COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report Country Chapter on the rule of law situation in Finland Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2023 Rule of Law Report The rule of law situation in the European Union
Date: 2023-07-05
Institutions: European Commission, Secretariat-General
Subjects: Finland, administrative transparency, corruption, democracy, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.7.2023  SWD(2023) 826 final  COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report      Country Chapter on the rule of law situation in Finland Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2023 Rule of Law Report                     The rule of law situation in the European Union {COM(2023) 800 final} - {SWD(2023) 801 final} - {SWD(2023) 802 final} - {SWD(2023) 803 final} - {SWD(2023) 804 final} - {SWD(2023) 805 final} - {SWD(2023) 806 final} - {SWD(2023) 807 final} - {SWD(2023) 808 final} - {SWD(2023) 809 final} - {SWD(2023) 810 final} - {SWD(2023) 811 final} - {SWD(2023) 812 final} - {SWD(2023) 813 final} - {SWD(2023) 814 final} - {SWD(2023) 815 final} - {SWD(2023) 816 final} - {SWD(2023) 817 final} - {SWD(2023) 818 final} - {SWD(2023) 819 final} - {SWD(2023) 820 final} - {SWD(2023) 821 final} - {SWD(2023) 822 final} - {SWD(2023) 823 final} - {SWD(2023) 824 final} - {SWD(2023) 825 final} - {SWD(2023) 827 final}  
 
 
ABSTRACT 

The perceived independence of the Finnish justice system remains at a very high level. The 
National Courts Administration continues its work in developing initiatives and supporting the 
work on courts, namely through expanding its activities, organising meetings and engaging in 
a variety of projects. A working group set up by the Ministry of Justice proposed constitutional 
amendments to strengthen judicial independence and a new working group was set up to follow 
up on these proposals. In November 2022 and for the first time, the Government has submitted 
to Parliament a Report on the Administration of Justice. As identified in that report, resources 
for the justice system have been increased, while structural  shortages  remain.  The National 
Courts  Administration  has  received  additional  funding  for  the  development  of  the  case 
management systems.  

The perception among experts and business executives is that Finland is one of the least corrupt 
countries  in  the  world.  The  majority  of  actions  foreseen  in  the  National  Anti-Corruption 
Strategy  and  Action  Plan  2021-2023  have  started.  Work  is  ongoing  on  a  draft  proposal  on 
trading  in  influence  to  continue  to  strengthen  the  criminal  legal  framework  related  to 
corruption, while a decision on revising the legislation on bribery is pending. The Ministry of 
Justice has conducted an analysis of the legal framework on ministerial responsibilities. The 
Transparency Register Act  will enter into force on 1 January  2024. The  Parliament did  not 
conclude discussions on a proposal on limiting ‘revolving doors’ for Ministers before the end 
of  the  parliamentary  term.  While  civil  servants  and  persons  entrusted  with  top  executive 
functions are covered by the Code of Conduct, Ministers are still not covered. The Government 
presented a proposal to develop transparency in electoral and party funding legislation. 

Finland  generally  offers  a  free  and  protected  environment  for  journalists  and  media 
professionals. There are no regulatory changes concerning the media regulators or the Finnish 
public service broadcaster. Ethical  rules for the  press  are currently being reviewed, and the 
resources of the self-regulatory Finnish Council for Mass Media have been strengthened while 
it  continues  to  deal  with  a  rising  number  of  complaints  about  journalistic  ethics.  The 
specifically  appointed  working  group  dedicated  to  reform  of  the  Act  on  the  Openness  of 
Government Activities presented a proposal for urgent reform of the Act aimed at clarifying 
exceptions relating to documents in criminal proceedings. However, the proposal was not yet 
adopted due to the end of the Parliament’s mandate. The working group is expected to report 
on  the  overall  reform  in  late  autumn  2023.  The  government  has  prepared  legal  reforms  to 
address the harassment of journalists online. 

A new guide on fundamental and human rights impact assessments in drafting legislation has 
been published in November 2022. Generally, involvement of stakeholders in the legislative 
process remains meaningful, with some discrepancies reported. A targeted amendment to the 
Emergency Powers Act  was adopted, with  a more comprehensive reform pending. The law 
clarifying  the  division  of  powers  between  the  Chancellor  of  Justice  and  the  Parliamentary 
Ombudsman  has  entered  into  force.  Amendments  to  improve  the  model of  funding  of  civil 
society organisations were approved by the Parliament. 

1 

 
 
RECOMMENDATIONS 

Overall, concerning the recommendations in the 2022 Rule of Law Report, Finland has 
(made): 

  Fully implemented the recommendation to continue developing initiatives by the National 

Courts Administration to support the work of courts. 

  Some progress on continuing to strengthen the criminal legal framework on corruption, in 

particular, by the adoption of legislation on trading in influence. 

  Significant progress on continuing efforts to implement the new National Anti-corruption 
Strategy  and  Action  Plan  2021-2023,  including  by  starting  the  implementation  of  all 
planned measures. 

  Some  progress  on  continuing  the  reform  of  the  Act  on  the  Openness  of  Government 
Activities  to  ensure  effective  and  wider  access  to  documents  taking  into  account  the 
European standards on access to official documents. 

On this basis, and considering other developments that took place in the period of reference, it 
is recommended to Finland to 

  Continue to follow-up on the report on the assessment and future development trends of 
the court system, including the reform of the appointment of lay judges, taking into account 
European standards on judicial independence. 

  Adopt legislation on trading in influence and continue to take steps to propose a revision 

on the criminal offence of foreign bribery. 

  Strengthen  the  integrity  and  accountability  framework  applicable  to  ministers  and  other 
persons entrusted with top executive functions by adopting a code of conduct for them. 
  Advance with the reform of the Act on the Openness of Government Activities to ensure 
effective and wider access  to  documents taking into  account  the European standards on 
access to official documents. 

2 

 
 
 
 
I. 

JUSTICE SYSTEM  

The Finnish justice system  is  composed of the ordinary  judiciary, with  20 district  courts, 5 
courts of appeal and the Supreme Court, as well as the administrative judiciary with 6 regional 
administrative  courts  and  the  Supreme  Administrative  Court.  There  are  three  specialised 
courts1. The independent National Courts Administration is in charge of the administration of 
courts,  including  management  of  budgets,  buildings  and  ICT  systems2.  The  independent 
Judicial  Appointments  Board3  prepares  proposals  for  appointments  of  judges  to  the 
Government, while proposals for Supreme Court and Supreme Administrative Court judges 
are made by these courts themselves4. Judges are formally appointed by the President of the 
Republic5.  The  National  Prosecution  Authority  is  an  independent  state  authority6,  led  by  a 
Prosecutor General, who is appointed by the President on the proposal of the Ministry of Justice 
and can be dismissed or suspended by the Government7. The Finnish Bar Association8 is an 
independent  body  tasked  with  the  supervision  of  professional  activities  of  attorneys9. 
Disciplinary  proceedings  against  lawyers10  are  conducted  by  the  Disciplinary  Board,  an 
independent  supervisory  body  functioning  alongside  the  Finnish  Bar  Association11.  Finland 
participates in the European Public Prosecutor’s Office (EPPO)12. 

Independence  

The level of perceived judicial independence in Finland continues to be very high both 
among the general public and companies. Overall, 86% of the general population and 88% 
of companies perceived the level of independence of courts and judges to be ‘fairly or very 
good’  in  202313.  According  to  data  in  the  2023  EU  Justice  Scoreboard,  the  level  remains 

1   The Market Court,  the  Labour Court and the Insurance Court.  CEPEJ (2021), Study on the functioning of 

judicial systems in the EU Member States. 

2   Courts Act, Chapter 19a, National Courts Administration. 
3   It has twelve members – nine judges from different levels of courts, proposed by the judiciary, and three non-
judge  members  (one  lawyer,  one  prosecutor,  one  member  representing  legal  research  and  education).  All 
members are appointed by the Government for a five-year term. 

4   All judges of the Supreme Court and Supreme Administrative Court participate to the selection. Courts Act, 

Chapter 11, Section 7. 

5   Only one candidate is proposed per vacancy. While the proposal is non-binding, in practice, it is almost always 
followed, with only one exception each for ordinary court judges (in 2000, the year the Judicial Appointments 
Board was established) and for Supreme Court judges (in the 1970s). 
6   Act on the National Prosecution Authority (32/2019), Chapter 1, Section 2. 
7   The decision to dismiss can be appealed to the Supreme Administrative Court. 
8   Advocates Act (496/1958). 
9   There are three types of legal professionals tasked with provision of different types of legal services: attorneys, 

public legal aid attorneys and licensed legal counsels. 

10   The Disciplinary Board also conducts disciplinary proceedings against two other types of legal professionals, 

public legal aid attorneys and licensed legal counsels. 

11   The Disciplinary Board is composed of a Chair and eleven Members, six of which, in addition to the Chair, 
are attorneys elected by the supreme decision-making body of the Bar Association. The remaining members, 
two of which are licenced legal counsels and three of which are lawyers, who shall be non-members of the bar 
association, are appointed by the Government on the proposal of the Ministry of Justice after the Ministry has 
requested an opinion of the Bar Association on the eligibility of candidates; Sec. 7a of the Advocates Act. 
12   One European delegated prosecutor was appointed on 1 July 2021, the other was nominated on 14 October 
2021 and appointed in October 2022. Input from Finland for the 2022 Rule of Law Report, p. 17 and additional 
written input from Finland in 2023.  

13   Figures 50 and 52, 2023 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as follows: very low (below 30% of respondents perceive judicial independence as fairly good and very good); 
low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

3 

 
                                                           
consistently very high for both the general public and companies since 2016. The perceived 
judicial independence among the general public has decreased in comparison with 2022 (88%), 
but it is higher than in 2016 (80%). The perceived judicial independence among companies has 
increased slightly in comparison with 2022 (87%) as well as 2016 (87%).  

The National Courts Administration continues its activities to facilitate the work of the 
courts.  The  2022  Rule  of  Law  Report  recommended  to  Finland  to  “continue  developing 
initiatives by the National Courts Administration to support the work of courts”14. The National 
Courts  Administration  (NCA)  has  continued  in  its  tasks  throughout  202215,  namely  in 
conducting regular meetings with heads of courts, developing the case management systems 
for  administrative  and  general  courts16,  organising  trainings  for  judges  and  other  training 
events, or cooperating with national and international providers and networks17. Additionally, 
the NCA has  started to  organise meetings with  court administrators, courts’ data protection 
officers,  and persons responsible for risk management and proceeded to  build the networks 
with other actors in the justice system, such as public prosecutors or Legal Register Centre18. 
It is also developing a tool for measuring the workload of the courts to foster better distributing 
resources between them19. The NCA is an active participant in various projects and publishes 
statistics  on  its  website,  which  helps  improving  public  statistics  related  to  courts20. 
Stakeholders continue to welcome such initiatives and activities21. In light of the significant 
activities undertaken by the NCA to facilitate the work of the courts, the recommendation made 
in the 2022 Rule of Law report has been fully implemented. 

A Ministry of Justice working group proposed constitutional amendments to strengthen 
judicial independence. A working group22 set up by the Ministry of Justice published its report 
on the assessment and future development trends of the court system in October 202223. The 
working  group  defined  three  key  objectives:  i)  strong  independence,  ii)  high-quality  legal 

14   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4. 
15   The NCA is a body responsible for strengthening the structural autonomy and independence of the courts, as 
well as reinforcing the quality of the administration of justice. For more information on the establishment and 
structure see the Country Chapter on the rule of law situation in Finland for the following reports: 2020 Rule 
of Law Report; the 2021 Rule of Law Report; and the 2022 Rule of Law Report, p. 2, p. 3 and p. 4 respectively. 
16   Input from Finland for the 2023 Rule of Law Report, p. 6; Information received from the NCA in the context 

of the country visit to Finland. 

17   Input from Finland for the 2023 Rule of Law Report, pp. 7, 9 and 10. 
18   Ibid, p. 6; Information received from the NCA in the context of the country visit to Finland. 
19   Input from Finland for the 2023 Rule of Law Report, p. 9; Information received from the NCA in the context 

of the country visit to Finland. 

20   The website with statistics available online at: 

https://oikeus.fi/tuomioistuimet/en/index/tuomioistuinlaitos/statistics.html;  Input  from  Finland  for  the  2023 
Rule of Law Report, p. 8. 

