Title : Small modular reactors and the regulatory struggle: Reconfiguring the nuclear strategic action field in Finland
Abstract:
This paper examines how small modular reactors (SMRs) reshape nuclear regulation by generating a simultaneous struggle for de-regulation and re-regulation within the Finnish nuclear policy field. Instead of seeing SMRs only as a new technology, the study views them as a catalyst that disrupts existing regulations, shifts power, and brings in new actors and organizational models. The analysis is guided by strategic action field theory, which views policy domains as arenas in which incumbents, challengers, and governance units negotiate rules, resources, and forms of legitimate knowledge.
Empirically, the paper analyzes the ongoing reform of the Finnish Nuclear Energy Act (TEM032:00/2023). Finland provides a critical case due to its highly institutionalized nuclear safety culture, corporatist policymaking structures, and proactive regulatory modernization aimed at enabling SMR deployment for district heating and industrial decarbonization. The data consists of proposed bill to parliament and 55 official consultation statements submitted by ministries, the regulator, expert authorities, municipalities, energy companies, industry associations, SMR developers, research organizations, and civil society actors. The datal was analysed using theory-driven qualitative content analysis.
The findings show that SMRs do not produce a simple shift toward lighter regulation. Instead, they generate a dual regulatory dynamic. A broad coalition of incumbent utilities, industry associations, SMR developers, and industrial energy users advocates modular licensing, documentation reuse, and risk-based proportionality to enable serial production and improve investment predictability. At the same time, governance units, legal authorities, municipalities, and environmental organizations call for strengthened site-specific assessment, municipal planning authority, constitutional safeguards, and integration with security and critical infrastructure frameworks. Because SMRs are often associated with urban deployment, they expand regulatory oversight into new spatial and administrative domains rather than reducing it.
The analysis also identifies the emergence of challenging actors who do not fit the traditional model of vertically integrated utilities operating large reactors, including municipal energy companies, district heating operators, and technology startups. However, incumbent utilities adopt many of the same modular discourses and position themselves as central actors in the SMR transition, indicating a process of controlled incorporation rather than displacement.
Overall, the results demonstrate that SMRs open a period of negotiated adjustment within the Finnish nuclear strategic action field. Regulatory practices become more flexible and multi-level, new actors gain conditional access, and oversight extends into proximate domains, while core power relations remain largely intact. The paper contributes to sustainability transitions research by showing how regulatory regimes in high-risk infrastructures adapt through simultaneous pressures for de-regulation, re-regulation, and elite coordination.
