EUROPAM

European Public Accountability Mechanisms

Finland

Country score (EU Average*)
  • 58(72) Political Financing
  • 19(57) Financial Disclosure
  • 13(49) Conflict of Interest
  • 80(59) Freedom of Information
  • 57(63) Public Procurement
  • 57(66) Anti Money Laundering
  • 80(71) Asset Recovery

Country Facts

IncomeHigh
GNI per capita (2011 PPP $)39191.72
Population, total5495096.00
Urban population (% of total)84.36
Internet users (per 100 people)87.70
Life expectancy at birth (years)81.39
Mean years of schooling (years)11.2
Global Competitiveness Index5.5
Sources: World Bank, UNDP, WEF.

Political Financing

The Act on Candidate's Election Funding (2009, amended 2015) and the Act on Political Parties (1992, amended 2016) are the main laws regulating the financing of political parties in Finland.

There are a number of limits on the private income of political parties and candidates. Donations from foreign entities and corporations partially owned by the government are banned. However, donations from corporations in general and trade unions are permitted. There is not an explicit ban on anonymous donations. However, the law clarifies that a candidate, a candidate support group, and any other entity acting exclusively to support the candidate, may not receive any support that can not be clarified. There are also limits in place for the amount of donations that can be received.

Parties are allowed to receive grants from the state budget to finance the party’s public activities as specified in the rules and regulations and the party programme. The grant is allocated according to the number of seats and percentage of votes won in the previous election. There are no subsidies for media use but there is tax relief on certain donations available.

For regulations on spending, there are bans on vote buying and bands on state resources being used in favour or against parties or candidates. There are no limits on spending.

Parties are required to keep accounts which must include details in relation to election campaigns,. Reports are overseen by the State Audit Office. The Ministry of Justice oversees the compliance with the Act and the provisions and regulations issued under it, insofar as supervision does not fall within the remit of the State Audit Office. There are sanctions in the form of fines for those breaching the provisions of the law.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Bans and limits on private income283636363661
Public funding05050505038
Regulations on spending0000050
Reporting, oversight and sanctions428383838383

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Bans and limits on private income

Is there a ban on donations from foreign interests to political parties? Yes. Parties and party-affiliated entities may receive foreign support only from private individuals and from international organisations/foundations representing the party’s ideology; all other foreign donors are prohibited. (Act on Political Parties (Puoluelaki 10/1969), §8 b(3) (as amended, e.g. 650/2021; 1214/2023).)
Is there a ban on donations from foreign interests to candidates? Yes. Candidates/support groups may accept foreign contributions only from private individuals and international organisations/foundations representing the candidate’s ideology; contributions from foreign states, public bodies and companies under state/municipal control are prohibited. (Act on a Candidate’s Election Funding (273/2009), §4 (as amended, incl. 684/2010).)
Is there a ban on corporate donations to political parties? No. Absent from legal framework
Is there a ban on corporate donations to candidates? No. Absent from legal framework
Is there a ban on donations from corporations with government contracts to political parties? Yes. A party, a party branch and party close association may not receive grants from the state, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies which the state or a municipality has control in the manner provided for in Chapter 1. § 5 of the Accounting Act (1336/1997). This does not, however, use of premises and customary hospitality (Art 8.‌b, Act on Political Parties, 1969, amended 2016.)
Is there a ban on donations from corporations of partial government ownership to political parties? Yes. A party, a party branch and party close association may not receive grants from the state, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies which the state or a municipality has control in the manner provided for in Chapter 1. § 5 of the Accounting Act (1336/1997). This does not, however, use of premises and customary hospitality (Art 8.‌b, Act on Political Parties, 1969, amended 2016.)
Is there a ban on donations from corporations with government contracts to candidates? Yes. A candidate, a candidate's support group and any other entity exclusively working to support the candidate may not accept contributions for election campaign from the state, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies that State or a municipality has control in the manner referred to in Chapter 1. 5 § in Accounting Act (1336/1997). This does not apply customary hospitality. (Art 4, Act on Candidates Election Funding, 2009, amended 2015)
Is there a ban on donations from corporations of partial government ownership to candidates? Yes. A candidate, a candidate's support group and any other entity exclusively working to support the candidate may not accept contributions for election campaign from the state, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies that State or a municipality has control in the manner referred to in Chapter 1. 5 § in Accounting Act (1336/1997). This does not apply customary hospitality. (Art 4, Act on Candidates Election Funding, 2009, amended 2015)
Is there a ban on donations from Trade Unions to political parties? No. Absent from legal framework
Is there a ban on donations from Trade Unions to candidates? No. Absent from legal framework
Is there a ban on anonymous donations to political parties? No. There is not an explicit ban on anonymous donations. However, the law clarifies that 1) a candidate, a candidate support group, and any other entity acting exclusively to support the candidate, may not receive any support that can not be clarified. However, this does not apply to support from normal collecting activities. (Section 4(1) Act on Candidates Election Funding, 2009, amended 2015)
Is there a ban on anonymous donations to candidates? No. There is not an explicit ban on anonymous donations. However, the law clarifies that 1) a candidate, a candidate support group, and any other entity acting exclusively to support the candidate, may not receive any support that can not be clarified. However, this does not apply to support from normal collecting activities. (Section 4(1) Act on Candidates Election Funding, 2009, amended 2015)
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)? Yes. A party, a party branch and party close association may not receive grants from the state, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies which the state or a municipality has control in the manner provided for in Chapter 1. § 5 of the Accounting Act (1336/1997). This does not, however, use of premises and customary hospitality. A candidate, a candidate's support group and another association that exclusively works to support the candidate may not accept contributions for election campaign from the State, municipalities, federations of municipalities, state or municipal enterprises, public associations, institutions or foundations or companies which the state or a municipality has control over the manner referred to in Chapter 1. § 5 of the Accounting Act (1336/1997). This does not apply customary hospitality. (Art 8.‌b, Act on Political Parties, 1969, amended 2016 Art 4, Act on Candidates Election Funding, 2009, amended 2015)
Is there a ban on any other form of donation? Yes. (2) The candidate, the candidate's support team and any other entity acting exclusively to support the candidate may not receive, directly or indirectly, from the same sponsor more support than the value of EUR 3 000 in municipal elections, EUR 6 000 in parliamentary elections and EUR 10 000 in the European Parliament elections. However, a party or party association referred to in the Party Law (10/1969) may be higher than this if it does not include any of the above sums of money other than any other support. (5) The candidate, the candidate support team and any other entity acting solely for the candidate must ensure that the paid advertiser for the promotion campaign or for the promotion campaign indicates the advertiser's payer. However, the name of a private individual may not be disclosed without his explicit consent if the value of his paid advertisement is less than € 800 in municipal budgets or less than € 1,500 in parliamentary elections, European Parliament elections or presidential elections. (Section 4(2) (5) Act on Candidates Election Funding, 2009, amended 2015)
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)? Yes. The limit is on the amount parties can receive from the same donor during a calendar year. Limit: €30,000 euros per donor. This does not apply to the party's or party association's support of the party's community community or to the will. (Art 8.‌b, Act on Political Parties, 1969, amended 2016.)
Is there a limit on the amount a donor can contribute to a political party in relation to an election? Yes. (2) No candidate, his or her support group or other entity operating exclusively for the purpose of promoting the candidate may accept campaign contributions from a single donor in excess of 3,000 euros in municipal elections, 6,000 euros in parliamentary elections and 10,000 euros in the European Parliamentary elections. However, this limitation does not apply to campaign contributions received from the registered associations of political parties. (Section 4(2) Act on Candidates Election Funding, 2009, amended 2015)
Is there a limit on the amount a donor can contribute to a candidate? Yes. (2) No candidate, his or her support group or other entity operating exclusively for the purpose of promoting the candidate may accept campaign contributions from a single donor in excess of 3,000 euros in municipal elections, 6,000 euros in parliamentary elections and 10,000 euros in the European Parliamentary elections. However, this limitation does not apply to campaign contributions received from the registered associations of political parties. (Section 4(2) Act on Candidates Election Funding, 2009, amended 2015)

Public funding 

Eligibility criteria for direct public funding to political parties Yes. (1) Within the limits of the State budget, a political party represented in the Parliament may be granted party subsidy from government funds to finance the party’s public activities specified in its rules and regulations and the party programme. (Section 9(1) Act on Political Parties, 1969, amended 2016)
Eligibility criteria for direct public funding to political parties: Share of votes in previous election Yes. (3) A party that has received at least two percent of the votes cast throughout the country in the most recent parliamentary elections is entitled to the grant. The grant to a party of this kind is one third of what is allocated to a party referred to in subsection 1 for one seat. (Section 9(3) Act on Political Parties, 1969, amended 2016)
Eligibility criteria for direct public funding to political parties: Representation in elected body No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Participation in election No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of candidates No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election Yes. Party subsidy is allocated to the parties in accordance with the number of parliamentary seats each party has gained in the latest parliamentary elections (Section 9(1) Act on Political Parties, 1969, amended 2016)
Eligibility criteria for direct public funding to political parties: Share of votes in next election No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in next election No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other No. Absent from legal framework
Allocation calculations for direct public funding to political parties Yes. Party subsidy is allocated to the parties in accordance with the number of parliamentary seats each party has gained in the latest parliamentary elections. (although no specific mechanism for calculating is specified) (Section 9(1) Act on Political Parties, 1969, amended 2016)
Allocation calculations for direct public funding to political parties: Proportional to votes received Yes. (3) A party that has received at least two percent of the votes cast throughout the country in the most recent parliamentary elections is entitled to the grant. The grant to a party of this kind is one third of what is allocated to a party referred to in subsection 1 for one seat. (Section 9(3) Act on Political Parties, 1969, amended 2016)
Allocation calculations for direct public funding to political parties: Equal No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to seats received Yes. Party subsidy is allocated to the parties in accordance with the number of parliamentary seats each party has gained in the latest parliamentary elections. (although no specific mechanism for calculating is specified) (Section 9(1) Act on Political Parties, 1969, amended 2016)
Allocation calculations for direct public funding to political parties: Flat rate by votes received No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other No. Absent from legal framework
Earmarking provisions for direct public funding to political parties Yes. (1) Within the limits of the State budget, a political party represented in the Parliament may be granted party subsidy from government funds to finance the party’s public activities specified in its rules and regulations and the party programme. (Section 9(1) Act on Political Parties, 1969, amended 2016)
Earmarking provisions for direct public funding to political parties: Campaign spending Yes. (1) Within the limits of the State budget, a political party represented in the Parliament may be granted party subsidy from government funds to finance the party’s public activities specified in its rules and regulations and the party programme. (Section 9(1) Act on Political Parties, 1969, amended 2016)
Earmarking provisions for direct public funding to political parties: Ongoing party activities No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Intra-party institution No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Other No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Equal No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Number of candidates No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of seats No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Other No. Absent from legal framework
Are there provisions for free or subsidized access to media for candidates? No. Absent from legal framework
Are there provisions for any other form of indirect public funding? No. Absent from legal framework
Provisions for any other form of indirect public funding: Premises for campaign meetings No. Absent from legal framework
Provisions for any other form of indirect public funding: Space for campaign materials No. Absent from legal framework
Provisions for any other form of indirect public funding: Tax relief No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised transport No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost No. Absent from legal framework
Provisions for any other form of indirect public funding: Other No. Absent from legal framework
Is the provision of direct public funding to political parties related to gender equality among candidates? No. Absent from legal framework
Are there provisions for other financial advantages to encourage gender equality in political parties? No. Absent from legal framework

Regulations on spending 

Is there a ban on vote buying? Yes. The one who 1) promises, offers or gives another reward or other advantage in order to persuade another to vote in general or general vote in a particular way, or abstain, or 2) insists on the voting or non-voting of a prize or other interest in general or general voting, be sentenced for election to a fine or imprisonment for up to one year. (Chapter 14, paragraph 2, Penal Code, 1989/39, amended 2016)
Are there bans on state resources being used in favour or against a political party or candidate? Yes. State and municipal agencies and authorities of municipal federations, associations and institutions as the state, a municipality or a joint municipal authority exercises control should treat all parties equally and under equal grounds (Art 10, Act on Political Parties, 1969, amended 2016. )
Are there limits on the amount a political party can spend? No. Absent from legal framework
Are there limits on the amount a candidate can spend? No. Absent from legal framework

