COMMISSION STAFF WORKING DOCUMENT 2024 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 2024 Rule of Law Report The rule of law situation in the European Union
Date: 2024-07-24
Institutions: European Commission, Secretariat-General
Subjects: Finland, administrative transparency, corruption, democracy, freedom of the press, independence of the judiciary, infringement of EU law, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.7.2024  SWD(2024) 826 final  COMMISSION STAFF WORKING DOCUMENT 2024 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 2024 Rule of Law Report      The rule of law situation in the European Union {COM(2024) 800 final} - {SWD(2024) 801 final} - {SWD(2024) 802 final} - {SWD(2024) 803 final} - {SWD(2024) 804 final} - {SWD(2024) 805 final} - {SWD(2024) 806 final} - {SWD(2024) 807 final} - {SWD(2024) 808 final} - {SWD(2024) 809 final} - {SWD(2024) 810 final} - {SWD(2024) 811 final} - {SWD(2024) 812 final} - {SWD(2024) 813 final} - {SWD(2024) 814 final} - {SWD(2024) 815 final} - {SWD(2024) 816 final} - {SWD(2024) 817 final} - {SWD(2024) 818 final} - {SWD(2024) 819 final} - {SWD(2024) 820 final} - {SWD(2024) 821 final} - {SWD(2024) 822 final} - {SWD(2024) 823 final} - {SWD(2024) 824 final} - {SWD(2024) 825 final} - {SWD(2024) 827 final} - {SWD(2024) 828 final} - {SWD(2024) 829 final} - {SWD(2024) 830 final} - {SWD(2024) 831 final}  
 
 
ABSTRACT 

The perceived independence of the Finnish justice system continues to be very high. A working 
group  follows  up  on  the  report  on  the  assessment  and  future  development  trends  of  the  court 
system,  envisaging  conclusions  in  2027.  Some  steps  have  been  taken  on  a  reform  of  the 
appointment  process  of  lay  judges.  A  Government  Report  on  the  Administration  of  Justice 
contributed further to discussions on the most pressing issues in the justice system. The system of 
legal fees sparked a debate amongst stakeholders.  A National Legal Services Authority will be 
operational in 2025 with the aim to provide more consistent and high-quality legal aid. A case 
management system for general courts is expected to be fully implemented in 2024. Resources for 
the justice system have been increased, while structural shortages remain.  

The perception among experts and business executives is that Finland is one of the least corrupt 
countries in the world. The Ministry of Justice has started the work on the new anti-corruption 
Action Plan for 2024-27. The legislative proposal on trading in influence has been put on hold, 
and a decision on whether to revise the bribery legislation remains outstanding. No decision has 
been taken to further strengthen the integrity and accountability framework for Ministers, with no 
dedicated  Code  of  Conduct  in  place.  The  Transparency  Register  Act  entered  into  force, 
establishing  an  electronic  transparency  register  and  upgrading  the  lobbying  framework.  Two 
pending proposals on limiting ‘revolving doors’ for Ministers and on developing transparency in 
electoral and party funding legislation are expected to be submitted to Parliament by autumn 2024. 
Public  procurement,  urban  and  land  use  planning  have  been  identified  as  high  risk  sectors  for 
corruption, while various initiatives seek to address corruption risks in public procurement. 

Certain changes to the tasks and structures of the national regulatory authorities for the media are 
underway and their resources remain stable. The ethical rules for the press are being reviewed, and 
the  self-regulatory  Finnish  Council  for  Mass  Media  continues  to  deal  with  a  rising  number  of 
complaints  related  to  journalistic  ethics.  The  Government  has  published  a  research  report  with 
recommendations  on  media  concentration  and  diversity  of  media  content  in  Finland.  The 
Government is examining potential legislative amendments regarding public service media. Some 
further progress has been made concerning the right of access to information, with the government 
continuing to examine a possible reform on the Act on the Openness of Government Activities. 
Online  harassment  incidents  have  been  documented  within  the  context  of  journalists’  political 
reporting. The framework for the protection of journalists has remained strong.  

Stakeholders have reported a change in the practice of public consultations, resulting in shortened 
periods.  The  National  Human  Rights  institutions  proposed  legislative  amendments  to  further 
strengthen their position. The framework for civil society remains open, while stakeholders have 
reported on a hardening debate in relation to their role. 

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RECOMMENDATIONS 

Overall, concerning the recommendations in the 2023 Rule of Law Report, Finland has made: 

•  Significant  progress  on  the  recommendation  to  continue  to  follow-up  on  the  report  on  the 
assessment  and  future  development  trends  of  the  court  system,  and  some  progress  on 
progressing with the reform of the appointment of lay judges, taking into account European 
standards on judicial independence. 

•  No  further  progress  on  adopting  legislation  on  trading  in  influence  and  some  progress  on 
continuing to take steps to propose a revision on the criminal offence of foreign bribery. 
•  No  progress  on  strengthening  the  integrity  and  accountability  framework  applicable  to 
ministers  and  other  persons  entrusted  with  top  executive  functions  by  adopting  a  code  of 
conduct for them. 

•  Some further progress on advancing 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. 

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

•  Continue the work of the working group ‘Rule of Law Guarantees and Development of the 
Judicial System’ with a view to strengthen the independence of the justice system and increase 
the quality of legal protection.  

•  Reform  the  appointment  of  lay  judges,  taking  into  account  European  standards  on  judicial 

independence.  

•  Adopt legislation on trading  in  influence and 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.  
•  Further 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. 

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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  systems 2 .  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 
themselves 4.  Judges  are  formally  appointed  by  the  President  of  the  Republic 5.  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). 

Independence  

The  level  of  perceived  judicial  independence  in  Finland  continues  to  be  very  high  among 
both  the  general  public  and  companies.  Overall,  83%  of  the  general  population  and  91%  of 
companies perceived the level of independence of courts and judges to be ‘fairly or very good’ in 
2024 12 .  The  perceived  judicial  independence  among  the  general  public  has  decreased  in 

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-at-

law, public legal aid attorneys and licensed trial counsels. 

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

public legal aid attorneys and licensed trial counsels. 

11   The Disciplinary Board is composed of a Chair and eleven Members, six of which, in addition to the Chair, are 
attorneys-at-law elected by the supreme decision-making body of the Bar Association. The remaining members, 
two of which are licenced  trial 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  Figures 51 and 53, 2024 EU Justice Scoreboard and Figures 50 and 52, 2022 EU Justice Scoreboard. The level of 
perceived judicial independence is categorised as follows: very low (below 30% of respondents perceive judicial 

3 

 
 
 
 
 
comparison with 2023 (86%), as well as with 2020 (84%). The perceived judicial independence 
among companies has increased in comparison with 2023 (88%) as well as in comparison with 
2020 (85%)13. 

A working group follows up on the report on the assessment and future development trends 
of  the  court  system,  envisaging  conclusions  in  2027.  The  2023  Rule  of  Law  Report 
recommended  Finland  to  ‘continue  to  follow-up  on  the  report  on  the  assessment  and  future 
development trends of the court system, […], taking into account European standards on judicial 
independence’ 14 .  In  February  2023,  a  working  group  on  ‘Rule  of  Law  Guarantees  and 
Development  of  the  Judicial  System’  was  established 15  to  follow  up  on  the  report  on  the 
assessment and future development trends of the court system of October 202216. The overarching 
goal of this working group is to further strengthen the independence of the administration of justice 
and to promote the provision of high-quality legal protection and a user-oriented approach in the 
administration  of  justice17.  The  working  group  has  started  its  work  and  is  organised  into  six 
subgroups, with  a broad representation of experts,  officials,  and members of the judiciary18. In 
October 2023, a working plan was adopted for the years 2023 until 202719. In order to properly 
assess  the  necessary  constitutional  and  other  legislative  changes  required  to  ensure  the  strong 
independence  of  courts  and  judges,  in  January  2024  the  working  group  established  a  separate 
‘Independence working group’ to conduct this assessment and make proposals. This new working 

independence as fairly good and very good); low (between 30-39%), average (between 40-59%), high (between 
60-75%), very high (above 75%). 

13   82% of the companies in Finland are either fairly or very confident that their investments are protected by the law 
and courts in the Member State. Only 4% of the surveyed companies see the quality, efficiency or independence 
of justice as one of the main reasons for concern about investment protection in the country. Figures 55 and 56, 
2024 EU Justice Scoreboard.  

14   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
15   Decision of the former Finnish Government of 1 February 2023, No. VN/34680/2022-OM-12. Page two of the 
decision refers to the tasks of the working group, where point 5 foresees the working group to ‘assess the need for 
amendments to the Constitution and other legislation, as it deems necessary to ensure strong independence of the 
judiciary and make proposals for legislative changes’.  

16   This report is also known as ‘Memorandum of the working group of administration of justice’. The report proposes, 
among  other  changes,  a  revision  of  the  Constitution  to  introduce  safeguards  against  undue  political  influence, 
laying  down  the  maximum  number  of  Supreme  Court  Judges  in  the  Constitution,  as  well  as  a  compulsory 
retirement age of judges. See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, 
p. 5. Input from Finland for the 2024 Rule of Law Report, p. 7.  

17   Input from Finland for the 2024 Rule of Law Report, p. 8. 2023 Rule of Law Report, Country Chapter on the rule 
of law situation in Finland, p. 5. Some of the challenges in the agenda stem also from the Report on Administration 
of Justice.  

18   The  six  subgroups  are  as  follows:  1.  Crime  and  handling  of  criminal  cases,  as  well  as  punishments  and  their 
enforcement; 2. Handling of civil cases, mediation and alternative dispute resolution methods; 3. Administrative 
law matters and special court matters; 4. Legal advice and assistance; 5. Enforcement and operation of the National 
Enforcement Authority; 6. Administrative, personnel and training matters. Ministry of Justice (2023), Decision 
No VN/34680/2022. Input from Finland for the 2024 Rule of Law Report, p. 7, Information received from the 
Ministry of Justice, Supreme Court, Supreme Administrative Court, Finnish Association of Judges, and Finnish 
Bar  Association  in  the  context  of  the  country  visit  to  Finland.  Written  contribution  from  the  Finnish  Bar 
Association for the 2024 Rule of Law Report, p. 11.  

19   Input from Finland for the 2024 Rule of Law Report, p. 7. Information received from the Ministry of Justice and 
the  National  Courts Administration in the context of the  country visit to Finland. Finnish Government (2023), 
Working  Plan  of  the  Working  Group  ‘Rule  of  Law  Guarantees  and  Development  of  the  Judicial  System’ 
(Työsuunnitelma, Oikeuslaitostyöryhmä vuosille 2023-2027).  

4 

 
 
 
 
group particularly focuses on the current constitutional provisions regarding the number of judges 
in the highest courts, judges' right to remain in office, the appointment process for judges, and 
judicial  misconduct.  20 .  These  objectives  are  welcomed  by  stakeholders,  who  are  broadly 
represented in the working group21. The plan of the working group foresees the process to be split 
in phases and is expected to present its conclusions in 202722. Considering that a follow-up process 
to the report on the assessment and future development trends of the court system has been put in 
place, there has been significant progress on this part of the recommendation made in the 2023 
Rule of Law Report.  

