E-invoicing in Finland: Law 241/2019, EN 16931, and an implementation checklist

An e-invoice is an electronic invoice sent in a structured format, which transfers 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. 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.

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 has the right to request an e-invoice from another business
• The Act does not yet mandate e-invoicing for all private sector invoicing, but the trend 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 identifier)
3. Enter into an agreement with an e-invoice operator (or use the invoicing software's built-in operator)
4. Update your invoice template to include all statutory information
5. "Test sending e-invoices to a few customers"
6. "Inform your customers of your e-invoicing address and update it in TIEKE's e-invoicing address directory"

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

"A five-person renovation company won 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 adopted Eemel Invoicing, which has e-invoicing built-in:"

1. "E-invoicing address was automatically created upon implementation"
2. "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 via their online bank."

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