Qualifying holding
A qualifying holding is a direct or indirect stake of 10% or more of the capital or voting rights in a regulated financial firm, or any stake that gives significant influence over its management. Anyone planning to acquire or increase one must notify the firm's regulator in advance and can be blocked.
How the rule works
The concept comes from EU banking law and applies, with adaptations, to e-money institutions, payment institutions, investment firms and insurers. For a bank, a proposed acquirer must notify the regulator before crossing 10%, and again before crossing 20%, 30% and 50%, or before the bank becomes its subsidiary. For an e-money institution, Article 3(3) of the E-money Directive requires advance notice of acquiring a qualifying holding and of crossing 20%, 30% or 50%. Finland's Payment Institutions Act (297/2010, section 21 a) sets the first notice point for e-money institutions at 20% of capital or votes, or comparable influence, then 30% and 50%. Reductions below these thresholds must be notified too, and the e-money institution reports its qualifying owners to FIN-FSA at least once a year.The regulator, FIN-FSA in Finland, assesses the acquirer's reputation, financial soundness and the source of the money used, and whether the deal raises money laundering concerns. It can oppose the acquisition within a set assessment period.
Why it matters outside the firm
For investors, a qualifying holding means a regulatory approval step before closing. For a licensed firm's clients and partners, it's one reason ownership changes at regulated providers are slow and public.FAQ
No. A UBO is a person who ultimately owns or controls a company, with a 25% threshold under AML rules. A qualifying holding is a prudential concept with a 10% threshold, and the holder can be a company.
Related terms and sources
FIN-FSA · E-money institution · Ultimate beneficial owner · Source of funds · Browse the full glossary
Last reviewed October 23, 2026Disclaimer
This publication is provided for general information purposes and does not constitute legal, tax, or other professional advice from Narvi Payments Oy Ab or its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
This publication is provided for general information purposes and does not constitute legal, tax, or other professional advice from Narvi Payments Oy Ab or its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
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