Some progress has been made on a reform of the appointment process of lay judges, which 
is  being  discussed  in  the  framework  of  the  working  group.  The  2023  Rule  of  Law  Report 
recommended  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’23. As already reported in the 
2023  Report,  lay  judges,  who  participate  in  certain  non-criminal  cases24,  as  well  as  in  serious 
criminal  cases,  where  the  maximum  penalty  of  an  offence  is  more  than  two  years  of 
imprisonment25, are currently appointed by political parties, with the number of lay judges each 
party may appoint corresponding to the outcome of the local elections26. Following the publication 
of the assessment report on the procedure for selecting lay judges by the Ministry of Justice in 
February 2023, the Ministry is currently evaluating alternatives to the current selection procedure, 

20   Ministry of Justice (2024), Decision No. VN/1886/2024-OM-2 of 12 February 2024, and also as stated in a press 
release  of  the  Ministry  of  Justice  on  23  April  2024  ‘The  work  for  the  independence  of  judiciary  continues”. 
Information received from the Supreme Court in the context of the country visit to Finland. Finnish Government 
(2024), Revised decision on the subgroup on the independence of the judiciary from February 2024. 

21   For example, the chair of the Board of Directors of NCA, who is also a judge of the Supreme Court, presides the 
main Working Group; The Presidents of the Supreme Court and Supreme Administrative Court are presiding some 
of these subgroups. During the setting up of the Working Group and its subgroups, a suggestion to amend Article 
106 of the Constitution (to give courts more flexibility in constitutional matters) was made. However, the Ministry 
of Justice has eventually abandoned this suggestion and is seen  as a missed opportunity by many stakeholders. 
Information provided in the context of the country visit to Finland by the Finnish Bar Association and the Supreme 
Court. The President of the Supreme Court stated in a press release that he regrets the decision not to strengthen 
the independence of the judiciary, as quoted in Helsingin Sanomat (2024). 

22   The working plan envisages evaluation of alternative measures and come up with an options paper in autumn 2024, 
make proposals for legislative amendments by the end of 2026, including possible amendments to the Constitution; 
consulting  with  experts  and  updating  the  options  paper  based  on  the  consultations  by  the  beginning  of  2027; 
presenting the options paper with proposed measures,  including a plan for their implementation, by the end of 
2027. Working plan pp. 6, 9, 10. Input from Finland for the 2024 Rule of Law Report, p. 7. Information provided 
in the context of the country visit to Finland by the NCA, the Finnish Bar Association, the Chancellor of Justice 
and the Supreme Court.  

23   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
24   So-called land law matters, which deal with disputes arising from real estate transactions; information provided at 
the website of the Finnish judiciary, https://oikeus.fi/tuomioistuimet/en/index/asiat/riita-asiat/landcourtcases.html 
udet/whatmattersaredealtwithbythedistrictcourt.html#. 

25   In a panel of one professional judge and two lay judges.  See CEPEJ Evaluation Report 2022 – Country Profile 

Finland, p. 49. 

26   There  are  no  lay  judges  in  appeal  courts,  administrative  courts,  the  Supreme  Court  or  specialised  courts. 

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

5 

 
 
 
 
however, with no clear timeline27. This matter is discussed also in the framework of the working 
group on ‘Rule of Law  Guarantees and  Development of the Judicial System’. While there is  a 
general consensus on the need to amend the selection procedure of lay judges, some stakeholders 
call for the institute of lay judges to be entirely abolished28. In view of the foregoing, overall, some 
progress has been made on this part of the recommendation addressed in the 2023 Rule of Law 
Report.  

Quality  

The Government Report on the Administration of Justice has contributed to the discussions 
on the most pressing issues in the justice system. The 2023 Rule of Law Report highlighted the 
adoption of a Report on the Administration of Justice (hereafter ‘the report’) in November 2022, 
offering a comprehensive overview of the current state of the administration of justice in Finland29. 
The key issues identified in the report concern the length of proceedings, the high cost of trials, 
and  the  underfunding  of  the  justice  system30.  The  findings  of  this  report  were  the  basis  for  an 
increase in the resources allocated to the judiciary31. The challenges outlined in the report are also 
taken into account by a working group set up in September 2023 by the Ministry of Justice and the 
Ministry of Education and Culture to conduct a comprehensive assessment of legal education32. 
Parliament mandated the Government to promote legislative amendments presented in the report, 
but also to issue a written report by the end of 2023 and a comprehensive report by September 
202633.  

The  system  of  legal  fees  sparked  a  debate  amongst  stakeholders.  The  Ministry  of  Justice 
received  an  assessment  report  on  the  effects  of  the  Act  on  Court  Fees,  which  is  in  force  since 
201634. This report concluded, among others, that while the current system of court fees does not 
hinder  access  to  justice,  in  some  cases  court  fees  might  be  inappropriately  high  and  suggests 

27   Input from Finland for the 2024 Rule of Law Report, p. 8. The commitment to amend the procedure of selection 
of lay judges is also stated in the Government programme, adopted in June 2023, p. 209. Input from Finland for 
the 2024 Rule of Law Report, p. 7. Information received by the Ministry of Justice in the context of the country 
visit to Finland. 

28   Information provided in the context of the country visit to Finland by the Finnish Association of Judges, National 
Courts  Administration,  and  Parliamentary  Ombudsperson.  The  National  Courts  Administration  explained  that 
there is broad consensus within the judiciary that the current system of participation of lay judges is not working 
as it should, despite the long-standing tradition.  

29   Ministry of Justice, Government report on administration of justice.  
30   The report, p. 3; Input from Finland for the 2023 Rule of Law Report, p. 5. 2023 Rule of Law Report, Country 

Chapter on the rule of law situation in Finland, p. 6. 

31   Input from Finland for the 2024 Rule of Law Report, pp. 9, 10. Information provided in the context of the country 

visit to Finland by the Finnish Bar Association.  

32   Input from Finland for the 2024 Rule of Law Report, p. 11. The challenges taken into account are notably the 
anticipated retirements, regional disparities, and the impact of digitalisation. The project is expected to be finished 
by July 2024.  

33   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 6. Input from Finland for the 

2024 Rule of Law Report, p. 28.  

34   Input from Finland for the 2024 Rule of Law Report, p. 9. The Legal Affairs Committee of the Parliament kept 
monitoring the effects of this reform and for that reason the Ministry of Justice commissioned an assessment that 
was conducted by the University of Eastern Finland. Additional input from Finland for the 2024 Rule of Law 
Report. 

6 

 
 
 
 
lowering the court fees in certain respect35. Stakeholders consider that the legal fees are prohibitive 
in terms of access to courts36. The Report on the Administration of Justice notes that the level of 
legal aid fees paid for private practitioners should be increased37. In this light, the Bar Association 
has  suggested  a  reform  to  tackle  the  cost  issue,  including  by  reviewing  the  cost  distribution 
between the parties 38. The widened courts’ discretion in allocating legal costs in civil cases has 
been in place since May 2023, as indicated in the 2023 Rule of Law Report39. Evaluations on the 
impact of this reform are currently ongoing40. 

A National Legal Services Authority will be operational in 2025 with the aim to provide more 
consistent  and  high-quality  legal  aid.  The  Government  aims  to  improve  the  conditions  for 
providing  more  consistent  and  high-quality  legal  aid,  public  guardianship,  financial  and  debt 
counselling services by establishing a National Legal Services Authority (‘the Authority’)41. The 
Authority will consist of a central administration and legal aid and public guardianship offices. 
The aim of this Authority will be to enable a more efficient and coherent development, equally 
distributed availability of services,  as well as  a  better resourcing of  activities42. It will become 
operational on 1 January 202543.  

The case management system for general courts is expected to be fully implemented in 2024. 
The gradual deployment of the case management and digitalisation system for the general courts 
(‘AIPA’) is ongoing and is expected to be fully  operational in June 2024, with certain steps to 
follow at a later stage, such as the inclusion of insolvency cases44. The prosecution offices will 
also transition to AIPA, where it is expected to be fully implemented by 202545. The corresponding 
system for the administrative courts (‘HAIPA’), finalised since 2020, is already used by all staff 
in courts, including judges46, with stakeholders noting room to make further use of the potential to 

35   Input from Finland for the 2024 Rule of Law Report, p. 9.  
36   Information received from the Supreme Court and the Finnish Bar Association in the context of the country visit 

to Finland. 

37   The Report on the Administration of Justice, p. 49 Written contribution from the Finnish Bar Association for the 
2024 Rule of Law Report p. 14. The amount has not been increased since 2014, while the private practitioners 
handle around 80 % of the criminal cases. Information received from the Finnish Bar Association in the context 
of the country visit to Finland.  

38   Written contribution from the Finnish Bar Association for the 2024 Rule of Law Report, p. 15. The bearing of 
costs by the losing party was also raised as an issue by the Supreme Court. Information received  from Supreme 
Court and Finnish Association of Judges in the context of the country visit to Finland. 
39   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. 
40   Information received from the Ministry of Justice in the context of the country visit to Finland. 2023 Rule of Law 

Report, Country Chapter on the rule of law situation in Finland, p. 7. 

41   Government Programme, p. 211. Input from Finland for the 2024 Rule of Law Report, p. 9. Information received 
from the Ministry of Justice in the context of the country visit to Finland. Currently, there are six legal aid and 
public  guardianship  districts.  The  Act  No.  1133/2023  Coll.,  on  the  National  Legal  Services  Authority,  was 
approved by the Parliament on 24 November 2023 and will enter into force on 1 January 2025. 

42   Input from Finland for the 2024 Rule of Law Report, p. 9. Act No. 1133/2023 Coll., on the National Legal Services 

Authority 1: 2. 

43   Ministry  of  Justice  (2023),  Decision  No.  VN/24741/2023  of  21  September  2023  on  the  establishment  of  the 

National Legal Service Authority. 

44   Input from Finland for the 2024 Rule of Law Report, p. 11. For further information, see 2021, 2022 and 2023 
Country Chapters on the rule of law situation in Finland, p. 3 (for 2021), p. 4 (for 2022) and pp. 6-7 (for 2023). 

45   Information received from the Ministry of Justice in the context of the country visit to Finland.  
46   Input from Finland for the 2024 Rule of Law Report, p. 11.  

7 

 
 
 
 
extract data from the system, including to assess the workload47. The reform of the use of video 
recordings in taking of evidence, adopted in 2022, will come into force once a data system for 
video  recordings  has  been  developed,  as  expected  in  2025 48 .  Stakeholders  welcomed  the 
introduction of the AIPA system, while also considering it to be only a minimal solution, indicating 
clear  room  for  further  development49.  Overall,  according  to  the  2024  EU  Justice  Scoreboard, 
Finland mostly has procedural rules for the use of digital technology in place50 as well as electronic 
communication tools in courts and prosecution services51, while digital solutions to initiate and 
follow proceedings in civil, commercial, and criminal cases52 and online publication of judgments 
could be improved53. A new portal for attorneys and other legal representation was expected to be 
operational  by  the  end  of  2023.  However,  no  further  developments  have  taken  place  in  that 
regard54.  

Resources for the justice system have been increased, while structural shortages remain. The 
Report on the Administration of Justice concluded in 2022 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 justice55, with approximately one third 
of this amount to be allocated to the courts56. As of 2024, based on these conclusions, additional 
permanent funding was allocated to the courts, and other funding is planned for the next years57. 
This resulted also in a significant increase in human resources – approximately 100 new judges 
and court staff58. Stakeholders welcomed this additional funding and considered it as an important 

47   Information received from the Supreme Administrative Court in the context of the country visit to Finland.  
48   Ibidem, pp. 11-12.  
49   Information  received  from  the  Supreme  Court  in  the  context  of  the  country  visit  to  Finland.  The  Finnish 
Association of Judges reported practical issues with the use of the AIPA system in civil cases during the past three 
years and has rather pessimistic views on its future usage also in criminal cases. The complaint by the Association 
of District Court Judges filed to the National Audit Office (reported in the 2023 Rule of Law  Report,  country 
chapter on the rule of law situation in Finland, p. 7), regarding the use of finances for the AIPA system, has still 
not been decided upon. Information provided by the Finnish Association of Judges in the context of the country 
visit to Finland. 

