COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Finland Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Finland, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 23 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans    Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Finland  Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)    Third River Basin Management Plans   Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Finland 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, Member State characterisation ............................................................................................................. 4 

2. Horizontal aspects ...................................................................................................................................................................... 8 

2.1 Governance ............................................................................................................................................................................ 8 

2.2 Characterization of River Basin District ................................................................................................................. 9 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 12 

3.1 Surface Water: what is their ecological status or potential .................................................................... 12 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 14 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 15 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 16 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 17 

3.6 What Finland is doing for abstractions and water scarcity ..................................................................... 18 

3.7 Adaptation to climate change .................................................................................................................................. 19 

4. Policy elements contributing to zero pollution ........................................................................................................ 20 

4.1 Surface Water: what is their chemical status ................................................................................................. 20 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 22 

4.3 What Finland is doing to combat pollution from agriculture ................................................................. 23 

4.4 What Finland is doing to combat pollution from other sectors ............................................................ 24 

4.5  What  Finland  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 24 

5. Exemptions and economics ............................................................................................................................................... 25 

5.1 To what extent are exemptions applied in Finland ...................................................................................... 25 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 26 

6. WFD recommendations ........................................................................................................................................................ 27 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 30 

7. Flood risk management under floods directive (FD) ............................................................................................ 31 

7.1 Flood hazard and risk maps ...................................................................................................................................... 31 

7.2 Flood risk management plans .................................................................................................................................. 32 

8. FD recommendations ............................................................................................................................................................ 34 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, Member State characterisation

Finland  is  bordering  three  countries:  Sweden,  Norway,  and  Russia,  with  a  total  surface  area  of 
304,000 km2, and a population of 5.6 million inhabitants1, so it has a very low population density of 
16.4 people per km2. About 55% of the population lives in cities, with the remaining 45% living in 
settlements of less than 50,000 inhabitants or outside urban areas. Finland is a country characterised 
by vast forests (covering 78% of its territory), that makes it the most forested country in Europe, very 
rich in water and with a huge number of water bodies, with over 187,000 lakes and ponds, as well 
as a similar count of islands and islets. 

To the west and the south Finland is flanked by the Gulf of Bothnia and the Gulf of Finland, in the 
Baltic Sea. Finland’s climate is humid continental in the south and boreal in the north.  

Finland  has  eight  river  basin  districts  (RBDs),  some  of  which  are  transboundary  and  shared  with 
countries  which  are  not  members  of  the  EU.  It  needs  to  be  highlighted  that  the  Åland  is  an 
autonomous,  Swedish  speaking  region  of  the  Finnish  republic  with  its  own  legislation  and 
responsibilities related to water. This translates into differences in water management between the 
mainland and Åland, as well as differences in the structure of the River Basin Management Plans 
(RBMPs) and of the monitoring programmes. Agriculture in Finland is characterised by many medium 
size  farms,  highly  modernised  and  mechanised.  There  are  around  44500  agricultural  holdings  in 
Finland, with an average farm size of 51 hectares. Around 14.4% of Finland’s agricultural land is 
dedicated to organic farming2. However, the largest sector in rural areas is forestry. Finland has the 

1  Finland – EU country profile | European Union  
2 At a glance: Finland's CAP Strategic Plan 

4 

 
 
fifth largest timber resources in Europe, after Russia, France, Sweden, and Germany. It has an annual 
logging volume of approximately 60 to 75 million cubic meters. 

Water resources 

Finland is rich in water resources, with almost a tenth of the country’s total land area covered by 
water. Finland’s WEI +3 index for 2017 was 0.612%, which is well below the 20% threshold generally 
considered as an indication of water scarcity. Despite the rich water resources, these are not evenly 
distributed across the country. Just over 2% of the available water resources are used annually, with 
the largest user being industry (taking up 80%), followed by households (15%)4. Only 3% of total 
freshwater consumption is taken up by irrigation. Despite the richness in water resources, Finland 
has experienced regional or local water shortages, especially during the summer.  