Reporting, oversight and sanctions 

Do political parties have to report regularly on their finances? Yes. (1) The provisions in the Accounting Act (655/73) on an association’s legal obligation to keep books apply to political parties. (Section 8(1) Act on Political Parties, 1969, amended 2016.)
Do political parties have to report on their finances in relation to election campaigns? Yes. Section 5 – The notification (1) An election funding disclosure is to be filed by: 1) a deputy in the parliamentary elections, when elected as a member of the Parliament and when the results of the elections are determined; 2) the party nominated for the presidential election and the electorate of the candidate or his alternate; 3) an authorized or reserve delegate in the municipal elections; 4) in the European Parliament elections, a Member of the European Parliamen (Section 5(1) Act on Candidates Election Funding, 2009, amended 2015)
Do candidates have to report on their campaign finances? Yes. Section 5 – The notification (1) An election funding disclosure is to be filed by: 1) a deputy in the parliamentary elections, when elected as a member of the Parliament and when the results of the elections are determined; 2) the party nominated for the presidential election and the electorate of the candidate or his alternate; 3) an authorized or reserve delegate in the municipal elections; 4) in the European Parliament elections, a Member of the European Parliamen (Section 5(1) Act on Candidates Election Funding, 2009, amended 2015)
Is information in reports from political parties and/​or candidates to be made public? Yes. (2) Information relating to parliamentary and municipal elections is to remain available in a public data network for a period of five years; information relating to European Parliamentary elections for six years; and information relating to a Presidential election for seven years from the date of confirmation of the election results. Advance disclosures filed by parties other than the disclosers defined in section 5 are to remain available in a public data network for a period of 30 days from the date of confirmation of the election results (Section 12 Act on Candidates Election Funding, 2009, amended 2015)
Must reports from political parties and/​or candidates reveal the identity of donors? Yes. (2) Each individual aid and its donor must be notified separately if the value of the support is at least 800 euros in municipal elections or at least 1 500 euros in the parliamentary elections, the European parliamentary elections or the presidential election. (Section 6(2) Act on Candidates Election Funding, 2009, amended 2015)
Institutions receiving financial reports from political parties and/​or candidates
Institutions receiving financial reports from political parties and/​or candidates: Electoral Management Board No. Absent from legal framework
Institutions receiving financial reports from political parties and/​or candidates: Auditing agency Yes. (2) The party submits to the State Audit Office the auditing report, the report of the activity and the balance sheet of the party and the association referred to in the grant decision and the accounts and information referred to in section 9 a subsection 1. For this purpose, the association referred to in the grant decision shall provide the corresponding documents and information to the party concerned. The party's documents and information will be provided within three months of the party's financial statements being confirmed. The documents and information of the association referred to in the grant decision shall be submitted within one month of the establishment of the association's financial statements. (Section 9 (d) Act on Political Parties, 1969, amended 2016)
Institutions receiving financial reports from political parties and/​or candidates: Ministry No. Absent from legal framework
Institutions receiving financial reports from political parties and/​or candidates: Special institution No. Absent from legal framework
Institutions receiving financial reports from political parties and/​or candidates: Court No. Absent from legal framework
Institutions receiving financial reports from political parties and/​or candidates: Other No. Absent from legal framework
Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Ministry Yes. The Ministry of Justice oversees compliance with this Act and the provisions and regulations issued under it, insofar as supervision does not fall within the remit of the State Audit Office. (Section 9 e § Act on Political Parties, 1969, amended 2015)
Institution responsible for examining financial reports and/or investigating violations: Auditing agency Yes. The National Audit Office supervises 9 §: the use of the subsidy referred to in this Act as well as support, notification of the election campaign costs and funding, as well as the preparation and submission of documents and information relating thereto comply with the provisions of the Party, the Party of the local community and the association referred to in the grant decision ( monitor ) operation. In this role, the Office may audit the supervised entity's accounts and the use of funds and, where appropriate, urge the supervised entity to fulfill its obligations under this Act. The Finnish Financial Supervisory Authority may, subject to a fine, require the supervised entity to fulfill its obligations if, despite the request of the Agency, the documents or information have not been provided, corrected or supplemented, or their accuracy and adequacy have been resolved and the negligence as a whole is essential. The penalty payment is condemned by the Penalty Board referred to in Section 15 of the Act on the State Audit Office (676/2000) . An appeal may be filed and ordered to be appealed by appealing to the Supreme Administrative Court as provided in the Administrative Procedure Act (586/1996) . The statutory audit of the State Audit Office is regulated otherwise by the law on the State Audit Office. The State Audit Office reports annually to Parliament on its activities under the supervision of compliance with this law. The Ministry of Justice oversees compliance with this Act and the provisions and regulations issued under it, insofar as supervision does not fall within the remit of the State Audit Office. (Section 9 e § Act on Political Parties, 1969, amended 2016)
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Other No. Absent from legal framework
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court No. Absent from legal framework
Institutions with a formal role in political finance oversight: Ministry No. Absent from legal framework
Institutions with a formal role in political finance oversight: Auditing agency No. Absent from legal framework
Institutions with a formal role in political finance oversight: EMB No. Absent from legal framework
Institutions with a formal role in political finance oversight: Institution for this purpose No. Absent from legal framework
Institutions with a formal role in political finance oversight: Other No. Absent from legal framework
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines Yes. (2) If the notifier does not, despite the request of the State Audit Office, make the notification provided in this Act or if the notice is found to be manifestly inaccurate or incomplete, the State Audit Office may oblige the person liable to pay the fine to make a declaration or to correct the error or omission. The penalty payment is imposed by the Penalty Board referred to in Section 15 of the Act on the State Audit Office (676/2000). An appeal may be filed and ordered to be appealed by appealing to the Supreme Administrative Court as provided in the Administrative Procedure Act (586/1996). (Section 10(2) Act on Candidates Election Funding, 2009, amended 2015)
Sanctions for political finance infractions: Loss of public funding No. Absent from legal framework
Sanctions for political finance infractions: Penal/Criminal No. Absent from legal framework
Sanctions for political finance infractions: Forfeiture No. Absent from legal framework
Sanctions for political finance infractions: Deregistration of party No. Absent from legal framework
Sanctions for political finance infractions: Loss of elected office No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party No. Absent from legal framework
Sanctions for political finance infractions: Loss of nomination of candidate No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights No. Absent from legal framework
Sanctions for political finance infractions: Other No. Absent from legal framework

Legislation

Act on Political Parties, 1969, amended 2016 (Finnish)pdf
Act on Candidates Election Funding, 2009, amended 2010 (English)pdf
Penal Code, 1989/39, amended 2016 (Finnish)pdf

*Last update: 2017

Financial Disclosure

While no financial disclosure regulations apply to the Finish Head of State, regulations with only small differences apply to Ministers, Members of Parliament, and Civil Servants. The Constitution (1999, last amended in 2011) requires Ministers to declare real estate, movable assets, cash, shareholdings, as well as any additional duties that may be relevant to decision-making. The Parliament's Rules of Procedure (1999, last amended in 2015) make these same requirements for MP’s financial disclosure. In addition, MPs must disclose any income they receive from outside employment. Civil Servants make the same disclosures as Members of Parliament, except from being exempted from declaring cash. This is laid down in the State Civil Servants Act (last amended 2015). 

MPs make their declarations annually, while Civil Servants submit any changes to declarations ad hoc. There is no legally specified filling frequency for Ministers. Additionally, no specifications are made as to depository and enforcement body, or to sanctions for Ministers and for Civil Servants. In the meanwhile, MPs submit their declarations to the Central Office, and late or non-filling are announced publicly in parliament. The Central Office also ensures MPs’ declarations are made publicly available on an online network. Declarations made by Ministers and Civil Servants are not accessible to the public.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Disclosure items66664230
Filing frequency66663131
Sanctions17171717178
Monitoring and Oversight01919194412
Public access to declarations1212661912

Alternative Metric

201220152016201720202024Trend
Head of State1000390
Ministers00003912
Members of Parliament334843434342
Civil servants0000122

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Disclosure items

Spouses and children included in disclosure No. Absent from legal framework
Income and Assets
Real estate No. Absent from legal framework
Movable assets No. Absent from legal framework
Cash No. Absent from legal framework
Loans and Debts No. Absent from legal framework
Income from outside employment/assets No. Absent from legal framework
Incompatibilities
Gifts received as a public official No. Absent from legal framework
Private firm ownership and/or stock holdings No. Absent from legal framework
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework
Holding government contracts No. Absent from legal framework
Board member, advisor, or company officer of private firm No. Absent from legal framework
Post-employment No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework
Participating in official decision-making processes that affect private interests No. Absent from legal framework
Concurrent employment of family members in public sector No. Absent from legal framework

Filing frequency

Filing required upon taking office No. Absent from legal framework
Filing required upon leaving office No. Absent from legal framework
Filing required annually No. Absent from legal framework
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) No. Absent from legal framework
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) No. Absent from legal framework
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) No. Absent from legal framework

Monitoring and Oversight

Depository body explicitly identified No. Absent from legal framework
Enforcement body explicitly identified No. Absent from legal framework
Some agency assigned responsibility for verifying submission No. Absent from legal framework
Some agency assigned responsibility for verifying accuracy No. Absent from legal framework

Public access to declarations

Public availability No. Absent from legal framework
Timing of information release specified No. Absent from legal framework
Location(s) of access specified No. Absent from legal framework
Cost of access specified No. Absent from legal framework

Ministers

Disclosure items

Spouses and children included in disclosure No. Ministers must present account of commercial activities, assets, liabilities, outside duties (per Constitution, s.63). New Ministers’ Handbook (2023) includes anti-corruption guidance and gifts registration rules, but GRECO notes it is not a full Code of Conduct; no confidential counselling; supervision/sanctions remain weak. (Constitution s.63; Minister’s Handbook 2023; GRECO RC5 Addendum 2024)
Income and Assets
Real estate Yes. A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (adopted in 1999, last amended in 2018))
Movable assets Yes. A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (1999, last amended in 2018))
Cash Yes. A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (1999, last amended in 2018))
Loans and Debts No. Absent from legal framework
Income from outside employment/assets No. Financial disclosure obligations for ministers remain constitutional. No systematic review mechanism; declarations included in Govt. comm. to Parliament but review is informal. GRECO: still no formal review system. (Constitution s.63; GRECO RC5 Addendum 2024)
Incompatibilities
Gifts received as a public official Yes. Gifts: Ministers’ Handbook + PMO Decisions (VN/23634/2020, VN/23637/2020) set detailed procedures for registering gifts. A register exists (since 2020). But still not tied to FD declarations; supervision limited. (PMO Decisions 2020; GRECO RC5 Addendum 2024)
Private firm ownership and/or stock holdings Yes. While holding the office of a Minister, a member of the Government shall not hold any other public office or undertake any other task which may obstruct the performance of his or her ministerial duties or compromise the credibility of his or her actions as a Minister.A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (1999, last amended in 2018))
Ownership of state-owned enterprises (SOEs) Yes. While holding the office of a Minister, a member of the Government shall not hold any other public office or undertake any other task which may obstruct the performance of his or her ministerial duties or compromise the credibility of his or her actions as a Minister.A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (1999, last amended in 2018))
Holding government contracts No. Absent from legal framework
Board member, advisor, or company officer of private firm Yes. While holding the office of a Minister, a member of the Government shall not hold any other public office or undertake any other task which may obstruct the performance of his or her ministerial duties or compromise the credibility of his or her actions as a Minister.A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests which may be of relevance when his or her performance as a member of the Government is being evaluated. (Section 63 of the Constitution (1999, last amended in 2018))
Post-employment No. Draft law (2024) on cooling-off period for ministers (12 months) still pending. No statutory restriction yet. Special advisers subject to 6-month period. (Draft Law (2024 consultation); GRECO RC5 Addendum 2024)
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework
Participating in official decision-making processes that affect private interests No. Absent from legal framework
Concurrent employment of family members in public sector No. Absent from legal framework