21   Contribution from the Finnish Bar Association for the 2023 Rule of Law Report, p. 11 and from the Chancellor 
of Justice, p. 11; Information received from the Finnish Association of Judges in the context of the country 
visit to Finland. 

22   The members of the working group ranged from representatives of the Ministry of Justice, the highest courts 
as well as courts of appeal and district courts, administrative courts, of the Office of the Prosecutor General, 
Finnish Bar Association, legal advisers and administrative assistants. The report on the assessment and future 
development trends of the court system, p. 10.  

23   The report on the assessment and future development trends of the court system by the Ministry of Justice; 

Input from Finland for the 2023 Rule of Law Report, p. 8. 

4 

 
 
 
                                                           
 
protection, and iii) user-orientation24. As a measure to foster strong independence, it proposes 
a  revision  of  the  Constitution  to  introduce  safeguards  against  potential  undue  influence25. 
Laying down the maximum number of Supreme Court judges in the Constitution, as well as a 
compulsory retirement age of judges, are among the proposed measures26. As a follow-up to 
the report, a new working group entitled ‘Rule of Law Guarantees and Development of the 
Judicial System’ was appointed by the Ministry of Justice in January 2023 to further strengthen 
the independence of the administration of justice, to promote the provision of high-quality legal 
protection and user-oriented approach in the administration of justice. This working group is 
expected to deliver proposals by the end of 202727. Stakeholders have generally welcomed this 
debate and assess the potential changes of the Constitution positively28. 

A reform of the appointment of lay judges is being discussed. Currently, lay judges, who 
participate in certain29 and serious criminal cases, where the maximum penalty of an offence 
is  more  than  two  years  of  imprisonment  (in  a  panel  of  one  professional  judge  and  two  lay 
judges)30,  are  appointed  by  political  parties,  with  the  number  of  lay  judges  each  party  may 
appoint corresponding to the outcome of the local elections31. This matter was examined by 
GRECO  in  the  past32  and  is  currently  subject  to  discussion33.  While  it  is  generally 
acknowledged that there is a long tradition of employing lay judges in deciding cases, some 
stakeholders call for reducing the political influence in the appointment34, others consider this 
model  to  be  inefficient35  and  causing  risks  to  the  outcome  of  the  case,  due  to  the  lack  of 
professionalisation36. The report on the assessment and future development trends of the court 
system  concluded  that  the  whole  appropriateness  of  the  lay  judges’  system  should  be 

24   The report on the assessment and future development trends of the court system, p. 12; Input from Finland for 
the 2023 Rule of Law Report, p. 14; Information received from the Ministry of Justice in the context of country 
visits in Finland. 

25   The report on the assessment and future development trends of the court system, pp. 12, 18, 97, 126, 127 and 

146. 

26   Ibid, p. 127. 
27   Ministry of Justice’s appointment decision: ‘Rule of Law Guarantees and Development of the Judicial System’ 

working group, No. VN/34680/2022-OM-12, pp. 1 – 2.  

28   Contribution from the Finnish Bar Association for the 2023 Rule of Law Report, p. 11; Information received 

from the NCA and the Supreme Administrative Court in the context of the country visit to Finland. 

29  So-called  land  law  mattersdeal  with  disputes  and  appeals  arising  from  real  estate  transactions;  information 
provided 
at: 
the 
https://oikeus.fi/tuomioistuimet/en/index/tuomioistuinlaitos/tuomioistuimet/yleisettuomioistuimet/karajaoike
udet/whatmattersaredealtwithbythedistrictcourt.html#. 

judiciary, 

available 

website 

Finnish 

the 

of 

at 

30   CEPEJ Evaluation Report 2022 – Country Profile Finland, p. 49.  
31   There  are  no  lay  judges  in  appeal  courts,  administrative  courts,  supreme  courts  nor  specialised  courts. 

Assessment report on the procedure for selecting lay judges by the Ministry of Justice, p. 8. 

32   GRECO Fourth evaluation round, paras. 94, 101. It encourages Finnish authorities to seek ways to involve the 

judiciary in the appointment of lay judges, in light of the concerns raised by the ombudsperson. 

33   Information received from the Chancellor of Justice, the Finnish Bar Association and the Finnish Association 

of Judges in the context of the country visits to Finland. 

34   Information  received  from  the  Chancellor  of  Justice  in  the  context  of  the  country  visit  to  Finland. 
Oikeuspoliittinen yhdistys Demla ry – Legal Policy Association in Finland (Demla) calls for abolishment of 
the institute of lay judges, information received in the context of the country visit to Finland from Demla. 
35   Information received from the Finnish Association of Judges in the context of the country visit to Finland. 
This argument is raised also in the report on the assessment and future development trends of the court system, 
p. 100. 

36   Some discrepancies in decisions made by lay judges occurred in cases regarding sexual offences, which had 
to  be  corrected  on  appeal  level.  Information  received  from  the  Finnish  Bar  Association  and  the  Finnish 
Association of Judges in the context of the country visit to Finland. 

5 

 
 
                                                           
reassessed37. Subsequently, the Ministry of Justice published an assessment report in February 
2023,  which  examines  various  options  for  the  appointment  procedure  of  lay  judges  and 
concluded that a broader assessment of the system should be made38. The Ministry of Justice 
collected  comments  from  various  stakeholders,  who  also  recognized  the  importance  of  the 
issue39. 

Quality  

For  the  first  time,  the  Government  submitted  to  Parliament  its  Report  on  the 
Administration of Justice. In November 2022, the Government presented to Parliament the 
Report  on  the  Administration  of  Justice  (“the  report”  hereafter),  which  provides  a 
comprehensive overview of the current state of the administration of justice in Finland40. The 
NCA participated in the preparation of the report, and the Chancellor of Justice, courts, as well 
as other stakeholders,  were  consulted41. The key issues identified by the  report concern the 
length  of  proceedings,  high  cost  of  trials,  and  the  underfunding  of  the  justice  system  (see 
below)42. Parliament held  a general debate on the report in  December 2022 and adopted an 
opinion  in  February  2023,  welcoming  the  efforts  and  urging  the  Government  to  take  an 
immediate  action  on  the  report’s  findings43.  Parliament  has  requested  the  Government  to 
present  a  written  report  by  the  end  of  2023  and  to  submit  a  new  comprehensive  report  by 
September 202644. Stakeholders welcome this report, as it addresses the most pressing issues 
in the justice system45. 

The digitalisation of the justice system is advanced, while room for improvement remains 
in upgrading case management systems. The NCA has received additional funding for the 
development of the two complex case management systems, one for administrative and special 
courts (‘HAIPA’) and one for general courts (‘AIPA’)46. As noted in the 2022 Rule of Law 

37   The report on the assessment and future development trends of the court system, p. 100; Assessment report on 

the procedure for selecting lay judges, p. 40. 

38   Assessment report on the procedure for selecting lay judges by the Ministry of Justice. Information received 
from the Ministry of Justice in the context of country visits to Finland. Written information received from 
Finnish authorities in the context of the country visit to Finland, p. 1. 

39   Evaluation note on the selection of jurors, Summary of the opinions on the assessment report, forthcoming. 
40   Input from Finland for the 2023 Rule of Law Report, p. 5. The Report on the Administration of Justice and 
the  report  on  the  assessment  and  future  development  trends  of  the  court  system  are  substantively 
complementary  one  to  the  other,  however,  each  report  focuses  on  different  aspects  of  the  Finnish  justice 
system. Information received from the Ministry of Justice in the context of the country visit to Finland.  
41   Contribution from the Chancellor of Justice for the 2023 Rule of Law Report, p. 11. Chancellor of Justice has 

issued statement to the Legal Affairs Committee of Parliament, OKV/2823/22/2022. 

42   The report, p. 3; Input from Finland for the 2023 Rule of Law Report, p. 5; Contribution from the Chancellor 
of Justice for the 2023 Rule of Law Report, p. 11. To secure funding for the actors in the judicial system, as 
well as to improve the conditions for providing more consistent and high quality legal aid (by establishing a 
national legal services authority) are among the objectives set out in the new draft Government Programme. 

43   The  Opinion 

of 

the  Legal  Affairs  Committee, 

at 
online 
available 
https://www.eduskunta.fi/FI/vaski/JulkaisuMetatieto/Documents/VNS_13+2022.pdf;  Written 
information 
received from Finnish authorities in the context of the country visit to Finland, p. 1; Information received from 
the Ministry of Justice in the context of country visit to Finland.  

16; 

pp. 

5, 

44   Information received from the Ministry of Justice in the context of the country visit to Finland. 
45   Contribution from the Finnish Bar Association for the 2023 Rule of Law Report, p. 2 and the Chancellor of 
Justice,  p.  11;  Information  received  from  the  Supreme  Court,  the  Supreme  Administrative  Court  and  the 
Parliamentary Ombudsman in the context of the country visit to Finland. 

46   For more information on the development see the 2021 Rule of Law Report, Country Chapter on the rule of 
law situation in Finland, p. 3 and the 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland, p. 4; Input from Finland for the 2023 Rule of Law Report, pp. 6, 11. 

6 

 
 
 
                                                           
Report, the HAIPA system was finalised in 202047, however, it has been used only to a limited 
extent in some courts as a tool by the supporting staff so far, not by the judges48. Due to delays, 
the AIPA system continues to be under development, with the implementation expected to be 
finalised  in  June  202449.  The  introduction  of  the new  system  is  generally  welcomed  by  the 
stakeholders, while some shortcomings, such as the lack of access to the system by lawyers, 
and occasional technical issues, still remain, as already noted in the 2022 Rule of Law Report50. 
Some of these challenges have been addressed by the NCA and a new portal for attorneys and 
other legal representation is currently being prepared and expected to be operational by the end 
of 202351. Moreover, the NCA has also participated in the development of a new system, which 
would  manage  administrative  issues  in  courts  (‘HILDA’)52.  Generally,  the  use  of  digital 
technology by courts and prosecution services is advanced, with a possibility of remote work, 
use  of  electronic  case  management  system  and  availability  of  distance  communication 
technology53. 

To  make  justice  more  accessible,  a  legislative  reform  increased  courts’  discretion  in 
allocating legal costs in civil cases. The Report on the Administration of Justice has suggested 
to  reduce legal  costs and to  examine the possibility to  introduce a simplified trial  for small 
claims proceedings, as measures to tackle the high costs of proceedings54. As a follow-up to 
this  Report,  the  Ministry  of  Justice  has  adopted  an  assessment  memorandum  on  the  small 
claims’ procedure. In January 2023, Parliament approved a reform which provides the courts 
with a wider opportunity to reduce the costs of the losing party in civil cases55. The reform 
entered  into  force  in  May  202356.  The  Bar  Association  has  also  reported  high  costs  of 
proceedings  as  an  issue  having  a  possible  prohibitive  effect  for  the  access  to  justice57.  The 

47   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4.  
48   Input from Finland for the 2023 Rule of Law Report, p. 7. The NCA explained that the reason for the practical 
problems  with  AIPA  and  HAIPA  lies  with  the  complex  nature  of  the  multi-layered  information  and 
communication technology, which needs cooperation between various actors. Moreover, Finland is still in the 
process of transition from the original system from 1990s to the new ones, which demands AIPA and HAIPA 
to be introduced in stages. That is also the reason for the courts and the public prosecution service to be using 
both the old and the new case management systems at the moment. Information received from the NCA in the 
context of a country visit to Finland. Other stakeholders have also pointed out that lack of resources are one 
of the main issues for the implementation of AIPA; information received from the Finnish Bar Association, 
the Supreme Court and the Finnish Association of Judges in the context of the country visit to Finland. 

49   Input from Finland for the 2023 Rule of Law Report, pp. 7, 11. 
50   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4; Contribution from the 
Finnish  Bar  Association  for  the  2023  Rule  of  Law  Report,  p.  16  and  the  Chancellor  of  Justice,  p.  11. 
Information  received  from  the  Finnish  Bar  Association,  the  Chancellor  of  Justice,  the  Supreme  Court,  the 
Supreme Administrative Court and the Association of Judges in the context of the country visit to Finland. 
The Association of District Court Judges has filed a complaint to the National Audit Office concerning the use 
of finances for the AIPA system. The answer is expected to come around September 2023. 

