the consumer’s request.

When the consumer does not have the right of withdrawal, indicate

• that there is no right of withdrawal.

Conditions and time limits for exercising the right of withdrawal 

Most distance sale products are subject to a 14-day cancellation period, within which the consumer may cancel the purchase for no particular reason. An online store may grant the consumer a longer cancellation period if it so wishes.

Inform the consumer about the terms for exercising the right of withdrawal and the period during which they have to notify about the cancellation.

The consumer also has the right to cancel the contract before the delivery of the products.

No right of withdrawal or losing the right of withdrawal

You cannot limit the consumer’s right of withdrawal other than on grounds referred to in the Consumer Protection Act. For example, contract terms cannot limit the right of withdrawal because the product is sold at a discount or is of second-rate quality.

Tell the consumer

• whether they do not have the right of withdrawal at all or
• whether they may lose the right of withdrawal in certain circumstances. For example, when selling a sealed computer program to the consumer, they must be informed that opening the seal will result in losing the right of withdrawal.

Return costs

Inform the consumer if they are responsible for the costs of returning the products.

Also provide the amount of return costs if the products cannot be returned in the usual way by mail due to their nature–for example, if the products require separate handling or special transport by the post office due to their size or weight. In these situations, it is sufficient that you name one carrier and one price for the return of the products.

The consumer does not have to pay the return costs if you have not informed the consumer that they will be responsible for paying any return costs as well as the amount of such costs in cases where it is not possible to return the products by mail in the usual way

Notice of withdrawal and withdrawal form

Give the consumer instructions on how to cancel the order.

An order can be cancelled by submitting a withdrawal form (Withdrawal form template) or by other appropriate means, for example by email or by sending a notification with the products to be returned. The consumer must be given a withdrawal form adhering to the template provided in the Ministry of Justice Decree, or it must be made available.

If you do not explain the procedures for exercising the right of withdrawal, the consumer’s withdrawal period will be extended from the end of the normal 14-day withdrawal period to 12 months (14 days + 12 months). If the vendor provides the missing information, the withdrawal period ends 14 days after the date on which the consumer received the correct information.

Consumer liability for services provided (services concerning non-digital content)

The provision of a service may commence after the delivery of a confirmation before the end of the withdrawal period if the consumer has made an explicit request to that effect and has given their consent that they no longer have the right of withdrawal after the service has been provided in its entirety.

Even if the provision of the service has begun during the withdrawal period at the request of the consumer, the consumer may still cancel the service. However, the consumer must pay the vendor a reasonable compensation for the service they have used.

A reasonable compensation means the amount corresponding to the proportional share of the total price of the service that was provided before the cancellation of the contract. However, there is no right of withdrawal if the service has been fully provided and the consumer has been informed of the lack of the right of withdrawal in such a situation.

The consumer does not have to pay for a service that the company provided partly or in full during the cancellation period if the company started providing it during the withdrawal period without the consumer’s consent or has not informed of the liability for compensation related to a cancellation.

Read more

Consumer Ombudsman’s guidelines and the legislation

Inform the consumer that the seller is liable for a defect in the products on the basis of the provisions on liability for defects laid down in the Consumer Protection Act. It is sufficient to explain the liability for defects in general terms.

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Consumer Ombudsman’s guidelines and the legislation

A warranty is an additional benefit provided voluntarily by a seller or other party, and it must be explained when offered to the consumer.

If a product has a warranty, explain at least its validity period and what does it cover.

A clear way to indicate a warranty’s coverage and other warranty terms is to provide, for example, a direct link to the warranty terms provided by the seller, manufacturer or importer in connection with the product information or description.

Read more

Consumer Ombudsman’s guidelines and the legislation

Inform the consumer clearly of the terms of delivery for the products or services.

1. Delivery time

Explain by when the products are delivered or the service is performed.

For example, indicate that the company agrees to deliver the product by normal delivery in 5-9 business days and by express delivery in 1-2 business days. Note that the promised timeframe for delivery is binding. Under the law, the product must be delivered within 30 days unless otherwise agreed.

2. Delivery options

Provide the available delivery options.

For example, by mail, courier or freight.

3. Delivery costs

Provide the delivery costs.

Read more

Consumer Ombudsman’s guidelines and the legislation

Explain delivery restrictions, for example, if you deliver to certain countries only, at the latest at the beginning of the ordering process. It is recommended that delivery restrictions are also mentioned in the information concerning deliveries.

Read more

Consumer Ombudsman’s guidelines and the legislation

Provide sufficient information for the purchase decision. The features of a complex product or service must be described in more detail than those of a simple product.

For digital products, information on their functionality and compatibility with hardware and software must be provided.