Filing frequency

Filing required upon taking office Yes. Filling required upon taking office (Section 63 of the Constitution (1999, last amended in 2018))
Filing required upon leaving office No. Absent from legal framework
Filing required annually No. Absent from legal framework
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) No. Absent from legal framework
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) No. Absent from legal framework
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) No. Absent from legal framework

Monitoring and Oversight

Depository body explicitly identified No. Absent from legal framework
Enforcement body explicitly identified No. Absent from legal framework
Some agency assigned responsibility for verifying submission No. Absent from legal framework
Some agency assigned responsibility for verifying accuracy No. Absent from legal framework

Public access to declarations

Public availability No. Absent from legal framework (Available at government's website)
Timing of information release specified No. Absent from legal framework
Location(s) of access specified No. Absent from legal framework (Available at government's website)
Cost of access specified No. Absent from legal framework

Members of Parliament

Disclosure items

Spouses and children included in disclosure No. Absent from legal framework
Income and Assets
Real estate Yes. A Representative shall, within two months from when his or her credentials have been examined, provide Parliament with an account of any outside duties, commercial activities, interests as an owner in businesses and other significant assets which may be of relevance in evaluating his or her performance as a Representative. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015) Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Movable assets Yes. A Representative shall, within two months from when his or her credentials have been examined, provide Parliament with an account of any outside duties, commercial activities, interests as an owner in businesses and other significant assets which may be of relevance in evaluating his or her performance as a Representative. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015))
Cash Yes. A Representative shall, within two months from when his or her credentials have been examined, provide Parliament with an account of any outside duties, commercial activities, interests as an owner in businesses and other significant assets which may be of relevance in evaluating his or her performance as a Representative. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015))
Loans and Debts Yes. Significant debts taken for business operations or investment activities as well as significant guarantees and other liabilities given for the same purpose (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Income from outside employment/assets Yes. A Representative shall also provide Parliament with an account of such income received from outside duties and commercial activities which may be of relevance in evaluating his or her performance as a Representative and which exceed 5000 EUR (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015) Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Incompatibilities
Gifts received as a public official Yes. Items worth over EUR 400 given as gifts and accepted by Members of Parliament when acting as official representatives of Parliament shall be the property of Parliament. These items must be declared in the register maintained by the Central Office and given over to Parliament’s collections (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Private firm ownership and/or stock holdings Yes. A Representative shall, within two months from when his or her credentials have been examined, provide Parliament with an account of any outside duties, commercial activities, interests as an owner in businesses and other significant assets which may be of relevance in evaluating his or her performance as a Representative. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015) Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Ownership of state-owned enterprises (SOEs) Yes. A Representative shall, within two months from when his or her credentials have been examined, provide Parliament with an account of any outside duties, commercial activities, interests as an owner in businesses and other significant assets which may be of relevance in evaluating his or her performance as a Representative. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015) Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (ad)
Holding government contracts No. Absent from legal framework
Board member, advisor, or company officer of private firm Yes. The obligation to declare concerns all types of administrative duties. These include memberships of, for example, management boards, administrative boards or other similar bodies, and performing the roles of chairperson, deputy chairperson or auditor. (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Post-employment No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework
Participating in official decision-making processes that affect private interests Yes. A Representative is disqualified from consideration of and decision-making in any matter that concerns him or her personally. However, he or she may participate in the debate on such matters in a plenary session of the Parliament. In addition, a Representative shall be disqualified from the consideration in a Committee of a matter pertaining to the inspection of his or her official duties. (Section 32 of the Constitution (1999, last amended in 2018))
Concurrent employment of family members in public sector No. Absent from legal framework

Filing frequency

Filing required upon taking office Yes. The declaration must be submitted to Parliament within two months of the inspection of the Member’s credentials. The income from outside activities shall be declared each calendar year by the end of June of the year following the year when the income was accrued. (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Filing required upon leaving office No. Absent from legal framework
Filing required annually Yes. The income from outside activities shall be declared each calendar year by the end of June of the year following the year when the income was accrued. (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. If a Representative, despite a request to do so, fails to submit an account of his or her personal interests, the Speaker shall announce this at the plenary session of the Parliament. (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) No. Absent from legal framework
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) No. Absent from legal framework

Monitoring and Oversight

Depository body explicitly identified Yes. The accounts of personal interests are submitted to the Central Office, which keeps a register (Section 76a of the Parliament's Rules of Procedure (1999, last amended in 2015))
Enforcement body explicitly identified No. Absent from legal framework
Some agency assigned responsibility for verifying submission No. Absent from legal framework
Some agency assigned responsibility for verifying accuracy No. Absent from legal framework

Public access to declarations

Public availability Yes. The Central Office maintains a register of personal interests declared by the Representatives. The information is public and made accessible to the public on a public information network. Once a person no longer holds office as a Representative, the information is removed from the register and the information network. (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Timing of information release specified No. Absent from legal framework
Location(s) of access specified Yes. The Central Office maintains a register of personal interests declared by the Representatives. The information is public and made accessible to the public on a public information network. Once a person no longer holds office as a Representative, the information is removed from the register and the information network. (Instructions of the speaker's council on the declaration of private interests by members of parliament and other corresponding practices related to the position of members (adopted 9 March 2015))
Cost of access specified No. Absent from legal framework

Civil servants

Disclosure items

Spouses and children included in disclosure No. Absent from legal framework
Income and Assets
Real estate Yes. A person proposed to be appointed as a service should before the appointment submit a statement of its commercial activities, shareholdings in companies and other assets as well as for their duties outside the service. Notification must when it comes to secondary occupations that require secondary occupation contain information on the income from ancillary activities. (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Movable assets Yes. A person proposed to be appointed as a service should before the appointment submit a statement of its commercial activities, shareholdings in companies and other assets as well as for their duties outside the service. Notification must when it comes to secondary occupations that require secondary occupation contain information on the income from ancillary activities. (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Cash No. Absent from legal framework
Loans and Debts No. Absent from legal framework
Income from outside employment/assets Yes. They have to provide infotmation about on the income they received from ancillary activities and on the tasks outside service (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Incompatibilities
Gifts received as a public official Yes. Guidelines on hospitality, benefits and gifts updated 1 Nov 2023 (VN/27196/2023) for PTEFs other than ministers; apply alongside declaration/secondary-activity guidance. (GRECO RC5 Addendum (2024) noting 2022 declaration guidance and 1 Nov 2023 hospitality/benefits/gifts guidance.)
Private firm ownership and/or stock holdings Yes. A person proposed to be appointed as a service should before the appointment submit a statement of its commercial activities, shareholdings in companies and other assets as well as for their duties outside the service. Notification must when it comes to secondary occupations that require secondary occupation contain information on the income from ancillary activities. (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Ownership of state-owned enterprises (SOEs) Yes. A person proposed to be appointed as a service should before the appointment submit a statement of its commercial activities, shareholdings in companies and other assets as well as for their duties outside the service. Notification must when it comes to secondary occupations that require secondary occupation contain information on the income from ancillary activities. (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Holding government contracts No. Absent from legal framework
Board member, advisor, or company officer of private firm Yes. A person proposed to be appointed as a service should before the appointment submit a statement of its commercial activities, shareholdings in companies and other assets as well as for their duties outside the service. Notification must when it comes to secondary occupations that require secondary occupation contain information on the income from ancillary activities. (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Post-employment No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework
Participating in official decision-making processes that affect private interests No. Absent from legal framework
Concurrent employment of family members in public sector No. Absent from legal framework

Filing frequency

Filing required upon taking office Yes. A person proposed to be appointed as a service should before the appointment submit a statement (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Filing required upon leaving office No. Absent from legal framework
Filing required annually No. Absent from legal framework
Ad hoc filing required upon change in assets or conflicts of interest Yes. The officials have been appointed to service shall promptly notify any changes or inaccuracies in the information (Articles 8a of State Civil Servants Act (1994, last amended 2016))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) No. Filing is a requirement for appointment (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) No. Filing is a requirement for appointment (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) No. Absent from legal framework

Monitoring and Oversight

Depository body explicitly identified Yes. Appointing institution (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Enforcement body explicitly identified No. Absent from legal framework
Some agency assigned responsibility for verifying submission No. Absent from legal framework
Some agency assigned responsibility for verifying accuracy No. Absent from legal framework

Public access to declarations

Public availability No. Information about a person's financial position given an authority to be kept secret (Articles 8a of State Civil Servants Act (1994, last amended 2016))
Timing of information release specified No. Absent from legal framework
Location(s) of access specified No. Absent from legal framework
Cost of access specified No. Absent from legal framework

Legislation

The Constitution of Finland of 1999_FIN (Finnish)pdf
Rules of Procedure of Parliament of 1999_FIN (Finnish)pdf
Instructions of the Speaker's Council on the Declaration of Private Interests by MPs of 2015_FIN (Finnish)pdf
State Civil Servants Act of 1994_FIN (Finnish)pdf

*Last update: 2017

Conflict of Interest

There are no general restrictions on conflicts of interests regarding the Finish Head of State. Specifically, the only restriction regards the prohibition for an elected President to continue to hold representative functions. The Criminal Code (1889, last amended in 2016) prevents Ministers, Members of Parliament, and Civil Servants from accepting gifts. Additionally, both Ministers and MPs are required by the Constitution (1999, last amended in 2011) to abstain from decision-making where they have a private interest. A general clause on avoiding positions which may lead to a conflict of interests exists only for Ministers. No further limitations, for example as to outside employment, firm membership or post-employment, are made for any public officials.

Sanctions for violating regulations on conflicts of interests exist only for accepting gifts. Here, Ministers, MPs and Civil Servants face a fine or imprisonment of up to two years. No further sanctions are specified. Additionally, no enforcement or monitoring body exists for Ministers and Civil Servants. Meanwhile, the Parliamentary Office is tasked with supervising and enforcing these laws for MPs.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Restrictions108884530
Sanctions8888178
Monitoring and Oversight12121212380

Alternative Metric

201220152016201720202024Trend
Head of State000007
Ministers00004010
Members of Parliament413838384113
Civil servants00005121

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Restrictions

General restriction on conflict of interest Yes. An official (here included the Office of the President of the Republic) may not take part in the proceedings or be present at the hearing if he is prevented from attending. An official cannot take part in proceedings: 1) if s/he or a person close to him or her is a party; 2) if s/he or a person close to him or her assists or represents the party or the person to whom a special benefit or damage is expected from the resolution of the matter; 3) if special benefit or harm is expected from the resolution of the matter to him or her or his or her close relative referred to in subsection 2 (1); 4) if he or she is in an employment relationship or in an assignment relationship related to the matter under consideration to a party or to whom a special benefit or damage is expected from the resolution of the matter; 5) if he or a relative referred to in subsection 2 (1) is a member of the board of directors, supervisory board or equivalent body or managing director or an equivalent position in an association, foundation, state enterprise or institution which is a party or for which a special benefit or harm is expected; 6) if he or she or a relative referred to in subsection 2 (1) is a member of the board of directors of the agency or institution or an institution equivalent thereto and the matter is related to the guidance or supervision of this agency or institution; or 7) if confidence in his or her impartiality is compromised for any other special reason. (Administrative Law of 2003, as amended in 2020, §§ 2, 27 and 28 )
Accepting gifts Yes. Acceptance of gifts or benefits is prohibited where it may compromise impartiality. Updated binding rule in the 2023 amendment to the State Civil Servants Act, applied to all public officials including the Office of the President. (State Civil Servants Act (750/1994), as amended by Act 1235/2023, Section 15.)
Private firm ownership and/or stock holdings No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. Absent from legal framework.
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector No. Absent from legal framework.

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) No. Absent from legal framework.
Enforcement body specified (sanctions, hearings) No. Absent from legal framework.