51   Information received by the Ministry of Justice in the context of a country visit to Finland. The service portal 
will be limited in its functionalities in the first implementation phase and significant development is planned 
throughout the year 2024. 

52   Input from Finland for the 2023 Rule of Law Report, p. 6.  
53   Figure 42, 2023 EU Justice Scoreboard. 
54   The  report,  p.  59;  Information  received  from  the  Ministry  of  Justice  in  the  context  of  the  country  visit  to 

Finland. 

55   Information received from the Ministry of Justice in the context of the country visit to Finland.  
56   Act No 3.2.2023/143, amending Chapter 21, Section 8(2) and 8b of the Code of Judicial Procedure. Input from 

Finland for the 2023 Rule of Law Report, p. 8. 

57   Contribution from the Finnish Bar Association for the 2023 Rule of Law Report, p. 15. 

7 

 
                                                           
Ministry of Justice has also commissioned a study on the effects of the law concerning court 
fees, the results of which are expected to be published in July 202358. 

Resources for the justice system have been increased, while structural shortages remain, 
as  identified  by  the  Report  on  the  Administration  of  Justice.  The  Report  on  the 
Administration  of  Justice  has  concluded  that  approximately  EUR  90  million  in  permanent 
annual additional funding would be needed to secure appropriate operating conditions and to 
achieve the objectives set for the administration of justice59, with approximately one third to 
be allocated to the courts60. While the level of financial resources has increased over the past 
years, there are still insufficient resources, mostly at the district and appellate courts61. Lack of 
human,  as  well  as  financial,  resources  has  also  been  reported  as  an  issue  with  the  NCA62. 
Moreover,  some  stakeholders  have  pointed  out  that  the  supporting  staff  working  at  courts 
remains underfunded, which results in lack of human resources and delays in proceedings63. 
The courts have obtained additional funding for the second half of 2022 and 2023 to clear the 
backlog caused by the COVID-19 pandemic64. Additional funding was also provided to the 
public prosecution service for the years 2021 and 2022 to clear the COVID-19 backlog and to 
hire new public prosecutors65. Due to the funding, the numbers of personnel at the prosecution 
service are expected to rise to 613 in 2023, compared to 558 in 202166. Nevertheless, the overall 
number of pending cases in the public prosecution service continues to increase67. 

Efficiency 

The justice system performs overall efficiently, with the Report on the Administration of 
Justice finding some room for improvement as  regards the length  of proceedings.  The 
estimated time to resolve administrative cases slightly increased to 296 days in the first instance 
in 2021 (compared to 274 in 2020)68. The clearance rate for civil and commercial cases at first 
instance improved from 93.6 % in 2020 to 100.3 % in 202169. The justice system performs at 
an average level when it concerns the estimated time to resolve litigious civil and commercial 
cases (305 days in the first instance in 2021, compared to 300 in 2020)70. However, the Report 
on  the  Administration  of  Justice,  as  well  as  several  stakeholders,  found  the  length  of 

58   Input from Finland for the 2023 Rule of Law Report, p. 8; Information received from the Ministry of Justice 

in the context of the country visits to Finland. 

59   The report, p. 5; Input from Finland for the 2023 Rule of Law Report,  p. 9; Contribution from the NCA for 

the 2023 Rule of Law Report, p. 6. 

60   Contribution from the NCA for the 2023 Rule of Law Report, p. 6; Information received from the Supreme 

Court in the context of the country visit to Finland.  

61   Contribution from the NCA for the 2023 Rule of Law Report, p. 6; General issue of lack of resources was 
mentioned  also  in  contribution  from  the  Finnish  Bar  Association  for  the  2023  Rule  of Law  Report,  p. 15. 
Information received from the Supreme Court and the Association of Judges in the context of the country visit 
to Finland.  

62   Information received from the NCA in the context of the country visit in Finland. 
63   Contribution from the NCA for the 2023 Rule of Law Report, p. 7; Information received from the Supreme 

Administrative Court, Finnish Association of Judges in the context of the country visit to Finland. 

64   Input from Finland for the 2023 Rule of Law Report, p. 9. 
65   Input  from  Finland  for  the  2023  Rule  of  Law  Report,  pp.  9,  10;  Information  received  from  the  National 

Prosecution Authority in the context of the country visit to Finland. 

66   Input from Finland for the 2023 Rule of Law Report, p. 10. 
67   Input from Finland for the 2023 Rule of Law Report, p. 9.  
68   Figure 10, 2023 EU Justice Scoreboard. 
69   Figure 12, 2023 EU Justice Scoreboard. 
70   Figure 8, 2023 EU Justice Scoreboard. 

8 

 
 
 
                                                           
proceedings as one of the key problems in the justice system71. The NCA has pointed out that 
one of the reasons for the slight decrease in efficiency is the higher complexity of incoming 
cases72. 

II. 

ANTI-CORRUPTION FRAMEWORK  

The monitoring, detection, and prevention of cases of corruption in Finland relies on multiple 
bodies and authorities. Alongside the Police, the National Bureau of Investigation (NBI) and 
the Prosecution Service, relevant  authorities are  the Financial  Intelligence Unit  (FIU)73, the 
National Audit Office of Finland (NAOF), the Finnish Competition and Consumer Authority 
as well as the Parliamentary Ombudsman74 and Chancellor of Justice75. The authority in charge 
of planning and coordinating anti-corruption activities is the Ministry of Justice’s Department 
of Criminal Policy and Criminal Law, including by coordinating the anticorruption network 
which  brings  together  representatives  of  several  ministries,  police,  trade  unions  and  civil 
society76. 

The perception among experts and business executives is that Finland is one of the least 
corrupt countries in the world. In the 2022 Corruption Perceptions Index by Transparency 
International, Finland scores 87/100 and ranks 2nd in the European Union and globally77. This 
perception  has  been  relatively  stable  over  the  past  five  years78.  The  2023  Special 
Eurobarometer on Corruption shows that 13% of respondents consider corruption widespread 
in  their  country  (EU  average  70%)  and  7%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 24%)79. As regards businesses, 22% of companies 
consider that corruption is widespread (EU average 65%) and 11% consider that that corruption 
is a problem when doing business (EU average 35%)80. Furthermore, 44% of respondents find 
that  there  are  enough  successful  prosecutions  to  deter  people  from  corrupt  practices  (EU 
average 32%)81, while 64% of companies believe that people and businesses caught for bribing 
a senior official are appropriately punished (EU average 30%)82. 

71   The report, p. 11; Contribution from the Chancellor of Justice for the 2023 Rule of Law Report, pp. 11, 16, 

and from the Finnish Bar Association, p. 17, and from the NCA, p. 7. 

72   Input from Finland for the 2023 Rule of Law Report, p. 13.  
73   Financial Intelligence Unit: https://poliisi.fi/en/money-laundering. 
74   Parliamentary Ombudsman of Finland: https://www.oikeusasiamies.fi/en. 
75   Chancellor of Justice: https://www.okv.fi/en/. 
76   The  dedicated  website  of  the  government  on  anti-corruption  (anti-corruption.fi)  details  the  relevant  bodies 

involved in the fight against corruption, as well as their tasks. 

77   Transparency  International  (2023),  Corruption  Perceptions  Index  2022,  pp.  2-3.  The  level  of  perceived 
corruption  is  categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public 
sector corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-
50), high (scores below 50). 

78   In 2018 the score was 85, while, in 2022, the score is 87. The score significantly increases/decreases when it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

79   Special Eurobarometer 534 on Corruption (2023). The Eurobarometer data on citizens’ corruption perception 

and experience is updated every year. The previous data set is the Special Eurobarometer 523 (2022). 

80   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year.  The  previous  data  set  is  the  Flash 
Eurobarometer 507 (2022). 

81   Special Eurobarometer 534 on Corruption (2023). 
82   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). 

9 

 
 
                                                           
Significant progress has been made to implement the majority of the actions planned in 
the National Anti-Corruption Strategy and Action Plan 2021–2023. The 2022 Rule of Law 
Report  recommended  to  Finland  to  “continue  efforts  to  implement  the  new  National  Anti-
corruption Strategy and Action Plan 2021-2023, including by starting the implementation of 
all  planned  measures”83.  The  Action  Plan  of  the  Anti-Corruption  Strategy  for  2021–2023 
included 79 actions. Of the 79 planned measures, 73 started to be implemented84, of which 17 
have  been  completed  and  28  are  well  advanced85.  The  preparation  for  the  next  Strategy  is 
expected to start during 202386. In 2023, Finland aims to increase transparency of the UNCAC 
process  and  of  the  development  of  the  national  anti-corruption  strategy87.  To  improve 
transparency, the Ministry of Justice will rely on the official webpage on anticorruption88. As 
only six actions of the strategy have not started89, and 45 measures have been completed or 
well  advanced,  significant  progress  has  been  made  on  the  implementation  of  the 
recommendation made in the 2022 Rule of Law Report. 

Some  progress  has  been  made  on  strengthening  the  criminal  legal  framework  on 
corruption, as the preparation of the draft proposal on trading in influence is ongoing, 
while a decision on revising the legislation on bribery is pending. The 2022 Rule of Law 
Report recommended to Finland to “continue to strengthen the criminal legal framework on 
corruption,  in  particular  by  the  adoption  of  legislation  on  trading  in  influence”90.  The 
Government presented a draft proposal on trading in influence in summer 2022, which was 
revised taking into account the feedback received from the public consultation. Depending on 
the upcoming Government term, the earliest time to submit the draft proposal in Parliament is 
autumn  202391.  Although  the  National  Prosecution  Authority  is  overall  satisfied  with  the 
content,  it  drew  attention  to  some  issues  that  might  increase  the  difficulties  in  collecting 

83   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
84   Compared  to  the  2022  Rule  of  Law  Report,  five  more  actions  of  the  79  planned  measures  started  to  be 
implemented (65 measures in 2022), four more actions have been completed (nine actions in 2022) and five 
amore earned the status of “well advanced” (22 actions in 2022). 

85   Input from Finland for the 2023 Rule of Law Report, p. 15. This implementation status is based on the fifth 
reporting round of March 2023. As an attachment to the written contribution to the 2023 Rule of Law Report, 
the Finnish Government sent also the chart on the implementation status for each action. 

86   Information received in the context of the country visit to Finland from the Ministry of Justice. A few already 
planned initiatives are facing the upcoming elections in April: this is the case of the draft proposal on trading 
in  influence  (see  below)  and  the  discussion  around  the  priorities  to  be  included  in  the  next  Strategy.  The 
Ministry of Justice has committed to try to include the new Strategy in the program of the new Government 
but further discussions need to take into account next elections’ results.  

87   Input  from  Finland  for  the  2023  Rule  of  Law  Report,  p. 15.  Moreover,  in  spring  2022 Finland  signed  the 

UNCAC Coalition’s Transparency Pledge. 

88   Input from Finland for the 2023 Rule of Law Report, p. 15. The webpage (www.anticorruption.fi) includes 
the presentation of the anti-corruption strategy, as well particular milestones, a FAQ section and instructions 
on how to report corruption.  

89   Among the non-started actions, action 5.1.1. prescribed to “Investigate whether the provisions under chapter 
30 of the Criminal Code on bribery offences in business should be amended so that the provisions related to 
bribery offences in public office and in business are more similar”. The Action Plan points out that this action 
– of which is in charge the Ministry of Justice - needs further funding. 

90   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
91   Input from Finland for the 2023 Rule of Law Report, p. 14; information received in the context of the country 
visit to Finland from the Ministry of Justice. The legislative proposal drafted by the Ministry of Justice was 
submitted to public consultation with deadline on 25 November 2022. The legislative proposal includes the 
criminal liability of legal persons as well. 

10 

 
                                                           
evidence and to  prove influences92. The Ministry  of Justice still has to  analyse whether the 
Criminal Code provisions on bribery offences are in need of further amendment93. The OECD 
recently underlined the need for Finland to enforce its foreign bribery offence, including by 
addressing concerns about the definition of the offence94. As reported last year95, in February 
2022 the Government published an independent study on corruption in international business, 
including foreign bribery96. Another study is planned for 2023, also in response to the OECD, 
to follow up in more depth on the independent one on corruption in international business97. 
Potential  amendments  on  the  legislation  on  bribery  will  be  assessed  on  this  basis98.  The 
Ministry of Foreign Affairs is working on guidelines for personnel operating abroad on how to 
identify corruption and how to proceed when corruption is detected99. As the preparation of the 
draft  proposal  on  trading  in  influence  is  ongoing,  some  progress  has  been  made  on  the 
recommendation made in the 2022 Rule of Law Report. 

