Subject of the report / Parties involved: ______________________
Subject: Incorrect change of address data in the electricity market Datahub, the directing of invoices to the wrong address, and the billing of payment reminder and debt collection fees resulting from this. A request to assess the conduct in terms of good debt collection practice and consumer protection.
1. Background and description of the matter
I hold several electricity contracts at different addresses. The contracting parties are the energy companies listed below, which have outsourced their billing and payment monitoring to Ropo Suomi Oy.
I have noticed that when I make changes to one of my electricity connections, the billing address of my other valid electricity contracts also changes. As a result, paper invoices and e-invoices have been directed to wrong or empty premises and have not reached me.
Specific features and observations regarding your own situation:
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2. How the debt collection fees arise
Because the original invoices have not been directed to me, I have not received them before the matter progressed to the payment reminders and debt collection letters with fees sent by Ropo Suomi Oy.
I have paid the principal amounts of the invoices immediately upon becoming aware of them, and I have disputed the debt collection fees. I ask you to assess whether charging fees in such a situation is in line with good debt collection practice.
3. Legal points I ask you to assess
- The Act on the Collection of Debts (perintälaki 513/1999), Section 4: in debt collection, the debtor must not be caused unnecessary costs. I ask you to assess the charging of costs in a situation where the delay is due to an error in the delivery of the invoice.
- The Act on the Collection of Debts (perintälaki 513/1999), Section 10 a: fees for a payment reminder may be charged only if the claim has been delivered to the debtor in the manner required by law.
- Consumer protection: I ask you to assess who bears responsibility for the invoice reaching its destination when the consumer has provided their billing address correctly.
4. Request
I ask the Finnish Competition and Consumer Authority to assess the conduct described above in terms of good debt collection practice and consumer protection. With this report I do not request a resolution of my own individual case, but bring the conduct to the authority's attention.