Ministers

Restrictions

General restriction on conflict of interest Yes. While holding the office of a Minister, a member of the Government shall not hold any other public office or undertake any other task which may obstruct the performance of his or her ministerial duties or compromise the credibility of his or her actions as a Minister. A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests (The Consitution of Finland (as of 2020), § 63 )
Accepting gifts Yes. Ministers may not accept gifts, benefits or hospitality that could influence performance of their duties; prohibition confirmed in the 2023 State Civil Servants Act amendment, which applies mutatis mutandis to members of government. (State Civil Servants Act (750/1994), as amended by Act 1235/2023, Section 15.)
Private firm ownership and/or stock holdings No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. Absent from legal framework.
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position Yes. While holding the office of a Minister, a member of the Government shall not hold any other public office or undertake any other task which may obstruct the performance of his or her ministerial duties or compromise the credibility of his or her actions as a Minister. A Minister shall, without delay after being appointed, present to the Parliament an account of his or her commercial activities, shareholdings and other significant assets, as well as of any duties outside the official duties of a Minister and of other interests (The Consitution of Finland (as of 2020), § 63 )
Participating in official decision-making processes that affect private interests No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector No. Absent from legal framework.

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. A decision to bring charges against a Member of the Government may be made if he or she has, intentionally or through gross negligence, essentially contravened his or her duties as a Minister or otherwise acted clearly unlawfully in office. A charge against a Member of the Government for unlawful conduct in office is heard by the High Court of Impeachment, as provided in more detail by an Act. The decision to bring a charge is made by the Parliament, after having obtained an opinion from the Constitutional Law Committee concerning the unlawfulness of the actions of the Minister. Before the Parliament decides to bring charges or not it shall allow the Minister an opportunity to give an explanation. When considering a matter of this kind the Committee shall have a quorum when all of its members are present. A Member of the Government is prosecuted by the Prosecutor-General. (The Consitution of Finland (as of 2020), §§ 114, 115 and 116 )

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) No. Absent from legal framework.
Enforcement body specified (sanctions, hearings) No. Absent from legal framework.

Members of Parliament

Restrictions

General restriction on conflict of interest Yes. A Representative is disqualified from consideration of and decision-making in any matter that concerns him or her personally. However, he or she may participate in the debate on such matters in a plenary session of the Parliament. In addition, a Representative shall be disqualified from the consideration in a Committee of a matter pertaining to the inspection of his or her official duties. (The Consitution of Finland (as of 2020), § 32 Administrative Law of 2003, as amended in 2020, §§ 2, 27 and 28 )
Accepting gifts Yes. MPs must not accept gifts or other benefits intended to influence their work. Clarified in the 2021 amendment to the Parliament’s Rules of Procedure. (Parliament’s Rules of Procedure (40/2000), as amended by 1099/2021, Section 31a.)
Private firm ownership and/or stock holdings No. Private firm ownership and/or stock holdings are not restrited. However, within two months of the verification of his or her credentials, the Member of Parliament shall report to Parliament on his or her non-parliamentary duties, business activities, holdings in companies and other significant assets that may be relevant in assessing his or her activities as a representative. Substantial changes in affiliations during the election period will be announced within two months of the change. The representative shall also report to Parliament on such non-parliamentary duties and income from business activities that may be relevant in assessing his or her activities as a representative. Revenue is reported per calendar year by the end of June of the year following the accrual of revenue. The report is submitted to the central office. If, despite being instructed to do so, the Member fails to make a statement, the President shall announce it in Parliament. (Rules of Procedure of Parliament, as amended in 2020, § 76a)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. Absent from legal framework.
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position Yes. A person holding military office cannot, however, be elected as a Representative. The Chancellor of Justice of the Government, the Parliamentary Ombudsman, a Justice of the Supreme Court or the Supreme Administrative Court, and the Prosecutor-General cannot serve as representatives. If a Representative is elected President of the Republic or appointed or elected to one of the aforesaid offices, he or she shall cease to be a Representative from the date of appointment or election. The office of a Representative shall cease also if the Representative forfeits his or her eligibility. (The Consitution of Finland (as of 2020), § 27)
Participating in official decision-making processes that affect private interests Yes. A Representative is disqualified from consideration of and decision-making in any matter that concerns him or her personally. However, he or she may participate in the debate on such matters in a plenary session of the Parliament. In addition, a Representative shall be disqualified from the consideration in a Committee of a matter pertaining to the inspection of his or her official duties. (The Consitution of Finland (as of 2020), § 32)
Assisting family or friends in obtaining employment in public sector No. Absent from legal framework.

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) No. Absent from legal framework.
Enforcement body specified (sanctions, hearings) No. Absent from legal framework.

Civil servants

Restrictions

General restriction on conflict of interest No. Absent from legal framework.
Accepting gifts Yes. An official shall not claim, accept or receive any financial or other advantage which may undermine confidence in the official or authority. (State Civil Servants Act, as amended in 2020, § 15)
Private firm ownership and/or stock holdings No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm Yes. An official may not receive or hold an ancillary activity which requires the use of working time to perform ancillary duties unless authorized to do so by the relevant authority on application. A side license may also be granted for a limited and limited period. A side license may be revoked when there is a reason to do so. When considering the granting of an ancillary authorization, it must be borne in mind that the official must not be prevented from attending to his duties as a result of the ancillary activity. Nor must the ancillary activity jeopardize confidence in the impartiality of the performance of the task or otherwise interfere with the proper performance of the task or, as a competing activity, manifestly harm the employer. An official shall notify the relevant authority of an ancillary work other than that referred to in subsection (1). The authority may prohibit the receipt and holding of such an ancillary activity on the grounds provided for in subsection (2). For the purposes of subsections 1 to 3, an ancillary job means a position as well as paid work and duties which the official has the right to refuse, as well as the profession, business and movement. (State Civil Servants Act, as amended in 2020, § 18)
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. An official has the right to take time off work to perform a municipal position of trust as provided in sections 80 and 81 of the Municipal Act (410/2015). (State Civil Servants Act, as amended in 2020, § 66a)
Participating in official decision-making processes that affect private interests Yes. Civil servants must abstain in cases of conflict of interest. Strengthened by the 2020 amendment to the Administrative Procedure Act and reaffirmed in the 2023 update to the State Civil Servants Act. (State Civil Servants Act (750/1994), amended by 1235/2023.)
Assisting family or friends in obtaining employment in public sector No. Absent from legal framework.

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior Yes. If a public official, for his or her actions while in service, for himself or herself or for another: (1) asks for a gift or other unlawful benefit or otherwise takes an initiative in order to receive such a benefit; (2) accepts a gift or other benefit which influences, which is intended to influence or which is conducive to influencing him or her in said actions; or (3) agrees to the gift or other benefit referred to in paragraph (2) or to a promise or offer thereof, he or she shall be sentenced for acceptance of a bribe to a fine or to imprisonment for at most two years. (The Criminal Code of Finland, as amended in 2020, Chapter 40, § 1)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) No. Absent from legal framework.
Enforcement body specified (sanctions, hearings) No. Absent from legal framework.

Legislation

The Constitution of Finland of 1999 (Finish)pdf
The Criminal Code of Finland of 1889 (Finish)pdf
Rules of Procedure of Parliament of 1999 (Finish)pdf
State Civil Servants Act of 1994 (Finish)pdf
Administrative Law of 2003 (Finish)pdf

*Last update: 2017

Freedom of Information

The right to information in Finland is established in the Constitution (1999) and implementing measures are provided by the Act on the Openness of Government Activities (621/1999; amended 2016). This law applies to state administrative authorities and other state agencies and institutions, parliamentary agencies and institutions, courts of law and the other bodies for the administration of law, state enterprises, municipal authorities, independent institutions subject to public law, and organizations performing public duties pursuant to law.

Specific exemptions to disclosure are outlined in the aforementioned FOI law and the Personal Data Act (1999). No public interest test exists whereby exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

Appeals may be filed with public authorities and with the courts. There is no appeals process through an independent non-judicial mechanism, such as an information commissioner.

Administrative sanctions, fines, and criminal sanctions may be applied by the public prosecutor, as specified by the criminal code. However, no organization is mandated with overseeing FOI implementation.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope and Coverage808080808093
Information access and release888888888888
Exceptions and Overrides676767676767
Sanctions for non-compliance00000100
Monitoring and Oversight171717171750

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope and Coverage

Scope of disclosure

Existence of legal right to access Yes. Everyone has the right of access to public documents and recordings. (Section 12, Constitution of Finland, 1999, amended 2018)
"Information" or "Documents" is defined Yes. (1) For the purposes of this Act, a document is defined as a written or visual presentation, and also as a message relating to a given topic or subject-matter and consisting of signs which, by virtue of the use to which they are put, are meant to be taken as a whole, but are decipherable only by means of a computer, an audio or video recorder or some other technical device. (2) An official document is defined as a document in the possession of an authority and prepared by an authority or a person in the service of an authority, or a document delivered to an authority for the consideration of a matter or otherwise in connection with a matter within the competence or duties of the authority. In addition, a document is deemed to be prepared by an authority if it has been commissioned by the authority; and a document is deemed to have been delivered to an authority if it has been given to a person commissioned by the authority or otherwise acting on its behalf for the performance of the commission. (Section 5, Act on the Openness of Government Activities (621/1999; amended 2021))
Proactive disclosure is specified Yes. (1) The authorities shall promote the openness of their activities and, where necessary for this purpose, produce guides, statistics and other publications, as well as information materials on their services and practices, as well as on the social conditions and developments in their field of competence. When the extent of this duty is being assessed, due consideration shall be given to the opportunities to obtain information on the activity of the authority by means of access to its documents or the general compilations of statistics. (2) The authorities shall publicise their activities and services, as well as the rights and obligations of private individuals and corporations in matters falling within their field of competence. (3) The authorities shall see to it that the documents or the pertinent indexeswhich are essential to the general public’s access to information are available where necessary in libraries or public data networks, or otherwise easily accessible to the members of the public. (Section 20, Act on the Openness of Government Activities (621/1999; amended 2021))

Coverage of public and private sectors

Executive branch Yes. (1) For the purposes of this Act, authorities are defined as: (1) State administrative authorities and other State agencies and institutions; (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Legislative branch Yes. (6) Parliamentary agencies and institutions; (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Judicial branch Yes. (2) courts of law and the other bodies for the administration of law; (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Other public bodies Yes. (3) State enterprises; (4) municipal authorities; (5) the Bank of Finland, including the Finance Supervision Authority, the National Pensions Institution of Finland and other independent institutions subject to public law; however, this Act applies to the documents of the Pensions Security Centre and the Agricultural Pensions Institute as provided in subsection 2; independent boards, consultative bodies, committees, commissions, working groups, investigators, as well as auditors of municipalities and federations of municipalities, and other comparable organs appointed for the performance of a given task on the basis of an Act, a Decree or a decision of an authority referred to in paragraph 1, 2 or 7. (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Private sector No. Absent from legal framework

Access to specific documents (subject to reactive and/or proactive disclosure)

Draft legal instruments Yes. (1) Unless otherwise follows from the secrecy provisions, an authority shall keep available the documents which contain information on (1) the initiation of a legislative reform project, a commission relating to the same, a deadline set and the person in charge of the drafting; and (2) plans, accounts and decisions on pending matters of general importance. (Section 19, Act on the Openness of Government Activities (621/1999; amended 2021))
Enacted legal instruments Yes. Section 1, (1) Official documents shall be in the public domain, unless specifically provided otherwise in this Act or another Act. Section 79, An Act which has been confirmed or which enters into force without confirmation shall be signed by the President of the Republic and countersigned by the appropriate Minister. The Government shall thereafter without delay publish the Act in the Statutes of Finland. (Section 1, Act on the Openness of Government Activities (621/1999; amended 2021) Section 79, Constitution of Finland, 1999, amended 2011)
Annual budgets Yes. (1) Unless otherwise provided on document publicity or secrecy or another restrictionof access to information in this Act or another Act, a document prepared by an authority shall enter the public domain as follows: (4) the budget propositions of ministries and the agencies and institutions within their fields of competence enter the public domain when the Ministry of Finance has signed its first position on the budget proposition; thereafter, the propositions sent to the Ministry of Finance from the other ministries and the other propositions drafted for and included in the budget proposal enter the public domain when the budget proposal has been submitted to Parliament; (Section 6, Act on the Openness of Government Activities (621/1999; amended 2021))
Annual chart of accounts (actual expenditures) Yes. Section 1, (1) Official documents shall be in the public domain, unless specifically provided otherwise in this Act or another Act. Section 46, The Government shall submit to the Parliament annual reports on governmental activities and on the measures undertaken in response to parliamentary decisions, as well as annual reports on State finances and adherence to the budget. (Section 1, Act on the Openness of Government Activities (621/1999; amended 2021) Section 46, Constitution of Finland, 1999, amended 2011)
Annual reports of public entities and programs Yes. (1) Unless otherwise provided on document publicity or secrecy or another restrictionof access to information in this Act or another Act, a document prepared by an authority shall enter the public domain as follows: (5) studies and statistics, as well as other comparable accounts which, forming a coherent whole, contain information on the alternatives, reasons and impacts pertaining to a decision or plan of general importance,even when they otherwise concern unfinished business, enter the public domain when they are fit for their purpose; (Section 6, Act on the Openness of Government Activities (621/1999; amended 2021))