After a significant increase last year, the number of prosecutions of corruption-related 
offences are back to previous years’ average. The resources of the Police and of the NBI 
have been strengthened with four additional officers from the second half of 2022 until the end 
of January 2023100. The Police considers that the needed expertise to deal with anti-corruption 
cases is guaranteed101. The Police benefits from the support of external experts and specific 
trainings for the NBI, local police stations and the FIU on how to identify corruption cases102. 
Following  GRECO  recommendations103,  the  National  Police  Board  have  developed  anti-

92   Information received in the context of the country visit to Finland from the National Prosecution Authority. In 
particular, the prosecutors mentioned an unnecessary increased burden in collecting evidence when it comes 
to intermediaries in trading in influence.  

93   See the 2022 Rule of Law Report (p. 8). The assessment - which will also cover the possibility of extending 
liability for acts in office to municipal and state majority-owned companies - was supposed to be carried out 
already in 2020 and 2021. Government Resolution on the National Anti-Corruption Strategy and Action Plan 
2021-2023, p. 41. 

94   The OECD Working Group on Bribery expressed serious concerns on the lack of foreign bribery enforcement 
in Finland, which date back to the OECD Phase 4 evaluation report in 2017. It is recommended to Finland to 
revise  the  foreign  bribery  offence  to  remove  significant  deficiencies  that  could  impede  its  effective 
enforcement. In December 2022 OECD stated that following Finland’s continued insufficient compliance with 
a core aspect of the OECD Anti-Bribery Convention, as well as the lack of enforcement of its foreign bribery 
laws,  the  OECD  Working  Group  on  Bribery  will  send  a  high-level  mission  to  Helsinki,  unless  tangible 
progress is reported in June 2023.  

95   2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, pp. 9 -10. 
96   Government  Office  (2022),  Corruption  in  international  business,  Current  state  of  regulation,  application 
practice and training and needs for change. As recommended in the study, the Ministry committed to continue 
the trainings for criminal investigators, prosecutors, and judges on the application of foreign bribery offences. 
As reported last year (2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 
9), the trainings started in 2021. 

97   Information received in the context of the country visit to Finland from the Ministry of Justice. 
98   This commitment was included in the new Anti-Corruption Strategy, to be approved by the new government. 

Information received in the context of the country visit to Finland from the Ministry of Justice. 

99   Information received in the context of the country visit to Finland from the Ministry of Justice. Action Plan, 

4.4.1, p. 23. The measure is currently labelled as “well advanced”.  

100  Input from Finland for the 2023 Rule of Law Report, p. 16. In total, two positions have been allocated to the 
criminal investigation division (financial crime), one position to the Financial Intelligence Unit (FIU), and one 
to the Helsinki Police Department. 

101  Information received in the context of the country visit to Finland from National Police Board. The Police 

does not foreseen upcoming discussions to establish a separate and dedicated unit to corruption.  

102  Information received in the context of the country visit to Finland from the NBI. 
103  GRECO Fifth Evaluation Round – Evaluation Report, recommendation vii, para 129. 

11 

 
                                                           
corruption guidelines and internal instructions that will be implemented during 2023104. The 
anti-corruption policy of the Border Guard is planned to be finalised by 31 December 2023 and 
to  enter  into  force  in  January  2024  at  the  latest105.  There  are  six  prosecutors  specialised  in 
corruption  offences  and  19  specialised  in  prosecuting  offences  committed  in  office106. 
Specialised  financial  crime  prosecutors  often  handle  bribery  offences  in  all  prosecution 
districts107,  while  junior  prosecutors  are  involved  in  corruption  cases  to  assist  higher-level 
prosecutors. In 2022, the prosecution service received nine corruption cases from the police. 
During  the  same  year,  24  cases  resulted  into  prosecutions108.  Compared  to  2021109  -  with 
prosecution service receiving 90 corruption cases from the police, and deciding on 68 cases, 
out of which charges were brought in 56 cases, and 19 cases dismissed - data seems to have 
returned to  the average  of ten cases  prosecuted  per  year110.  As for the cooperation with  the 
EPPO, no particular challenge has been reported. By December 2022, the number of corruption 
related cases pending a decision of the prosecutor is 57, of which 17 have been opened111 for 
more than 12 months112. 

The  Ministry  of  Justice  has  analysed  the  current  legal  framework  on  ministerial 
responsibilities, while a political decision is still required. Investigations of corruption by 
members  of  the  Government  follow  a  different  procedure  than  normal  corruption 
investigations113. A background memorandum was drafted and published by the Ministry of 
Justice in August 2022114, describing the state of the regulation on ministerial responsibilities, 
as  well  as  arguments  in  favour  of  preserving  the  current  state  of  play  and  proposals  for 
regulatory assessment needs. The memorandum is expected to be discussed in Parliament115. 
Questions  as  to  whether  Parliament  is  the  most  appropriate  forum  to  discuss  ministerial 
responsibilities were raised, suggesting the intervention of  a judicial authority  rather than a 
parliamentary  committee116.  The  same  issue  was  already  noted  by  GRECO  as  a  potential 
obstacle to the effective functioning of the criminal justice system117.  

104  Input from Finland for the 2023 Rule of Law Report, p. 15; Information provided as an additional input from 

Ministry of Justice following the country visit of Finland. 

105  Written input from the Finnish Border Guard following the country visit of Finland. There are plans to develop 
cooperation with the municipalities and private sector to make the economic conditions for criminal activities 
in such environments more difficult, without a clear timeline. Input from Finland for the 2023 Rule of Law 
Report, p. 16. 

106  Written input from Ministry of Justice following the country visit of Finland.  
107  Written contribution from the National Prosecutor Authority in the context of the country visit in Finland. 
108  Information received in the context of the country visit to Finland from the national prosecutor.  
109  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 9. Data refers to 2021. 
This represented an exponential increase from the average of ten cases prosecuted per year, as reported in the 
2021 Rule of Law report (p. 6). 

110 According to the data for years 2010-2019, received in the context of the 2021 country visit to Finland from 
national prosecutor, the average annual number of cases of prosecuted corruption and economic crime offenses 
has remained relatively stable over the ten-year reporting period with an average of ten cases per year.  

111 Open cases refer to cases where the prosecutor has not yet decided whether bringing charges or not prosecuting. 
112  Written input from Finnish authorities following the country visit to Finland.  
113 2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7; 2022 Rule of Law 

Report, Country Chapter on the rule of law situation in Finland, p. 9. 

114 Finnish Government (2022), Background note on legal ministerial responsibility and the request for permission 

to prosecute a Member of Parliament. 

115  Input from Finland for the 2023 Rule of Law Report, p. 20. 
116  Information received in the context of the country visit to Finland from the National Prosecution Authority.  
117  GRECO Fifth Evaluation Round – Compliance Report, para. 39-41.  

12 

 
                                                           
The Transparency Register Act is scheduled to enter into force following parliamentary 
approval  and  an  electronic  register  is  currently  being  developed.  Currently,  there  is  no 
comprehensive legislation dedicated to lobbying, as the framework relies on multiple acts and 
administrative guidelines118. The Transparency Registry Act – that is scheduled to enter into 
force on 1 January 2024  - lays  down the obligation for legal  persons and private traders to 
register for influencing activities and related professional advice119. An electronic register is 
currently  being  developed  by  the  National  Audit  Office  (NAOF)  and  is  expected  to  be 
operational at the end of 2023120. Monitored by the NAOF, the Transparency Register aims to 
improve 
influence  and 
strengthening public confidence. In connection with the register, an advisory board involving 
the  Ministry  of  Justice,  the  Ministry  of  Finance,  and  representatives  of  academia,  has  been 
appointed to draft recommendations on good practices on lobbying121.  

transparency  of  decision-making,  combating 

ineffective 

the 

The Parliament did not conclude discussions on a proposal on limiting ‘revolving doors’ 
for  Ministers  before  the  end  of  the  parliamentary  term.  The  proposal  was  submitted  to 
Parliament in September 2022. However, the discussion on the proposal was not finished when 
the parliamentary session ended in spring 2023 and no further work was planned before the 
April 2023 elections122. This proposal – which was planned to be submitted to Parliament in 
spring 2021123 – aims to establish procedures to prevent and avoid conflicts of interest when a 
member of the Government moves to another position for a period of up to 12 months124. 

While civil servants and persons entrusted with top executive functions are covered by a 
Code  of  Conduct,  Ministers  are  still  not  covered.  The  issue  was  already  raised  in  the 
framework  of  the  2022  Rule  of  Law  Report125,  as  well  as  being  subject  to  a  GRECO 

118  There is currently no separate legislation related to lobbying apart from the new Transparency Register Act 
(expected by the Ministry to entry into force on 1 January 2024). The regulation of lobbying relies on different 
provisions, such as the  Civil Servant’s Act (750/1994), the Act on the Openness of Government Activities 
(621/1999),  and  the  Administrative  Procedure  Act  (434/2003),  as  well  as  on  administrative  guidelines.  In 
December 2022, the Ministry of Finance issued Guidelines for Government agencies to combat corruption, 
which aims to improve awareness and to identify risks of corruption in government agencies and institutions. 
2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10; 2021 Rule of Law 
Report, Country Chapter on the rule of law situation in Finland, p. 8. 

119  Input from Finland for the 2023 Rule of Law Report, p. 17. Government proposal (HE 98/2022 vp) for the 
Transparency  Registration  Act.  The  proposal  would  lay  down  an  obligation  for  legal  persons  and  private 
traders to notify the register of influencing activities directed at Parliament and ministries and related advice 
on influencing activities carried out as a business. 

120  Information received in the context of the country visit to Finland from the Ministry of Justice. 
121  Information  received  in  the  context  of  the  country  visit  to  Finland  from  the  Ministry  of  Justice;  written 
contribution from the Ministry of Justice in the context of the country visit in Finland. The advisory board will 
be set up in the spring of 2023 for the Transparency Register. No time schedule is expected for issuing these 
recommendations, as the decision is up to the advisory board. 

122  Written input from Ministry of Justice following the country visit of Finland. In accordance with the Finnish 
Constitution, consideration of the proposal will lapse at the end of the parliamentary term in April 2023. The 
proposal was as at the expert consultation stage in Parliament. To finalize the proposal on limiting ‘revolving 
doors’ for Ministers is one of the objectives of the new draft Government Programme. 
123  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 11.  
124  Ministers can commit to follow the Advisory Board for Civil Service Ethics recommendation to inform about 
their intention to take upon new duties after their appointment as ministers. Thus, they are not subject to the 
“revolving door” restrictions of the State Civil Servants’ Act. The state of play was reported both in 2020 (p. 
8)  and  2022  (p.  11).  Government  proposal  HE  192/2022  vp.  To  note  that  each  Government  considers  its 
commitment to the recommendation of the Advisory Board for Civil Service Ethics.  
125  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10. 

13 

 
                                                           
recommendation  in  its  Fifth  Evaluation  round126.  The  Code  of  Conduct127  aims  to  give  a 
comprehensive view and standard on integrity and is complemented by the constitutional basis 
and  the  supervision  of  the  Chancellor  of  Justice.  Although  Ministers  are  often  Members  of 
Parliament – and thus covered by particular provisions on conduct128 – there is room to expand 
the personal scope of the Code to apply explicitly to Ministers. The Prime Minister’s Office 
updated  the  Handbook  on  ministerial  responsibilities:  the  Handbook  includes  a  section  on 
regulations  and  principles  guiding  the  Government’s  activities,  such  as  the  rule  of  law, 
principles of good governance and the openness and handling of documents129. Nevertheless, 
Ministers  are  still  not  covered  by  a  Code  of  Conduct  which  would  address  other  sensitive 
integrity related areas, currently not covered in the Ministers’ Handbook130. As reported last 
year131, the amendment to the State Civil Servants’ Act on the post government employment 
waiting  period  agreement  entered  into  force  in  June  2022,  in  line  with  a  GRECO 
recommendation132. 