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the Member States were assessed based on the datasets available by this date. 

Finland has not submitted full electronic reporting by September 2023. Therefore, the assessment is 
based on the data mining of the pdf RBMPs. 

Despite  the  cut  off  dates to  produce  this  report,  reporting  continued,  and, for  the  State  of  Water 
report, the EEA aggregated  the results available by  July  2024 in their products and dashboards 
available at WISE Freshwater web portal. 

3 The Water Exploitation Index plus (WEI+) is a measure of total fresh water use as a percentage of the renewable 
freshwater resources (groundwater and surface water) at a given time and place. It quantifies how much water is 
abstracted and how much water is returned to the environment after use. 
4 UN Global Compact – Water Action Hub: https://wateractionhub.org/about/ 

5 

 
 
 
 
Changes in Status, Pressures, Exemptions and Measures 

Surface Water 
Bodies (6876)  

Trend (% good 
status/potential) 

ECOLOGICAL 
STATUS 

100%

50%

73,3% 74,6%

Main Pressures & Changes & Exemptions 

There has been a slight improvement in the proportion of surface water bodies (SWBs) in good or higher ecological status or potential. 
Coverage of monitoring has increased, mostly due to the use of grouping, but it is not clear whether the coverage of specific quality 
elements has improved, due to limited data available. Information on methods used for the assessment of biological and physico-
chemical quality elements is reported. Moreover, the national methodology used for the designation of heavily modified water bodies 
and artificial water bodies is described. However, while a list of River Basin Specific pollutants has been established, no information is 
provided on how these pollutants have been used in the classification of ecological status. Furthermore, no information on the confidence 
in the assessment was provided.  

The  slow  progress  in  improving  the  ecological  status  or  potential  is  largely  due  to  diffuse  pollution  from  agriculture  and  forestry. 
Challenges  have  been  also  identified  with  hydromorphological  alterations.  Finland  has  not  indicated  what  the  expected  ecological 
status/potential projections of surface water bodies are for 2027. 

0%

2015 2021

Exemptions under Article 4(4) have also been applied on the grounds of technical feasibility (712 SWBs) and natural conditions (1483 
SWBs). One water body in the Oulujoki–Iijoki River Basin District (RBD) (VHA4) has been exempted under Article 4(5) because the change 
caused by human activity is permanent and good ecological status cannot be achieved. 

CHEMICAL STATUS 

100%

50%

49,5
%

0,0%

0%

2015 2021

The 3rd RBMPs indicate that 100% of surface water bodies are in poor chemical status, mainly due to the presence of uPBT 
substances, including mercury and PBDEs (flame retardants). Apart from uPBTs, other chemicals cause exceedances, but on a more 
limited scale. These are primarily heavy metals - cadmium, nickel, and lead. Two pesticides are also reported to affect some RBDs: 
cypermethrin and dichlorvos. The information provided does not allow to assess whether the spatial coverage of monitoring is 
adequate, and no information was provided on the confidence in the assessments. Monitoring is based on 53 substances, but it is not 
clear which of these substances are monitored in each RBD. Monitoring in sediment and biota is incomplete both in terms of 
substances included and spatial coverage. The situation is not expected to improve by 2027.  

Exemptions under Article 4(4) have been applied on grounds of technical feasibility (36 SWBs) and natural conditions (79 SWBs). Two 
surface water bodies in the RBD of Vuoksi (VHA1) have been exempted under Article 4(5). In these water bodies, changes caused by 
human activity will not allow good status to be reached because of its permanent nature and lack of technology.  
Finally, one surface water body in the Teno-, Näätämöjoki- and Paatsjoki RBD (VHA7) has been exempted under Article 4(5) on the 
grounds of infeasibility. 

