eInvoicing in Finland

Legislation

On February 2019, Finland’s parliament passed a law requiring public bodies to accept exclusively electronic invoices (eInvoices) being compliant with the European standard on eInvoicing (EN). The transposition of the Directive 2014/55/EU was realised with the law on eInvoicing that entered into force on 1 April 2019 for central government bodies [1].

Finland used the extra year for compliance of non-central entities, so that sub-central contracting authorities and contracting entities must receive and process eInvoices, which comply with the European standard on eInvoicing as of 1 April 2020. Thus, for public procurement entities, other than central government bodies, the adoption deadline is on 1 April 2020.

The Finnish law on eInvoicing has two national extensions to the Directive 2014/55/EU:

• extend nationally to invoices based on contracts above national thresholds but below EU thresholds;
• the contracting entity and the trader shall have the right to receive, on request, an invoice from another contracting entity or trader as an EN-compliant eInvoice.

The public procurement process area is one of the key development areas in the Government Financial Administration Strategy for 2014-2020. The State Treasury is responsible for implementing public procurement in central throughout the entire procure-to-pay process.

Triggered by Covid-2019 health-crisis, the Finnish treasury released a statement on 18 March 2020 in which they revoked the 1 April deadline. Therefore, public entities and Finnish companies still had the possibility to exchange eInvoices by using the “old national” standard until 1 April 2021. As of this date, the Finnish government and sub-national public administrations only accept and processes EN-compliant eInvoices.

From 6 April 2021, economic operators and service providers have the obligation to exchange, validate and process eInvoices aligned on the European standard on eInvoicing. Validation rules are strict. In the case of unstructured eInvoices, the sender receives an error message. Whenever the sender does not have the capability to send EN-compliant eInvoices, a bilateral agreement can be set between the two trading partners[2].

eInvoicing platform and eInvoicing management solutions

Central, regional and local authorities receive eInvoices through the eInvoice operators' network or via the three platforms free-of-charge, provided by the State Treasury:

1. The Finnish Government’s eBilling service Handi to produce and send eInvoices.
2. The Basware Supplier Portal. To submit eInvoices via the Basware Supplier Portal, economic operators need to register as a supplier and must be approved by public contracting authorities as a "supplier candidate". This portal allows the registration of both Finnish and foreign companies as suppliers. It also enables the storage of eInvoices in the database for three months after their creation.

Approach for receiving and processing eInvoices

The eInvoices submitted to the government must follow the established content requirements; eInvoices sent as email attachments are not accepted. The eInvoices sent to the government are centrally processed at the Finnish Government Shared Services Centre for Finance and HR.

Today, most of the EN-compliant eInvoice processing and payments are done manually. At the government level, eInvoices are used to facilitate the payment execution and there is already an achieving system in operation. The proof-of-concepts for Distributed ledger technology (DLT) and the usage of robotics are part of the technical tools used by administration. The goal is to enable the automation of the public sector's eInvoice process.

The Finnish government has also started to implement electronic receipts (e-Receipt) for both businesses (and consumers), called eKuitti in Finland. In the fall of 2019, eKuitti’s first pilot was launched, and it will go live in 2025.

EInvoicing implementation is promoted at the Scandinavian level, in the Nordic Smart Government (NSG) project. In Finland, the NSG project is led by the Finnish Patent and Registration Office (PRH) in cooperation with the Ministry of Finance and the Tax Authorities. The aim of the NSG project is to automate the financial flow of information between companies in Scandinavian countries [3]. The target eInvoicing benefits are the cost and operational savings and the reduction of administrative burden.

No electronic signature is required for eInvoices and the archiving period amounts to 10 years, with the exception of invoices related to real estate investments whose archiving period is 13 years[4].

eInvoicing implementation in sub-central level contracting authorities 

The eInvoicing model in place is based on a shared-service approach. The exchanges of eInvoices are ensured by the eInvoice service providers and Peppol network. The information about the contracting authorities involvement is available on the State Treasury's web page. Peppol is used to ensure the reception of the eInvoicing from the non-domestic suppliers to all contracting authorities. 