The Government presented in Parliament a proposal to develop transparency in electoral 
and party funding legislation. The Government’s proposal was submitted to Parliament in 
November 2022133. However, due to the parliamentary elections in April 2023, the ongoing 
work on the draft stopped134. By amending the Candidate’s Election Funding Act, the Electoral 
Act and the Citizens’ Initiatives Act, the proposal aims to improve the provisions and practices 
for the disclosure of electoral  and party  funding135, as well as to  strengthen the right  of the 
NAOF  to  monitor  candidates’  election  funding  declarations136.  Although  it  has  found  that 
parties comply reasonably well with the funding regulations, NAOF has been critical about the 
recent legislation on election funding137, as the proposal does not cover local associations of 
the parties138. In January 2023, the Ministry of Justice funded a report on foreign funding and 

126  GRECO Fifth Evaluation Round – 2nd Compliance Report, recommendation iv and v, paras 28-41. 
127  Finnish Government (2021), Code of conduct for officials. The Code of Conduct on Civil Service Ethics was 
issued in 2021. It aims at giving a comprehensive set of rules targeting senior officials in central government, 
including special advisers, who are now also subject to financial disclosure requirements. More specifically, 
the Code of Conduct covers all civil servants. 

128 Such particular provisions refer to the Constitution and to the Parliament’s Rules of Procedure. 
129  Information received in the context of the country visit to Finland from the Prime Minister’s Office; written 

input from the Prime Minister’s Office following the country visit of Finland. 

130  GRECO Fifth Evaluation Round – 2nd Compliance Report, recommendation i, para. 17 and para. 96. 
131  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10. 
132  Input  from  Finland  for  the  2023  Rule  of  Law  Report,  p.  17.  Amendment  to  section  44a  of  the  State  Civil 
Servants’ Act (750/1994); GRECO Fifth Evaluation Round – Compliance Report, recommendation v, paras 
32-34. 

133  Finnish  Parliament  (2023),  Government  proposal  to  Parliament  for  acts  amending  the  Act  on  Candidates' 
Election Funding, the Parties Act, Sections 112 and 143 l of the Election Act and Section 10 of the Act on the 
Citizens' Initiative, No HE 254/2022 vp; Information received in the context of the country visit to Finland 
from the Ministry of Justice.  

134  Parliamentary  communication  (SS  87/2022  vp)  -  Termination  of  Parliament's  work,  lapsed  matters  and 

Parliament convening. 

135  The draft proposal includes obligations for candidates to publish names of sources of loaned money. 
136 Input from Finland for the 2023 Rule of Law Report, p. 17.  
137  National Audit Office of Finland (2022), Report on the oversight of political party funding 2022; National 
Audit  Office  of  Finland  (2022),  Proposed  amendments  to  the  Electoral  and  Party  Act  will  significantly 
improve transparency. 

138  When drafting the proposal, discussions have been raised on whether the control of party funding should also 
be  extended  to  local  associations  of  parties.  Nevertheless,  the  current  draft  does  not  expand  the  NAOF's 
supervisory role in this regard. Besides, a relevant Finnish newspaper reported that electoral funding has been 
rapidly increasing in Finland, and that is relatively easy and common to maintain the funding anonymous and 
divide it under the threshold of EUR 1 500. Helsingin Sanomat (2023), Do you want to become an MP? 

14 

 
                                                           
potential  loopholes  of  the  current  legislation,  especially  from  the  perspective  of  preventing 
foreign political parties’ potential attempts to exert influence139. The key findings of the report 
show that the prohibition of foreign funding laid down in the current legislation is not absolute 
and is relatively easy to circumvent.  

The national law aiming at transposing the Whistleblowers Directive entered into force. 
The implementation of the national law will start in 2023140. The Ministry of Justice applied 
for external funding to work on an awareness raising and training project on public and private 
sector organizations and citizens141. With funding, the Ministry of Justice expects to carry out 
national  data  analysis  and  regular  situation  reporting  on  corruption142.  Citizens  can  report 
misconducts  through  different  channels  to  authorities  (National  Audit  Office,  Tax 
Administration, and Financial Supervisory Authority) or electronically to the police143.  

To address risks in public procurement and political decision-making tailored trainings 
are being organised144. During 2022, the Ministry of Justice organised targeted and tailored 
trainings for high-risk sectors of corruption, focusing on concept and forms of corruption, on 
risk  mapping  in  the  public  procurement  process  as  well  as  on  vulnerabilities  and  possible 
ethical  loopholes  in  the  decision-making  processes145.  Furthermore,  every  training  session 
provides tools to further develop the organisations’ integrity and anti-corruption framework146.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

In Finland, freedom of expression is protected by the Constitution, which also guarantees the 
right  of  access  to  public  documents147.  The  tasks  and  powers  of  the  Finnish  Transport  and 

139  Muukkonen (2023), Foreign policy financing and its regulatory needs. 
140  Input from Finland for the 2023 Rule of Law Report, p. 15. Finnish Parliament (2023), HE 147/2022 vp. 
141  Input from Finland for the 2023 Rule of Law Report, p. 18. The Ministry of Justice received external funding 
to carry out a training project on the implementation of the whistleblower legislation (project to start in autumn 
2023).  Besides,  the  Ministry  of  Justice  will  also  apply  for  external  funding  to  work  on  awareness  raising, 
training projects and actions of the national strategy, such as national data analysis and regular situation report 
on corruption (application period in late autumn 2023). 

142  Input from Finland for the 2023 Rule of Law Report, p. 15. Currently Finland does not have a specific anti-

corruption agency responsible with investigating suspicious of corruption. 

143  Anti-Corruption.fi,  Report  corruption.  Reports  coming  from  external  individuals  are  received  by  the 
Chancellor  of  Justice’s  Office.  2022  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in 
Finland, p. 11. Information received in the context of the country visit to Finland from the Ministry of Justice. 

144  Input from Finland for the 2023 Rule of Law Report, p. 18. 
145 Input from Finland for the 2023 Rule of Law Report, p. 18. Trainings for the local government were organized 
in collaboration with the Association of Municipalities in the beginning of 2022, and tailored trainings will 
continue  in  2023  as  follow  up  to  the  report  entitled  “Combating  Corruption  in  Local  Government  –  Steps 
Towards Good Governance”, which was published in December 2022. 

146  Input from Finland for the 2023 Rule of Law Report, p. 18. The Flash Eurobarometer on Businesses’ attitudes 
towards corruption in the EU shows that 23% of companies in Finland (EU average 26%) think that corruption 
has prevented them from winning a public tender or a public procurement contract in practice in the last three 
years. This is 3 percentage points below the EU average. 

147  Finland ranks 5th in the 2023 Reporters Without Borders World Press Freedom Index similarly to the previous 

year. 

15 

 
 
                                                           
Communications Agency (Traficom), the media regulatory authority, are enshrined in law148, 
as are the mandate and monitoring of the public service media149.  

The  independence  of  the  national  regulatory  authority  and  public  service  media  have 
remained stable. Since the publication of the 2022 Rule of Law Report, no changes have been 
reported with regard to the regulation and resources of the two national regulatory authorities 
–  Traficom  and  the  National  Audiovisual  Institute150.  Discussions  are  currently  ongoing 
regarding possible new responsibilities deriving from the Digital Services Act151. The MPM 
2023 registers low risk in terms of the independence and effectiveness of these two authorities, 
unchanged compared to the previous year152. Similarly, the MPM confirms that public service 
media continues to be perceived as independent153. In spite of this positive perception, MPM 
highlights  the  fact  that  it  remains  under  indirect  political  control  and  that  there  is  therefore 
scope  to  increase  transparency  in  the  appointment  system  for  the  leading  positions154.  The 
amendment  mentioned  in  the  2022  Rule  of  Law  report155  requiring  the  online  text  content 
published by the public service media to be more closely linked to its audio and video content 
entered  into  force  in  August  2022156.  Finland  requires  media  service  providers  to  make 
information concerning their ownership structure publicly accessible157. Since the 2022 Rule 
of  Law  Report,  no  regulatory  changes  regarding  transparency  of  media  ownership  or 
restrictions to media ownership and concentration have been reported. MPM 2023 considers 
that  media  market  pluralism  is  an  area  of  very  high  risk  driven  by  the  extensive  combined 
market share of the four largest audiovisual media owners158. 

The ethical rules for the press are being reviewed and the resources of the self-regulatory 
Finnish  Council  for  Mass  Media  have  been  strengthened,  while  it  deals  with  a  rising 
number  of  complaints  about  journalistic  ethics.  This  self-regulatory  council  reports  that 
complaints  about  journalistic  ethics  have  been  rising  for  three  consecutive  years.  The  body 
considers this to reflect citizens’ increased trust in the complaint mechanism and has managed 
to secure more resources and reduce the average length of the complaint handling procedure159. 
Nearly  all  journalistic  organisations  in  Finland  are  committed  to  the  ethical  rules  for  the 

148  Act on the Transport and Communications Agency 935/2018. 
149  Act  on  Yleisradio  Oy  (Laki  Yleisradio  Oy:stä)  1380/1993;  According  to  European  Parliament’s  Flash 
Eurobarometer: News & Media Survey 2022, Finland is the Member State where citizens demonstrate by far 
the highest trust in public TV and radio stations (incl. online). 

150  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 12-13; Input from Finland 
for the 2023 Rule of Law report, p. 21; Information received from Traficom and the National Audiovisual 
Institute in the context of the 2023country visit to Finland. 

151  Information  received  from  Traficom  in  the  context  of  the  2023  country  visit  to  Finland;  Regulation  (EU) 
2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital 
Services and amending Directive 2000/31/EC (Digital Services Act). 

152  2023 Media Pluralism Monitor, country report for Finland, p. 11. 
153  According  to  European  Parliament’s  Flash  Eurobarometer:  News  &  Media  Survey  2022,  Finland  is  the 
Member State where citizens demonstrate by far the highest trust in public TV and radio stations (incl. online) 
with 73% of respondents stating they trust these channels (compared to 49% on average in the EU). 

154  Ibid, p. 15. 
155  2022 Rule of Law report, Country Chapter on the rule of law situation in Finland, p. 14. 
156  Act amending Section 7 of the Act on Yleisradio Oy 159/2022. 
157 Act on Electronic Communications Services 917/2014, Art. 4a; Regional Act (2011: 95) on radio and television 

activities, Art. 5, As amended by Act of Åland 2020/119. 

158 2023 Media Pluralism Monitor, country report for Finland, p. 12-13. 
159  Information received from the Council for Mass Media in Finland in the context of the 2023 country visit; 

Council for Mass Media (2022) Annual Report 2022. 

16 

 
                                                           
press160.  The  self-regulatory  council  is  supported  by  an  association,  which  has  a  board 
representing publishers and journalists. Following a consultation  of media stakeholders, the 
supporting association has decided to review the ethical rules for the press in view of changes 
brought by the digital media environment and in order to make the rules easier to use. It has 
appointed a working group to this end161. 

There  has  been  some  progress  on  preparing  to  reform  the  Act  on  the  Openness  of 
Government Activities. The 2022 Rule of Law Report recommended Finland to “continue the 
reform  of the Act on the Openness of  Government  Activities to  ensure effective and wider 
access  to  documents  taking  into  account  the  European  standards  on  access  to  official 
documents”. The dedicated working group appointed by the Ministry of Justice in 2021 has 
continued its work in assessing the sufficiency of the scope and possible shortcomings of the 
current legislation in addition to providing solutions162. A possible reform has been generally 
supported  by  media  stakeholders  and  journalists163.  In  November  2022,  the  working  group 
presented  a  proposal  for  a  draft  legislation  to  clarify  exceptions  that  concern  documents  in 
criminal proceedings164. It  will present the final report on the overall reform in late autumn 
2023165. The work in the Parliament was interrupted due to the end of the Parliament’s mandate 
and  the  new  Government  will  decide  whether  to  continue.  In  parallel,  the  Supreme 
Administrative Court issued a judgment in December 2022 in favour of the right of media to 
obtain, for journalistic use, the list of public information on the income taxation of persons 
from the Tax Administration, even if the data sharing is objected to by those persons. The Court 
held that the disclosure of such electronic data has become part of the Tax Administration’s 
established operations to support the social debate on taxation in the media. The ruling helps 
to reconcile laws on the protection of privacy and public access to tax information166. The MPM 
2023 reports that the protection of the right to information acquires a low-risk score but access 
to documents and information held by officials is often delayed or denied167. In conclusion, 
there has been some progress on the recommendation made in the 2022 Rule of Law Report to 
continue preparations to reform the Act on the Openness of Government Activities. 