Information access and release

Procedural access

Universal access (agencies, citizens and non-citizens) Yes. (1) Everyone has the right of access to an official document in the public domain. (Section 9, Act on the Openness of Government Activities (621/1999; amended 2021))
Type of request is specified (written, electronic, oral) No. (1) A request for access to an official document shall be sufficiently detailed, so that the authority can determine which document the request concerns. The person requesting access shall be assisted, by means of official diaries and indexes, in specifying the document to which access is being requested. The person requesting access need not identify himself or herself nor provide reasons for the request, unless this is necessary for the exercise of the authority’s discretion or for determining if the person requesting access has the right of access to the document. (Section 13, Act on the Openness of Government Activities (621/1999; amended 2021))
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.) Yes. Section 8 — Advice (1) An authority shall provide to its customers the necessary advice, within its competence, for taking care of administrative matters; as well as respond to the questions and queries on its service. Advice shall be provided free of charge. (2) If the matter does not fall within the competence of an authority, it should direct the customer to the competent authority. Section 9 — Requirement of proper language (1) An authority shall use appropriate, clear and comprehensible language. (2) The right of a customer to use and receive service by an authority in his/her own language is subject to separate provisions and to the terms of international agreements binding on Finland. (Sections 8 and 9, Act on the Openness of Government Activities (621/1999; amended 2021))
Cost of access is specified (free, request fees, photocopying costs, other administrative costs) Yes. A copy of a document and the provision of access to information in the form of a printout or by means of a technical interface, otherwise electronically or in a comparable manner, as well as the retrieval and delivery service provided by an authority, may be subject to a charge, as specifically provided elsewhere. Other access provided by virtue of this Act shall be free of charge. (Section 34, Act on the Openness of Government Activities (621/1999; amended 2021))

Deadlines for release of information

20-day response deadline Yes. (4) A matter referred to in this section shall be considered without delay, and access to a document in the public domain shall be granted as soon as possible, and in any event within two weeks from the date when the authority received the request for the document. (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Agency granted right to extend response time Yes. If the number of the requested documents is large, if they contain secret parts or if there is any other comparable reason for the consideration and the decision of the matter requiring special measures or otherwise an irregular amount of work, the matter shall be decided and access to the document granted within one month of the receipt of the request for access by the authority. (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))
Maximum total response time of no more than 40 days Yes. If the number of the requested documents is large, if they contain secret parts or if there is any other comparable reason for the consideration and the decision of the matter requiring special measures or otherwise an irregular amount of work, the matter shall be decided and access to the document granted within one month of the receipt of the request for access by the authority. (Section 4, Act on the Openness of Government Activities (621/1999; amended 2021))

Exceptions and Overrides

Exemptions to disclosure

Existence of secrecy/states secrets law No . Absent from legal framework
Existence of personal privacy/data law Yes. Data Protection Act (1050/2018) ( Data Protection Act (1050/2018))
Specific exemptions to disclosure Yes. Exemptions are described in 32 sub-paragraphs of the law. (Section 24, Act on the Openness of Government Activities (621/1999; amended 2021))
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

Appeals

Appeals allowed within public entities Yes. (3) If the official or the other person referred to in subsection 2 refuses to grant the requested access, he or she shall (1) inform the person requesting access of the reason for the refusal; (2) inform the person requesting access that he or she may have the matter decided by the authority; (3) ask a person who has filed a written request for access whether he or she wishes to have the matter forwarded to that authority; and (4) inform the person requesting access of the charges involved in the consideration of the request. (Section 14, Act on the Openness of Government Activities (621/1999; amended 2021))
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding. No. Absent from legal framework
Judicial appeals mechanism Yes. If the taxpayer considers that an error has occurred in imposing a payment referred to in the State Basic Payment Act (150/1992) or the Municipal Act (410/2015) pursuant to section 34 , he may demand an adjustment of the payment within six months of the payment being imposed. Otherwise, the provisions of the Administrative Procedure Act (434/2003) apply to the rectification claim . The provisions of the Administrative Procedure Act (808/2019) shall apply to other decisions and decisions on appeals . However, an appeal against a decision of an administrative court in a matter referred to in subsection 1 may not be lodged. The provisions of the Act on the Openness of Proceedings in General Courts and the Act on the Openness of Proceedings in Administrative Courts shall apply to an appeal in a matter concerning the publicity of proceedings. (Section 33, Act on the Openness of Government Activities (621/1999; amended 2021))

Sanctions for non-compliance

Administrative sanctions are specified for violations of disclosure requirements Yes. 2. The public official may also be sentenced to dismissal if he or she is guilty of the offence referred to in subsection 1 by continuously or essentially acting in violation of his or her official duties, and the offence indicates that he or she is manifestly unfit for his or her duties. (Chapter 40, Sections 9 and 10, Criminal Code, amended 2021)
Fines are specified for violations of disclosure requirements Yes. 1. If a public official, when acting in his or her office, intentionally in a manner other than provided above in this chapter violates his or her official duty based on the provisions or regulations to be followed in official functions, and the act, when assessed as a whole, taking into consideration its detrimental and harmful effect and the other circumstances connected with the act, is not petty, he or she shall be sentenced for violation of official duty to a fine or to imprisonment for at most one year. (Chapter 40, Sections 9 and 10, Criminal Code, amended 2021)
Criminal sanctions are specified for violations of disclosure requirements Yes. 1. If a public official, when acting in his or her office, intentionally in a manner other than provided above in this chapter violates his or her official duty based on the provisions or regulations to be followed in official functions, and the act, when assessed as a whole, taking into consideration its detrimental and harmful effect and the other circumstances connected with the act, is not petty, he or she shall be sentenced for violation of official duty to a fine or to imprisonment for at most one year. (Chapter 40, Sections 9 and 10, Criminal Code, amended 2021)

Monitoring and Oversight

Information officers must be appointed in public agencies Yes. Access to the contents of a document shall be granted by an official or employee who has been so designated by the authority or to whom the task otherwise belongs by virtue of his/her office or duties. (Section 14, Act on the Openness of Government Activities (621/1999; amended 2021))
Public body that is responsible for applying sanctions Yes. Criminal code is enforced by the public prosecutor (Chapter 40, Sections 9 and 10, Criminal Code, amended 2021)
Public body that is responsible for public outreach (raising public awareness) Yes. Individual public bodies are responsible for promoting FOI within their sphere of influence. (2) The authorities shall publicise their activities and services, as well as the rights and obligations of private individuals and corporations in matters falling within their field of competence. (Section 20, Act on the Openness of Government Activities (621/1999; amended 2021))
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman. No. Absent from legal framework
Ombudsman involvement in implementation is specified by law No. Absent from legal framework
Reporting of data and/or implementation is required No. Absent from legal framework

Legislation

The Constitution of Finland of 1999_FIN (Finnish)pdf
The Criminal Code of Finland of 1889_FIN (Finnish)pdf
Act No. 621 on the Openness of Government Activities of 1999_FIN (Finnish)pdf
Act No. 1050 on Data Protection Act of 2018_FIN (Finnish)pdf

*Last update: 2017

Public Procurement

The Finnish public procurement system is regulated mainly by the Act on Public Contracts (348/2007), and the Act on Procurement Procedures of Entities Operating in the Water, Energy, Transport and Postal Services Sectors (349/2007). The public procurement body is the Public Procurement Advisory Unit which is an organization under the Ministry of Employment and Economy.

The lowest minimum thresholds for conducting a public procurement tender are:

▪         EUR 134,000 for goods

▪         EUR 5,186,000 for works

▪         EUR 134,000 for services

The minimum number of bidders is 5 for restricted procedures and 3 for negotiated procedures and competitive dialogue. The minimum submission period is 35 days for open procedures, 30 days for restricted procedures and 30 for negotiated procedures from dispatch date. The final beneficial owners do not have to be disclosed when placing a bid.

There is no preferential treatment. However, there are several options for bid exclusion: conviction for certain crimes (economic etc.), bankruptcy, outgoing tax liabilities, false information. Bids can be also excluded because of abnormally low bid prices.

In the bid evaluation phase, there are conflict of interest restrictions on the composition of the evaluation committee and independence of  the contracting authority is mandated for the evaluation committee.

There is no payable fee in case of an arbitration procedure. It is not specified by law whether court decisions are published.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope10010010010086
Information availability8383834631
Evaluation6969697556
Open competition7575757575
Institutional arrangements2121212136

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope

Threshold - lowest PP

What is the minimum contract value above which the public procurement law is applied? (Product type GOODS) EUR 60000. The minimum contract value for which the procurement law applies to goods contracts is EUR 60,000, excluding VAT. Any contract for the supply of goods above this value must follow public procurement rules, otherwise only minimal requirements apply. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (1))
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS) EUR 150000. The minimum contract value for which the law applies to works contracts is EUR 150,000, excluding VAT. Contracts below this amount are exempt from the main legal procedures of the Act. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (2))
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES) EUR 60000. The threshold for services is the same as for goods: EUR 60,000, excluding VAT. Service contracts below this value are not covered by the core procurement procedures laid out in the Act. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (1))

Threshold - by PP type

What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR) EUR 60000. For public sector contracting entities, all contracts for goods and services above EUR 60,000 fall under the procurement regime. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (1))
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES) EUR 443000. For utilities, the application threshold is EUR 443,000 for goods/services and EUR 5,538,000 for works/concessions (exclusive of VAT), based on EU thresholds. (Act on Procurements and Concession of 2016, as amended, § 13)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE) EUR 100000. Defence contracts are subject to their own law, with the application threshold for goods and services set at EUR 100,000, excluding VAT. (Law on Public Defense and Security Procurement of 2011, as amended, § 13)

Threshold - by product type

What are the minimum application thresholds for the procurement type? (Product type GOODS) EUR 60000. Contracts for goods above EUR 60,000 must comply with the Act. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (1))
What are the minimum application thresholds for the procurement type? (Product type WORKS) EUR 150000. Works contracts valued at or above EUR 150,000 are regulated by the Act. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (2))
What are the minimum application thresholds for the procurement type? (Product type SERVICES) EUR 60000. The national threshold value, excluding VAT, is EUR 60,000 for the procurement of goods, services and design contests, unless otherwise provided at points 3–4. The Act does not apply to procurement agreements or concession contracts of estimated value falling below the national threshold values. Section 26 stipulates EU thresholds. (Law on Public Procurement and Concessions of 2016, as amended, § 25 (1))

Information availability

Publishing and record keeping

Is there a requirement that tender documents must published in full? Yes. The contracting entity shall make the invitation to tender, the invitation to negotiate and their annexes, as well as other procurement documents, available free of charge, without restriction, directly and in full in electronic form. The contract documents must be made available from the date on which the contract notice is published. The notice shall state the internet address at which the invitation to tender and other procurement documents are available in electronic form. (Law on Public Procurement and Concessions of 2016, as amended, §§ 58 and 69)
Are any of these documents published online at a central place? Yes. Tender documents and the notices referred to in § 58 shall be submitted for publication electronically on the Internet address https://www.hankintailmoitukset.fi/fi/ (Law on Public Procurement and Concessions of 2016, as amended, § 60)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system) Yes. Contracting entities shall keep, for at least the duration of the contract, copies of all contracts awarded with a value of at least EUR 1 000 000 for supply or service contracts and EUR 10 000 000 for works contracts. A report shall be prepared on a contract exceeding the EU thresholds and on a service contract exceeding the national threshold, a framework agreement, a procurement based on a framework agreement referred to in section 43 (3) or the establishment of a dynamic purchasing system. It is not necessary to draw up a report insofar as the corresponding information appears in the procurement decision, the ex post notification or other procurement documents. The contracting entity must adequately document the various stages of the procurement procedure and the solutions adopted. The documents must be kept for at least three years from the conclusion of the contract. The report shall be submitted to the European Commission and the Ministry of Employment and the Economy upon request. (Law on Public Procurement and Concessions of 2016, as amended, §§ 124 and 170)
Are contracts awarded within a framework agreement published (ie mini contracts)? No. The ex-post obligation to notify procurement (ie to publish procurement notices) does not apply to individual contracts awarded under a framework agreement. (Law on Public Procurement and Concessions of 2016, as amended, § 58)