50   In particular for administrative cases, and also to a large extent for civil, commercial and criminal cases. Figure 

43, 2024 EU Justice Scoreboard.  

51   Figures 45-46, 2024 EU Justice Scoreboard.  
52   E.g. digital solutions enabling the clients in civil or commercial cases to access the electronic file of their closed 
or  ongoing  cases,  or  in  the  criminal  cases  the  possibility  for  the  defendant  to  access  their  ongoing  case 
electronically. Figures 47-48, 2024 EU Justice Scoreboard.  

53   Figure 49, 2024 EU Justice Scoreboard.  
54   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. Contribution from the 

Finnish Association of Judges, p. 16.  

55   The Report on the Administration of Justice, p. 5. 2023 Rule of Law Report, Country Chapter on the rule of law 

situation in Finland, p. 8.  

56  Information received from the Finnish Bar Association, Supreme Court in the context of the country visit to Finland. 
57   In 2024, EUR 19.4 million for the courts and 30 million for the administration of justice in general. In 2025, the 
increase for the administration of justice is planned to be EUR 65 million. Input from Finland for the 2024 Rule 
of Law Report, pp. 9-10. Information on the increase of the resources for the judiciary received from the National 
Courts Administration, Supreme Court, Supreme Administrative Court in the context of country visit to Finland. 
See on that matter also Figure 34, 2024 EU Justice Scoreboard.  

58   Input  from  Finland  for  the  2024  Rule  of  Law  Report,  p.  10.  Information  received  from  the  National  Courts 

Administration, Supreme Court in the context of country visit to Finland. 

8 

 
 
 
 
step59. At the same time, they reported that there are still shortages, notably as regards securing 
permanent  positions  for  judges 60 ,  funds  to  cover  the  increased  costs  for  the  use  of  digital 
technology61, as well as the increased costs of the renting of the courts’ premises62. Stakeholders 
also reported that the supporting staff working at courts remains underfunded63. [placeholder for a 
review of the salary system] The human resources at the public prosecution service have slightly 
increased and are expected to increase further64. This has also had a positive effect on the number 
of pending cases in 2023, which decreased compared to previous years, and estimations for 2024 
indicate a similar trend65.  

Efficiency 

The  justice  system  performs  overall  efficiently,  though  stakeholders  see  some  room  for 
improvement as regards the length of proceedings. The estimated time to resolve litigious civil 
and commercial cases at first instance has seen a further slight increase and remains at an average 
level (327 days in 2022 compared to 305 days in 2021), while the clearance rate remains stable at 
100%66. In administrative cases, the average time to resolve cases has slightly decreased (281 days 
in 2022 compared to 296 in 2021), while the clearance rate has further improved (104% in 2022 
compared to 102% in 2021)67. Certain challenges exist regarding the average length of proceedings 
in specific areas of EU law, such as competition law (805 days in 2022) and EU trademarks (681 
days  in  2022),  while  Finland  performs  well  in  bribery  cases  (186  days)68.  Following  also  the 
findings of the 2022 Report on the Administration of Justice, which had identified the length of 
proceedings as one of the key issues in the justice system69, stakeholders continue to consider there 

59   Information  received  from  the  NCA,  Supreme  Court,  the  Finnish  Association  of  Judges  in  the  context  of  the 

country visit to Finland.  

60   Information received from the Finnish Association of Judges. They reported that in the district court in Helsinki, 
for example, one third of judges’ functions on non-permanent positions, which they perceive as posing the risk of 
interference with their independence. 

61   Information received from the NCA in the context of the country visit to Finland.  
62   Information  received from  the  NCA  in  the  context  of  the country  visit  to  Finland.  The  high  level of premises 
expenditure and their growth is also noted in the Input from Finland for the 2024 Rule of Law Report, p. 10. The 
Finnish Bar Association reported the trend of judges and prosecutors sharing the same premises, regardless of 
separated entrances, as potentially interfering with the independence of both bodies. Contribution from the Finnish 
Bar Association for the 2024 Rule of Law Report, p. 12.  

63   Information  received  from  the  Finnish  Association  of  Judges,  Supreme  Court,  Supreme  Administrative  Court. 

Stakeholders have generally agreed that the salaries of the administrative staff are uncompetitive.  

64   Input from Finland for the 2024 Rule of Law Report, p. 10. Information received from the National Prosecution 

Authority in the context of the country visit to Finland.  

65   While at the end of 2022 there were cca 18 900 open cases, in 2023 there were cca 17 300. The goal for 2024 is 
16 400 and the status up till 22. 3. 2024 was 17 060. Input from Finland for the 2024 Rule of Law Report, p. 10. 
Information received from the National Prosecution Authority in the context of the country visit to Finland.  

66   Figures 6 and 11, 2024 EU Justice Scoreboard.  
67   Figures 8 and 12, 2024 EU Justice Scoreboard.  
68   Figures 17, 19 and 23, 2024 EU Justice Scoreboard.  
69   2023 Rule of Law Report, Country Chapter on the rule of law situation, pp. 8-9.  

9 

 
 
 
 
is room for improvement in this respect70. A number of the measures related to increasing resources 
and reforming the procedural code aim to expedite judicial proceedings71.  

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)72, the National 
Audit Office of Finland (NAOF), the Finnish Competition and Consumer Authority as well as the 
Parliamentary Ombudsman73 and Chancellor of Justice74. 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 anti-corruption network which brings together 
representatives of several ministries, police, trade unions and civil society75. 

The  perception  among  experts  and  business  executives  is  that  Finland  is  one  of  the  least 
corrupt  countries  in  the  world.  In  the  2023  Corruption  Perceptions  Index  by  Transparency 
International,  Finland  scores  87/100  and  ranks  2nd  in  the  European  Union  and  globally76.  This 
perception has been relatively stable over the past five years77. The 2024 Special Eurobarometer 
on Corruption shows that 18% of respondents consider corruption widespread in their country (EU 
average 68%) and 6% of respondents feel personally affected by corruption in their daily lives (EU 
average 27%)78. As regards businesses, 18% of companies consider that corruption is widespread 
(EU average 65%) and 14% consider that that corruption is a problem when doing business (EU 
average  36%) 79 .  Furthermore,  48%  of  respondents  find  that  there  are  enough  successful 
prosecutions to deter people from corrupt practices (EU average 32%)80, while 63% of companies 

70   Contribution from the Finnish Bar Association for the 2024 Rule of Law Report, p. 17 and Contribution from the 
Chancellor  of  Justice  for  the  2024  Rule  of  law  Report,  p.  18,  with  the  latter  noting  specific  challenges  at  the 
Helsinki  District  Court.  Information  received  from  the  Finnish  Association  of  Judges,  Supreme  Court,  in  the 
context of the country visit to Finland.  

71   Input from Finland for the 2024 Rule of Law Report, p. 12.  
72   Financial Intelligence Unit: https://poliisi.fi/en/money-laundering. 
73   Parliamentary Ombudsman of Finland: https://www.oikeusasiamies.fi/en. 
74   Chancellor of Justice: https://www.okv.fi/en/. 
75   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. 

76   Transparency  International,  Corruption  Perceptions  Index  2023  (2024).  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). 

77   In  2019  the  score  was  86,  while,  in  2023,  the  score  is  87.  The  score  significantly  increases/decreases  when  it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  has  been  relatively  stable 
(changes from 1-3 points) in the last five years. 

78   Special Eurobarometer 584 on Citizens’ attitudes towards corruption in the EU (2024. The Eurobarometer data on 
citizens’  corruption  perception  and  experience  is  updated  every  year.  The  previous  data  set  is  the  Special 
Eurobarometer 534 (2023). 

79   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). The Eurobarometer data 
on business attitudes towards corruption as is updated every year. The previous data set is the Flash Eurobarometer 
507 (2022). 

80   Special Eurobarometer 584 on Citizens’ attitudes towards corruption in the EU (2024). 

10 

 
 
 
 
believe that people and businesses caught for bribing a senior official are appropriately punished 
(EU average 31%)81. 

The Ministry of Justice has started work on the new anti-corruption Action Plan for 2024-
2027. The Ministry of Justice expects to complete the final implementation report of the National 
Anti-Corruption Strategy and 2021-2023 Action Plan by July 202482. In March 2024, the Ministry 
of Justice received the mandate from the Government to develop the new 2024-2027 Action Plan, 
which will be based on the already established anti-corruption strategy83. The Ministry of Justice 
has committed to involve civil society in designing the new Action Plan, aiming to finalise it by 
the end of 202484. Anti-corruption policy for the police, which was recommended by GRECO85, 
was published on 19 March 202486. On 14 June 2024, the National Police Board published the 
implementation plan of the Anti-corruption policy of the Police87. The anti-corruption action plan 
for the border guard entered into force in November 2023. Additionally, the tax administration’s 
tailor-made anti-corruption policy has been suggested by the authorities as a best-practice model 
for public sector organisations88.  

The national proposal for legislation on trading in influence is currently on hold with a view 
to align with EU level legislation currently under negotiations, and consequently there has 
been no further progress to adopt legislation. The 2023 Rule of Law Report recommended to 
Finland to ‘adopt legislation on trading in influence […]’89. As already reported in previous years, 
the  Ministry  of  Justice  prepared  a  draft  proposal  on  criminalising  trading  in  influence,  which 
underwent public consultation in November 202290. However, the draft proposal did not advance 

81   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). 
82   Information received from the Ministry of Justice in the context of the country visit to Finland. The Action Plan 
of  the  Anti-Corruption  Strategy  for  2021–2023  included  79  actions.  As  of  March  2024,  76  of  the  79  planned 
measures started to be implemented. Only 3 actions remain ‘non-started’, one of which regards manipulation of 
sport competitions.  

83   Information received from the Ministry of Justice in the context of the country visit to Finland. The key priorities 
of  the  strategy  remain  the  same:  reinforcement  and  clarification  of  the  official  structures  for  preventing  and 
combating  corruption  and  improvement  of  cooperation  between  the  parties  involved;  raising  awareness  of 
corruption; increasing transparency; promoting the exposure of cases of corruption; examination of the functioning 
of  legislation  relevant  to  the  prevention  of  corruption,  and  the  development  of  legislation;  and  promotion  of 
research related to corruption and its prevention.  

84   Information received from the Ministry of Justice in the context of the country visit to Finland. Starting from the 
end of March 2024, the Ministry of Justice expects that the overall designing process would take from three to 
four months. Following the publication of the report, the Ministry of Justice will organise a webinar to present the 
results of the Action Plan. Written contribution from the Finnish authorities in the context of the country visit to 
Finland. 

85   GRECO Fifth Evaluation Round – Second Compliance Report, recommendation vii, p. 9.  
86   Police of Finland (2024), Police Anticorruption Policy. 
87   Written contribution from the Finnish authorities in the context of the country visit to Finland. The National Police 

Board has drafted the Police Anticorruption Policy in February 2024.  

88   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 17. 
89   Ibidem, p. 2. In the 2023 Rule of Law Report, the Commission concluded that some progress was made on the 

recommendation. 

90   Both the National Police Board the National Bureau of Investigation expressed themselves in favor of the proposal, 
as  it  would  play  an  important  role  in  the  fight  against  cross-border  corruption  crime.  See  Draft  proposal  to 
criminalise the offence of trading influence. Summary of the opinion (2023). 2023 Rule of Law Report, Country 
Chapter on the rule of law situation in Finland, pp. 10-11; 2022 Rule of Law Report, Country Chapter on the rule 
of law situation in Finland, p. 8.  

