facturación electrónica en Finlandia: Ley 241/2019, EN 16931 y lista de comprobación de implementación

An e-invoice is an electronic invoice sent in a structured format, which is transferred directly from the sender's system to the recipient's system without manual processing.

An e-invoice is not the same as an email invoice or a PDF invoice. The key difference:

• E-invoice: structured data (e.g., Finvoice, TEAPPSXML, Peppol BIS), machine-readable
• PDF invoice: an image of an invoice, requires manual processing or OCR reading
• Email invoice: PDF as an email attachment – does not meet e-invoice requirements

The Act on Electronic Invoicing for Contracting Entities and Business Operators (241/2019) came into force on 1.4.2020. It is based on EU Directive 2014/55/EU.

The key content of the Act:

• Invoices sent to the public sector (state, municipalities, joint municipal authorities) must be e-invoices
• The recipient must be able to receive e-invoices compliant with the EU standard (EN 16931)
• A business operator has the right to request an e-invoice from another business operator
• The Act does not yet mandate all private sector invoicing to be e-invoices, but the direction of development is clear

EN 16931 is the common EU standard for the data content of an e-invoice. It defines what information an e-invoice must contain and in what format.

In practice, EN 16931 means that a Finnish e-invoice is compatible with a German, French, or Spanish system – as long as both comply with the same standard.

In Finland, the most common e-invoice formats are Finvoice (used by banks) and TEAPPSXML (used by operators). Both are EN 16931 compliant.

1. Choose invoicing software that supports e-invoicing (e.g., Eemel Invoicing)
2. Obtain an e-invoicing address (OVT ID or Peppol identifier)
3. Enter into an agreement with an e-invoicing operator (or use the invoicing software's built-in operator)
4. Update your invoice template to include all statutory information
5. Test sending an e-invoice to a few customers
6. Communicate your e-invoice address to customers and update it in TIEKE's e-invoice address registry

• E-invoice address not registered: customer cannot find your address
• Mandatory information missing from invoice template: invoice recipient will reject it
• VAT identifier not correctly marked: in EU trade, an incorrect identifier causes problems
• PDF invoice is mistaken for an e-invoice: a PDF in an email is not an e-invoice
• Operator agreement missing: invoice will not move through the operator network

A five-person renovation company received its first public sector contract from a municipality. The invoice had to be sent as an e-invoice – otherwise, it would not have been accepted.

The company started using Eemel Invoicing, which has e-invoicing built-in:

1. An e-invoice address was automatically created during implementation
2. The invoice was sent directly to the municipality's system in Finvoice format
3. Payment was received in 7 days (previously 21 days with paper invoices)

Now the company sends all its invoices as e-invoices – even to private customers' online banks.

This article is general in nature and does not constitute legal advice.