At the end of the year, we wrote about amendments to the Consumer Protection Act arising from the EU’s Sale of Goods Directive (2019/771). In addition to transposing of the Sale of Goods Directive, the Consumer Protection Act has now been also been updated for the digital age by transposing the Digital Content and Digital Services Directive (2019/770) (also called the Digital Contracts Directive). These amendments entered into force on 1 January 2022.
20.1.2022
Consumer Protection Enters the Digital Age: Digital Content and Services Now Expressly Regulated
Hilma-Karoliina Rozell & Piia Raappana
Digital Content and Services Now Expressly Accounted for in Consumer Protection Act
The Consumer Protection Act now includes a new Chapter 5a, which includes specific provisions concerning digital content and services. The Consumer Protection Act previously did not expressly regulate digital content and services. In the future, Chapter 5a will include provisions on, among other things, delivering digital content and services, defects in digital content and services and the consequences of such defects, as well as on modification of digital content or services.
Digital content means, for example, computer programs, digital games and electronic books. Digital services mean, for example, cloud services and services such as social media.
It is worth noting that the new Chapter 5a applies not only to the contracts by which consumers commit to pay for digital content or services, but with certain limitations also to contracts by which consumers commit to provide personal data to traders.
Here are some of the key amendments:
New Provisions Seek to Clarify Legal State
Like the Sale of Goods Directive, the new provisions of the Digital Contracts Directive are intended to facilitate the offering and availability of content and services in the EU between Member States. Adding express provisions concerning digital content and services to the Consumer Protection Act also helps clarify the legal state, even though the Consumer Protection Act was already analogically applied to digital content and services as appropriate.
The most significant amendments are definitely the application of the new Chapter 5a to contracts by which consumers provide or commit to provide their personal data in exchange for digital content or services. Previously, the Consumer Protection Act’s provisions on delays and defects were not even analogically applied to such contracts.
Latest news
Latest references
Suominen Corporation – Rights Issue
We advised Suominen Corporation in connection with its rights issue. The offering was oversubscribed, and the company raised gross proceeds of approximately EUR 28 million. We also advised Suominen in connection with the renegotiation of the terms of the company’s three-year EUR 100 million syndicated credit facility, under which the maturity was extended and headroom was added to the financial covenants. “I would like to thank our shareholders for their support and confidence in Suominen’s future. The completion of the Offering will enable us to accelerate the implementation of our Full Potential Program while strengthening our capital structure. Our transformation particularly focuses on enhancing the reliability and efficiency of our production and supply, and on reinforcing our commercial capabilities, allowing us to better meet the expectations of our customers and shareholders”, comments Charles Héaulmé, President and CEO of Suominen. Suominen is a nonwovens manufacturer operating in global markets. Suominen creates value by taking fiber raw materials and turning them into nonwovens that the company’s customers convert into both consumer and professional end products. Suominen’s vision is to be the frontrunner for nonwovens innovation and sustainability. Suominen’s net sales in 2025 were EUR 412.4 million and the company has almost 700 professionals working in Europe and in the Americas. Suominen’s shares are listed on Nasdaq Helsinki.
Case published 6.7.2026
Nordea Bank Abp and Avain Yhtiöt – A financing arrangement of a real estate portfolio
We acted as joint legal advisor for Nordea Bank Abp and Avain Yhtiöt in an approximately EUR 48 million financing arrangement which included facilities for refinancing of an existing real estate portfolio and also for acquisition and property development purposes. The financing arrangement strengthens Avain Yhtiöt’s objective to build and maintain a functional, safe and environmentally friendly living environment, as well as to develop the overall quality of housing and construction. Avain Yhtiöt is a Finnish group specialising in housing and housing-related services, construction contracting and new construction. Its goal is to build 1,000 new apartments per year in key growth areas in Finland.
Case published 2.7.2026
Shareholders – Sale of the Suomen Autohuolto Group
We advised the shareholders of Suomen Autohuolto Oy in connection with the sale of the company’s entire share capital, to SAKA Finland Group Oy. Suomen Autohuolto Group is one of Finland’s largest companies specializing in brand-specific automotive maintenance and has locations in Oulu, Tampere, and from July, also in Järvenpää. The transaction is subject to final approval by the Finnish Competition and Consumer Authority (KKV).
Case published 26.6.2026
Natural Resources Institute Finland – AI training
We delivered two tailor-made AI workshops for the lawyers at the Natural Resources Institute Finland (Luke). We discussed the AI revolution and its impact on lawyers’ ways of thinking and working, and left the participants with practical solutions for enhancing and streamlining their work with Legora. Our AI-specialist lawyers prepared use cases tailored to Luke and the needs of public administration, which Luke received for its own use following the workshops. These use cases covered topics such as: utilising legal sources and the organisation’s own data to maximise AI results building and leveraging AI workflows AI-enhanced contract drafting based on a large volume of documents. The workshops sparked wide-ranging discussion on the role and benefits of AI in legal work. Participants appreciated how clearly and comprehensively our experts were able to present the nature and benefits of AI specifically within a legal context. ‘The workshops provided excellent support for Luke’s goal of leveraging AI responsibly and gave us concrete and ready-to-use practical takeaways,’ says Hannu Laitinen, Luke’s Senior Vice President, Administrative Affairs.
Case published 26.6.2026