6 

 
 
 
 
 
Ground Water 
Bodies (3918) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

In the 3rd RBMPs, almost all groundwater bodies (GWBs) - except 2 - are in good quantitative status, which represents an improvement 
from an already quite favourable situation in the 2nd RBMPs (98.3%). However, no information is reported on the confidence in the 
assessments. Considerations on groundwater associated surface waters and on groundwater dependent ecosystems are considered in 
the assessments. While water scarcity is not at present an issue in Finland, there has been some spells of drought in recent years and 
with climate change it is expected that some water scarcity issues may arise at least seasonally and in certain areas. Climate change 
impacts are analysed in the 3rd RBMPs but not in a very detailed or quantified manner. No projections for 2027 have been reported.  

Exemptions under Article 4(4) on the ground of technical feasibility have been claimed for 2 groundwater bodies and a detailed 
justification provided. 

CHEMICAL STATUS 

100%

A large proportion of groundwater bodies are in good chemical status. Considerations of impacts on groundwater associated surface 
waters and groundwater dependent ecosystems are included in the assessment, but not all substances causing a risk of deterioration 
are considered. No information was provided on the confidence in the assessments. The substances more frequently responsible for 
failing to reach good status are chloride, nitrate, plant protection products, solvents, polycyclic aromatic hydrocarbons (PAH compounds) 
and chlorophenols. No information was provided on the expected status in 2027.  

50%

93,5% 93,4%

Exemptions under Article 4(4) have been claimed on grounds of technical feasibility for 75 water bodies and natural conditions for 25 
water bodies. One groundwater body has been exempted under article 4(5) on grounds of technical feasibility. 

0%

2015 2021

7 

 
 
 
 
2. Horizontal aspects 

2.1 Governance 

In Finland, two ministries share responsibility for the coordination and implementation of the Water 
Framework Directive (WFD): the Ministry of Agriculture and the Ministry of the Environment. The latter 
is also responsible for reporting to the European Commission.  

The preparation and implementation of the RBMPs is done by regional authorities: 13 Centres for 
Economic Development, Transport, and the Environment (ELY Centres) and the Government of Åland. 
National coordination and support to the preparation of the RBMPs is ensured by a monitoring group 
for  water  management,  run  by  the  Environment  Ministry,  and  which  involves  different  ministries. 
Furthermore,  for  the  3rd  RBMPs,  to  facilitate  the  correct  implementation  of  the  measures  and  to 
ensure  the  full  involvement  of  stakeholders,  the  Environment  Ministry  together  with  the  Finnish 
Environment Institute have published guidance documents and other support tools.  

All RBMPs comprise two parts: one part is specific to each RBD, while the second part is set at the 
national  level  and  common  to  all  RBDs.  This  section  includes  information  on  methods,  tools  and 
principles used in the drafting of the RBMPs. Finland submitted the 3rd RBMPs in pdf format in May 
2022, but had shared, by letter to the Commission and by the legal deadline of March 2022, the links 
to all the RBMPs. Finland did not submit electronic data but clarified that all data related to individual 
water bodies is publicly accessible through an open data portal5.  

All  Finland’s  RBMPs  refer  to  the  objectives  of  the  national  legislation  implementing  the  Floods 
Directive. The Kokemäenjoki RBMP even includes measures related to the management of floods, 
being particularly vulnerable to floods. In some RBMPs, the consultation for the preparation of the 
RBMPs and the Flood Risk Management Plans (FRMPs) were held simultaneously to ensure better 
coordination. It is welcome that, similarly, all RBMPs include the Marine Strategy Framework Directive 
(MSFD)  objectives  amongst  their  objectives  and  the  measures  under  the  RBMPs  were  designed 
bearing these MSFD objectives in mind or are common between the two different management plans. 
For example, the Oulujoki-Iijoki RBMP reports that the measures to reduce the nutrient load were 
designed  with  the  requirements  to  improve  the  status  of  marine  waters,  besides  that  of  surface 
waters.  

Finland has designated two international RBDs, and developed international RBMPs, in cooperation 
with Norway and Sweden. However, cooperation with Russia takes place through a Finnish-Russian 
Transboundary River Commission.   

