A guide to recordkeeping in 2026: best practice, tools, and future state for the Nordics

Unlike other regions, where regulators take a ‘wait and see’ approach, Nordic authorities lead with direct data inspections. And as the sector moves towards harmonizing how financial institutions handle risk and surveillance, recordkeeping best practices must keep up.

In this guide, explore the expectations that Nordic regulators hold around recordkeeping in 2026, recent enforcement action, and the tools that you can implement to stay on the right side of the legislation.

What are the regulatory expectations for 2026?

As of 2026, Nordic regulators have aligned their expectations with the broader European trend of proactive enforcement.

Finanstilsynet, Finansinspektionen, and the FIN-FSA have each moved away from checking whether compliant entities simply have a policy in place or simply reacting to flagrant violations. Instead, they’re actively inspecting whether the policies are being technically enforced and ensuring that all the relevant data is being captured and preserved in a secure and useful way.

Having introduced recordkeeping expectations regarding the granularity and accessibility of data, the Nordic regulators look to be applying more pressure in their enforcement actions.

Recent violations and regulator activity

The financial sector is highly concentrated compared to other global regions, with six major banks dominating much of the market. Yet, many of these banks have received regulatory enforcement action after failings in recordkeeping:

• A Danish multinational bank was fined hundreds of millions in cumulative fines after breaching the Anti-Money Laundering Act in Denmark, among other things.
• A Finnish Bank received a penalty payment of €980,000 after FIN-FSA found that “its risk-based approach has not been sufficiently comprehensive to meet the requirements of the Act on Detecting and Preventing Money Laundering and Terrorist Financing nor had it obtained adequate customer due diligence data.”
• A Nordic corporate bank received a censure and SEK 1 billion fine from Sweden’s Finansinspektionen. The regulator found that a “substantial portion” of business volumes and transactions were from customers deemed high-risk for money laundering in the bank’s subsidiaries in the Baltic region.

With this in mind, it is likely that more financial institutions in the region will prioritize their access to communications data going forward to prevent these examples from repeating. New rules from the EU are already accelerating this push, with regulations like the proposed Financial Data Access (FiDA), to improve data handling and the Digital Operational Resilience Act (DORA) to strengthen digital security.

But reworking the recordkeeping function can also bolster surveillance efforts by actively monitoring the data coming in and going out of the business. In the past, much of this informal communications data, such as WhatsApp, Slack messages, or phone transcripts, have been overlooked. But 2026 data governance standards involve capture-at-source to cover both on and off-channel comms, unifying all of the data into a single archive. More on that later.

Regulatory commentary and announcements

The Nordic region in 2026 is defined by a shift towards proactive compliance. Of course, AI is as big a focus in the Nordics as the rest of the world, and regulators here have started to look beyond the EU AI Act. Specific recordkeeping commentary has targeted operational resilience and digitalization.

The table below covers announcements around 2026 focus areas from each of the major regulators in the Nordic region:

Regulator	Priority	Key takeaway
Datatilsynet	Monitoring and controlling data born from AI and digital channels, especially in medical devices and healthcare records	This focus has been a consequence of a number of data breaches, so firms should ensure that they validate metadata like device IDs, IP addresses, and session tokens, and that personal data processed or controlled is compliant with GDPR.
FIN-FSA	The Finnish regulator announced a new excel-based machine-language reporting model for integrated reporting.   “The operation and use of financial sector services are completely dependent on the reliable functioning of digital channels”	Your records must do more than just exist; they must prove your systems are unbreakable in real-time. Since integration with the portal happens without manual intervention, firms must be sure that they are collecting, storing and retrieving the correct communications data.
Finansinspektionen	Strengthen supervision in money laundering, terrorist financing and investment fraud through a collaboration with law enforcement, increasing information exchanged between authorities.	Intelligent recordkeeping means catching these criminal attempts before the regulators do. Your records must link transaction data with communication data (emails, chats) and suspicion indicators and prove that you’ve followed extra verification rules where appropriate.
Finanstilsynet	Norway’s regulator is reaching the end of its 2023-2026 strategy, but a main theme of this era has been digitalisation. Finanstilsynet’s strategy explicitly prioritises the reliable functioning of digital infrastructure.	Under DORA, detailed ICT incident logs and third-party risk records must be kept. Firms must also adhere to data standards, records kept in proprietary, non-exportable formats are now a compliance risk.

Tools to meet recordkeeping standards

Meeting the recordkeeping expectations set by Nordic regulators requires more than a policy document — it demands technical infrastructure that can capture, preserve, and surface data on demand.

Compliance tools, such as Global Relay Archive, capture and standardize communications data from email, social media, and collaboration platforms into a single compliant archive, directly addressing the Nordic regulators’ push for granular, accessible, and technically enforced recordkeeping.

Within the Archive, each communication is preserved once as a single authoritative record, with a proprietary security feature that provides continuous validation so records remain complete, unaltered, and available throughout their retention lifecycle — the kind of defensible audit trail that Finansinspektionen and FIN-FSA increasingly expect to inspect.

Critically for firms navigating the off-channel communications challenge — WhatsApp, Slack, voice calls, and beyond — Global Relay Archive captures content in full context, including edits, emojis, reactions, and threads, to help protect against misconduct and compliance risks. This capture-at-source approach means informal communications no longer represent a blind spot.

When investigations do arise, the ability to retrieve records quickly and completely is just as important as having captured them in the first place. Global Relay’s eDiscovery capability allows teams to search across email, messaging, voice, mobile, and collaboration platforms from a single, normalized archive, with identity-aware search, legal hold controls, and defensible export supported by a full object change log.

For firms managing GDPR expectations (a live concern for Datatilsynet given the region’s focus on data breaches and personal data handling), this same infrastructure supports the ability to locate, isolate, and where necessary delete personal data in a timely and auditable way, helping firms demonstrate that data processed or controlled meets regulatory expectations without relying on manual, error-prone processes.

Recordkeeping tooling not only exists but is becoming increasingly advanced with the maturation of AI. In time, it is likely we will see communications data archives acting as the critical underpinning of AI decision making platforms that can turn data into productivity tools.

What’s the future state of the industry?

In 2026 and beyond, regulators look to move quickly on criminal activities and compliance violations alike.

With Sweden tightening their legal framework against gross negligence, for example, meticulous recordkeeping could become the only shield in avoiding jail time. As the new Criminal Liability for Unlicensed Financial Activities Act criminalizes negligence, so without formal reports, firms may only find the proof of care they need in things like informal communications data.

It’s therefore likely that more firms will transition from defensive data capturing to real-time capture and monitoring, effectively providing a buffer against these claims. Ensuring that regulators and inspectors can be provided with accurate, complete audit trails in a timely manner will be essential.

Moreover, with the EU moving towards a single hub for ICT-related incident reporting, firms will need to work on a standardized model for recordkeeping in this area. It begs the question: if firms are willing to bear the digital transformation costs to meet these standards in one area, why not bring all recordkeeping up to par?

After spending millions standardizing IT incident data, it becomes illogical to leave communication records, surveillance operations, and trade records in decaying legacy silos.

Recordkeeping with Global Relay

Future-proof your communications data strategy with smarter risk management across all your communication channels. With central and unified recordkeeping storage across all channels, gain immutable preservation as a single authoritative record, a ‘source of truth’.

Our proprietary security feature provides continuous validation so that records remain complete, unaltered, and available throughout their retention lifecycle. Protect against data breaches and uphold your company’s reputation by meeting regulatory standards in 2026 and beyond.