Real-Time Mobile Payment


We advised Automatia Pankkiautomaatit Oy in its real-time mobile payment project and assisted Automatia in an investigation by the Finnish Competition and Consumer Authority (FCCA).

Automatia is a company owned in equal shares by Danske Bank, Nordea Bank and the OP Group. Automatia maintains and develops the network of Otto., OttoPlus. and TalletusOtto. automatic telling machines. Every full-service bank operating in Finland is a customer of Automatia. 


Thanks to its ATM network, Automatia has the all of the inter-bank account connections. With them, Automatia can produce a payment forwarding platform enabling real-time mobile payments in applications provided by banks and other service providers.

Automatia’s service consists of the payment forwarding platform that enables real-time mobile payment and the related user register used to forward payment in real time using the users’ telephone numbers.

FCCA Proceedings

Due to Automatia’s ownership base, the project was assessed as cooperation between competitors. The competition law assessment had to ensure that the cooperation would lead to consumer benefits and not restrict competition.

Given the challenging starting circumstances, the matter was presented to the FCCA at an early stage in order to ensure that the cooperation was permissible from the perspective of the authorities. Numerous discussions were held with the FCCA concerning the details and practical implementation of the real-time payment forwarding platform and the closely related user register.

FCCA Proceedings (continues)

The FCCA raised several concerns in these discussions and consulted numerous experts and market participants. Several negotiations were held with the FCCA concerning these concerns and various solutions to them.

During the FCCA proceedings, it became clear that the only way to remove the FCCA’s concerns and implement the mobile payment platform was for Automatia to undertake to comply with certain conditions. As a result, Automatia proposed certain conditions to the FCCA, which it complies with when providing the service.


Once the negotiations with the FCCA reached a favourable result, Automatia’s board decided to implement the real-time mobile payment forwarding platform starting on 1 March 2017. The matter was finally closed on 19 June 2017 when the FCCA issued its decision on the conditions to be complied with by Automatia.

Our advice in the matter made it possible for Automatia to establish and maintain a payment forwarding platform in Finland that allows consumers to make and receive real-time payments using mobile applications offered by banks or other service providers.

The Team