Finland published the timetable, work programme, consultation plan, overview of significant water 
management issues and all the draft RBMPs and made them available for the required 6 months for 
public consultation, in good time and in line with the WFD  requirements. All the RBMPs include a 
summary  of  the  changes  made  after  the  consultation.  Besides  the  online  consultation  of  the 
documents, the regional authorities responsible for the preparation of the RBMPs (the ELY centres) 
organised advisory groups with all key stakeholders in their areas. These advisory groups were fully 
involved and have monitored, evaluated, and forecasted the use, protection and condition of waters 

5 https://wwwp2.ymparisto.fi/scripts/kirjaudu.asp 

8 

 
 
and their development in the region, and contributed proposals for the management of water, thus 
having a clear say in the water management measures to be taken in their RBDs. 

2.2 Characterization of River Basin District 

Finland has eight river basin districts, as detailed in Table 1 below.  

Table 1. Overview of Finland‘s River Basin Districts (RBDs)  

RBD 

Name 

Size (km2) 

Countries sharing RBD 

FIVHA1 

Vuoksi  

58,158 

FIVHA2 

FIVHA3 

Kymijoki-Gulf of 
Finland (short 
Kymijoki) 

57,074 

Kokemäenjoki-
Archipelago Sea-
Bothnian Sea 
(short 
Kokemäenjoki) 

83,357 

FIVHA4 

Oulujoki-Iijoki  

68,084 

FIVHA5 

Kemijoki 

54,850 

FIVHA6 

FIVHA7 

Tornionjoki (Finnish 
part) 

14,587 

NO, SE 

Teno, Näätämöjoki 
and Paatsjoki 
(Finnish part) 

25,566 

NO  

FIWDA 

Åland 

9,379 

The Tornionjoki RBD is the Finnish part of the Torne river, shared with Sweden, which forms part of 
the border between the countries, and to a smaller extent with Norway. The ‘Teno, Näätämöjoki, and 
Paatsjoki’ RBD is shared with Norway.  

The ‘Teno, Näätämöjoki, and Paatsjoki’ and the other eastern RBDs - ‘Oulujoki-lijoki’, ‘Kemijoki’ and 
‘Vuoksi’ - share river basins with the Russian Federation, but Finland has not established international 
river basin districts in line with WFD with Russia.  

The Åland is an autonomous, Swedish speaking region of the Finnish republic with its own legislation 
and responsibilities related to water. This translates into differences in water management between 

9 

 
 
 
 
 
 
 
the mainland and Åland, as well as differences in the structure of the RBMPs and of the monitoring 
programmes. 

Finland delineated a total of 6876 surface water bodies and 3918 groundwater bodies across its 
eight RBDs, as detailed in Table 2.  

Table 2. water bodies delineated in Finland  

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
Waters 

Groundwater 
Bodies 

RBD 
(Index) 

Vuoksi  
(VHA1) 

343 

1187 

Kymijoki-Gulf of Finland  
(VHA2) 

347 

928 

Kokemäenjoki-Archipelago 
Sea-Bothnian Sea  
(VHA3) 

439 

625 

Oulujoki-Iijoki (VHA4) 

278 

965 

Kemijoki  
(VHA5) 

307 

434 

Tornionjoki (VHA6) 

103 

169 

Teno-, Näätämöjoki- and 
Paatsjoki  
(VHA7) 

143 

317 

Åland 
(WDA) 

TOTAL 

0 

15 

1960 

4640 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

730 

54 

907 

134 

959 

19 

5 

3 

0 

644 

489 

149 

35 

61 

5 

276 

3918 

Type specific reference conditions and environmental objectives 

Finland has made considerable efforts to establish type specific reference conditions, and to fill the 
gaps that were apparent in the 2nd RBMPs, notably the fact that type specific reference conditions for 
hydromorphological quality elements were not established for any water category. The RBMPs’ part, 
which is common and set at national level, reports that reference conditions have been defined for 
each type of river, lake, and coastal water body and for all quality elements.  