Sub-contracting

Is it mandatory to publish information on subcontractors (ie names) in some cases? No. Contracts above EU thresholds must have their respective award notices published. In this case, information on subcontractors may be published. However, there is no explicit obligation to do so. Moreover, the procurement report to be submitted, upon request, to the European Commission must contain an estimate of the parts of the contract or framework agreement to be subcontracted to third parties or the names of any subcontractors. But, again, this report is not publicly available. (Law on Public Procurement and Concessions of 2016, as amended, § 77, 78, 124 (7) and 131)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column. There is no statutory percentage threshold that triggers mandatory public disclosure of subcontractor names; procurement law does not require publication of subcontractor identities by reference to a share of contract value. (Law on Public Procurement and Concessions of 2016, as amended, §§ 77, 78, 124(7) and 131)

Evaluation

Preferential treatment

Is there a ban on mentioning specific companies or brands in tender specification/call for tender? Yes. The definitions shall allow equal opportunities for tenderers to participate in the call for tenders and shall not unduly restrict competition in public procurement.The definition of the subject-matter of the procurement may not mention a specific manufacturer or goods of a particular origin, nor may it refer to a trademark, patent, product type, origin, specific method specific to the goods, services or production of a particular supplier in a way that favors or discriminates against certain suppliers. or goods. Such a reference is exceptionally permitted only if it is not possible to describe the subject-matter of the contract in a sufficiently precise and clear manner otherwise. The reference shall then be accompanied by the words "or equivalent". (Law on Public Procurement and Concessions of 2016, as amended, § 71)
Is there a preferential treatment for small-to-medium enterprises (SMEs)? Yes. Procurement must be organized in such a way that small and medium-sized enterprises and other entities have equal access to tenders with other tenderers. (Law on Public Procurement and Concessions of 2016, as amended, § 2)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies) No. The contracting entity shall treat tenderers and other suppliers in a fair and non-discriminatory manner and shall act in a transparent and proportionate manner. (Law on Public Procurement and Concessions of 2016, as amended, § 3)
Is there a specific set of rules for green/sustainable procurement? Yes. The contracting entity may require in the description of the contract, in the criteria for overall economic advantage set out in the invitation to tender or in the conditions for performance of the contract, a specific indication that the contract meets the required environmental, social or other characteristics. Moreover, the contracting entity may decide not to award a contract to the tenderer who has submitted the most economically advantageous tender if it has determined that the tender does not comply with environmental obligations. Violations of environmental obligations constitute, furthermore, grounds for tenderer exclusion. The contracting entity may ask the candidate or tenderer for an explanation of the environmental impact management measures to be taken in connection with the execution of the work or the provision of the service. When requesting certificates from independent bodies that a candidate or tenderer meets the requirements of environmental management standards, the contracting entity shall refer to the Union eco-management and audit scheme (EMAS) or to recognized environmental schemes or other environmental management standards based on European or international standards recognized by recognized bodies. (Law on Public Procurement and Concessions of 2016, as amended, §§ 72, 79, 81 (5) 90, 93 and 95)

Bid evaluation

Are there restrictions on allowable grounds for tenderer exclusion? Yes. Legal final conviction for any of the following offences constitutes mandatory grounds for tenderer exclusion: 1) bribery; 2) participating in the activity of an organized criminal group; 3) trafficking in human beings; 4) tax fraud; 5) giving of bribes in business; 6) money laundering; 7) offence made with terrorist intent; 8) occupational health and safety offences; 9) failure to pay taxes and social security contributions. On the other hand, a candidate or tenderer shall not be excluded from competitive tendering if more than five years have elapsed since the issuing of a legally final judgement. A candidate or tenderer may be (discretionary exclusion grounds) excluded if: 1) they are bankrupt or subject to liquidation; 3) the contracting entity can prove that they are guilty of grave professional misconduct calling its reliability into question; 4) the contracting entity can prove they have defaulted on a duty to pay the taxes or social security contributions of Finland or of its country of establishment; 5) they have infringed the environmental, social and labour law obligations contained in Finnish or European Union legislation, collective agreements, or the international treaties listed in Annex C, where the contracting entity can prove the infringement; 6) they have concluded agreements with other suppliers seeking to distort competition, and the contracting entity can prove that this has occurred; 7) conflict of interest in the procurement procedure cannot be effectively eliminated by other measures; 8) their participation in preparing the procurement procedure has distorted competition, and the distortion cannot be eliminated by other, less intrusive measures; 9) their performance in previous procurement agreements or concession contracts have involved significant or repeated shortcomings in implementing some key requirement; 10) they are guilty of material misrepresentation in furnishing the contracting entity with information or has failed to supply the required information; 11) they have sought to unduly influence the decision-making process of the contracting entity, to obtain confidential information that may confer an undue advantage upon it in the procurement procedure, or to wilfully provide misleading information that may have a material influence on decisions concerning the selection of a tenderer or tender. (Law on Public Procurement and Concessions of 2016, as amended, §§ 80 and 81)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc. No. The contracting entity may reject a tender which is abnormally low in terms of price or cost in relation to the quality and scope of the contract, provided that the tenderer's explanation and other evidence provided do not satisfactorily explain the low level of prices or costs offered. The contracting entity shall reject the tender if the abnormally low price or costs of the tender are due to failure to comply with environmental, social and labor law obligations. It may also reject a tender which is abnormally low because of unlawful State aid received by the tenderer, but only if the tenderer is unable to prove, within a reasonable period set by the contracting entity, that the State aid has been granted lawfully. The contracting entity shall notify the Ministry of Employment and the Economy of the rejection of the tender for the reason referred to in this subsection. (Law on Public Procurement and Concessions of 2016, as amended, § 96)
Is scoring criteria published? Yes. The contracting entity shall indicate the criterion of overall economic advantage or value for money in the contract notice, the invitation to tender or the invitation to negotiate. The contracting entity shall specify the relative weighting of the benchmarks in the contract notice, the invitation to negotiate or the invitation to tender. The weighting can also be expressed by indicating a reasonable range. If, for objective reasons, the relative weighting of the benchmarks cannot be determined, the benchmarks shall be listed in descending order of importance. (Law on Public Procurement and Concessions of 2016, as amended, § 93)
Are decisions always made by a committee? No. Appointment of an evaluation or selection committee is not generally mandatory for public procurement. Only for design contests, a jury must be established, composed of independent experts who are autonomous and without conflict of interest, as prescribed by the law. (Law on Public Procurement and Concessions of 2016, as amended, §§ 55, 93 and 123)
Are there regulations on evaluation committee composition to prevent conflict of interest? No. Aside from requirements concerning the modality "design contest", which must have a jury whose members must be natural persons who are independent of the contest participants and who are autonomous in their decisions or opinions, the Law on Public Procurement and Concessions of 2016 essentially does not mention conflict of interests. It does not define the term and, more importantly, only stipulates that: 1. the contracting entity may decide to exclude a candidate or tenderer whose conflict of interest in the procurement procedure cannot be effectively eliminated by other measures; and 2. a description of any conflicts of interest that may have been found in the procurement procedure and of the consequent measures taken must be included in the procurement report to be submitted, upon request, to the European Commission. (Law on Public Procurement and Concessions of 2016, as amended, §§ 81 (1) 7 and 124 (1) 11.)
Is some part of evaluation committee mandatorily independent of contracting authority? No. In the modality "design contest", the jury shall be autonomous in its decisions or opinions. (Law on Public Procurement and Concessions of 2016, as amended, § 55)
Are scoring results publicly available? No. A contracting entity shall make a written decision on resolutions affecting the status of candidates and tenderers and on procurement procedure resolutions, which shall be substantiated. The decision or its associated documents shall state the facts that integrally affected the resolution, which shall at least include the grounds for rejecting a candidate, tenderer or tender, and the principal criteria on which the comparison of approved tenders was made. The decision made by the contracting entity with its justifications, and the instructions for appeal and rectification shall be served in writing to the parties concerned either electronically or by means of a letter sent by post. However, there is no mention in the Law concerning publicity of this information. (Law on Public Procurement and Concessions of 2016, as amended, §§ 123 and 127)
Does the law specify under which conditions the tender can be cancelled? No. The Law does not specify under which conditions the tender can be cancelled but § 132 provides that the contracting entity may quash its own erroneous decision or cancel some other resolution made in a procurement procedure with legal effects on the status of candidates or tenderers and decide the matter again (rectification of procurement) if the decision or other resolution made in the procurement procedure is based on an erroneous application of the law, or if new information has come to light in the case that could affect the decision, the resolution, or the conditions for concluding the procurement agreement. Rectification of a decision or resolution shall not require the consent of the concerned party. (Law on Public Procurement and Concessions of 2016, as amended, § 132)

Open competition

CFT publication

Does the law specify the location for publicizing open calls for tenders? Yes. Official Journal of the European Union (TED) and online at https://www.hankintailmoitukset.fi/fi/ (Law on Public Procurement and Concessions of 2016, as amended, § 60)
Does the law specify the location for publicizing restricted calls for tenders? Yes. Official Journal of the European Union (TED) and online at https://www.hankintailmoitukset.fi/fi/ (Law on Public Procurement and Concessions of 2016, as amended, § 60)
Does the law specify the location for publicizing negotiated calls for tenders? Yes. Official Journal of the European Union (TED) and online at https://www.hankintailmoitukset.fi/fi/ (Law on Public Procurement and Concessions of 2016, as amended, § 60)

Minimum # of bidders

What is the minimum number of bidders for restricted procedures? 5. For restricted procedures, a minimum of five candidates must be invited to tender, provided that enough candidates show interest and meet the selection criteria set by the authority. (Law on Public Procurement and Concessions of 2016, as amended, § 33 (3))
What is the minimum number of bidders for negotiated procedures? 3. In negotiated procedures, a minimum of three candidates are required to be invited for participation, where possible based on the outcome of selection. (Law on Public Procurement and Concessions of 2016, as amended, § 34 (5))
What is the minimum number of bidders for competitive dialogue procedures? 3. In competitive dialogue procedures, at least three candidates must be invited, subject to the sufficiency of qualified applicants. (Law on Public Procurement and Concessions of 2016, as amended, § 36 (4))

Bidding period length

What are the minimum number of days for open procedures? 35. The minimum period for submission of tenders in open procedures is 35 days from the date of publication of the contract notice, ensuring fair access to contract opportunities for all suppliers. (Law on Public Procurement and Concessions of 2016, as amended, § 56)
What are the minimum number of days for restricted procedures? 30. In restricted procedures, the law requires at least 30 days between invitation to submit a tender and submission deadline, providing sufficient time for qualified candidates. (Law on Public Procurement and Concessions of 2016, as amended, § 56)
What are the minimum number of days  for competitive negotiated procedures? 30. For negotiated procedures and competitive dialogue, the statutory minimum deadline for tender submission is 30 days from invitation. (Law on Public Procurement and Concessions of 2016, as amended, § 56)

