Finland Act 241/2019 doesn't automatically turn every invoice sent to a Finnish company into an e-invoice. But since 1 April 2020, a contracting authority (hankintayksikko, meaning a public-sector buyer under Finnish procurement law) or a business owner (elinkeinonharjoittä) whose annual turnover exceeds €10,000 has the right to require that another party in that same category send an invoice as a proper European standard e-invoice. In practice, that means this: if your Finnish client, whether a company, a municipality, or a state body, chooses to use this right, emailing a PDF invoice no longer meets the request. You need to be able to issue a technically correct e-invoice instead. If the client doesn't ask, your existing routine keeps working exactly as before.

Who has the right to demand an e-invoice, and when does it apply?

The rule is simpler than it first sounds. Since 1 April 2020, a contracting authority or a business owner can ask another contracting authority or business owner to send an invoice specifically as an e-invoice. This is a right to request, not an automatic obligation. An invoice does not become an e-invoice on its own. It only becomes one when the other party specifically asks for it.

The law isn't unlimited, though. If using an e-invoice would expose confidential information or threaten Finland's essential security interests, the right to demand one does not apply. That exception mainly concerns security and defense procurement, not ordinary B2B sales.

Who can demand it, and from whom?

Two categories the law defines

The act deals with two types of parties: contracting authorities (hankintayiksku) and business owners (elinkeinonharjoittä). A contracting authority, in the sense Finnish procurement law uses the term, is a public-sector entity: a ministry, a municipality, a state agency, or another body subject to procurement rules. A business owner, meanwhile, is anyone carrying out business or professional activity whose turnover for the financial year exceeds €10,000. Turnover sitting exactly at that line doesn't count yet. The threshold has to be exceeded, not just reached.

Where the law stops: consumers

It's worth being clear about what the law does note cover: ordinary consumers. If you sell goods or services to a private individual, that customer has no basis under this act to demand an e-invoice. The Finnish State Treasury explains that consumers generally receive invoices through their own online banking rather than as a structured e-invoice. Act 241/2019 governs invoicing between organizations and with the public sector only, not consumer billing.

Why is the public sector a tougher case?

A B2B buyer's right to ask for an e-invoice and a public body's obligation to receive one are two different things, and they get mixed up constantly. Section 3 of the act requires contracting authorities to accept and process European-standard e-invoices for every procurement and concession covered by Finnish procurement law. That obligation took effect for central government bodies and central purchasing agencies on 1 April 2019, and for every other contracting authority, including municipalities and their entities, a year later, on 1 April 2020.

What this means if you sell to the public sector

In practice, if you sell to a Finnish city, a local authority, or a ministry, that buyer has already been required to accept and process e-invoices for some time, regardless of whether they specifically ask you for one. State Office confirms that this obligation sits inside a broader push to automate invoicing between the public and private sectors.

Is a PDF invoice sent by email an e-invoice?

This is the most common misunderstanding. A verkollasku (the Finnish term for e-invoice) is a structured, machine-readable document that flows directly into accounting software or online banking, not an image a person reads on a screen. The State Office states this plainly: a PDF or image-format invoice attached to an email is not an online invoice, no matter how correct it looks.

The technical backbone of a legally valid e-invoice is the European e-invoicing standard EN 16931-1:2017, published by the European Commission together with a list of permitted message formats (referred to as “syntaxes”). In practice, there are two main formats: UN/CEFACT Cross Industry Invoice and UBL. In Finland, the formats most commonly used are Finvoice 3.0 and TEAPPSXML 3.0, but these only meet the European standard if the required data fields are filled in correctly. The format alone does not guarantee compliance.

What should you do if a client asks for an e-invoice?

Once a Finnish client tells you they want invoices only as e-invoices, manual work is on its way out. The only question is how fast you can get there.

  • Get the client's e-invoice address. Before changing anything, confirm the client's exact billing details, their e-invoice receiving address, and their operator ID.
  • Check your own software. If you already use accounting software or an ERP system, ask the provider whether it can generate e-invoices to the European standard. Not every Finvoice or TEAPPSXML setup does this automatically.
  • No software yet? Take the fast route. You can adopt an invoicing tool that supports e-invoices, or use a portal the client offers, since many larger organizations give suppliers that option directly.
  • Reissue the invoice properly. If the first invoice went out as a PDF by email, that doesn't satisfy the request. It needs to be recreated and sent again as a structured e-invoice. Attaching the same file to a new email won't do.

Three situations you're likely to run into

The private sector client

Imagine you issue a €1,200 invoice to a Finnish limited company (OY) whose annual turnover is comfortably above €10,000. If that client explicitly asks for an e-invoice, they have the legal right to do so, and you need to be able to respond accordingly. A PDF by email is not a valid answer.

The municipality

Now say you send a €700 invoice to a Finnish municipality. Here, the client doesn't even need to ask. The municipality has already been obliged, since 1 April 2020, to accept and process e-invoices, so it makes sense to send an e-invoice from the outside, without waiting to be asked.

Your own turnover under the threshold

Or say your own company's annual turnover is under €10,000. In that case, your business doesn't meet the law's definition of elinkeinonharjoittät, and a Finnish client can't invoke this specific act to demand an e-invoice from you. Plenty of larger clients will ask for one anyway, simply because of their own internal procurement rules, independent of any legal obligation.

What might change next?

Finland's own consultation

Finland's current setup, a right to request rather than a blanket mandate, isn't fixed in stone. The State Office ran a public consultation from 2 February to 13 March 2026 there are three possible models for regulating e-invoices, Peppol procurement messages (Peppol being the pan-European network standard for exchanging structured business documents), and e-receipts, receiving 47 responses. The consultation itself isn't tied to any pending bill, and collecting feedback doesn't mean a broader e-invoice mandate is imminent. The material has now been passed to the relevant ministries for further review.

The EU deadline is coming in 2030

At the same time, the EU level is moving on its own timeline. The ViDA Directive (EU) 2025/516, short for VAT in the Digital Age, brings, from 1 July 2030, mandatory structured e-invoicing for cross-border transactions, a ten-day invoice-issuance deadline for those transactions, and a rule that a business or public-sector recipient can no longer separately approve an EN-compliant e-invoice before accepting it. In effect, cross-border e-invoice acceptance across the EU becomes the standard practice in 2030, not the exception. For a Finnish business, that means B2B e-invoicing readiness stops being a purely domestic Finnish question. It becomes a requirement wherever you trade across borders within the EU.

FAQ

Will a Finnish invoice automatically become an e-invoice?

No. Finnish Act 241/2019 does not automatically convert every invoice into an e-invoice. An invoice will only become an e-invoice if the contracting authority or the economic operator specifically requests it.

Who has the right to request an e-invoice in Finland?

An e-invoice can be requested by a procurement authority (hankintayksikkö) and a business operator with an annual turnover exceeding 10,000 euros. The law does not cover ordinary consumers who prefer to use their online bank for invoices.

Is a PDF email an e-invoice within the meaning of the law?

No. An invoice in PDF or image format as an attachment to an email is not an e-invoice. A legal e-invoice must be structured and comply with the European e-invoice standard EN 16931-1:2017.

Was the acceptance of public sector e-invoices mandatory from 2020?

Yes, the timeline for the obligation is phased. Central government agencies and the central purchasing body had to achieve compliance on 1 April 2019, other procurement authorities, including municipalities, on 1 April 2020.