11 

 
 
 
 
to  parliamentary  proceedings  due  to  the  Parliamentary  elections  in  spring  2023.  The  National 
Prosecution Authority was overall satisfied with the proposal, although some of its concerns were 
not taken into account91. The Ministry of Justice has in the meantime indicated its preference to 
wait for the finalisation of the current discussion at European level on the proposal for a directive 
combating corruption, before adopting at national legislation92. Therefore, as the national proposal 
on  trading  in  influence  did  not  advance,  no  further  progress  has  been  made  on  this  part  of the 
recommendation made in the 2023 Rule of Law Report. 

There  has  been  some  progress  on  revising  the  criminal  offence  of  foreign  bribery,  as  the 
Ministry of Justice is still to decide on the revision of the offence. The 2023 Rule of Law Report 
recommended  to  Finland  to  ‘[…]  continue  to  take  steps  to  propose  a  revision  on  the  criminal 
offence of foreign bribery’93. The Ministry of Justice has not yet decided on the opportunity of 
further amending the Criminal Code provisions on bribery offences. The pending decision has been 
noted in previous reports94, and by the OECD, which underlined the need for Finland to enforce 
its foreign bribery offence, including by addressing concerns about its definition95. In February 
2022 the Government had published an independent study on corruption in international business, 
covering also foreign bribery, which noted the need to further develop the legislative framework96. 
The Ministry of Justice commissioned in the second half of 2023 a new independent study97. The 
Ministry of Justice still has to decide on amending the legislation on bribery on the basis of this 
latest study, which has been published on 31 May 202498. Overall, as a second study was launched 
on the opportunity to revise the provisions on bribery offences, some progress has been made on 
this part of the recommendation made in the 2023 Report. 

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

92   Information received from the Ministry of Justice in the context of the country visit to Finland. Proposal for a 

Directive of the European Parliament and of the Council on combating corruption, COM(2023) 234 final. 

93   2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
94   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. 

95   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.  

96   Government Office (2022), Corruption in international business, Current state of regulation, application practice 
and training and needs for change. The study shows that there is a need to develop the supply of education as well 
as  legislation  and  application  practice.  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   The study is currently with the Ministry of Justice to be revised. Input from Finland for the 2024 Rule of Law 
Report,  p.  6.  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Finland,  pp.  9-10. 
Information received from the Ministry of Justice in the context of the country visit to Finland.  

98   Information received from the Ministry of Justice in the context of the country visit to Finland. See also Finnish 

Government (2024), Need to develop the bribery criminal code. 

12 

 
 
 
 
Cooperation between the police and prosecution continued smoothly99, with a strengthening 
of  resources  for  police  and  prosecution  allowing  them  to  efficiently  perform  their  tasks. 
Police  resources  on  prevention  and  investigation  of  corruption  have  been  strengthened  in  the 
framework of the National Anti-Corruption Strategy and 2021-2023 Action Plan100. The Police 
considers  the  current  level  of  resources  and  expertise  to  deal  with  anti-corruption  cases  as 
adequate101. The Police benefits from the support of external experts and specific trainings for the 
National Bureau of Investigation (NBI), local police stations and the Financial Intelligence Unit 
(FIU) on how to identify corruption cases102. Its objectives focus on enhancing public trust and 
identifying  corruption  risks  in  the  police.  There  are  six  prosecutors  specialised  in  corruption 
offences and 19 specialised in prosecuting offences committed in office103. Specialised financial 
crime  prosecutors  often  handle  bribery  offences  in  all  prosecution  districts 104 ,  while  junior 
prosecutors  are  involved  in  corruption  cases  to  assist  higher-level  prosecutors.  As  for  the 
cooperation  with  the  EPPO,  cooperation  is  good105.  The  number  of  prosecutions  of  corruption 
offences  is  stable.  In  2023,  40  corruption  cases  were  received  by  the  prosecutor  and  25  were 
decided106. By the same year, the number of corruption cases pending a decision of the prosecutor 
was 15, of which 3 had been opened for over 12 months107. Compared to 2022 – with prosecution 
service  receiving  nine  corruption  cases  from  the  police  –  data  are  reported  to  be  stable  on  the 
average of ten cases prosecuted per year108.  

There  has  been  no  progress  on  the  integrity  framework  for  Ministers  and  top  executive 
functions,  with  Ministers  still  not  covered  by  the  Code  of  Conduct,  pending  a  political 
decision. The 2023 Rule of Law Report recommended to Finland to ‘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’109. A Code of Conduct for civil servants and 
top executive functions is in place since 2021, which however does not apply to Ministers110. The 

99   Information received from the national prosecutor and police in the context of the country visit to Finland. 
100  Input  from  Finland  for  the  2024  Rule  of  Law  Report,  p.  14.  Of  these  two  additional  police  officers,  one  was 
assigned to the NBI financial team, the other to the FIU. In 2024, two more police officers are expected to be 
assigned to the NBI investigation division to investigate corruption offences.  

101  Information received from National Police Board and NBI in the context of the country visit to Finland. The Police 
does not foresee upcoming discussions to establish a separate and dedicated unit to corruption. Within the NBI, 
one national coordinator is responsible for the fight against corruption, and two detectives are charged with anti-
corruption tasks. 

102  Information received from the NBI in the context of the country visit to Finland. 
103  Written input from the Ministry of Justice following the country visit of Finland.  
104  Written contribution from the National Prosecutor Authority in the context of the country visit in Finland. 
105  The 2023 EPPO Annual Report does not refer corruption cases for Finland.  
106  Written input from the Ministry of Justice following the country visit of Finland. 
107  Written contribution from the Finnish authorities in the context of the country visit to Finland.  
108  According to the data for years 2010-2019, received in the context of the 2021 country visit to Finland from the 
national prosecutor, the average annual number of cases of prosecuted corruption and economic crime offences 
has remained relatively stable over the ten-year reporting period with an average of ten cases per year. See also 
2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10, in 2022 data were reported 
to have returned to the average of ten cases prosecuted per year.  

109  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. 
110  The Code 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. Finnish Government (2021), Code of conduct for officials. 
The Code of Conduct on Civil Service Ethics was issued in 2021. It targets senior officials in central government, 

13 

 
 
 
 
 
Minister’s  Handbook  aims  to  give  an  oversight  of  the  organisation  and  functioning  of  the 
government,  including  on  legality  issues,  ministerial  responsibilities,  and  principles  of  good 
governance, which was revised in spring 2023111. Still, a dedicated Code of Conduct would address 
other  sensitive  integrity  related  areas,  currently  not  covered  in  the  Ministers’  Handbook112.  A 
background memorandum was published by the Ministry of Justice in August 2022113, describing 
the  state  of  the  regulation  on  ministerial  responsibilities.  The  memorandum  has  not  yet  been 
discussed in Parliament114. As previously noted115, the personal scope of the Code of Conduct for 
civil servants and top executive officials could be further expanded to apply explicitly to Ministers, 
as also recommended by GRECO116. No concrete timeline has been fixed to discuss the adoption 
of a Code of Conduct for ministers117. Overall, as Ministers are not covered by a dedicated Code 
of Conduct, there has been no progress on the implementation of the recommendation made in the 
2023 Rule of Law Report. 

The Transparency Register Act entered into force, establishing an electronic transparency 
register  and  upgrading  the  lobbying  framework.  The  Transparency  Registry  Act  –  which 
entered into force on 1 January 2024 – lays down the obligation to register influencing activities 

including special advisers, who are since then also subject to financial disclosure requirements. 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.  

111  Legal and political responsibility of ministers, ministers’ declaration of private interests, disqualification including 
example cases concerning ministers, receiving hospitality, benefits and gifts as a minister, ministers’ commitment 
to  actions  when  transferring  to  other  duties,  principles  of  good  governance,  openness  of  administration,  non-
disclosure and prohibition on the use of information, insider matters, civil servants’ obligations and liability for 
acts in office.  

112  GRECO  Fifth  Evaluation  Round  – 2nd  Compliance  Report,  recommendation  i,  paras.  17,  96. Investigations  of 
corruption by members of the Government follow a different procedure than normal corruption investigation. The 
Minister’s Handbook is generic and no enforcement mechanism is in place. The website of the Ministry of Finance 
contains declarations of private interests of senior management in central government and of special advisers to 
ministers.  However,  there  is  no  centralised  statistical  monitoring  of  declarations  of  interest,  and  these  are  not 
verified  in  a  specific  process.  It  is  the  duty  of  a  civil  servant  to  correct  and  supplement  any  changes  and 
shortcomings in the information contained in the declaration of private interests (State Civil Servants’ Act, section 
8a). In addition, the authority concerned is responsible for keeping the published information up to date (State 
Civil Servants’ Act, section 8d).  

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

prosecute a Member of Parliament. 

114 Information received from the Ministry of Justice in the context of the country visit to Finland. 2023 Rule of Law 
Report, Country Chapter on the rule of law situation in Finland, p. 12. Input from Finland for the 2023 Rule of 
Law Report, p. 20.  

115  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10. 2023 Rule of Law Report, 

Country Chapter on the rule of law situation in Finland, pp. 13-14.  

116  GRECO noted the issue as a potential obstacle to the effective functioning of the criminal justice system. GRECO 
Fifth  Evaluation  Round  –  2nd  Compliance  Report,  recommendation  iv  and  v,  paras.  28-41.  GRECO  Fifth 
Evaluation Round – Compliance Report, para. 39-41. The Ministry of Finance and the Ministry of Justice have 
jointly prepared an integrity training course for senior civil servants. According to the Ministry of Justice, this is 
the first time that Finland offers dedicated integrity and anti-corruption training to top civil servants. The course 
is also recommended for mid-level management. The digital eOppiva course consists of seven modules: (1) role 
of top management in fostering good governance and fighting corruption, (2) foundations of good administration, 
(3) corruption prevention, (4) conflict of interests, (5) stakeholder cooperation, (6) emerging ethical questions, and 
(7) way forward. 

117  Information received from the Prime Minister’s Office in the context of the country visit to Finland.  

14 

 
 
 
 
and related professional advice by legal persons and private traders118. Civil society organisations 
welcomed the legislation as an important step forward119. As of 2024, lobbying activities targeted 
at Parliament and ministries must be reported to the Transparency Register, which is managed by 
the  National  Audit  Office.  The  Government  will  monitor  the  functioning  of  the  Transparency 
Register  and  evaluate  the  relevant  legislation  towards  the  end  of  the  government  term  (2026-
2027)120. The Ministry of Justice is working on a communication and training campaign: the new 
transparency register has also been included as a specific topic in the e-learning course for the top 
executive functions. In connection with the register, an advisory board appointed according to law 
by the National Auditing Office, involving the Ministry of Justice, the Ministry of Finance, the 
National Audit Office, variety of register users, representatives of those subject to the reporting 
obligation  and  representatives  of  academia,  drafted  recommendations  on  good  practices  on 
lobbying which were published in June 2024121. However, the framework for lobbying relies on 
multiple  acts  and  administrative  guidelines,  and  there  is  still  no  comprehensive  legislation 
dedicated to lobbying122. 

Work on the proposal on limiting ‘revolving doors’ for Ministers has been resumed and is 
expected  to  be  submitted  to  Parliament by  August  2024.  After  some delays123,  a  legislative 
proposal on limiting ‘revolving doors’ for ministers was submitted to the Parliament in September 
2022124. However, the discussion on the proposal did not progress when the parliamentary session 
ended  in  spring  2023125.  A  new  legislative  initiative  is  now  included  in  the  2024  Government 
legislative plan, and is still pending discussion within the Prime Minister’s office. The proposal is 
estimated to be submitted to Parliament by August 2024126. The new text was drafted according to 
the previous proposal127, which aimed 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 
months128.  