Institutional arrangements

Institutions and regulations

Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations? Yes. This Act shall not govern procurements: 1) that are subject to mandatory procedural provisions governing the contracting entity that deviate from this Act and are concluded: a) pursuant to an international treaty concluded between Finland and one or more countries outside of the European Economic Area or parts thereof and in accordance with the treaties establishing the European Union, which concerns public works contracts, goods or services intended for implementing or exploiting a joint undertaking of the signatory States; the contracting entities and other authorities shall inform the Ministry of Economic Affairs and Employment of the international treaties on request; b) by an international organisation; or c) pursuant to an international treaty on deployment of forces concerning enterprises operating in some Member State of the European Union or in a country outside of the European Economic Area; 2) that the contracting entity concludes or arranges in accordance with procedural provisions issued by an international organisation or international financial institution and that are wholly financed by the said organisation or institution; 3) whose principal purpose is to enable the contracting entity to make public communications networks available or to maintain them, or to provide the public with one or more electronic communication services. Furthermore, this Act shall not govern: 1) purchases or leasing of land, existing buildings or other immovable property under any form of financing, or procurement of associated rights; 2) purchasing, development, production or co-production procurements of programme material intended for audiovisual media services or radio services made by providers of audiovisual media services or radio services; 3) procurements concerning radio or television transmission times or the delivery of programmes when these are made with providers of audiovisual media services or radio services; 4) procurements concerning arbitration and conciliation services; 5) procurements concerning attorney services and directly associated legal advisory services provided by attorneys and trial counsel referred to in the Licenced Legal Counsel Act (715/2011); 6) procurements concerning document authentication or verification services performed by public notaries; 7) procurements concerning legal services performed by trustees, and other legal services whose performer is appointed by a court of law or designated by law to discharge special functions under the supervision of a court of law; 8) procurements of other legal services associated with the exercise of public power; 9) procurements concerning central bank services or financial services pertaining to the issue, purchase, sale or transfer of securities or other financing instruments, and other business operations whereby a contracting entity procures finance or capital; 10) employment contracts; 11) procurements concerning the civil defence, rescue services and hazard prevention, emergency care and emergency response operations referred to in Schedule A that are provided by nonprofit organisations or consortia thereof; 12) procurements concerning the political campaigning services referred to in Schedule A when a political party concludes a service contract in the course of an election campaign; 13) procurements concerning the research and development services referred to in Schedule A, except where the benefits derived from them accrue solely to the contracting entity for use in its operations and the contracting entity pays in full for the service performed; 14) procurements of assigned amount units, emission reduction units and certified emission reductions permitted under the Kyoto Protocol to the United Nations Framework Convention on Climate Change (Finnish Treaty Series 13/2005);15) procurements of air transport services falling within the scope of Council Regulation (EEC) No 2408/92 on access for Community air carriers to intra-Community air routes. (Law on Public Procurement and Concessions of 2016, as amended, §§ 8 and 9)
Does the law specify the main types of institutions that must apply the public procurement law? Yes. Authorities of central and local government and joint municipal authorities, the Evangelical-Lutheran and Orthodox churches of Finland and their parishes and other authorities, state-owned institutions, institutions of public law character, and any party conducting a procurement when it has secured the support in doing so of a contracting entity referred to in paragraphs 1–4 amounting to more than half of the value of the procurement. (Law on Public Procurement and Concessions of 2016, as amended, § 5)
Does the law specify the main procedure types or procurement methods permitted? Yes. Open procedure, restricted procedure, negotiated procedure, competitive negotiated procedure, innovation partnership, directly procurement, framework agreement, design contest (Law on Public Procurement and Concessions of 2016, as amended, §§ 32-55)
Is there a procurement arbitration court dedicated to public procurement cases? Yes. The Market Court is a specialized judicial body competent to review and resolve public procurement disputes brought by aggrieved bidders and enforce remedies, including the annulment of contract awards. (Law on Public Procurement and Concessions of 2016, as amended, §§ 126 (1), 145 and 146)
Is there a procurement regulatory body dedicated to public procurement? Yes. The Finnish Competition and Consumer Authority monitors compliance with the Law on Public Procurement and Concessions of 2016 and the Competition and Consumer Agency may also examine a matter within its competence on its own initiative. (Law on Public Procurement and Concessions of 2016, as amended, § 139)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)? No. The only relevant provision about this matter is that in case of design contests, at least a third of the members of the jury shall have the particular professional qualification that is required from participants in the contest or an equivalent qualification. (Law on Public Procurement and Concessions of 2016, as amended, § 55)
Is disclosure of final, beneficial owners required for placing a bid? No. The law does not require the disclosure of beneficial ownership information as a precondition for participation in public procurement. (No mention in the law)

Complaints

Is there a fee for arbitration procedure? Yes. The contracting entity shall attach to its decision a notice of appeal explaining how it is possible to bring the matter before the Market Court, the contracting entity's contact information for the notification referred to in section 148 and instructions on how to use the remedy (rectification instruction). Otherwise, the provisions of Chapter 7 of the Administrative Law (434/2003) concerning the notice of appeal and the instruction for rectification shall apply to the issuance and correction of a notice of appeal and a rectification instruction. Section 47 of the Administrative Law (434/2003) establishes that the notice of appeal shall set out the provisions on the content of the notice of appeal, the annexes and the delivery of the appeal, as well as the fees for handling the appeal. In addition, provisions of Chapter 10 of the Administrative Procedure Act (808/2019), apart from Section 95 (3), shall otherwise apply to the reimbursement of legal costs. (Law on Public Procurement and Concessions of 2016, as amended, §§ 126 and 149 Administrative Law No. 434 of 2003, as amended, § 47 Administrative Procedure Act No. 808 of 2019, as amended, Chapter 10)
Is there a ban on contract signature until arbitration court decision (first instance court)? No. In the case of a direct procedure, in which the contract may be awarded at the earliest 14 days after publication of the notice, the contracting entity may not enter into a procurement contract if the matter has been brought before the Market Court with an appeal. However, for other procedures, upon receipt of the appeal, the Market Court may, while examining interim measures, refuse, suspend or permit the execution of the procurement decision or order the procurement procedure to be temporarily suspended for the duration of proceedings. There is, therefore, no automatic ban until the Court delivers its final decision. (Law on Public Procurement and Concessions of 2016, as amended, §§ 131, 150, 151 and 152)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts? N/S. No statutory maximum duration for Market Court review was identified in procurement legislation; the length depends on the case. (Law on Public Procurement and Concessions of 2016, as amended, §§ 147, 148, 154; no fixed statutory maximum identified)
Is there a requirement to publicly release arbitration court decisions ? Yes. The Market Court shall maintain and publish an optimally comprehensive and current list of procurement cases filed at the Market Court. Moreover, according to the Law on Public Access to Proceedings in Administrative Courts which is applicable to the Market Court, a court document containing the decision of the Court is made public. The exceptions to publicity are clearly stated and revolve around classified information. In any event, the outcome of the decision and the applicable law are always public. However, the Court may decide that, notwithstanding the provisions on secrecy, the decision shall be made public to the extent necessary for the overriding public or private interest involved. Market Court decisions can be found on its website: https://www.markkinaoikeus.fi/fi/index.html (Law on Public Procurement and Concessions of 2016, as amended, § 148 and 162 Law on Public Access to Proceedings in Administrative Courts, as amended, §§ 2 and 16)

Legislation

Act on Public Defence and Security Procurement (Finnish)pdf
Act on Public Procurement and Concession Contracts (Finnish)pdf
Administrative Judicial Procedure Act (808/2019) (Finnish)pdf
Administrative Procedure Act (434/2003) (Finnish)pdf
Act on the Openness of Court Proceedings in Administrative Courts (Finnish)pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data

Primary Metric

201220152016201720202024Trend
Risk-based approach67
Sanctions for natural persons57
Sanctions for legal persons50
Pecuniary sanctions for obliged entities60
Beneficial ownership of legal persons and legal arrangements43
Supervision of obliged entities0
Financial Intelligence Units (FIUs)100
Mutual legal assistance (MLA) and International Cooperation100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Risk-based approach

Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it. Yes. The Act requires a national money laundering and terrorist financing risk assessment and states its purpose, including identifying sectoral risks and supporting consistent AML/CFT policies and measures. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 2, section 1.)
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years. No. The national risk assessment must be updated on a regular basis, but the Act does not require review at least every four years. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 2, section 1.)
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks. Yes. The Ministry of the Interior and the Ministry of Finance are designated as the national authorities coordinating preparation of the national ML/TF risk assessment. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 2, section 1.)

Sanctions for natural persons

The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action; Yes. Conversion, transfer, transmission, receipt, use and possession of criminal property are criminalised when done for concealment or to assist evasion of legal consequences. (Criminal Code (39/1889), Chapter 32, section 6(1).)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity; Yes. Concealing or disguising the true nature, source, location, disposition of, or rights with respect to, criminal property is a money laundering offence. (Criminal Code (39/1889), Chapter 32, section 6(1)(2).)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity. No. Finnish money laundering requires acquisition, use or possession plus a further purpose element; the law does not clearly criminalise mere acquisition, possession or use on knowledge alone. (Criminal Code (39/1889), Chapter 32, section 6(1); Chapter 32, section 1.)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence. Yes. Attempt is expressly punishable, and general Criminal Code rules criminalise incitement and abetting of intentional offences and punishable attempts. (Criminal Code (39/1889), Chapter 32, sections 6 and 7; Chapter 5, sections 1, 5 and 6.)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years. Yes. Aggravated money laundering is punishable by imprisonment for up to six years. (Criminal Code (39/1889), Chapter 32, section 7.)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences No. Absent from legal framework
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator; No. Absent from legal framework

Sanctions for legal persons

Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person. No. Finnish law provides legal-person sanctions for money laundering offences and administrative sanctions under the existing AML/Funds Transfers framework, but it does not clearly establish liability for breaches of Regulations (EU) 2024/1624 or 2023/1113 as described. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 8, sections 1–3; Criminal Code (39/1889), Chapter 9, sections 1–3 and Chapter 32, section 14.)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority. Yes. A legal person may be sentenced to a corporate fine if the care and diligence necessary to prevent the offence were not observed and the offence was committed on behalf of or for the benefit of the legal person. (Criminal Code (39/1889), Chapter 9, sections 2 and 3; Chapter 32, section 14.)
Legal persons held liable are punishable by criminal or non-criminal fines. Yes. Legal persons can be punished by a corporate fine. (Criminal Code (39/1889), Chapter 9, sections 1 and 5; Chapter 32, section 14.)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence. No. The Criminal Code provides a corporate fine, but no equivalent list of additional sanctions for legal persons such as exclusion from benefits, disqualification, judicial supervision, winding-up or closure was identified for money laundering offences. (Criminal Code (39/1889), Chapter 9, sections 1 and 5; Chapter 32, section 14.)

Pecuniary sanctions for obliged entities

In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach. Yes. Finland’s supervisory regime substantively satisfies the indicator because pecuniary sanctions and administrative measures can be imposed for breaches of the national AML framework implementing EU AML obligations, and the Funds Transfers Regulation is expressly sanctionable. Under your methodology, sanctions for breach of the national implementing law are sufficient. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 8, sections 1–5; Chapter 7, sections 6–7.)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention). Yes. The Finnish regime allows pecuniary sanctions for serious AML breaches committed wilfully or through negligence, including failures to comply with core AML obligations and with the Funds Transfers Regulation. Read substantively, that is sufficient even though the law is framed through the national AML Act rather than mirroring Regulation (EU) 2024/1624 word for word. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 8, sections 1 and 3.)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed. Yes. Supervisors can apply administrative measures where they identify AML-law breaches, including rectification orders, prohibitions of execution, public warnings, conditional fines and penalty payments. That substantively covers the indicator where the national AML law implements the EU framework. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 7, sections 5–7; Chapter 8, sections 2–5.)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures. No. Finnish law provides conditional fines to enforce prohibitions and rectification orders, but not periodic penalty payments as described in the indicator. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 7, sections 6 and 7; Act on the Financial Supervisory Authority (878/2008), section 33a.)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments. No. Publication is required for administrative fines, public warnings and penalty payments, but not clearly for all administrative measures or periodic penalty payments as described in the indicator. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 8, section 8; Act on the Financial Supervisory Authority (878/2008), section 43.)