The framework for the protection of journalists has remained stable. Since the 2022 Rule 
of Law Report168, the overall protection of freedom of expression has remained stable at a high 
level169.  The  MPM  2023  considers  Finland  to  be  a  free  and  protected  environment  for 
journalists  and  media  professionals,  the  legislative  framework  providing  them  with  relative 

160  2023 Media Pluralism Monitor, country report for Finland, p. 15. 
161  Council for Mass Media (2022) The working group preparing the update of the journalist's instructions has 

been appointed. The revision of the rules was done previously in 2014. 

162  More information is available at https://oikeusministerio.fi/hanke?tunnus=OM083:00/2020. 
163  Responses to the public consultation of the Ministry of Justice on the initiative (see the previous footnote); 
Information received from the Council for Mass Media in Finland, the Union of Journalists and the Finnish 
Media Federation in the context of the 2023 country visit. 

164  Input from Finland for the 2023 Rule of Law Report, p. 21; more information is available at HE 273/2022 vp 

(eduskunta.fi).  

165 Follow-up written input from Finland for the 2023 Rule of Law Report. 
166  Tax Administration (2022) Supreme Administrative Court: Customers do not have the right to object to the 
electronic  release  of  their  tax  information  to  the  media;  Supreme  Administrative  Court,  judgment  of  21 
December 2022, 21814/2021, ECLI:FI:KHO:2022:146. 

167  2023 Media Pluralism Monitor, country report for Finland, p. 10. 
168  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 15. 
169  Input from the Union of Journalists in the context of the 2023 country visit. 

17 

 
                                                           
security170. According to recent surveys, citizens trust news media more than ever171. Since the 
publication of the 2022 Rule of Law report, the Council of Europe’s platform to promote the 
protection  of  journalism  and  safety  of  journalists172  has  updated  its  alert  with  regard  to  the 
criminal conviction of two journalists following charges brought in 2021 against them and one 
other journalist for the disclosure of a state security secret and for intending to disclose other 
state  secrets.173  A  separate  new  alert  concerns  the  brief  detention  of  a  journalist  covering  a 
protest and the confiscation of his memory card174. 

Legislative reforms have been prepared to address the harassment of journalists online. 
Since the 2022 Rule of Law Report, the Criminal Code has been amended for gender to be 
added among the motives that constitute grounds for increasing the punishment for (any) crime. 
The  amendment,  which  entered  into  force  in  January  2023175,  could  address  hate  speech 
directed towards female journalists and has been supported by the journalistic community176. 
Additionally, new legislation has been adopted with an aim to make restraining orders more 
effective177,  tackling  in  part  online  hate  campaigns.  In  September  2022,  an  assessment  was 
published  exploring  whether  amendments  to  criminal  law  are  needed  to  improve  the 
effectiveness of prosecutions of targeting, which refers to systemic harassment of a person in 
the form of mass actions on online platforms because of his or her work or social duties178. In 
the future, the Government will examine whether to prepare a proposal for the Parliament179. 
The Union of Finnish Journalists has been involved with the Occupational Safety and Health 
Centre  and  the  Finnish  Media  Federation  in  drawing  up  guidelines  on  how  to  prepare  and 
prevent  harassment  and  targeting  online,  which  they  see  as  one  of  the  biggest  problems 
journalists are facing in  Finland with  possible implications on self-censorship  or journalists 
leaving the profession180. 

IV. 

OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Finland is a unicameral, parliamentary democracy, in which legislative proposals may emanate 
from the Government or Parliament (although in practice most laws are based on Government 
proposals). Ex ante constitutionality review is carried out by the Chancellor of Justice, who is 
attached  to  the  Government,  and  the  Constitutional  Law  Committee,  a  parliamentary 

170  2023 Media Pluralism Monitor, country report for Finland, p. 10-11. 
171  Media Field Research Foundation (2022) Finns' trust in the news is greater than ever; Reuters Institute for the 

Study of Journalism (2022) Digital News Report 2022. 

172  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Finland. 
173  In January 2023, two of the original three journalists charged were convicted by the Helsinki District Court. 
International Press Institute (2023) Finland: Conviction of two Helsingin Sanomat journalists sets dangerous 
precedent; Reporters Without Borders (2023) The conviction of Finnish journalists for revealing state secrets 
sets a dangerous precedent for press freedom internationally; Union of Journalists (2023) Union of Journalists: 
Journalists' freedom of speech verdict makes it difficult for the public to access information; Input from the 
Council for Mass Media, Finnish Media Federation and Union of Journalists in the context of the 2023 country 
visit to Finland. 

174 Council of Europe, Platform to promote the protection of journalism and safety of journalists, Finland. 
175  More information is available at https://oikeusministerio.fi/hanke?tunnus=OM024:00/2019. 
176  Responses to the public consultation of the Ministry of Justice on the initiative (see the previous footnote). 
177  More information is available at https://oikeusministerio.fi/hanke?tunnus=OM015:00/2020. 
178  Ministry of Justice (2022) Criminal regulation of targeting - Evaluation memorandum 2022:29.  
179  Input from Finland for the 2023 Rule of Law report, p. 23. 
180  Union  of  Journalists  (2023)  Support  for  social  media  harassment  and  bullying  from  the  Center  for 
Occupational Safety; input from the Union of Journalists in the context of the 2023 country visit to Finland. 

18 

 
                                                           
committee181  that  assesses  the  constitutionality  of  proposals  submitted  to  Parliament. 
Moreover, all courts can carry out  ex post constitutionality review in concrete cases182. The 
Chancellor of Justice, the Human Rights Centre and the Parliamentary Ombudsman play an 
important role in the system of checks and balances. 

A new guide on fundamental and human rights impact assessments in drafting legislation 
has  been  published.  In  November  2022,  the  Ministry  of  Justice  adopted  a  guide  on 
fundamental  and  human  rights  impact  assessment  in  law  drafting,  to  facilitate  easier 
recognition and assessment of the impacts of legislation on fundamental and human rights183. 
Moreover,  in  October  2022,  the  Permanent  Secretaries  of  all  ministries  have  published  the 
updated regulatory impact assessment guidelines, which include instructions for the regulatory 
impact assessment on economic, environmental, and other human and societal impacts184. The 
guidelines  also  include  a  section  on  impacts  concerning  democracy  and  rule  of  law.185 
Generally,  involvement  of  stakeholders  in  the  legislative  process  remains  meaningful,  with 
some discrepancies reported, namely in the different approach amongst the ministries and their 
departments186.  In  order  to  improve  the  systematic  inclusion  of  civil  society  in  legislative 
processes,  ministerial  employees  responsible  for  the  draft  laws  are  systematically  offered 
education  and  instructions  for  better  stakeholder  cooperation187.  The  Action  Plan  on  Better 
Regulation, adopted by the Government in August 2020, aiming to further improve the quality 
and  transparency  of  the  legislative  drafting  process,  as  described  in  the  2021  Rule  of  Law 
Report188,  is  planned  to  be  completed  by  the  end  of  2023  and  its  implementation  report  is 
scheduled for September 2023189.  

On  1  January  2023,  Finland  had  nine  leading  judgments  of  the  European  Court  of 
Human Rights pending implementation, the same number as the previous year190. At that 
time, Finland’s rate of leading judgments from the past 10 years that remained pending was at 

181  The committee is made up of members of Parliament and regularly hears independent experts on constitutional 

law. 

182  According to Section 106 of the Constitution if in a case before a court, the application of an act would be in 

evident conflict with the Constitution, the court of law shall give primacy to the Constitution. 

183  Guide on Fundamental and Human Rights Impact Assessment in Law Drafting, available online in Finnish at: 
https://julkaisut.valtioneuvosto.fi/handle/10024/164464. Input from Finland for the 2023 Rule of Law Report, 
p. 25. 

184  The  Updated  Guidelines  for  Impact  Assessment  in  Law  Drafting,  available  online  in  Finnish  at: 
https://julkaisut.valtioneuvosto.fi/handle/10024/164464; 
at: 
https://julkaisut.valtioneuvosto.fi/handle/10024/164932. Input from Finland for the 2023 Rule of Law Report, 
p. 25. 

available 

English 

and 

in 

185 Written input from Finland for the 2023 Rule of Law Report. 
186  Information received from the Advisory Board for Civil Society Policy, Demla and Amnesty International in 

the context of the country visit to Finland. 

187  Written information received from Finnish authorities in the context of the country visit to Finland, p. 1. The 
focus of the education and instructions lies in the identification of stakeholders, planning of equal and timely 
consultation processes and the transparency of the preparation process. 

188 2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 13; 2022 Rule of Law 

Report, Country Chapter on the rule of law situation in Finland, p. 17. 

189 Written information received from Finnish authorities in the context of the country visit to Finland. 
190 The  adoption  of  necessary  execution  measures  for  a judgment  by  the  European  Court  of  Human  Rights  is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

19 

 
 
 
 
                                                           
50% (compared to 60% in 2022) and the average time that the judgments had been pending 
implementation was 12 years and 11 months (compared to 11 years and 11 months in 2022)191. 
The oldest leading judgment, pending implementation for 17 years, concerns the protection of 
private and family life in relation to the lack of proper safeguards for the implementation of 
search and seizure measures192.  On 15 June 2023, the number of leading judgments pending 
implementation has decreased to seven193. 

A  targeted  amendment  to  the  Emergency  Powers  Act  was  adopted,  with  a  more 
comprehensive reform pending. The main purpose of the amendment, which was adopted in 
urgent  procedure  for  constitutional  enactment  in  July  2022194,  was  to  enable  a  state  of 
emergency to be declared also in case of serious hybrid influencing against Finland195. A more 
comprehensive reform to the Emergency Powers Act commenced in autumn 2022 and a new 
working  group  and  a  parliamentary  committee  have  been  appointed.  The  aim  of  the 
comprehensive reform is to update the Emergency Powers Act and to amend it to bring it in 
line with the constitution and with the current society’s view on the environment and the factors 
threatening it196. The working group consists of representatives from all the Ministries, from 
the Office of the President of the Republic, as well as independent experts on constitutional 
law.  The  proposal  is  expected  to  be  submitted  by  autumn  2025197.  The  Ministry  of  Social 
Affairs and Health has prepared a memorandum  on the needs to reform  the Communicable 
Diseases Act198. 

The  law  clarifying  the  division  of  powers  between  the  Chancellor  of  Justice  and  the 
Parliamentary Ombudsman has entered into force199. The law, which aims to clarify the 
division of tasks between the two institutions, was adopted on 19 April 2022, as stated in the 
2022 Rule of Law Report200, and entered into force on 1 October 2022201. The application in 
practice  so  far  is  evaluated  positively,  especially  with  regard  to  the  more  efficient  use  of 
resources,  specialisation  and  the  ability  to  better  addressing  the  needs  of  citizens202.  The 
Government  proposal  to  establish  a  new  agency  to  provide  administrative  support  to 

191 All figures are calculated by the European Implementation Network and are based on the number of cases that  
are considered pending at the annual cut-off date of 1 January 2023. See the Contribution from the European  
Implementation Network for the 2023 Rule of Law Report, p. 3. 

192  Judgment of the European Court of Human Rights of 27 September 2005, Petri Sallinen and Others v. Finland, 

50882/99, pending implementation since 2005. 

193  Data according to the online database of the Council of Europe (HUDOC-EXEC). 
194  Section 73 of the Constitution prescribes that any legislative proposal which entails a limited derogation of the 
Constitution  must be enacted following the  procedure  of constitutional enactment,  ie,  hold the proposal in 
abeyance or declare it urgent by a majority of at least five-sixths.In ‘Finland: Legal Response to Covid-19‘, T 
Kotkas, A Kantola, H Wass, E Husu. Oxford University Press, 2021. 

195  Input from Finland for the 2023 Rule of Law Report, pp. 5, 25. 
196  Information received from the Ministry of Justice in the context of the country visit to Finland. 
197  Input from Finland for the 2023 Rule of Law Report, p. 26; Information received from the Ministry of Justice 

in the context of country visits to Finland. 

198  Written input from Finland for the 2023 Rule of Law Report; Contribution from the Chancellor of Justice for 

the 2023 Rule of Law Report, pp. 24, 25. 

