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Legislation

The law on eInvoicing, entering into force in 1 April 2020, 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 by electronic invoice.

This public procurement process area is one of the key development areas in the Government Financial Administration Strategy for 2014-2020. In fact, in 2010 Finnish Government Programme mandates the adoption of electronic invoicing (eInvoicing) by public authorities. The State Treasury is responsible for implementing public procurement in central government following the guidelines from the "From procurement to payment" processes.

Finland is using the extra year for compliance of non-central entities, so that sub-central contracting authorities and contracting entities must receive and process electronic invoices, which comply with the European standard on electronic invoices as of  1 April 2020.

Between 2014 and 2015, the State Treasury developed a process area named "From procurement to payment" that covers the planning and preparation of public procurement processes, calls for tenders, contracts management, monitoring and processing payments.

eInvoicing platform and eInvoicing management solutions

Economic operators can submit eInvoices to contracting authorities through their eInvoice Operator. The government agencies are using OpusCapita as eInvoice operator. It is also possible to send the invoices to government agencies using the Peppol network. 

Approach for receiving and processing eInvoices

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 invoices.
2. The Post Network Service allows the creation and sending of eInvoices by Finnish companies. Once registered to the platform, economic operators can create and send eInvoices. The system verifies the correct provision of information by economic operators and guarantees the successful submission of an electronic invoice to the contracting authority. 
3. 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 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;

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.

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 operators. 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. 

The European standards are only partially implemented due to the use of one year extension for the sub-central level. At domestic level commonly used eInvoice formats are Finvoice and TEAPPSXML. 

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

The target eInvoicing benefits are the cost and operational savings and the reduction of administrative burden. Today, most of the eInvoice acceptance 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.

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

With effect from April 2019 onward, public administrations will accept only those electronic invoices whose data content corresponds to the semantic data model of the EN. Invoices whose data content complies with the semantic data model may be sent to central government from August 2018 onward. 

The sender of an electronic invoice shall 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.

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 EU standard’s codes are to be used in invoices unless the seller and buyer agree otherwise. Codes in accordance with EU standards must always be used in national invoices. Further information and guidelines can be found on the State Treasury’s web pages. 

Consolidated invoices are not permitted. The broader contents of the invoice (i.e. the information content of summary invoices) will be agreed separately between the buyer and seller. The contracted software companies have been unable so far to proceed with the development work needed for new eInvoice requirements, as there are many requirements that will need to be implemented.

Monitoring eInvoicing implementation

The government has set specific targets for eInvoicing and its uptake is monitored on a monthly basis. The monitoring includes the number of invoices that are submitted electronically. According to latest data available, 94/95% of the invoices to public buyers are submitted electronically. The data is available in the State Treasury's website here (in English).

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

A CIUS is being drafted to reflect the government VAT requirements. The government is planning to have only one document for consultation by companies, presenting all the expected requirements.

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. In 2017, the Finish government had already the goal to receive 95% of invoices in electronic format.

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