Beneficial ownership of legal persons and legal arrangements

Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered. Yes. Finland maintains beneficial ownership information in the Trade Register for legal entities and for foreign express trusts or similar legal arrangements that must be registered there. (Trade Register Act (564/2023), sections 1, 5 and 6; Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 6, sections 3 and 4.)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation. No. The register authority may require information and documents for registration and correction of register data, but no clear explicit rule was identified empowering it to request from legal entities, legal owners and beneficial owners all information listed in the indicator, such as board minutes or powers of attorney. (Trade Register Act (564/2023), sections 13, 17 and 22.)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number No. Finnish law allows the register to record that no beneficial owner exists or could be identified, but it does not clearly require the central register to include the full substitute data set for all senior managing officials described in the indicator. (Trade Register Act (564/2023), section 5.)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date. Yes. Finland’s framework substantively satisfies this indicator because the registration authority must react to incomplete or suspected incorrect register data, and key entities must confirm the up-to-dateness of register information every calendar year. Under your methodology, those concrete timing and review rules are enough even without the exact formula “within a reasonable time upon submission ... and on a regular basis thereafter.” (Trade Register Act (564/2023), sections 22 and 23.)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them. No. Finnish law requires discrepancy reporting by obliged entities, supervisors and the Bar Association, but it does not clearly impose that duty on competent authorities generally as described in the indicator. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 6, section 5.)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register. No. Finnish law requires beneficial ownership information to be kept up to date and allows the register authority to demand updated or confirmed information, but no clear explicit rule was identified stating that the central register must include every change following first registration in the terms of the indicator. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 6, section 2; Trade Register Act (564/2023), sections 22 and 23.)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date. No. No clear explicit rule was identified empowering the register authority to carry out checks, including on-site inspections at business premises or registered offices, to establish current beneficial ownership and verify register data. (Trade Register Act (564/2023), sections 22 and 23.)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration. No. Absent from legal framework
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership. Yes. The registration authority can impose effective measures for failures to provide accurate and up-to-date beneficial ownership information: negligence fees for incomplete or incorrect filings, repeated increased fees, and in some cases liquidation or deregistration for failure to file or correct beneficial-owner information. That is enough in substance for this indicator. (Trade Register Act (564/2023), sections 24 and 28.)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States. No. Finnish law provides access for national authorities to register data, but no clear explicit rule was identified granting the full set of authorities listed in the indicator immediate, unfiltered, direct and free access to the interconnected central registers in the terms described. (Trade Register Act (564/2023), sections 2 and 30.)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers. No. Finnish law allows access to Trade Register information and fees are set by ministerial decree, but no clear explicit rule was identified limiting fees for beneficial ownership information to what is strictly necessary to cover the costs described in the indicator. (Trade Register Act (564/2023), section 2; Ministry of Employment and the Economy Decree on chargeable services of the Finnish Patent and Registration Office in 2026 (1216/2025), as amended by Decree 171/2026.)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest. Yes. Finnish law allows disclosure of beneficial-ownership information where the recipient is identified and has a reason under the AML Act’s objective clause for handling the information, or where an authority needs it for a statutory duty. Read substantively, this functions as a legitimate-interest access route at least as broad as the indicator. (Trade Register Act (564/2023), section 2; section 5; Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 1, section 1.)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; Yes. Persons acting for journalism, reporting or other media expression connected with preventing or combating money laundering or terrorist financing can satisfy the Finnish access test because disclosure is permitted where the identified recipient has a reason under the AML Act’s objective clause. The national rule is functionally broad enough even though it does not list journalists expressly. (Trade Register Act (564/2023), section 2; Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 1, section 1.)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; Yes. Civil-society organisations and academia connected with preventing or combating money laundering or terrorist financing can satisfy the Finnish access test because disclosure is permitted where the identified recipient has a reason under the AML Act’s objective clause. Express naming is not required under your methodology. (Trade Register Act (564/2023), section 2; Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 1, section 1.)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing; Yes. A natural or legal person likely to enter into a transaction and wishing to avoid links to money laundering or terrorist financing can reasonably fall within Finland’s access criterion, since beneficial-ownership information may be disclosed where the identified recipient has a reason connected with the AML Act’s prevention objective. This is sufficient in substance. (Trade Register Act (564/2023), section 2; Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 1, section 1.)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure; Yes. Public authorities may receive the information where they require it for a statutory duty. That is broader than the indicator’s minimum public-procurement example, so this row should be treated as compliant under your methodology. (Trade Register Act (564/2023), section 2.)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing. No. Absent from legal framework
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days. No. Absent from legal framework
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679. Yes. Finland’s access regime contains operative grounds that can function as refusal grounds: the applicant must be identified, and beneficial-ownership information may be disclosed only where the applicant has a qualifying AML-related reason or where an authority needs the information for a statutory duty. Under your methodology, at least one such condition is enough. (Trade Register Act (564/2023), section 2.)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed. No. Finnish law protects certain personal data in Trade Register disclosures, but no clear explicit case-by-case exemption regime for beneficial ownership access based on disproportionate risk, minority or legal incapacity was identified in the terms of the indicator. (Trade Register Act (564/2023), sections 2 and 7.)

Supervision of obliged entities

Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113. No. Finnish law appoints several AML supervisors and gives them supervisory and sanctioning powers, but no clear explicit rule in force on 30 April 2026 was identified requiring supervision of compliance with Regulations (EU) 2024/1624 and (EU) 2023/1113 across all obliged entities in the terms of the indicator. (Act on Preventing Money Laundering and Terrorist Financing (444/2017), Chapter 7, section 1; Chapter 8, sections 1–3 and 8.)

Financial Intelligence Units (FIUs)

Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing. Yes. The National Bureau of Investigation has a Financial Intelligence Unit established by law. Its statutory duties cover the prevention, detection and investigation of money laundering and terrorist financing. (Act on the Financial Intelligence Unit (445/2017), sections 1 and 2.)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing. Yes. The Financial Intelligence Unit is expressly tasked with receiving and analysing suspicious transaction reports and other relevant reports under the AML Act. (Act on the Financial Intelligence Unit (445/2017), section 2(1)(2).)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing. Yes. Read substantively, the FIU is responsible for disseminating relevant analysis and information to competent authorities when suspicions arise: its statutory duties include preventing, detecting and investigating money laundering and referring cases for criminal investigation, and it may disclose information from the money-laundering register, including without a prior request, and to supervisory authorities when necessary. The absence of the exact indicator wording is not enough for No. (Act on the Financial Intelligence Unit (445/2017), sections 2 and 4(4).)
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference. Yes. Functionally, the Finnish FIU is operationally autonomous enough for this indicator. Although located within the National Bureau of Investigation, the law gives it its own statutory tasks, its own register as controller, and its own decision-making by commanding officers working at the Unit for obtaining, disclosing and restricting information and for transaction suspensions. I did not find a requirement that it obtain permission from another authority to perform its core functions. (Act on the Financial Intelligence Unit (445/2017), sections 2, 3, 4, 5 and 6.)
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information. Yes. The FIU has a broad statutory right to obtain necessary information free of charge from authorities, bodies performing public functions, obliged entities and certain private persons and entities, notwithstanding secrecy rules. (Act on the Financial Intelligence Unit (445/2017), section 4(1) and (2).)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction. Yes. A commanding police officer working at the FIU may order an obliged entity to suspend a transaction for up to ten working days and may take related urgent measures. The same power may also be exercised at the request of a foreign authority. (Act on the Financial Intelligence Unit (445/2017), section 6(1)–(4).)

Mutual legal assistance (MLA) and International Cooperation

Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU. Yes. Section 5 substantively meets this indicator because, when dealing with foreign FIUs, the Finnish FIU may request and disclose the same categories of information that it can obtain domestically under section 4. That is enough to show that the requested FIU can use its available domestic powers when answering a foreign request. (Act on the Financial Intelligence Unit (445/2017), sections 4 and 5.)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange. Yes. Finnish law substantively requires and enables FIU information-sharing both upon request and spontaneously for money laundering, terrorist financing and related predicate offences. The rule is broad enough even though it does not repeat every clause of the indicator verbatim about unidentified predicate offences. (Act on the Financial Intelligence Unit (445/2017), section 5.)

Legislation

Act on Political Parties, 1969, amended 2016missing file:
Act on Candidates Election Funding, 2009, amended 2010missing file:
Penal Code, 1989/39, amended 2016missing file:

*Last update: 2017

Asset Recovery

Quantitative Data

Primary Metric

201220152016201720202024Trend
Asset Offices100
Confiscation78
International cooperation75

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Asset Offices

Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters. Yes. Finland has a national Asset Recovery Office within the National Bureau of Investigation/Police, designated to trace criminal assets and cooperate with foreign authorities under the EU ARO (National designation of the Finnish Asset Recovery Office under Council Decision 2007/845/JHA and Police Act)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order. Yes. Confiscated assets and seized items are managed under the supervision of the enforcement authorities and the state Treasury, (Coercive Measures Act 806/2011, Chapter 7 (Seizure and confiscation for security) together with Enforcement Code (Ulosottokaari 705/2007) and State Budget Act)

Confiscation

Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures) Yes. The Coercive Measures Act allows seizure and confiscation for security of property in order to secure forfeiture or payment obligations, including urgent court‑ordered (Coercive Measures Act 806/2011, Chapter 7, Sections 1–3 (Securing of forfeiture and confiscation for security; seizure and prohibition on transfer).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation) Yes. Chapter 10 of the Criminal Code provides that proceeds of an offence and the instrument used in the commission of an offence may be ordered forfeited to the State. (Criminal Code of Finland (39/1889), Chapter 10, Sections 1–2 (Forfeiture of proceeds of an offence; Forfeiture of an instrumentality or object).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value) Yes. If the proceeds of an offence or an object subject to forfeiture cannot be seized, (Criminal Code, Chapter 10, Section 3 (Forfeiture in value).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation) Yes. Forfeiture of proceeds may be imposed also on a person to whom the benefit of the offence has passed, (Criminal Code, Chapter 10, Section 4 (Forfeiture from a third party).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation) Yes. Extended forfeiture allows ordering forfeiture of property of the offender when the offence is of a kind that can normally yield significant economic benefit and the offender’s (Criminal Code, Chapter 10, Section 3a (Extended forfeiture of proceeds of an offence).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation) Yes. Forfeiture may be ordered in separate proceedings even where the suspect cannot be convicted due to limitation or other procedural obstacles, (Criminal Code, Chapter 10, Section 9 (Forfeiture without sentencing); Coercive Measures Act 806/2011, Chapter 7, Section 5 (seizure for forfeiture even when the suspect is unknown or absent).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation) Yes. Forfeiture without sentencing is limited to cases where the commission of an offence has been established and where the forfeiture concerns proceeds or instruments of the offence; (Criminal Code, Chapter 10, Section 9 (Forfeiture without sentencing).)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth) No. Finland has extended forfeiture, but a separate unexplained‑wealth confiscation regime, as envisaged in Article 16 of Directive (EU) 2024/1260, was not yet implemented by 31.12.2024. (Criminal Code, Chapter 10, Section 3a (extended forfeiture); no specific unexplained‑wealth)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027) No. Finnish law does not provide for a specific national asset recovery strategy with a mandatory five‑year update cycle; this follows from Directive (EU) 2024/1260 (No explicit asset‑recovery strategy provision in Criminal Code, Coercive Measures Act)

International cooperation

To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters. Yes. The Coercive Measures Act and the Mutual Legal Assistance in Criminal Matters Act allow Finnish authorities to trace and seize assets at the request of foreign states and EU instruments, (Coercive Measures Act 806/2011, Chapter 7; Act on International Legal Assistance in Criminal Matters 4/1994, Sections 13–15 (execution of foreign requests for seizure and confiscation).)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information Yes. Finland’s Asset Recovery Office is part of the EU ARO network and is mandated to exchange information with other Member States’ AROs (Designation of the Finnish Asset Recovery Office under Council Decision 2007/845/JHA; Police Act)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders. No. Finnish law on mutual legal assistance and enforcement of confiscation orders does not contain a specific rule on cost‑sharing (No explicit cost‑sharing provision identified in Act on International Legal Assistance in Criminal Matters or Coercive Measures Act.)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions Yes. Finland may share confiscated assets with foreign states in accordance with international agreements and national provisions implementing the Council of Europe (Act on International Legal Assistance in Criminal Matters 4/1994, Sections on disposal of confiscated assets in international cases, implementing Council of Europe)

Legislation

Act on Political Parties, 1969, amended 2016missing file:
Act on Candidates Election Funding, 2009, amended 2010missing file:
Penal Code, 1989/39, amended 2016missing file:

*Last update: 2017