118  Input from Finland for the 2024 Rule of Law Report, p. 16. Transparency Register Act (430/2023).  
119  Information received from Transparency International in the context of the country visit to Finland. 
120  Input from Finland for the 2024 Rule of Law Report, p. 16.  
121  Information received from the Ministry of Justice in the context of the country visit to Finland. 
122  There is currently no separate legislation related to lobbying apart from the new Transparency Register Act. 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. 2023 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. 10; 2021 Rule of Law 
Report, Country Chapter on the rule of law situation in Finland, p. 8. 

123  The  proposal  was  originally planned  to  be  submitted  to  Parliament  in  spring  2021.  2022  Rule  of  Law  Report, 

Country Chapter on the rule of law situation in Finland, p. 11. 

124  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 13. 
125  Written input from the 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 finalise the proposal on limiting ‘revolving doors’ 
for Ministers is one of the objectives of the new draft Government Programme. 

126  Information received from the Prime Minister’s Office in the context of the country visit to Finland. 
127  Input from Finland for the 2024 Rule of Law Report, p. 15.  
128  Information received from the Prime Minister’s Office in the context of the country visit to Finland. In practice, 
the proposal aims to postpone for 12 months the commencement of the new post for a Minister (or former Minister, 
as the proposal would apply also to former ministers within 12 months after their resignation). 

15 

 
 
 
 
The Government proposal to develop transparency in electoral and party funding legislation 
is expected to be submitted to Parliament in autumn 2024. The Ministry of Justice has been 
working  on  amendments  to  the  transparency  in  electoral  and  party  funding  legislation.  The 
Government’s proposal – which was submitted to Parliament in November 2022 – did not progress 
when the parliamentary session ended in spring 2023129. The plan to amend the legislation is now 
included in the 2024 Government legislative plan, and the legislative proposal is intended to be 
submitted to Parliament in autumn 2024130. The new proposal builds upon the previous one, and 
aims to improve the provisions and practices for the disclosure of electoral and party funding131. 
The  previous  provision  to  strengthen  the  right  of  the  NAOF  to  monitor  candidates’  election 
funding declarations is no longer included in the new draft132. In the 2023 parliamentary elections, 
the National Audit Office (NAOF) was responsible to oversee compliance with the obligation to 
disclose election campaign funding and election campaign costs: all the 273 persons subject to the 
disclosure obligation filed the election funding disclosure referred to in the relevant legislation, i.e. 
a disclosure of the funding and costs of their election campaign133. 

The Ministry of Justice aims to raise awareness on the Whistleblower Act. The national law 
aiming at transposing the whistleblower protection directive entered into force in January 2023. In 
September 2023, the Ministry of Justice started a training project on whistleblower directive to 
ensure that both public sector and private sector organisations have the necessary knowledge and 
understanding  of  the  Whistleblower  Act134.  Citizens  can  report  misconducts  through  different 
channels  to  authorities  (National  Audit  Office,  Tax  Administration,  and  Financial  Supervisory 
Authority) or electronically to the police135.  

129  Parliamentary communication (SS 87/2022 vp) - Termination of Parliament's work, lapsed matters and Parliament 
convening.  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 from the Ministry of Justice in the context 
of the country visit to Finland. 

130  Information received from the Ministry of Justice in the context of the country visit to Finland. Prime Minister’s 
Office, A strong and committed Finland – Programme of Prime Minister Petteri Orpo's Government 20 June 2023, 
pp.  215-216.  The  aim  to  amend  the  Candidate's  Election  Funding  Act,  Parties  Act,  the  Electoral  Act  and  the 
Citizens' Initiatives Act. Input from Finland for the 2024 Rule of Law Report, p. 16. 

131  The proposal aims to amend the Candidate’s Election Funding Act, the Electoral Act and the Citizens’ Initiatives 

Act. 

132  Information received from the Ministry of Justice in the context of the country visit to Finland. Input from Finland 
for the 2023 Rule of Law Report, p. 17. A parliamentary working group was established to develop voting and 
electoral practices (expected to close activities on 31 December 2025). The working group will also examine the 
role of the NAOF and the opportunity to intensify its supervisory work.  It will also evaluate the possibilities to 
make amendments to the Act on the election funding of candidates regarding that the National Audit Office would 
be given the opportunity to intensify its supervisory work with conditional fine. 

133  As laid down in the Act on a Candidate’s Election Funding (273/2009). NAOF (2023), Report on the oversight of 
election campaign funding in the 2023 parliamentary elections. A total of 162 disclosers supplemented or modified 
the information in their disclosure after it was filed. The National Audit Office did not receive any complaints 
concerning the election funding disclosures in connection with the 2023 parliamentary elections. 

134  Input from Finland for the 2024 Rule of Law  Report,  p. 17. The training project is funded by the EU Internal 

Security Fund. 

135  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. 
16 

 
 
 
 
Public procurement and urban and land use planning are considered high risk sectors for 
corruption,  while  various  initiatives  seek  to  address  corruption  risks.  The  Flash 
Eurobarometer  on  Businesses’  attitudes  towards  corruption  in  the  EU  shows  that  14%  of 
companies in Finland (EU average 27%) think that corruption has prevented them from winning a 
public tender or a public procurement contract in practice in the last three years136. The Ministry 
of Justice published the Municipal Government Anti-Corruption Report in December 2022, which 
identified  public  procurement  as  a  high-risk  sector  for  corruption137.  Other risk  sectors  include 
urban and land use planning, and specialised procurement (such as ICT, medicines and medical 
supplies). Following up to these identified areas, an anti-corruption training for municipal office 
holders was organised in spring 2023138. Through external funding, the Ministry of Justice aims to 
develop a regular situational report which would provide work on awareness raising and training 
projects, such as national data analysis on corruption cases139. The project aims also to develop an 
online course on anticorruption for prosecutors, judges and police officer.  

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  documents 140 .  The  tasks  and  powers  of  the  Finnish  Transport  and 
Communications Agency (Traficom), the media regulatory authority, are enshrined in law141, as 
are the mandate and monitoring of the public service media142. 

Certain  changes  to  the  tasks  and  structures  of  the  national  regulatory  authorities  are 
underway and their resources remain stable.  Since the publication of the 2023 Rule of Law 
Report, the national regulatory authority Traficom has received slightly more human resources, 
due to its designation as the Digital Service Coordinator and new tasks under the Digital Services 
Act and the European Accessibility Act143. It is also managing a temporary state subsidy for the 

136  Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). This is 13 percentage 

points below the EU average. 

137  Input  from  Finland  for  the  2024  Rule  of  Law  Report,  p. 17.  In 2022,  procuring  entities  were  provided  with  a 
procedural guide to tackle the grey economy in public procurement to provide information on how to identify grey 
economy, including corruption. 

138  Input from Finland for the 2024 Rule of Law Report, p. 17. Training for elected municipal counselors took place 

in January 2024. 

139  Information received from the Ministry of Justice in the context of the country visit to Finland. The Ministry of 
Justice aims to repeat the analysis every two years. The analysis will include inter alia how many corruption cases 
are open, how many led to convictions, which sectors are concerned. The project will last for c. 24 months. The 
Ministry of Justice expects to recruit project officers by autumn 2024, including a communication specialist.  
140  Finland continues to rank 5th in the 2024 Reporters Without Borders World Press Freedom Index for the third year 

in a row. 

141  Act on the Transport and Communications Agency 935/2018. 
142  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). 

143  Information received from Traficom in the context of the 2024 country visit to Finland; Input from Finland for the 
2024 Rule of Law Report, p. 20; 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); 
Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility 
requirements for products and services. 

17 

 
 
 
 
distribution of newspapers144. There are no new tasks for the second national regulatory authority, 
the  National  Audiovisual  Institute.  However,  a  working  group  appointed  by  the  previous 
government has proposed clarifications and technical improvements on the legislation concerning 
age limits that would fall within the remit of the National Audiovisual Institute145. Potential next 
steps in the national legislative process are still pending. Additionally, the National Audiovisual 
Institute is expected to merge with another institution, the Arts Promotion Centre Finland, through 
a reform process that aims to strengthen the quality of the two institutes’ services, operations, and 
governance without affecting their tasks146. Both Traficom and the National Audiovisual Institute 
reported to have stable resources amidst political pressure to reduce funding in the future147. No 
developments have been noted regarding the authorities’ independence and the MPM 2024 finds 
a very low risk in this field148.  

The ethical rules for the press are being reviewed, and the self-regulatory Finnish Council 
for  Mass  Media  continues  to  deal  with  an  increasing  number  of  complaints  related  to 
journalistic ethics. The project to review the ethical rules for the press referred to in the 2023 
Rule of Law Report149 is progressing. The renewed rules were published in spring 2024 together 
with  a  guidebook  on  their  application  and  will  become  applicable  as  of  October  2024150.  The 
purpose is, among others, to take account of changes brought by the digital environment and to 
make the rules easier to use151. In the meantime, the self-regulatory Council reports that complaints 
alleging violation of journalistic ethical rules in journalistic content have continued to increase for 
four  consecutive  years,  partly  driven  by  the  proliferation  of  clusters  of  complaints.  This  has 
resulted in longer processing periods152. 

The  Government  has  published  a  research  report  with  recommendations  on  media 
concentration and diversity of media content in Finland. The findings of the independent study 
published  in  March  2024  show  that  when  it  comes  to  news  media,  two  groups  of  companies 
dominate well over half of the press sector – with impacts particularly at regional and local level 
– whereas radio and TV have evolved towards increased competition153. Since 2000, the number 

144  Information received from Traficom in the context of the country visit to Finland; Traficom (2024) Information 

on state aid for the distribution of newspapers. 

145  Information received from the National Audiovisual Institute in the context of the country visit to Finland; Ministry 
of Education and Culture (2023) Clarifications and technical improvements proposed to the Law on Audiovisual 
Programmes. 

146  Information received from the National Audiovisual Institute in the context of the 2024 country visit to Finland; 
Ministry of Education and Culture (2023) Education Governance 2023 Reform Project, Steering Group; Ministry 
of Education and Culture (2023) Progress on the reform of the educational administration – Five agencies would 
carry out tasks in the administrative area of the OKM at the beginning of 2026. 

147  Information received from Traficom and the National Audiovisual Institute in the context of the country visit to 

Finland. 

148  2024 Media Pluralism Monitor, country report for Finland, p. 15. 
149  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 17. 
150  The Council for Mass Media in Finland (2024) The journalist guidelines have been updated; The Council for Mass 

Media (2024) The journalist guidelines’ application guide was published. 

151  Information received from the Council for Mass Media in Finland and the Finnish Media Federation in the context 
of the 2024 country visit to Finland; 2023 Rule of Law Report, Country Chapter on the rule of law situation in 
Finland, p. 17 Council for Mass Media in Finland (2023), Annual Report for 2023, pp. 3, 16. 

152  Information received from the Council for Mass Media in Finland in the context of the country visit to Finland, 

Council for Mass Media (2024) Annual Report for 2023, pp. 4-5. 

153  Finnish Government (2024) Media concentration and diversity of media content in Finland, pp. 163-164. 

18 

 
 
 
 
of journalists working in newspapers has fallen by one third154. The report recommends, among 
other things, to adapt the national legislation in view of the requirements of the European Media 
Freedom Act, and endorses broad debates about the criteria for media concentrations that impact 
media pluralism155. Since the 2023 Rule of law Report, there have been no regulatory changes 
concerning  transparency  of  media  ownership  or  restrictions  to  media  ownership  and  media 
concentrations are assessed under competition law only. MPM 2024 considers that media market 
pluralism continues to be an area of very high risk driven by the extensive combined market share 
of the largest media owners156. 