1. Main features

On the product page, describe the main features of the products and services. These may include the intended use of the product and information related to its identification, such as the product number.

For a simple product that is familiar to consumers, it is often enough to simply describe the title and possible size or colour options.

For example, a more comprehensive and detailed description must be provided for a complex technical device so that the consumer can assess whether the product is suitable for their purposes.

Where the object of the sale is a product, digital content or service containing digital elements, the consumer must be informed of their functioning and applicable technical protection measures.

Compatibility with hardware and software must also be described. Compatibility refers to, for example, information about the operating system, its version and certain hardware features needed to access digital content. Interoperability must also be described. The information must be provided to the extent the online store has knowledge or the online store can reasonably be expected to have knowledge.

2. Total price

Give the total price of the product or service including taxes. If the exact price cannot be calculated beforehand, state the basis for determining the price.

If the price of the products or services has been determined individually on the basis of automated decision-making, the consumer must be informed of this.

The total price must include not only the price of the product but also the delivery costs. If delivery costs are not included in the price of the product, state the possible delivery costs or at least that delivery costs will be added to the price of the product.

The requirements concerning the provision of unit price must also be considered in giving the price.

Also note the following when giving the price of contracts:

Contracts valid until further notice must state the total costs per month and per invoicing period. If the total costs cannot reasonably be calculated in advance, the manner in which they are calculated must be described.

Contracts that are valid until further notice or include recurring payments must define the total costs for the invoicing period.

• For example, if the contract is invoiced at an interval of half a year, such as a magazine subscription or electricity contract, give the total price for the invoicing period.
• In the case of a fixed-price contract, give the total costs per month and per invoicing period.

When marketing a contract for a fixed term, the total price must be given for the entire term, such as 12 months.

3. Duration of the contract and information on its termination

In the case of a fixed-term contract that ends at the end of the fixed term,

• provide the duration of the fixed term.

In the case of a contract that is automatically extended to be valid until further notice after a certain fixed-term period,

• provide the duration of the fixed-term contract period and the terms and conditions for terminating the contract.

In the case of a contract that is valid until further notice,

• provide the terms and conditions for terminating the contract.

Read more

Consumer Ombudsman’s guidelines and the legislation

An online store must provide information on payment methods and payment at the beginning of the ordering process at the latest. An ordering process begins, for example, when a consumer enters their personal information or other information needed to place an order on the website.

In other words, it is not enough to display the payment methods and their costs on the order path only when selecting the payment method or in another section after the beginning of the ordering process. The consumer should not be allowed to proceed beyond the beginning of the ordering process until they have been informed of the payment methods and their costs.

Presentation of payment methods online

As of 1 October 2023, payment methods must be presented to consumers online in a certain order when they are concluding a contract (chapter 6, section 12 b of the Consumer Protection Act). For example, a payment method that involves taking out credit or otherwise deferring payment may not be offered as the primary option.

Payment methods must be presented in the following order:

1. Payment methods that do not include the possibility to apply for or use credit or otherwise defer payment. These include for instance oline payments, debit cards or Visa Electron cards or exercise and culture benefits.
2. Payment methods that may include the possibility to apply for or use credit or otherwise defer payment. These include for instance combination cards with debit and credit functions and mobile payment applications to which the consumer can link their debit or credit card.
3. Payment methods that involve applying for or using credit or otherwise deferring payment. These include for instance concluding a credit contract, using a charge or credit card and paying by invoice or mobile payment application when it means using credit.

No payment method should be set as the default option. The consumer must select the payment method without an automatic default option for each contract, so a payment method must not be set as default even on the basis of the consumer’s previous purchase.

If the payment service provider, creditor or other trader has been able to influence the manner in which payment methods are presented, the obligation to present payment methods in a lawful order also applies to the operator in question.

Accepted payment methods

An online store must always offer at least one commonly used payment method that has no additional costs. Customers must be able to pay for their purchases without any additional costs caused by a payment method. However, no additional costs may be charged

• for using consumers’ most common payment cards, such as Visa and MasterCard
  when the consumer pays for their purchase with a SEPA credit transfer or direct debit.
• Clearly indicate all accepted payment methods and the additional costs for using them.

More information needs to be provided on new payment methods than on options that have been used for a long time.

Invoice

Remember to clearly indicate if the invoicing method causes additional costs. Agree with the consumer whether the invoice is to be delivered by email or by mail.

There must be a clear distinction between an invoice and credit.

Indicate the due date and overdue interest. Remember that you cannot charge customers a higher interest rate than what is specified in the Interest Act.

Information that must be provided before a credit contract is concluded

If your online store offers credit to finance an online purchase, make sure that the following information is provided to the consumer before concluding the credit contract.

