Finnish law 241/2019 According to the law, not every invoice submitted to a Finnish company will automatically become an e-invoice. However, a procurement authority (hankintayksikkö, or public sector contracting authority) or an entrepreneur with an annual turnover exceeding 10,000 euros (elinkeinonharjoittaja) will have the right, as of 1 April 2020, to request an invoice from another party in the same circle. As an e-invoice that complies with the European standard. This means: if your Finnish customer (company, municipality or state agency) exercises this right, it is no longer enough to send a PDF invoice by email. You must be able to provide a technically correct e-invoice. If the customer does not ask for anything, the previous habits continue to apply.
Who has the right to request an e-invoice and when is it valid?
The rule is simpler than it seems at first glance. From From April 1, 2020 A contracting authority or an e-commerce operator may ask another contracting authority or e-commerce operator to send an invoice to it as an e-invoice. This is a right to request, not an automatic obligation. An invoice does not automatically become an e-invoice, but only if the other party specifically requests it.
However, the law is not unlimited. If the use of e-invoices would reveal confidential information or jeopardize the protection of Finland's essential security interests, this right of claim will not apply. This exception applies primarily to security and defense procurement, not to ordinary B2B sales.
Who can request an e-invoice and from whom?
The law speaks of two parties: the procurement authority (hankintayksikkö) and the entrepreneur (elinkeinonharjoittaja). A procurement authority is a public sector entity within the meaning of Finnish public procurement law – a ministry, a local government, a state agency or another contracting authority. An entrepreneur is any business or professional activity whose annual turnover exceeds 10,000 euros. Turnover that is exactly at the limit is not yet covered by the law, because the threshold must be exceeded, not simply reached.
It is important to understand what the law does NOT cover: ordinary consumers. If you sell goods or services to a private individual, that customer cannot request an e-invoice based on this law. The State Office explains, that consumers would rather receive invoices in their online bank, rather than as a structured e-invoice. Law 241/2019 only regulates inter-organizational and public sector invoicing.
Why are public sector bills a tougher case?
The right of a B2B buyer to request an e-invoice and the obligation of the public sector to accept e-invoices are two different things. They are often confused. Section 3 of the Act obliges contracting authorities to accept and process e-invoices that comply with European standards in all procurements and concessions falling under the Public Procurement Act. This obligation entered into force for central government agencies and central purchasing bodies. April 1, 2019 and all other procurement authorities, including municipalities and their units, one year later, April 1, 2020.
In practice, this means that if you sell goods or services to a Finnish city, local authority or ministry, they have been ready to accept and process e-invoices for some time. This applies regardless of whether they specifically ask you for an e-invoice or not. The State Office confirms, that this commitment is part of a broader goal to automate public and private sector billing.
Is a PDF invoice in an email an e-invoice?
This is the most common misunderstanding. An e-invoice, or e-invoice, is a structured, machine-readable document that goes directly into financial management software or an online bank, not as an image that a person reads on a screen. The State Treasury says it directly.: Invoices in PDF or image format sent as an email attachment are not an online invoice, no matter how correct they look.
The technical basis for a legal e-invoice is European e-invoicing standard EN 16931-1:2017, which the European Commission published with a list of permitted message formats (syntax). In practice, the two main formats are UN/CEFACT Cross Industry Invoice and UBL. In Finland, the Finvoice 3.0 and TEAPPSXML 3.0 formats are predominantly used, but they comply with the European standard only if the requisites are filled in correctly. The format itself does not automatically guarantee compliance.
What to do if a customer asks for an e-invoice?
When a Finnish customer says they only want invoices as e-invoices, manual work will soon be behind them. The only question is how quickly you can get it ready.
- Ask for the customer's e-invoice address. Before making any changes, find out the customer's exact billing information, e-invoice receiving address, and operator ID.
- Check your software. If you already use accounting software or ERP, check with your service provider whether it supports e-invoicing according to the European standard. Not all Finvoice or TEAPPSXML solutions do this automatically.
- If there is no software, choose the fast path. You can implement an invoicing program that supports e-invoices or use a portal provided by the client, if larger organizations allow this for suppliers.
- Send the invoice again correctly. If the first invoice was sent as a PDF in an email, it is not considered completed. The invoice must be created and sent again as a structured e-invoice, not attached to a new email with the same file.
What are three typical situations?
Imagine that you are presenting 1,200 euro bill To a Finnish limited liability company (OY) whose annual turnover definitely exceeds 10,000 euros. If this customer explicitly requests an e-invoice, they have a legal right to do so and you must be able to respond. There is no response in the PDF email..
Second situation: you present 700 euro bill To the Finnish municipality. There is no need for the client to ask anything here. The municipality is already From April 1, 2020 are required to accept and process e-invoices, so it makes sense to send an e-invoice right from the start.
Third situation: Your own company's annual turnover is less than 10,000 euros. In this case, your company does not meet the definition of an e-commerce trader under the law and a Finnish customer cannot request an e-invoice from you based on this specific law, although many larger customers request it anyway due to their internal rules, regardless of the legal obligation.
What might change next?
Finland's current rule (right to claim, not automatic obligation) is not set in stone. The State Office organized A public consultation on three possible models for regulating e-invoices, Peppol procurement messages and e-receipts was held from 2 February to 13 March 2026, receiving 47 responses. The consultation itself is not related to the ongoing draft law and the collection of opinions does not mean that a broader e-invoice obligation is already coming. The material will now go to the ministries for further assessment.
In parallel, the European Union level is moving at its own pace. ViDA Directive (EU) 2025/516 will introduce the use of structured e-invoices in cross-border transactions from 1 July 2030, a ten-day invoicing period for covered transactions, and a requirement that an e-invoice that complies with the EN standard no longer needs to be separately approved by the recipient, whether a business or a public legal entity. This means that in 2030, cross-border e-invoice acceptance will become the norm in the European Union, not the exception. For a Finnish business, this means that B2B e-invoice readiness is no longer just a matter for the Finnish internal market, but will become an obligation wherever you operate cross-border in the European Union.
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.