E-fakturering i Finland: lag 241/2019, EN 16931 och en checklista för implementering

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 attached to an email – does not meet the requirements of an e-invoice

The Act on Electronic Invoicing for Contracting Entities and Businesses (241/2019) came into force on April 1, 2020. It is based on EU Directive 2014/55/EU.

Main content of the law:

• 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 has the right to request an e-invoice from another business
• The law does not yet mandate e-invoicing for all private sector invoicing, 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-invoice address (OVT ID or Peppol ID)
3. Sign 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. Inform your customers of your e-invoice address and update it in TIEKE's e-invoice address directory

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

A renovation company of five people received its first public sector contract from the 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. The e-invoice address was created automatically upon implementation
2. The invoice was sent directly to the municipality's system in Finvoice format
3. Payment was received in the account within 7 days (previously 21 days with paper invoices)

Now the company sends all its invoices as e-invoices – even to private customers via their online bank.

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