The Government is examining potential legislative amendments regarding the public service 
media.  The  new  Government  Programme  envisages  strengthening  the  Finnish  Broadcasting 
Company’s (Yle) independence and editorial neutrality157. To this end, a parliamentary working 
group has been examining the need to amend the existing legislation and is estimated to submit its 
report  during  summer  2024 158.  As  stated  previously,  the  long-standing  unwritten  practice  in 
Finland  is  to  require  a  consensus  of  all  parties  in  the  Parliament  for  any  political  decisions 
concerning the law governing public service media159. In this context, the public service media 
would welcome further safeguards for their independence160. The MPM 2024 continues to report 
a low risk regarding the independence of public service media but takes note of recent incidents 
where the public service media’s editorial line has been openly challenged by politicians161. 

Some further progress has been made concerning the right of access to information, with the 
government  continuing  to  examine  a  possible  reform  on  the  Act  on  the  Openness  of 
Government Activities. The 2023 Rule of Law Report recommended Finland to ‘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’162. Following the extension of its mandate, the dedicated working group appointed in 
2021 by the Ministry of Justice published its final report in December 2023, proposing to make 
the Act on the Openness of Government Activities more effective. The report proposes, inter alia, 
to  clarify  the  provisions  on  the  handling  of  requests  for  information,  while  reconciling  the 
protection of personal data with the principle of openness. It also suggests expanding the scope of 
application of the Act to private parties responsible for certain public administrative duties and 

154  Ibidem, p. 19,163. 
155  Ibidem, p. 174-179. 
156  2024 Media Pluralism Monitor, country report for Finland, p. 18. 
157  Finnish  Government  (2023),  A  strong  and  committed  Finland  –  Programme  of  Prime  Minister  Petteri  Orpo’s 

Government 20 June 2023 (2023:60), p. 128. 

158  Input from Finland for the 2024 Rule of Law Report, p. 20; Finnish Government (2023), Parliamentary Working 

Group on the Public Service Mission and Financing of Broadcasting. 

159  2022 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 14. 
160  Information received from Yleisradio Oy in the context of the 2024 country visit; Helsingin Sanomat (2024) Halla-

Aho accuses Yle to be leaning ‘very strongly’ to the left and calls for funding to be cut. 

161  2024 Media Pluralism Monitor, country report for Finland, p. 26; According to the European Parliament’s Flash 
Barometer: News & Media Survey 2023, Finland continues to be the Member State where citizens demonstrate by 
far the highest trust in public TV and radio stations (incl. online). 

162  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 2. In the 2023 Rule of Law 

Report, the Commission concluded that ‘some progress’ hade been made on the 2022 recommendation.  

19 

 
 
 
 
corporations  or  foundations  controlled  by  a  public  body163.  These  recommendations  have  been 
supported by media stakeholders and journalists164. The next steps in the legislative process will 
be decided by the Government after analysing all the stakeholder input received in the relevant 
public consultation165. In the meantime, the Chancellor of Justice has been drawing attention of 
public authorities to the binding time limits for responding to access to documents requests, the 
need to provide reasons for any refusal to provide documents and the prohibition of unfounded, 
unspecified, or unreasonably large cost estimates166. At the same time, journalists reported having 
more difficulties  than before to  secure interviews and receive information from  politicians and 
public authorities167. The MPM 2024 finds that Finnish officials sometimes tend to err on the side 
of non-disclosure rather than openness168. Overall, some further progress has been made on the 
recommendation addressed in the previous years.  

Online  harassment  incidents  have  been  documented  within  the  context  of  journalists’ 
political reporting. Since the publication of the 2023 Rule of Law Report, the Council of Europe’s 
platform to  promote the  protection of journalism  and safety  of journalists169 has  registered two 
new alerts. Furthermore, the Mapping Media Freedom platform has registered further incidents – 
most  involving  intimidation  or  threatening  of  journalists  online  in  the  context  of  their  political 
reporting  activities 170 .  The  MPM  2024  considers  online  harassment  to  be  an  increasing 
phenomenon for Finnish journalists171. An appeal concerning the criminal conviction of journalists 
for the disclosure of a state security secret and for intending to disclose other state secrets reported 
in the 2023 Rule of Law Report is ongoing172. In the meantime, the Supreme Administrative Court 
passed a ruling in December 2023, stating that when an employer (in this case, a media company) 
covered journalists’ costs of a criminal procedure based on their  published article, the financial 
compensation for these costs deriving from the court proceedings was to be accounted as part of 
their  taxable  income 173 .  Concerns  have  been  expressed  by  media  stakeholders  about  the 
judgment’s potential deterrent effects on the work of investigative journalists, with calls to amend 
the relevant legislation174.  

163  Ministry of Justice (2023) The Working Group  proposes a reform of the Act on the  Openness of Government 

Activities; Input from Finland for the 2024 Rule of Law Report, p. 19. 

164  Ministry  of  Justice  (2024)  Updating  the  Act  on  the  Openness  of  Government  Activities  (OM083:00/2020) 
Responses by the Union of Journalists, Sanoma Media Finland Oy, the Association of Investigative Journalism 
and the Finnish Media Federation to the public consultation on the working group’s report. 
165  Information received from the Ministry of Justice in the context of the country visit to Finland. 
166  Contribution from The Office of the Chancellor of Justice for the 2024 Rule of Law Report, p. 24. 
167 Union of Journalists (2023), Access to information for journalists difficult: politicians and officers avoid interviews. 
168  2024 Media Pluralism Monitor, country report for Finland, p. 13. 
169  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Finland. 
170  European  Centre for  Press  and  Media  Freedom,  Mapping Media  Freedom,  25  alerts  in total.  One  of  the  cases 
concerned online insults of a female journalist by certain right-wing Members of the Parliament and subsequent 
threats addressed to the journalist by the politicians’ supporters. The Government notes that the police has initiated 
a criminal investigation of the matter. 

171  2024 Media Pluralism Monitor, country report for Finland, p. 13. 
172  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 18; Input from Finland for 

the 2024 Rule of Law Report, p. 22. 
173  SAC 2023:116 of 11 December 2023. 
174  Information  received  from  Finnish  Media  Federation,  Union  of  Journalists  and  the  Council  of  Mass  Media  in 
Finland in the context of the country visit to Finland; https://www.mapmf.org/alert/31102; Union of Journalists 

20 

 
 
 
 
 
The framework for the protection of journalists has remained strong. The MPM 2024 regards 
Finland as a free and well protected environment for journalistic media, the legal framework being 
well-developed and in tune with international treaties175. The previously planned amendments to 
criminal law concerning 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  duties,  have  been 
abandoned176. While the aim was to improve the effectiveness of prosecutions, the relevant public 
consultation  indicated  considerable  challenges  including  difficulties  in  defining  targeting  and 
restrictions arising from the protection of freedom of expression177. These concerns were echoed 
by  media  stakeholders  and  journalists,  deeming  that  the  identified  problems  could  be  better 
addressed through different measures178. On the other hand, new legislation successfully entered 
into force in October 2023, aimed at making restraining orders more effective179. Finally, the new 
Government programme envisages an action plan for victim policy aimed at securing the funding 
of  support  services  for  crime  victims  and  improving  the  position  of  victims  in  criminal 
proceedings, helping also journalists180.  

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 committee181 
that assesses the constitutionality of proposals submitted to Parliament182. Moreover, all courts can 
carry  out  ex  post  constitutionality  review  in  concrete  cases183.  The  Chancellor  of  Justice,  the 
Human Rights Centre, the Human Rights Delegation and the Parliamentary Ombudsman (the latter 
three constituting the national human rights institution) play an important role in the system of 

(2023)  SCA’s  judgment  is  a  threat  to  freedom  of  expression,  Council  of  Mass  Media  in  Finland  (2023)  Tax 
legislation should be reformed; 2024 Media Pluralism Monitor, country report for Finland, p. 12. 

175 2024 Media Pluralism Monitor, country report for Finland, p. 11. 
176  2023 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 18. 
177 Input from Finland for the 2024 Rule of Law Report, p. 21. 
178  Information received from Finnish Media Federation, Union of Journalists, and the Council of Mass Media in 

Finland in the context of the country visit to Finland. 

179  Ministry  of  Justice  (2023)  Enhancing  the  restraining  order.  This  could  potentially  tackle  in  part  online  hate 

campaigns. 

180  Finnish  Government  (2023)  A  strong  and  committed  Finland  –  Programme  of  Prime  Minister  Petteri  Orpo’s 

Government 20 June 2023 (2023:60), p. 217; Input from Finland for the 2024 Rule of Law Report, p. 21. 

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

law. 

182  The  ex  ante  legal  scrutiny  of  draft  legislation  for  its  compliance  with  the  Constitution  of  Finland  and  the 
international human rights obligations is a standard part of the regulatory process. The Finnish regulatory oversight 
body, the Finnish Council of Regulatory Impact Assessment reviews the impact assessments of law proposals. The 
Chancellor of Justice reviews all the law proposals passed to the Government plenary before they are adopted. 
This  duty  is  based  on  section  108  of  the  Constitution  according  to  which  the  Chancellor  shall  oversee  the 
lawfulness of the official acts of the Government. In the performance of his or her duties, the Chancellor of Justice 
monitors the implementation of basic rights and liberties and human rights. At the Parliament, the Constitutional 
Law Committee has a constitutional duty to issue statements on the constitutionality of legislative proposals and 
other matters brought into its consideration, as well as on their relation to international human rights treaties.  
183  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. 

21 

 
 
 
 
checks and balances, while the Non-Discrimination Ombudsman and the Equality Ombudsman 
function as the equality body. 

Stakeholders reported a change in the practice of public consultations, resulting in shortened 
periods. The rules on stakeholder consultations in the law-making process are laid down in the 
Government’s  internal  guidance184.  The  guidance  stipulates  that  there  should  be  a  consultation 
period of between six to eight weeks for stakeholders to provide their comments on legislative 
proposals, and limiting such periods must be duly reasoned and justified185. However, stakeholders 
have reported a recent trend of much shorter consultation periods (for example five days), which 
has not enabled them to respond in depth186, especially when it comes to significant reforms187. 
Different approaches were also noted across ministries188. The Chancellor of Justice has stated that 
four  of  the  proposals  made  by  the  Ministry  of  the  Interior  since  2024  have  provided  for  short 
consultation periods189 without a justified reason190. As reported in the 2023 Report, the guidelines 
on  impact  assessment  in  law  drafting  and  guide  on  fundamental  and  human  rights  impact 
assessment are in place since 2022191. Also, Government’s common principles for the monitoring 
and  ex-post  evaluation  of  legislation  were  adopted  in  May  2023  and  a  project  was  initiated  to 
update  governmental  guidelines  on  stakeholder  engagement  in  law  drafting,  with  a  view  to  be 
adopted  in  fall  2024 192.  Despite  the  rules  in  place,  stakeholders  have  pointed  to  the  lack  of 
meaningful human rights impact assessments in practice193. The Constitutional Law Committee of 

184  Information provided in the context of the country visit to Finland by the Finnish Bar Association, Human Rights 
Centre.  While  the  guidance  does  not  constitute  a  legally  binding  instrument,  it  has  been,  according  to  the 
Parliamentary  Ombudsman,  traditionally  respected.  Information  provided  in  the  context of  the  country visit  to 
Finland by the Parliamentary Ombudsman.  

185  ENNHRI input p. 10. Additional written contribution from the Finnish Bar Association. Information provided in 

the context of the country visit to Finland from the Human Rights Centre.  

186  Information provided in the context of the country visit to Finland by the Finnish Bar Association, Human Rights 
Centre,  Demla,  Amnesty  International  Finland  and  the  Parliamentary  Ombudsman.  These  stakeholders  have 
reported that the notable change has occurred after the new Government took up the office.  