• Information on the business, financial service provided, distance selling contract and redress mechanisms referred to inChapter 6 a, sections 6-9 of the Consumer Protection Act (in Finnish).
• Standard European consumer credit information referred to in Chapter 7, section 9 of the Consumer Protection Act (in Finnish). The information must be provided in a clear and understandable manner appropriate to the remote communication method used, that is, it must be appropriately shown in the financing offer process.

The obligation to provide advance information and contract terms applies to both creditors and companies acting as credit intermediaries. By contrast, companies acting as credit intermediaries are not legally obliged to provide standard European consumer credit information to the consumer.

Both standard and individually agreed terms and conditions must be printable, and the consumer must be able to save them.

Advertising credit

If the consumer can conclude a credit agreement as part of the online store’s purchasing process, your online store will act as a credit intermediary for the credit product in question, and you will be responsible for marketing consumer credit on your website together with the creditor.

In the role of a credit intermediary, a special level of accuracy is required from online stores. Acting as a credit intermediary involves several obligations imposed by mandatory legislation, for which online stores are responsible.

If you advertise credit as a payment method for a product and the advertising shows information on the terms of the credit contract, the details of the credit must be provided as referred to in the Consumer Protection Act. All information on the credit must be easily found in one place.

• If you only offer the possibility of obtaining consumer credit without mentioning the contract terms, you do not need to state the credit terms in the same context. For example, when your marketing tells about an accepted credit card or the possibility to pay in instalments.

If you advertise credit and explain the terms of the credit contract, you must provide

1. the actual annual interest on a credit
2. the interest on the credit and other credit costs
3. the amount of the credit or the credit limit
4. the duration of the credit contract
5. the cash price of the commodity and its possible down payment, in the case of a credit advertised to finance the purchase of a particular commodity
6. the total amount of the credit and credit costs and the number of payment instalments.
7. information on whether it is a one-time credit or a continuous credit.

The information provided on credits must be clear, prominent and concise in advertising and must not be scattered across websites in such a way that it is not easily accessible to the consumer as a whole. For example, the amount of a monthly instalment of a credit may not be emphasised if other required information must be hidden behind a link or a pop-up window due to space constraints.

The consumer must be informed if they are required to provide guarantees (for example, an authorisation hold from a payment card). In addition, the terms and conditions of the guarantees must be provided.

Payment delays

If the consumer pays an invoice late, they may be charged overdue interest as referred to in the Interest Act. These provisions are mandatory and cannot be applied in any other manner to the detriment of the consumer. (Interest Act 633/1982).

The amount of overdue interest in consumer relations depends on the reference rate set by the European Central Bank every six months. In consumer relations, overdue interest is the reference rate mentioned above plus 7 percentage points. However, if the current interest rate agreed on the debt is higher than this, the same interest will also be charged for the delayed instalment.

Read more about payment methods and invoicing in the Consumer Ombudsman’s guidelines

Consumer Ombudsman’s guidelines and the legislation

Consumer Ombudsman’s guidelines

The purpose of the Consumer Ombudsman’s guidelines is to provide companies with instructions, advice and information on the practical application of legislative provisions.

• Online sales and other distance selling (in Finnish)
• Payments in online shopping (in Finnish)
• Offering consumer loans (in Finnish)
• Payments and invoicing (in Finnish)
• Good practice in consumer debt collection (in Finnish)
• Drawing up contract terms (in Finnish)
• Changes in contract terms (in Finnish)
• Statutory liability for lack of conformity and guarantee in the sale of consumer goods (in Finnish)
• Stating the price of goods and services (in Finnish)
• Legislation (in Finnish)

The provisions of Chapter 6 of the Consumer Protection Act and the Ministry of Justice Decree on the withdrawal form and withdrawal instructions (110/2014) are applied to distance sales. The provisions are mandatory for the benefit of the consumer. Therefore, the trader cannot draw up its own conditions that weaken the consumer’s position. Operating methods that improve the consumer’s position can be used.

The following legislation must also be considered:

• marketing provisions in Chapter 2 of the Consumer Protection Act and provisions on delays and errors in Chapters 5 and 5 a
• provisions of Chapter 6 a of the Consumer Protection Act on distance selling of financial services and financial instruments
• Government Decree on communicating the price of consumer goods in marketing
• Information Society Code (electronic direct marketing, chapter 24, section 200)
• Information Society Code (obligation to provide information, chapter 22)
• Act on the Provision of Services (obligation to provide information, chapter 2, section 7 and 8)
• Guardianship Services Act (status of the incompetent person, chapter 4, sections 23–26)
• General Data Protection Regulation