Legal Framework for Electronic Invoicing in Finland
The legal framework for electronic invoicing in Finland is based on EU regulations and national Finnish legislation. Finland has implemented European provisions for electronic invoicing into its domestic laws and has established specific requirements for the issuance and receipt of electronic invoices.
1. EU VAT Directive (2006/112/EC)
The EU VAT Directive (2006/112/EC) serves as the primary legal foundation for recognizing electronic invoices across EU member states, including Finland. Key provisions include:
- Article 232: EU member states may accept electronic invoices provided their authenticity (the sender’s identity) and integrity (unaltered content) are ensured.
- Authenticity and integrity can be guaranteed through methods such as:
- Electronic signatures
- EDI (Electronic Data Interchange)
- Other appropriate technologies that secure and maintain the immutability of invoice data.
2. Finnish VAT Act (Arvonlisäverolaki)
The Finnish VAT Act (Arvonlisäverolaki) contains specific provisions regarding electronic invoicing:
- Section 200: Electronic invoices are legally valid if they meet general requirements for authenticity and integrity.
- These requirements can be fulfilled using technologies such as:
- Electronic signatures
- EDI systems.
- Electronic invoices must also include all mandatory VAT-related information (e.g., issuer and recipient names and addresses, VAT rate, invoice amount, description of goods or services).
3. Regulation on Electronic Invoicing in the Public Sector
All companies conducting business with public administration in Finland are required to send their invoices electronically. This obligation stems from the EU Directive 2014/55/EU on electronic invoicing in public procurement:
- Finland has implemented this directive into national law and introduced the Finland e-invoicing platform (eLasku) for processing electronic invoices related to public procurement.
- Since April 1, 2019, invoices sent to public sector entities (e.g., state agencies, municipal bodies) must be transmitted in structured formats such as UBL (Universal Business Language) or XML via the eLasku platform.
4. Regulation on the Exchange of Electronic Invoices (Sähköinen laskutus)
Finland has established a specific regulation for electronic invoicing (Sähköinen laskutus) to define the technical and administrative requirements for exchanging electronic invoices:
- Companies invoicing the public sector must adhere to specific technical formats and communication channels that support the Peppol standard and structured formats such as UBL or XML.
- Peppol (Pan-European Public Procurement Online) is an EU-wide system for the electronic exchange of business documents and is mandatory in Finland for public sector invoices.
5. Electronic Signatures
Electronic signatures are a common method in Finland to ensure the authenticity and integrity of electronic invoices. Finnish law allows the use of:
- Advanced Electronic Signatures (AES)
- Qualified Electronic Signatures (QES) compliant with the EU eIDAS Regulation.
These technologies ensure:
- Verifiable sender identity.
- Protection against content alterations after the invoice has been issued.
6. Archiving Requirements for Electronic Invoices
In Finland, electronic invoices must be retained for at least 6 years, regardless of whether they are sent to the public or private sectors. Key archiving requirements include:
- Readability: Invoices must remain readable and accessible at all times.
- Integrity: Invoice data must be protected against unauthorized changes.
- Accessibility: Stored invoices must be readily retrievable during tax audits or other official investigations.
7. Mandatory Electronic Invoicing for the Public Sector
Since January 1, 2020, all suppliers to the Finnish public administration are required to issue and submit electronic invoices. Key points include:
- All companies supplying goods or services to the public sector must use the eLasku platform.
- Invoices must comply with the formal standards of the platform and use structured formats such as UBL or XML.
For private companies that do not issue invoices to the public sector, electronic invoicing is not yet mandatory. However, broader requirements for B2B electronic invoicing may be introduced in the future.
Summary of Key Legal Provisions in Finland
- EU VAT Directive (2006/112/EC): Provides the basis for recognizing electronic invoices if authenticity and integrity are ensured.
- Finnish VAT Act (Arvonlisäverolaki): Specifies VAT compliance requirements for electronic invoices in line with EU law.
- Regulation on Electronic Invoicing in the Public Sector: Mandates electronic invoicing for public sector transactions in structured formats such as UBL and XML.
- Peppol Standard: Required for exchanging electronic invoices with the Finnish public administration.
- Electronic Signatures: Used to ensure the authenticity and integrity of invoices.
- Archiving Requirements: Electronic invoices must be stored securely for at least 6 years.
Conclusion
Electronic invoicing is already well-established in Finland, particularly in the public sector. Companies conducting business with the public administration are required to send invoices electronically via the eLasku platform, adhering to the Peppol standard and using structured formats like UBL/XML. There are clear legal requirements for authenticity, integrity, and storage of electronic invoices. While B2B invoicing is not yet mandatory for private companies, Finland’s strong digital infrastructure makes electronic invoicing the norm, and future regulations may expand its mandatory scope.