187  These  relate  for  example  to  draft  laws  on  the  border  control,  asylum  processes,  and  the  revision  of  the  social 
security  system.  The  reform  to  the  social  security  system was  criticized  by  Human  Rights  Centre,  see  Human 
Rights Centre (2023), Opinion of the Human Rights Centre on the report of the Parliamentary Committee on Social 
Affairs  and  Health  in  case  HE  75/2023  vp  (Ihmisoikeuskeskuksen  lausunto  eduskunnan  sosiaali-  ja 
terveysvaliokunnalle asiassa HE 75/2023 vp.). Information provided in the context of the country visit to Finland 
by the Human Rights Centre, Parliamentary Ombudsman and the Finnish Bar Association.  

188 Information provided in the context of the country visit to Finland by the Advisory Board for Civil Society Policy. 
During the present Government term, 203 consultations on draft laws have been organised at Lausuntopalvelu.fi, 
which constitutes circa 60% of the bills issued. According to the data from the platform Lausuntopalvelu.fi, the 
average consultation time in the dates between 12 June 2023 to 2 July 2024 was 35 days, the median consultation 
time was 39 days, and the consultation time range was 3-87 days.  

189  The consultation periods varied from two weeks to four weeks and five days. The Chancellor of Justice concluded 
that the reasons provided by the authorities for the deviation from the standard practice could not be accepted.  
190  Decision of the Chancellor of Justice OKV/608/20/2024. Additional written input of the Finnish Bar Association.  
191  2023 Rule of Law Report Country Chapter on the rule of law situation in Finland, p. 19. 
192  Input from Finland for the 2024 Rule of Law Report, p. 23. Additional written input from Finland for the 2024 
Rule  of  Law  Report.  Information  provided  in  the  context  of  the  country  visit  to  Finland  by  Parliamentary 
Ombudsman.  

193  Contribution from ENNHRI for the 2024 Rule of Law Report, p. 10. Information provided in the context of the 

country visit to Finland by the Human Rights Centre, Demla and Amnesty International Finland.  

22 

 
 
 
 
 
the Parliament has issued statements drawing attention to the shortened periods for the consultation 
of the public, as well as the insufficient human rights assessments on several proposals194.  

On 1 January 2024, Finland had two leading judgments of the European Court of Human 
Rights  pending  implementation,  a  significant  decrease  of  seven  compared  to  the  previous 
year195. At that time, Finland’s rate of leading judgments from the past 10 years that remained 
pending was at 25% (compared to 50% in 2023) and the average time that the judgments had been 
pending  implementation  was  10  years  and  2  months  (compared  to  12  years  and  11  months  in 
2023)196. The improvement in data is influenced by the closure of 7 cases in 2023 that had been 
pending implementation between 9 and 18 years. As regards the respect of payment deadlines, on 
31 December 2023 there were no cases awaiting confirmation of payments (the same as in 2022)197. 
On 1 July2024, the number of leading judgments pending implementation had decreased to one198. 

The National Human Rights institutions propose legislative amendments to strengthen their 
position. The budgetary situation of the National Human Rights institutions, which consist of the 
Parliamentary  Ombudsman,  the  Human  Rights  Centre  (HRC)  and  the  Human  Rights 
Delegation199, which are accredited with A-Status200, was reported as satisfactory201 and the budget 
of both the Parliamentary Ombudsman and the HRC has increased in 2024202. The cooperation 
within  the  National  Human  Rights  institutions,  but  also  between  them  and  the  Chancellor  of 
Justice,  as  well  as  with  other  human  rights  institutions,  is  reported  to  work  well203.  To  further 
strengthen the position of the National Human Rights institutions and to address recommendations 
of  the  UN  GANHRI  Sub-Committee  on  Accreditation,  in  March  2023  the  Parliamentary 

194  Statements  of  the  Parliamentary  Constitutional  Law  Committee  Nos.  11/2023,  14/2023,  15/2023,  16/2023. 
Information received from the Constitutional Law Committee of the Parliament in the context of the country visit 
to  Finland.  To  be  noted  that in  Finland,  only  7%  of  the  surveyed  companies  perceive  the  frequent  changes  in 
legislation or concerns about quality of law-making process as a reason for the lack of confidence in investment 
protection. Figure 56, 2024 EU Justice Scoreboard. 

195  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. 

196  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  2024.  See  the  Contribution  from  the  European 
Implementation Network for the 2024 Rule of Law Report, p. 3. 

197  Council of Europe (2024), Supervision of the execution of judgments decisions of the European Court of Human 

Rights – 17th Annual Report of the Committee of Ministers – 2023, p. 137.  
198  Data according to the online database of the Council of Europe (HUDOC). 
199  Contribution from ENNHRI for the 2024 Rule of Law Report, p. 6. 
200  Accreditation by the UN Global Alliance of National Human Rights Institutions (GANHRI).  
201  Information received from the Chancellor of Justice and the Human Rights Centre in the context of the country 
visit to Finland. It was, however, also reported that other human rights institutions, namely the Ombudsperson for 
children, are operating with limited resources, which was also referred to by the UN Committee on the Rights of 
the Child. Information received from the Parliamentary Ombudsman in the context of the country visit to Finland. 
202  However, budget cuts are expected for 2025-2027. Contribution from ENHRI for the 2024 Rule of Law Report, p. 
7. Information received from the Parliamentary Ombudsman, Chancellor of Justice in the context of the country 
visit to Finland. 

203  Information  received  from  the  Chancellor  of  Justice,  Parliamentary  Ombudsman,  HRC  in  the  context  of  the 

country visit to Finland.  

23 

 
 
 
 
Ombudsman  and  the  HRC  proposed  some  changes  in  legislation 204.  The  amendments  would 
clearly  stipulate  that  the  structure  of  the  three  institutions  constitute  one  NHRI205,  and  would 
introduce the right of the HRC to submit its report directly to Parliament, which can be currently 
done only by the Parliamentary Ombudsman206.  

The  framework  for  civil  society  remains  open,  but  stakeholders  and  civil  society 
organisations have reported on a hardening debate in relation to their role. The civil society 
space continues to be rated as ‘open’207. As noted in the 2023 Report, a new model of funding of 
civil society organisations (CSOs), is in place since January 2024. This model introduced funding 
of  CSO  activities  from  the  government  income,  instead  of  from  gambling  proceeds 208 .  An 
evaluation of the impact of the new system is yet to come. However, the Advisory Board for Civil 
Society Policy already noted that the new redistribution of funding from the Government, together 
with the Government’s plans to restrict funding for civil society in the coming years, might create 
a difficult situation for the CSOs209. The Government plans to reduce excess regulation in response 
to  calls  for  a  reduction  of  administrative  burden  that  CSOs  reportedly  face210,  and  to  explore 
opportunities to enhance fundraising activities for CSOs211. The Government has adopted a Civil 
Society  Organisations  Strategy  (2024-2027)  in  June  2024.  With  the  help  of  the  strategy,  the 
Government will promote independent fund-raising activities by CSOs, develop government grant 
activities concerning CSOs and dismantle bureaucracy that burdens them. A cross-administrative 
working  group  will  coordinate  the  implementation  of  the  strategy  in  the  Government,  and  a 
separate monitoring group will ensure the quality of its implementation212. Human rights actors, 
as well as CSOs, have raised concerns about the recent polarisation of the public debate, and the 
rise  in  hate  speech  and  smear  campaigns  targeting  them,  especially  those  actively  engaged  in 
societal  debates  as  part  of  their  duties 213 .  Stakeholders  reported  that  LGBTI  CSOs  and 
communities are especially targeted by hate speech and harassment214. They also noted a recent 

204  Amendments to the Parliamentary Ombudsman Act. 
205  NHRI in Finland comprises of the HRC, Human Rights Delegation and the Parliamentary Ombudsman. Currently, 

the structure of NHRI is not clearly stipulated. 

206  Contribution from ENHRI for the 2024 Rule of Law Report, pp. 5, 6. Information received from the Human Rights 

Centre and Parliamentary Ombudsman in the context of 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  2023 Rule of Law Report, Country Chapter on the Rule of Law Situation in Finland, p. 21.  
209 Information received from the Advisory Board for Civil Society Policy in the context of the country visit to Finland.  
210 Information received from the Advisory Board for Civil Society Policy in the context of the country visit to Finland.  
211  Input from Finland for the 2024 Rule of Law Report, p. 27.  
212  Ministry of Justice (2024) Press release of 6 June 2024 ‘The  Civil Society Organisations Strategy outlines the 
development of the operating conditions of non-governmental organisations’ (‘Kansalaisjärjestöstrategia linjaa 
kansalaisjärjestöjen toimintaedellytysten kehittämistä’). 

213  Contribution from ENNHRI for the 2024 Rule of Law Report, pp. 7, 19-20. A case of political criticism aimed at 
the deputy Chancellor of Justice, who issued an opinion on the Governments proposal related to the closure of the 
Eastern  border,  sparked  a  strong  reaction  from  human  rights  institutions,  CSOs,  and  also  from  the  Supreme 
Administrative Court. Information received from the Parliamentary Ombudsman, Chancellor of  Justice, Demla, 
Amnesty International Finland in the context of the country visit to Finland. Increased occurrence of hate speech 
and smear campaigns towards civil society and human rights actors, as well as journalists, was reported also by 
the Human Rights Centre in the context of the country visit to Finland.  

214  FRA Report 2024 country chapter for Finland, p. 20 et seq. See also a joint statement of human rights organisation 
LGBTI Rights in Finland – Seta on increased harassment and hate crimes: LGBTI Rights in Finland – Seta (2023), 

24 

 
 
 
 
 
increase  in  criticism  towards  the  judiciary  and  its  powers,  but  no  serious  interference  in  the 
independence or decision making of judges was reported215.  

Joint statement – attacks and hate speech against gender and sexual minorities must be stopped (Yhteislausunto: 
Hyökkäykset ja vihapuhe sateenkaari-ihmisiä kohtaan saatava loppumaan!). 

215  Information received from the Chancellor of Justice, Supreme Administrative Court in the context of the country 

visit to Finland.  

25 

 
 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2024 Rule of Law report can 
be 
found  at  https://commission.europa.eu/publications/2024-rule-law-report-targeted-stakeholder-
consultation_en. 

Advisory  Board 
https://avoimuusrekisteri.fi/en/perustietoa/hyva-edunvalvontatapan.  

the  Finnish  Transparency  Register 

for 

(2024),  Good 

lobbying  practice, 

Centre for Media Pluralism and Media Freedom, Monitoring Media Pluralism in the Digital Era in the year 
2023 (2024) Country report: Finland. 

Council for Mass Media (2024), Annual Report for 2023 (Julkisen Sanan Neuvoston Toimintakertomus 
2023), https://jsn.fi/wp-content/uploads/2024/03/JSN_toimintakertomus-2023.pdf. 

Council  for  Mass  Media  (2024),  The  journalist  instructions  have  been  updated  (Journalistin  ohjeet  on 
uudistettu), https://jsn.fi/journalistin-ohjeet-on-uudistettu/. 

Council for Mass Media (2024), The journalist guidelines’ application guide was published (Journalistin 
ohjeiden soveltamisopas julkistettiin), https://jsn.fi/journalistin-ohjeiden-soveltamisopas-julkistettiin/. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists. 

Council of Mass Media in Finland (2023), Tax legislation should be reformed (JSN: Verolainsäädäntöä on 
syytä muuttaa), https://jsn.fi/jsn-verolainsaadantoa-on-syyta-muuttaa/. 

European Centre for Press and Media Freedom, Mapping Media Freedom, https://www.mfrr.eu/monitor/. 

European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situation in 
Finnland. 

European Commission (2022), 2022 EU Justice Scoreboard. 