199  The Act on the division of tasks between the Chancellor of Justice of the Government and the Parliamentary 

Ombudsman, No 330/2022. 

200  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 18.  
201  Input from Finland for the 2023 Rule of Law Report, p. 27; Contribution from the Chancellor of Justice for 

the 2023 Rule of Law Report, pp. 17, 27. 

202  Contribution from the Chancellor of Justice for the 2023 Rule of Law Report, p. 27; Information received from 
the Chancellor of Justice, the Parliamentary Ombudsman and the Human Rights Centre in the context of the 
country visit in Finland.  

20 

 
 
                                                           
independent bodies, as reported in the 2022 Rule of Law Report203, has not been presented to 
Parliament under the previous Government. Further discussion on whether there is need for 
such a body will depend on the new Government’s programme204. The Human Rights Centre, 
which together with its delegation and the Parliamentary Ombudsman constitutes the National 
Human Rights Institution accredited with A Status205, has issued a report on the human rights 
structure, identifying several problems, including issues connected to high fragmentation of the 
human rights institutions in Finland206. 

Amendments  to  improve  the  model  of  funding  of  civil  society  organisations  were 
approved by the Parliament. Civic space in Finland is considered to be ‘open’207. As reported 
in  the  2022  Rule  of  Law  Report,  the  Government  prepared  a  proposal  for  a  new  model  of 
funding, which was finalised in February 2022208. In this new model, civil society organisations 
would obtain stable and sufficient funding, as the activities would be financed from a universal 
government income, instead of gambling proceeds, and without earmarking the intended use 
of the funds209. As a follow-up to the proposal, several legislative changes were drafted in order 
to accommodate the new funding model210. All these amendments will enter into force on 1 
January  2024211.  In  addition,  in  February  2023  the  Government  set  a  new  parliamentary 
advisory board on financing and developing activities of non-profit communities for the term 
of office of Parliament until a new advisory board is set up (at most until 31 December 2023).212 
Stakeholders assess this reform positively and expect greater stability213. The amendment to 
the Associations Act has entered into force on 8 February 2023214. The aim of the amendment 
is to promote and facilitate activities in the civic space, namely through introducing easier ways 
of organising administration, including financial and accounting issues, especially for smaller 
organisations215. The Advisory Board for Civil Society Policy has published its strategy for 
2022-2026 in October 2022216. The aim of the strategy is to clarify objectives as regards the 

203  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 18.  
204  Information received from the Ministry of Justice in the context of the country visit to Finland. 
205  2020 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 13. 
206 Human Rights Center (2022) Report on national fundamental and human rights actors. Information received 
from the Human Rights Center and Amnesty International in the context of the country visit to Finland.  
207  Rating given by Civicus, Finland. Ratings are on a five-category scale defined as: open, narrowed, obstructed, 

repressed and closed. 

208  2022 Rule of Law Report, Country chapter on the rule of law situation in Finland, p. 19.  
209  Input from Finland for the 2023 Rule of Law Report, p. 30; Memorandum on the new funding model 

available in Finnish online at: 
https://valtioneuvosto.fi/documents/10616/104236898/Rahapelituotoilla+rahoitettavien+yleishy%C3%B6dyl
listen+toimintojen+uusi+rahoitusmalli_FINAL.pdf/a623bb09-b3a3-4230-308f-
500b88f34862/Rahapelituotoilla+rahoitettavien+yleishy%C3%B6dyllisten+toimintojen+uusi+rahoitusmalli_
FINAL.pdf?t=1644326410914.  

210  In 2022, the Government submitted to Parliament a proposal (HE 255/2022 vp) on amendments to the Lotteries 
Act, a proposal (HE 282/2022 vp) on amendments to laws under the supervision of the Ministry of Education 
and Culture, proposal (HE 269/2022 vp) on the financing of associations in the social and health sector, and a 
proposal (HE 260/2022 vp) on the funds granted to horse breedings and to the promotion of equestrian sports. 

211  Input from Finland for the 2023 Rule of Law Report, p. 30.  
212 Written input  from Finland for the 2023 Rule of Law  Report.  More information on the  new parliamentary 

advisory board here: https://valtioneuvosto.fi/paatokset/paatos?decisionId=0900908f80811b84. 

213  In the context of the country visits in Finland, the Advisory Board on Civil Society Policy, Demla and Amnesty 

International expressed uncertainty when it comes to future funding. 

214  Information received from the Ministry of Justice in the context of a country visit to Finland.  
215  Input from Finland for the 2023 Rule of Law Report, p. 29; Information received from the Ministry of Justice 

in the context of the country visits in Finland. 

216  The  strategy  available  in  Finnish  online  at  https://julkaisut.valtioneuvosto.fi/handle/10024/164356;  Franet 
(2023),  Country  research  -  Legal  environment  and  space  of  civil  society  organisations  in  supporting 

21 

 
 
                                                           
future of the civil society. The three main goals of the strategy are to i) safeguard and strengthen 
the autonomy of CSOs, ii) develop interaction between public administration and civil society, 
and iii) to promote equal participation. The promotion of the strategy constitutes the core of 
the work for the Advisory Board for Civil Society Policy for the coming years217. It will also 
carry out a mid-term review of the strategy218. 

The  Government  adopted  a  resolution  on  Finnish  democracy  policy  up  to  2030.  On  3 
November  2022,  the  Government  adopted  a  resolution  on  Finnish  democracy  policy  in  the 
2020s219. There are six key goals set out for a long-term democracy policy, within which there 
are  dedicated  goals  concerning  democracy,  human  rights  and  media  education  and  a  goal 
concerning  the  operating  conditions  of  civil  society.  To  improve  the  level  of  education  on 
human rights and media, the policy recognised a lack of permanent structures and resources to 
train teachers and staff and proposed to strengthen open debate to counter disinformation220. 
When it comes to the participation of civil society, the policy recommends namely to establish 
long-term cooperation between municipalities and civil society, to work on better inclusion of 
children, youth, and other vulnerable residents in the process221, to support long-term funding 
for  civil  society  organisations,  and  young  people’s  participation222.  Most  of  the  measures 
proposed in the policy depend on the implementation decision of the new Government, as these 
are dependent on orientations and objectives of each government and competent ministry223. 

fundamental rights – Finland., p. 3; Information received from the Advisory Board on Civil Society Policy in 
the context of the country visit to Finland. 

217  Input from Finland for the 2023 Rule of Law Report, p. 31. 
218  Franet (2023), Country research - Legal environment and space of civil society organisations in supporting 

fundamental rights – Finland., pp. 3-4. 

219  Input from Finland for the 2023 Rule of Law Report, p. 31.  
220  Government’s resolution on Finnish democracy policy in the 2020s, p. 38. 
221  Finnish democracy policy, p. 33. 
222  Ibid. pp. 50, 51. 
223  Ibid. p. 55.  

22 

 
 
 
 
                                                           
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2023 Rule of Law report 
can 
https://commission.europa.eu/publications/2023-rule-law-report-targeted-
found 
stakeholder-consultation_en.  

be 

at 

Advisory Board on Civil Society Policy (2022), Autonomous and dynamic civil society for all: Advisory 
Board 
2022-2026, 
Policy 
https://julkaisut.valtioneuvosto.fi/handle/10024/164356. 

Strategy 

(KANE) 

Society 

Civil 

on 

Centre for Media Pluralism and Media Freedom (2023), Media pluralism monitor – country report on 
Finland. 

CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States 

CEPEJ (2022), Evaluation Report 2022 – Country Profile Finland, https://rm.coe.int/cepej-fiche-pays-
2020-22-e-web/1680a86276  

Chancellor of Justice, website: https://www.okv.fi/en/. 

Chancellor  of  Justice  (2022),  Statement  to  the  Legal  Affairs  Committee  of  Parliament,  No 
OKVP2823/22/2022. 

Chancellor of Justice (2023),  Contribution from the Chancellor of Justice for the 2023 Rule of Law 
Report. 

Civicus, Monitor tracking civic space – Finland https://monitor.civicus.org/country/finland/. 

Council  for  Mass  Media  (2022),  Annual  Report  2022  (Julkisen  Sanan  Neuvoston  toimintakertomus 
2022), https://jsn.fi/wp-content/uploads/2023/03/JSN-vuosikertomus-2022.pdf. 

Council for Mass Media (2022), The working group preparing the update of the journalist's instructions 
työryhmä  on  nimitetty) 
has  been  appointed  (Journalistin  ohjeiden  päivitystä  valmisteleva 
https://jsn.fi/journalistin-ohjeiden-paivitysta-valmisteleva-tyoryhma-on-nimitetty/. 

Council of Europe (2023), Platform to promote the protection of journalism and safety of journalists – 

Finland, https://fom.coe.int/en/pays/detail/11709508. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland.  

EPPO 
02/EPPO_2022_Annual_Report_EN_WEB.pdf. 

(2022), 

Annual 

report 

https://www.eppo.europa.eu/sites/default/files/2023-

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland. 

European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland. 

European Commission (2023), EU Justice Scoreboard. 

European Court of Human Rights, judgment of 27 September 2005, Petri Sallinen and Others v.  

Finland, 50882/99. 

European Implementation Network (2022), Contribution from the European Implementation Network 
for the 2022 Rule of Law Report. 

European  Parliament  (2022),  Flash  Eurobarometer:  News  &  Media  Survey  2022,  EB-ID 
2832/FL011EP https://europa.eu/eurobarometer/surveys/detail/2832. 

Financial Intelligence Unit, https://poliisi.fi/en/money-laundering. 

23 

 
Finnish Bar Association (2023), Contribution from the Finnish Bar Association for the 2023 Rule of 
Law Report. 

Finnish Government, website on anti-corruption, https://www.anticorruption.fi  

Finnish  Government  (2021),  Code  of  conduct  for  officials  (“Virkamieseettinen  toimintaohje”)  
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/163089/Virkamieseettinen%20toimintaohje.
pdf?sequence=1&is Allowed=y. 

Finnish Government (2021), Resolution on the national anti-corruption strategy and action plan  

2021-2023 

https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/163398/VN_2021_68.pdf?sequence=1&isA 

llowed=y. 

Finnish Government (2022), Background note on legal ministerial responsibility and the request for 
permission to prosecute a Member of Parliament. 

Government 

Finnish 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164448/VN_2022_67.pdf?sequence=1&isA
llowed=y. 

Administration 

(2022), 

Report 

the 

on 

Justice  

of 

Finnish  Government  (2022),  Report  on  corruption  in  international  business:  Current  state  of 
(“Lahjonta  kansainvälisessä 
regulation,  application  and 
liiketoiminnassa:  Sääntelyn,  soveltamiskäytännön  ja  koulutuksen  nykytila  ja  muutostarpeet”) 
https://julkaisut.valtioneuvosto.fi/handle/10024/163811. 

training  and  need 

for  change 

Finnish Government (2023), Input from Finland for the 2023 Rule of Law Report.  

Finnish Government (2023), Written contribution from the Finnish Government in the context of the 
country visit. 

Finnish  Government  (2022),  Memorandum  on  the  new  funding  model  for  non-profit  activities 
https://valtioneuvosto.fi/documents/10616/104236898/Rahapelituotoilla+rahoitettavien+yleishy%C3
%B6dyllisten+toimintojen+uusi+rahoitusmalli_FINAL.pdf/a623bb09-b3a3-4230-308f-
500b88f34862/Rahapelituotoilla+rahoitettavien+yleishy%C3%B6dyllisten+toimintojen+uusi+rahoitu
smalli_FINAL.pdf?t=1644326410914. 

Finnish Judiciary, Court-specific statistics  
https://oikeus.fi/tuomioistuimet/en/index/tuomioistuinlaitos/statistics.html.  

Judiciary 

(2023),  What  matters  are  dealt  with  by 
Finnish 
https://oikeus.fi/tuomioistuimet/en/index/tuomioistuinlaitos/tuomioistuimet/yleisettuomioistuimet/kar
ajaoikeudet/whatmattersaredealtwithbythedistrictcourt.html#. 

the  district 

court? 

Finnish National Courts Administration (2023), Contribution from the National Courts Administration 
for the 2023 Rule of Law Report.  

Finnish  National  Prosecution  Authority  (2023),  Written  contribution  from  the  National  Prosecution 
Authority in the context of the country visit. 