Status on the implementation of the European Standard on eInvoicing (EN)

From 1 April 2021 onwards, Finnish State accepts only eInvoices that are compliant with the European standard on eInvoicing. If the invoice does not meet the validation rules, it is not delivered to the recipient and the eInvoice broker rejects the invoice and the sender receives an error message. If an error has occurred, the sender must correct the deficiencies in the invoice and send the invoice again[5].

The sender of an eInvoice shall use:

• either use versions Finvoice 3.0 or TEAPPSXML 3.0 of the national descriptions;
• or the syntax specified in the EU standard (EN 16931-1:2017) in accordance with the guidelines contained in the ISO/IEC 19845 (UBL 2.1) and UN/CEFACT XML Cross Industry Invoice D16B standard;
• or send eInvoices via Peppol network.

The obligatory fields in the national format must be completed in accordance with the descriptions, for example the invoice number and the invoice date, so that the invoices provide the information required in a VAT invoice.

The European standard codes must be included in eInvoices unless the seller and buyer agree otherwise (i.e. bilateral agreements). Codes in accordance with EN must be used in national eInvoices. Further information and guidelines can be found on the State Treasury’s web pages. The broader contents of the eInvoice (i.e. the information content of summary invoices) will be agreed separately between the buyer and seller. Consolidated eInvoices are not permitted.

It is also possible to send the eInvoices to government agencies using the Peppol network and therefore Peppol BIS Billing 3.0[6].

Monitoring eInvoicing implementation

The government has set specific targets for eInvoicing and its uptake is monitored monthly. The monitoring includes the total number of invoices that are submitted electronically to public bodies.

According to latest data available (May 2023), 99% of the invoices to public buyers are submitted electronically. The data is available in the State Treasury's website here (in English)[7].

Use of Core Invoicing Usage Specifications (CIUS) at national level

A CIUS has been drafted to reflect the government VAT requirements and it is currently in place. The government plans to have only one document for consultation by companies, presenting all the expected business and VAT requirements.

The communication about the CIUS is performed through the State Treasury web page and the yearly Connecting Europe Facilities (CEF) Country factsheets. 

Additional information

The Finish Information Society Development Centre (TIEKE), a non-profit organisation, maintains an eInvoicing Registry with contact information and eInvoicing address of companies that have implemented eInvoicing. TIEKE also coordinates the Finnish eInvoicing Forum, established in 2001, that brings together experts, developers, service providers and users to promote the adoption of eInvoicing based on common standards and procedures. This Forum is divided into three working groups: the technical working group, the users working group and the software working group.

In 2015, the Finance Finland produced a Study report of the climate impact of accounting automation in the context of a commitment to foster sustainable development through the use of efficient digital financial management systems. This study concluded that accounting automation can be expected to reduce the climate impact of a company by 80 to 90%. The main challenge for Finland remains the need to get rid of its domestic formats and to automate eInvoicing processes.

Digital reporting requirements

In September 2020, a study was carried out to inform the design of digital reporting requirements to be adopted in Finland. It was assumed that the annual impact of digital reporting requirements on VAT revenue from secondary sources varies between +0.2% and +2.3%, depending on the evolution of the VAT gap and the type of reporting requirement introduced[8]. In January 2023, the Finnish government published a press release emphasising the support from the government to the VAT in the Digital Age (ViDA) proposal, and encouraged the parliament to take action.

The Finnish government aims to accommodate the objectives of the ViDA proposals and the deployment of digital technology in the fight against tax fraud. The government also supports the  goal of simplifying the VAT system and reducing administrative costs. However, the details of the proposals and the potential cost for companies and the Tax Administration are still need to be clarified. The Finnish government submitted the letter U 103/2022 vp in the form of a Petition to the parliament on the proposals of the ViDA initiative published on 8 December 2022

[1] (Smith, 2021), [2] (Valtiokonttori, 2021), [3] (E-Invoicing in Finland, 2021), [4] (Compliance updates – Finland, 2023), [5] (Valtiokonttori, 2021), [6] (Onken, 2021), [7] (Kinetix, 2021), [8] (VAT in the Digital Age Report Digital Reporting Requirements, 2022)

Last updated:  Jun 17, 2024 13:32