European Commission (2024), 2024 EU Justice Scoreboard. 

European Parliament (2023), Flash Eurobarometer: News & Media Survey 2023. 

Government 

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

Administration 

(2022), 

Report 

the 

on 

of 

Justice, 

Finnish  Government  (2023),  A  strong  and  committed  Finland  –  Programme  of  Prime  Minister  Petteri 
Orpo’s 
(2023:60), 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165044/Programme-of-Prime-Minister-Petteri-
Orpos-Government-20062023.pdf?sequence=4. 

Government 

2023 

June 

20 

Finnish Government (2023), Parliamentary Working Group on the Public Service Mission and Financing 
of  Broadcasting  (Yleisradion  julkisen  palvelun  tehtävää  ja  rahoitusta  arvioiva  parlamentaarinen 
työryhmä), https://valtioneuvosto.fi/hanke?tunnus=LVM038:00/2023. 

Finnish  Government  (2023),  Working  Plan  of  the  Working  Group  ‘Rule  of  Law  Guarantees  and 
Development  of  the  Judicial  System’  (Työsuunnitelma,  Oikeuslaitostyöryhmä  vuosille  2023-2027), 
https://api.hankeikkuna.fi/asiakirjat/52fe87c3-0732-48ef-b3a9-38db769912e0/0f32fd02-cbc0-4115-9e8d-
f1abddfa7fb3/SUUNNITELMA_20231018131934.PDF. 

Finnish 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165044/Programme-of-Prime-Minister-Petteri-
Orpos-Government-20062023.pdf?sequence=4.  

Government 

Government 

(2023), 

Programme, 

26 

 
 
 
Finnish  Government  (2024),  Media  concentration  and  diversity  of  media  content  in  Finland  (Median 
keskittyminen ja mediasisältöjen moninaisuus Suomessa) prepared by Lehtisaari, K, Grönlund M, Hellman, 
H, 
(2024:6), 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165517/VNTEAS_2024_6.pdf?sequence=1&is
Allowed=y. 

Suikkanen, 

Ranti, 

R, 

T, 

Finnish Government (2024) Revised decision on the subgroup on the independence of the judiciary from 
February 2024.  

Finnish 
https://julkaisut.valtioneuvosto.fi/handle/10024/165674. 

Government 

(2024), 

Need 

to 

develop 

the 

bribery 

criminal 

code; 

Government Office (2022), Corruption in international business, Current state of regulation, application 
practice and training and needs for change. 

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.  

GRECO (2023), Fifth Evaluation Round – Second Compliance Report on Finland on preventing corruption 
and promoting integrity in central governments (top executive functions) and law enforcement agencies.  

Helsingin Sanomat (2024), Halla-Aho accuses Yle to be leaning ‘very strongly’ to the left and calls for 
funding to be cut (Halla-aho syyttää Ylen olevan ”erittäin voimakkaasti” kallellaan vasemmalle ja vaatii 
rahoituksen leikkaamista), https://www.hs.fi/politiikka/art-2000010108179.html. 

Helsingin  Sanomat  (2024),  (Korkeimman  oikeuden  presidentti  harmittelee  hallituksen  hitautta: 
https://www.hs.fi/paivanlehti/25042024/art-
säällä”), 
”Palovakuutus 
2000010381663.html. 

hyvällä 

ottaa 

syytä 

Human Rights Centre (2023), Opinion of the Centre for Human Rights on the report of the Parliamentary 
Committee  on  Social  Affairs  and  Health  in  case  HE  75/2023  vp.  (Ihmisoikeuskeskuksen  lausunto 
vp.), 
terveysvaliokunnalle 
eduskunnan 
https://www.eduskunta.fi/FI/vaski/JulkaisuMetatieto/Documents/EDK-2023-AK-39035.pdf.  

sosiaali- 

75/2023 

asiassa 

HE 

ja 

LGBTI Rights in Finland – Seta (2023), Joint statement – attacks and hate speech against gender and sexual 
minorities must be stopped (Yhteislausunto: Hyökkäykset ja vihapuhe sateenkaari-ihmisiä kohtaan saatava 
loppumaan!), 
https://seta.fi/2023/06/26/yhteislausunto-hyokkaykset-ja-vihapuhe-sateenkaari-ihmisia-
kohtaan-saatava-loppumaan/. 

Ministry of Education and Culture (2023), Education Governance 2023 Reform Project, Steering Group 
(OKM034:00/2023), 
-uudistushanke, 
2030 
(Sivistyshallinto 
https://okm.fi/en/project?tunnus=OKM034:00/2023.  

ohjausryhmä) 

Ministry of Education and Culture (2023), Progress on the reform of the educational administration – Five 
agencies  would  carry  out  tasks  in  the  administrative  area  of  the  OKM  at  the  beginning  of  2026 
(Sivistyshallinnon  uudistus  etenee  –  OKM:n  hallinnonalalla  tehtäviä  hoitaisi  vuoden  2026  alusta  viisi 
virastoa), 
https://okm.fi/-/sivistyshallinnon-uudistus-etenee-okm-n-hallinnonalalla-tehtavia-hoitaisi-
vuoden-2026-alusta-viisi-virastoa. 

Ministry  of  Justice  (2023),  Enhancing  the  restraining  order  (Lähestymiskiellon  tehostaminen), 
https://oikeusministerio.fi/hanke?tunnus=OM015:00/2020. 

27 

 
 
 
justice, 
Ministry 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164658/VN_2023_9.pdf?sequence=4.  

(2023),  Government 

administration 

Justice 

report 

on 

of 

of 

Ministry  of  Justice  (2023),  The  Working  Group  proposes  a  reform  of  the  Act  on  the  Openness  of 
Government  Activities  (Työryhmä  ehdottaa  julkisuuslakia  uudistettavaksi),  https://oikeusministerio.fi/-
/tyoryhma-ehdottaa-julkisuuslakia-uudistettavaksi. 

Ministry of Justice (2023), Decision No. VN/24741/2023 of 21 September 2023 on the  establishment of 
the  National  Legal  Service  Authority,https://api.hankeikkuna.fi/asiakirjat/6004566c-8e7c-4201-b58f-
6d4846c54cda/7f7a0c9a-e83b-4c61-a32b-3bb610f4d7cb/ASETTAMISPAATOS_20230925070049.pdf. 

Ministry of Justice (2023), Decision No. VN/34680/2022 of 30. October 2023, Setting up sub-groups for 
the  Working  group  on  the  ‘Rule  of  Law  Guarantees  and  the  Development  of  the  Judicial  System’, 
https://api.hankeikkuna.fi/asiakirjat/52fe87c3-0732-48ef-b3a9-38db769912e0/f75b6177-e7e5-42c4-9c65-
1413bfa22de9/PAATOS_20231106142525.pdf. 

Ministry  of  Justice  (2024)  Press  release  of  23  April  2024  ‘The  work  for  the  independence  of  judiciary 
continues”, 
https://oikeusministerio.fi/-/tyo-oikeuslaitoksen-riippumattomuuden-eteen-
jatkuu#:~:text=Oikeusvaltioty%C3%B6ryhm%C3%A4n%20toimeksiantoa%20tarkennettiin%20lokakuus
sa%202023,valmistelua%20sek%C3%A4%20yleens%C3%A4%20parlamentaarista%20ulottuvuutta. 

Ministry of Justice (2024) Press release of 6 June 2024 ‘The Civil Society Organisations Strategy outlines 
organisations’ 
development 
the 
(‘Kansalaisjärjestöstrategia 
kehittämistä’), 
toimintaedellytysten 
https://oikeusministerio.fi/-/kansalaisjarjestostrategia-linjaa-kansalaisjarjestojen-
toimintaedellytysten-kehittamista?languageId=fi_FI. 

kansalaisjärjestöjen 

non-governmental 

conditions 

operating 

linjaa 

the 

of 

of 

of 

2024, 
Ministry 
https://api.hankeikkuna.fi/asiakirjat/ad29e2de-008c-4946-bcfe-3f53ed169982/113d6469-5c7f-4906-b41c-
5766c18c0ddd/ASETTAMISPAATOS_20240212112011.pdf. 

(2024),  Decision  VN/1886/2024-OM-2 

February 

Justice 

12 

of 

Ministry  of  Justice  (2024),  Updating  the  Act  on  the  Openness  of  Government  Activities  (Julkisuuslain 
ajantasaistaminen), (OM083:00/2020) Request for an opinion on the working group’s report 12/12/2023 – 
16/2/2024, https://oikeusministerio.fi/hanke?tunnus=OM083:00/2020#. 

NAOF (2023), Report on the oversight of election campaign funding in the 2023 parliamentary elections. 
Report on the oversight of election campaign funding in the 2023 parliamentary elections - National Audit 
Office of Finland (vtv.fi). 

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. 

Parliament, Constitutional Law Committee, statements  

No. 11/2023, https://intranet.eduskunta.fi/FI/vaski/Lausunto/Sivut/PeVL_11+2023.aspx;  

No. 14/2023, https://intranet.eduskunta.fi/FI/vaski/Lausunto/Sivut/PeVL_14+2023.aspx;  

No. 15/2023, https://intranet.eduskunta.fi/FI/vaski/Lausunto/Sivut/PeVL_15+2023.aspx;  

No. 16/2023, https://intranet.eduskunta.fi/FI/vaski/Lausunto/Sivut/PeVL_16+2023.aspx.  

Police  of  Finland  (2024),  Police  Anticorruption  Policy,  https://poliisi.fi/en/police-anticorruption-
policy. 

Reporters Without Borders (2024), 2024 World Press Freedom Index. 

28 

 
 
 
Traficom (2024), Information on state aid for the distribution of newspapers (Tietoa sanomalehtijakelun 
valtionavustuksesta), https://traficom.fi/fi/viestinta/posti/tietoa-sanomalehtijakelun-valtionavustuksesta. 

Transparency Register Act (430/2023), 430/2023 - Directory of legislative amendments - FINLEX ®. 

Union of Journalists (2023), Access to information for journalists difficult: politicians and officers avoid 
interviews  (Journalistien  tiedonsaanti  vaikeutunut:  politiikot  ja  viranhaltijat  välttelevät  haastatteluja), 
https://journalistiliitto.fi/fi/journalistien-tiedonsaanti-vaikeutunut-poliitikot-ja-viranhaltijat-valttelevat-
haastatteluja/. 

Union of Journalists (2023), SCA’s judgment is a threat to freedom of expression (Journalistiliitto: KHO:n 
päätös  on  uhka  sananvapaudelle),  https://journalistiliitto.fi/fi/journalistiliitto-khon-paatos-on-uhka-
sananvapaudelle/. 

29 

 
 
 
 
Annex II: Country visit to Finland 

The Commission services held virtual meetings in March 2024 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 Constitutional Law Committee  
•  Parliamentary Ombudsman 
•  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:  

•  Amnesty International EU 
•  Centre for Democracy and Technology Europe 
•  Centre for European Volunteering 
•  Civil Liberties Union for Europe 
•  Civil Rights Defenders 
•  Civil Society Europe 
•  Culture Action Europe 

30 

 
 
 
 
•  Democracy Reporting International 
•  European Centre for Non-Profit Law 
•  European Civic Forum 
•  European Federation of Journalists 
•  European Partnership for Democracy 
•  European Youth Forum 
•  Free Press Unlimited 
• 
• 
• 
• 
•  JEF Europe 
•  Open Society Foundations 
•  Philanthropy Europe Association 
•  PICUM 
•  Reporters Without Borders 
•  SOLIDAR 
•  Transparency International EU 

International Federation for Human Rights 
International Planned Parenthood Federation 
International Press Institute 
Irish Council for Civil Liberties 

31