Trade association price recommendations under review by the Finnish Competition Authority

Trade associations have been a focal point for the Finnish Competition and Consumer Authority (FCCA) for years. When competitors gather under an association's umbrella, concerted practices can easily cross into anti-competitive territory. This makes it essential for industry associations to exercise extreme caution in their communications with members, particularly regarding pricing matters.

Competition law requires businesses to make commercial decisions independently, prohibiting associations from issuing price recommendations, coordinating strategies, or facilitating the exchange of sensitive information. Violations can result in penalties of up to 10% of annual turnover.

Investigation into physiotherapy pricing guidance 

The FCCA recently investigated the Finnish Association of Physiotherapists after observing that the trade association had expressed views on physiotherapy pricing across multiple communication channels. These included the association’s website, webinars and their recordings, its magazine, and one-to-one member advisory services. The association had expressed concern that physiotherapy prices in Finland were too low.

The association avoided penalty payments by removing the problematic materials and committing to conduct a competition law self-assessment of its practices. The FCCA emphasised that each business must determine its commercial activities and prices independently, and that instructions aimed at influencing business behaviour or service price levels are prohibited – even when presented as helpful guidance or recommendations rather than binding requirements.

Key practices considered problematic by the FCCA

In detail, the problematic practices applied by the Finnish Association of Physiotherapists that concerned the FCCA included the following:

• Guidance on profit margin and service pricing: The association provided recommendations on appropriate profit margins and specific pricing for services such as home visits and remote consultations.
• Public commentary on market price levels: Public statements suggesting that market prices were too low effectively signalled acceptable pricing levels to members.
• Instruction to increase prices: The FCCA gave particular attention to an instruction to raise prices by 20% in the Finnish Social Insurance Institution's (Kela) 2022 tender compared to 2018 levels.
• Pre-filled cost calculators: The association published cost calculators containing pre-set prices. 

Recent enforcement actions against Finnish trade associations 

The FCCA has actively enforced competition law compliance in trade associations’ activities over the past decade, resulting in fines for several associations and their member companies. Sanctioned practices have often involved the exchange of sensitive information or coordination that restricts market competition. The form of coordination, whether formal or informal, has been irrelevant – the conduct itself has been the key consideration.

• Finnish Bakery Federation (Suomen Leipuriliitto, 2015): Following an FCCA proposal, the trade association was fined EUR 30 000 for issuing prohibited price recommendations by encouraging bakeries to raise prices through press releases, member letters, and magazine editorials. The infringement lasted over three years and affected a national association whose members held around two-thirds of the market share. The conduct was considered serious due to its nature, scope and duration – particularly as the association had previously received warnings.
• Uusimaa Driving School Association (Uudenmaan Autokouluyhdistys, 2021): The trade association and three of its members were fined between EUR 3 000 and EUR 25 000 for issuing price recommendations. The FCCA found that their actions sought to limit price competition and encourage competitors to raise prices.
• Finnish Real Estate Management Federation (Isännöintiliitto, 2025): The most recent and financially significant case resulted in fines exceeding EUR 6.5 million for conduct restricting price competition. The trade association’s public communications were deemed to have sought to influence prices across the entire sector in an anticompetitive manner.

For more information, please contact Katia Duncker, Petteri Metsä-Tokila or Maria Karpathakis.

VISIT OUR COMPETITION LAW HOMEPAGE