E-Invoicing in Finland – For Foreign Companies

An e-invoice is a structured electronic invoice that is sent directly from the billing system to the recipient’s system without any manual intermediate processes, such as printing on paper or sending a PDF file by email. In Finland, the E-Invoice Forum has been promoting the use of e-invoicing for over 20 years. The E-Invoice Forum includes both public sector organizations and private companies. E-invoicing has become highly significant in Finland, as approximately 90% of invoices are processed electronically.

Finland’s e-invoicing infrastructure operates based on the four-corner model. The four-corner model is a method of operation in which four parties are involved in the transmission of e-invoices: the sender, the sender’s intermediary (operator or bank), the recipient’s intermediary (operator or bank), and the recipient. The sender and recipient may be customers of different intermediaries. E-invoices can be sent and received regardless of which service provider the sender and recipient use.

Finland uses both national and EU-level e-invoice formats. The national formats are Finvoice and TEAPPSXML. The latest versions of both formats are interoperable with each other and with the EN 16931 standard.

Link to Finance Finland – Finvoice

Link to Tietoevry TEAPPSXML

It’s important to note that banks only use the Finvoice format, while operators use the TEAPPSXML format but can convert invoices to Finvoice if necessary. Finland aims to transition to the widespread use of invoices that comply with the EN 16931 standard in the near future.

Operators validate invoices sent in the EN 16931 format. For the sender, this means that if the invoice does not meet the validation requirements, it will not be transmitted further. National Schematron validation is based on the requirements of the EN 16931 standard. Validation files related to the Finvoice and TEAPPSXML formats are available for a separate fee.

Finland has a national e-invoice address registry containing up-to-date e-invoice addresses for all Finnish companies and organizations that can send or receive e-invoices. The use of the service is free of charge. It is possible to order access to all addresses through an API for a fee.

The e-Invoice operators and banks upload all the addresses to the registry. If an e-invoice operator wants to publish their clients’ information in the e-invoice address registry, the operator must have operator status in Finland. There is a one-time joining fee for operators to join the registry. The maintenance of the e-invoice address registry is funded by selling download rights. Companies and public sector organizations can purchase one-time or ongoing download rights.

The e-invoice address registry has been implemented by operators and banks, and later joined by the State Treasury in Finland, acting as the national Peppol authority.

Link to the e-invoice address registry

As of the end of 2024, the number of Peppol invoices among all e-invoices is still very low. However, the growth is expected to accelerate, and the number of invoices is likely to increase. The State Treasury serves as the national Peppol Authority in Finland, managing Finland’s national ACL registry.

Link to the State Treasury’s website

The national ACL registry contains Peppol addresses and capabilities only of Finnish public sector organizations and companies. Public sector organizations are mandated by the authority to place their Peppol information in the national ACL registry. In Finland, the use of the ICD code 0216 is mandatory for Peppol addresses.

An integration has been implemented between the national ACL registry and the national e-invoice address registry. This means that the Peppol addresses and capabilities of organizations and companies can be searched in the national e-invoice address registry.

Link to the e-invoice address registry

Sending e-invoices from outside Finland to Finnish organizations or companies is possible if the foreign company has an agreement for sending e-invoices with a local operator that, in turn, has an intermediary agreement with an operator or bank operating in Finland, which acts as the e-invoicing service provider for the invoice recipient.

Operators operating in Finland must have operator status, though this is not a legal requirement. Operator status and compliance with operator criteria, i.e., common rules of conduct, create a secure and smooth network for the transmission of e-invoices, preventing harmful use. The operator status is granted by the E-Invoice Forum’s operator and steering group.

If a foreign operator wishes to operate in Finland, the operator must familiarize themselves with the “Requirements of the four-corner model — responsibilities of the operators” and “The operator criteria” found on the TIEKE website.

Four-corner model – Obligations to the Parties

Operator Criteria

The applicant must submit a free-form document explaining how they meet the operator criteria. The document is to be sent to [palaute@tieke.fi]. After submission, the E-Invoice Forum’s operator group reviews the application and may request additional information if needed. Once the operator group has approved the application, it is further processed by the E-Invoice forum’s steering group, which grants the operator status.

Once the operator has received operator status, and to start transmitting e-invoices, the operator must enter into intermediary agreements with other intermediaries (operators and banks). There is no specific form for a intermediary agreement; it is a bilateral document between the parties.