Finnish  National  Prosecution  Authority  (2021),  Written  contribution  from  the  National  Prosecution 
Authority in the context of the country visit to Finland in 2021. 

Finnish  Parliament  (2022),  HE  147/2022  vp,  Government  proposal  to  Parliament  on  whistleblower 
protection https://www.finlex.fi/fi/esitykset/he/2022/20220147 

Finnish  Parliament  (2022),  HE  192/2022  vp,  Government  proposal  to  Parliament  for  acts  on  the 
cooling-off period related to the duties of a member of the Government and amending section 1 of the 
Fines 
Act 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_192+2022.aspx 

Enforcement 

the 

on 

of 

24 

 
 
Finnish Parliament (2022), HE 255/2022 vp, Government proposal to Parliament on amendments to 
the Lotteries Act  
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_255+2022.aspx 

Finnish Parliament (2022), HE 282/2022 vp, Government proposal to Parliament for certain legislative 
amendments in the administrative branch of the Ministry of Education and Culture due to amendments 
to the Loteries Act  https://www.eduskunta.fi/FI/vaski/HallituksenEsitys/Sivut/HE_282+2022.aspx. 

Finnish  Parliament  (2022),  HE  269/2022  vp,  Government  proposal to  Parliament  for  an  act  on  the 
sector  
care 
funding  of  associations  and 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_269+2022.aspx. 

social  and  health 

foundations 

the 

in 

Finnish Parliament (2022), HE 273/2022 vp, Government proposal to Parliament for an act amending 
section 
Activities  
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_273+2022.aspx. 

Government 

Openness 

Act 

the 

the 

on 

24 

of 

of 

Finnish Parliament (2022), HE 260/2022 vp, Government proposal to Parliament for an act on subsidies 
for 
sport  
horse 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_260+2022.aspx. 

equestrian 

promotion 

breeding 

and 

the 

of 

Finnish Parliament (2023), HE 254/2022 vp, Government proposal to Parliament for acts amending the 
Act on the Financing of Candidates' Elections, the Act on Political Parties, Sections 112 and 143 l of 
Initiative  
of 
10 
the  Electoral  Act 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_254+2022.aspx. 

the  Citizens' 

the  Act 

Section 

and 

on 

Finnish Parliament (2023), HE 98/2022 vp, Government proposal to Parliament for the Transparency 
Register Act. 

Finnish 
https://www.eduskunta.fi/FI/vaski/JulkaisuMetatieto/Documents/VNS_13+2022.pdf. 

Parliament 

Opinion 

(2023), 

Legal 

Affairs 

the 

of 

Committee  

Finnish  Parliament  (2023),  Parliamentary  communication  (SS  87/2022  vp)  -  Termination  of 
convening  
matters 
Parliament's 
https://www.eduskunta.fi/FI/vaski/HallituksenEsitys/Sivut/HE_254+2022.aspx. 

Parliament 

lapsed 

work, 

and 

Finnish Parliamentary Ombudsman, website: https://www.oikeusasiamies.fi/en. 

Franet,  Institute  for  Human  Rights,  Åbo  Akademi  University  (2023),  Country  research  -  Legal 
environment  and  space  of  civil  society  organisations  in  supporting  fundamental  rights  –  Finland, 
Vienna,  EU  Agency  for  Fundamental  Rights  https://fra.europa.eu/en/country-data/2023/civic-space-
report-2023. 

GRECO (2018), Fifth Evaluation Round – Evaluation Report on Finland on preventing corruption and 
promoting integrity in central governments (top executive functions) and law enforcement agencies. 

GRECO (2020) Fifth Evaluation Round – Compliance Report on Finland on preventing corruption and 
promoting integrity in central governments (top executive functions) and law enforcement agencies. 

GRECO  (2022)  Fifth  Evaluation  Round  –  Second  Compliance  Report  on  Finland  on  preventing 
corruption  and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law 
enforcement agencies. 

Hirvola Aino, Mikkonen Salla, Skippari Mika and Tiensuu Paul (2021), Towards more open lobbying: 
Current  state  of  lobbying  in  Finland  at  central  government  level  (“Oikeusministeriön  julkaisuja, 
Selvityksiä ja ohjeita 2021”). 

Human  Rights  Center  (2022)  Report  on  national 
https://www.ihmisoikeuskeskus.fi/uutiset/pio-toimija-selvitys/. 

fundamental  and  human  rights  actors  

International  Press  Institute  (2023),  Finland:  Conviction  of  two  Helsingin  Sanomat  journalists  sets 
dangerous  precedent  https://ipi.media/finland-conviction-of-two-helsingin-sanomat-journalists-sets-
dangerous-precedent/?mc_cid=1bdc28fbf6&mc_eid=dc57a49891. 

25 

 
 
Kotkas Toomas, Husu Elisa Anniina, Wass Hanna, Kantola Anu (2021), Finland: Legal Response to 
Covid-19. 

Media Field Research Foundation (2022) Finns' trust in the news is greater than ever (Suomalaisten 
luottamus  uutisiin  suurempaa  kuin  koskaan)  https://www.medialiitto.fi/uutiset/suomalaisten-
luottamus-uutisiin-suurempaa-kuin-koskaan/. 

Ministry of Justice (2019), Supplementing Chapter 6, Section 5 of the Criminal Code by providing for 
the 
motive, 
https://oikeusministerio.fi/hanke?tunnus=OM024:00/2019.  

gender-based 

aggravation 

offence 

based 

an 

on 

of 

a 

Ministry 
https://oikeusministerio.fi/hanke?tunnus=OM015:00/2020 

(2020), 

Justice 

Enhancing 

of 

the 

restraining 

order, 

Ministry  of  Justice  (2020),  Updating  the  Act  on  the  Openness  of  Government  Activities, 
https://oikeusministerio.fi/hanke?tunnus=OM083:00/2020 

Ministry  of  Justice  (2022)  Criminal  regulation  of  targeting  -  Evaluation  memorandum  2022:29 
(Maalittamisen rikosoikeudellinen sääntely - Arviomuistio). 

Ministry  of  Justice  (2022),  Guide  on  Fundamental  and  Human  Rights  Impact  Assessment  in  Law 
Drafting, https://julkaisut.valtioneuvosto.fi/handle/10024/164464. 

Ministry  of  Justice  (2022),  Updated  Guidelines  for  Impact  Assessment  in  Law  Drafting, 
https://julkaisut.valtioneuvosto.fi/handle/10024/164932. 

Ministry of Justice (2022), Report on the assessment and future development trends of the court system, 
https://julkaisut.valtioneuvosto.fi/handle/10024/164391. 

Ministry of Justice (2023), Appointment decision: ‘Rule of Law Guarantees and Development of the 
Judicial System’ working group, No. VN/34680/2022-OM-12. 

Ministry  of  Justice  (2023),  Assessment  report  on  the  procedure  for  selecting  lay  judges, 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164666/OM_2023_8_SO.pdf?sequence=4&
isAllowed=y. 

Muukkonen,  M.  (2023),  Foreign  policy  financing  and  its  regulatory  needs (“Ulkomainen  poliittinen 
sääntelytarpeet”) 
rahoitus 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164556/OM_2023_6_SO.pdf?sequence=1&
isAllowed=y. 

sen 

ja 

National  Audit  Office  of  Finland  (2022),  Report  on  the  oversight  of  political  party  funding  2022  
https://www.vaalirahoitusvalvonta.fi/en/index.html. 

National  Audit  Office  of  Finland (2022),  Proposed  amendments  to the  Electoral  and  Party  Act  will 
significantly  improve  transparency  (“Vaali-  ja  puoluelakiin  ehdotetut  muutokset  parantavat 
https://www.vtv.fi/uutiset/vaali-ja-puoluelakiin-ehdotetut-muutokset-
merkittävästi 
parantavat-merkittavasti-avoimuutta/. 

avoimuutta”) 

OECD  (2022),  Finland  should  urgently  step  up  its  efforts  to  enforce  its  foreign  bribery  offence, 
including 
offence  
about 
https://www.oecd.org/newsroom/finland-should-urgently-step-up-its-efforts-to-enforce-its-foreign-
bribery-offence.htm. 

addressing 

definition 

concerns 

the 

the 

by 

of 

Police  of  Finland  (2022),  Criminal  investigation  relating  to  berry  business  continues  –  police  and 
Border  Guard  suspect  aggravated  human  trafficking  https ://poliisi.fi/en/-/criminal-investigation-
relating-to-berry-business-continues-police-and-border-guard-suspect-aggravated-human-trafficking. 

Reporters without Borders (2023) – Finland https://rsf.org/en/finland. 

Reporters Without Borders (2023), The conviction of Finnish journalists for revealing state secrets sets 
a  dangerous  precedent  for  press  freedom  internationally  https://rsf.org/en/conviction-finnish-
journalists-revealing-state-secrets-sets-dangerous-precedent-press-freedom. 

26 

 
Reuters 
https://reutersinstitute.politics.ox.ac.uk/digital-news-report/2022. 

the  Study  of 

Journalism 

Institute 

for 

(2022),  Digital  News  Report  2022 

Supreme  Administrative  Court  of  Finland,  judgement  of  21  December  2022,  No  21814P2021, 
ECLI:FI:KHO:2022:146 

Tax Administration (2022), Supreme Administrative Court: Customers do not have the right to object 
to the electronic release of their tax information to the media (Korkein hallinto-oikeus: Asiakkailla ei 
oikeutta  vastustaa  verotietojensa  sähköistä 
luovutusta  medialle)  https://www.vero.fi/tietoa-
verohallinnosta/uutishuone/lehdist%C3%B6tiedotteet/2022/korkein-hallinto-oikeus-asiakkailla-ei-
oikeutta-vastustaa-verotietojensa-s%C3%A4hk%C3%B6ist%C3%A4-luovutusta-medialle/. 

Transparency International (2023), Corruption Perceptions Index 2022. 

Union  of  Journalists  (2023),  Union  of  Journalists:  Journalists'  freedom  of  speech  verdict  makes  it 
difficult  for  the  public  to  access  information  (Journalistiliitto:  Toimittajien  sananvapaustuomio 
vaikeuttaa 
https://journalistiliitto.fi/fi/journalistiliitto-toimittajien-
sananvapaustuomio-vaikeuttaa-yleison-tiedonsaantia/. 

tiedonsaantia) 

yleisön 

Union  of  Journalists  (2023),  Support  for  social  media  harassment  and  bullying  from  the  Center  for 
Occupational  Safety  (Työturvallisuuskeskukselta  tukea  somehäirinnän  ja  maalittamisen  varalle) 
https://journalistiliitto.fi/fi/tyoturvallisuuskeskukselta-tukea-somehairinnan-ja-maalittamisen-varalle/. 

27 

 
 
 
 
Annex II: Country visit to Finland 

The Commission services held virtual meetings in March 2023 with: 

  Advisory Board for Civil Society Policy 
  Amnesty International Finland 
  Anti-corruption Cooperation Network 
  Chancellor of Justice 
  Council for Mass Media in Finland 
  Demla 
  Financial Intelligence Unit 
  Finnish Association of Judges 
  Finnish Bar Association 
  Finnish Media Association 
  Human Rights Centre 
  Ministry of Finance 
  Ministry of the Interior 
  Ministry of Justice 
  Ministry of Transport and Communications 
  National Audiovisual Institute 
  National Bureau of Investigation 
  National Courts Administration 
  National Police Board 
  National Prosecution Authority 
  Parliamentary Ombudsman 
  Prime Minister’s Office 
  Supreme Administrative Court 
  Supreme Court 
  Traficom 
  Transparency International Finland 
  Union of Finnish Journalists 
  Yleisradio Oy 

* The Commission also met the following organisations in a number of horizontal meetings:  

  ALDA (European Association for Local Democracy) 
  Amnesty International  
  Civil Liberties Union for Europe  
  Civil Society Europe 
  Culture Action Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum  
  European Federation of Journalists  

28 

 
 
ILGA Europe  
International Commission of Jurists 
International Federation for Human Rights (FIDH)  
International Planned Parenthood Federation European Network 
International Press Institute  

  European Partnership for Democracy  
  European Youth Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
 
 
 
 
  JEF Europe  
  Osservatorio Balcani e Caucaso Transeuropa 
  Philea  
  Reporters Without Borders  
  SOLIDAR 
  Transparency International EU 

29