The Transport Code (formally the Act on Transport Services (320/2017)) is one of the government's key initiatives. The code's main purpose is to create a growth environment for business digitalisation and promote transport business by deregulation. The code will reform the regulation of all transport modes, so that the regulation itself will not become an obstacle to digitalisation, automation and new innovations.

The code is tailored to enable and promote seamless and multimodal travel and transportation chains and other combined added-value mobility services by opening up the data on traffic systems to be shared between customers, service providers and authorities as freely as possible.

The project covers all transport modes and aims to bring the provisions of the different transport services under this one code to promote interoperability. Due to the code's broad scope, its preparation has been divided into three stages.

The preparation of the first stage started in November 2015. In September 2016 the government submitted the bill to Parliament and preparation for the second stage began. The first stage of the code will enter into force on July 1 2018. However, the provisions relating to intelligent transport systems based on Directive 2010/40/EU entered into force on October 1 2017, and the provisions on opening essential data have applied since January 1 2018.

Second stage

The second stage of the code will unify and deregulate the national legislation of other transport modes (ie, air, sea and rail) and bring them under the code to ensure compatability with the provisions on road transport. Different transport mode-based registers will be consolidated into a single register containing data on service operator permits, transport vehicles and personal licences (eg, professional qualifications). The second stage will strengthen the role of the Transport Safety Agency as a licensing and supervisory authority and improve registered persons possibilities to use their own data in acquiring mobility services.

The second stage legislation will further develop the digitalisation and data availability of the mobility services. The aim is to increase and innovate mobility services and improve the official and service activities of the Transport Safety Agency. The agency is obliged to share collected data through an open interface, anonymously and with regard to data protection.

To promote customer-oriented development of individualised trip chains and combined services, there will be a new provision regarding 'acting another's behalf'. This should enable all service providers, not only those in a dominant position to administer data, to act on customer's behalf to incorporate tickets for all modes of transport and mobility services. Until now, the combined transport services have been constructed on voluntary contractual basis. The code will oblige transport service providers, or their ticket and sales operators, to open sales interfaces or other electronic access to the system for other transport service providers and intermediary operators to ensure that those service providers acting on the behalf of customers can acquire individualised and personal (eg, discounted) tickets and transport products by utilising existing customer identification and user information.

Access to sales interfaces must be open without restriction if the service operators have an authorisation or permit, or if operations satisfy general standards. The service providers that are obliged to open interfaces and the operators using them must cooperate to arrange practicalities and protect personal data as required by legislation, particularly the EU General Data Protection Regulation.

The code applies to service providers which have an office in Finland or are otherwise subject to the Finnish jurisdiction. Further, the code applies to transport service providers which operate from, to or via Finland. As the code applies to Finnish operators as well as foreign service providers (eg, airlines), it will be seen how the code will be put into practice and should be welcomed among service providers.

The government proposal of the second stage (consisting of a colossal 878 pages) was submitted to Parliament on October 19 2017 and was approved with some amendments on March 21 2018. The second stage of the code will enter into force on July 1 2018, with the provisions regarding acting on another's behalf entering into force on January 1 2019. Preparation for the third stage has begun.

For further information on this topic please contact Matti Komonen at HPP Attorneys Ltd by telephone (+358 9 474 2207) or email ( The HPP Attorneys Ltd website can be accessed at

This article was first published by the International Law Office, a premium online legal update service for major companies and law firms worldwide. Register for a free subscription.