Environmental objectives have been reported in all RBMPs and additional objectives have also been 
set for water bodies associated to protected areas where so needed, to ensure compliance with the 
requirements of the Directives applicable to those areas. 

Main pressures and impacts  

The  main  pressures  having  an  impact  on  water  resources  in  Finland  derive  from  agriculture  and 
forestry,  followed  by  wastewater  treatment  and  unconnected  dwellings,  and  hydromorphological 
pressures.  Mining,  fish  farming,  fur  production  and  peat  production  are  also  listed  as  drivers  of 
pollution.  

10 

 
For surface water bodies, the reported significant pressures are diffuse pollution from agriculture and 
forestry. While the overall share of arable land in Finland is small (7% of the total land area), diffuse 
agricultural pollution remains one of the main pressures affecting surface water bodies (around 20% 
of total surface water bodies are affected). This is despite the fact that Finland has got a very high 
percentage (93%) of utilised agricultural area under agri-environment-climate measures, which is 
well  above  the  EU  average,  and  around  14.4%  of  agricultural  area  under  organic  farming6,  and 
growing.  The  impacts  of  agriculture  are  not  evenly  felt  in  the  country  with  the  share  of  nutrient 
pollution from agriculture varying from less than 1% of total load of nitrogen and phosphorous in 
northern RBDs up to around 50% in more southern regions, where agriculture is more concentrated. 
See Figure 1. Diffuse pollution is also heavily linked to forestry, which is a large and important sector 
in Finland. Almost 13% of total surface water bodies are affected by pressures from the forestry 
sector, with a significant load of pollutants linked to managed forests run-off, as well as issues linked 
to drainage and soil erosion. 

Figure 1. Map of the monitoring points showing eutrophication assessment in Finland, according to the 
reporting of the Nitrates Directive 

Source: Joint Research Center of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) 
Trophic Status. [online] water.jrc.ec.europa.eu. Available at: 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa 
Note : 0% of the monitoring stations are above the threshold of 50mg/l 

6 At a glance: Finland's CAP Strategic Plan 

11 

 
 
 
Other significant pressures include nutrient pollution for wastewater discharges, with unconnected 
scattered dwellings affecting a sizeable proportion of surface water bodies.  

Furthermore, Finland reports significant hydromorphological pressures in all RBDs, with hydropower, 
flood  protection  and  agriculture  cited  as  the  most  common  reasons  for  hydromorphological 
modifications.  Drainage  is  not  mentioned  in  the  RBMPs  as  a  hydromorphological  pressure,  even 
though  drainage  is  common  practice  in  peatlands,  as  well  as  in  other  sectors  e.g.  forestry.  The 
presence of barriers is mentioned amongst the significant pressures affecting surface water bodies: 
while Finland has a relatively low level of artificialisation compared to other EU Member States, the 
hydropower  sector  represents  about  half7  of  the  Finnish  electricity  production  from  renewable 
sources. Hydropower installations may severely affect certain water bodies. 

Invasive alien species are not mentioned in the RBMPs as a significant pressure in Finland, despite 
the presence of some invasive alien species, such as the Canadian pondweed and the signal crayfish 
which can have significant impacts on freshwater ecosystems.  

Groundwater bodies fare better in Finland than surface water bodies, nevertheless some pressures 
and contamination remain, linked to diffuse pollution from agriculture and forestry, nutrient pollution 
from  wastewater  discharges  and  unconnected  dwellings,  as  well  as  pollution  from  industry  and 
contaminated sites, and transport. 

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

Finland  has  made  efforts  to  improve  its  overall  monitoring  strategy:  coverage  has  increased 
compared to the 2nd RBMPs and the definition of reference conditions and monitoring methods has 
improved. Moreover, Finland has issued national monitoring guidelines. Furthermore, to improve the 
monitoring of long-term changes Finland has established a list of sites where intensive long-term 
monitoring takes place. Finland is also planning to continuously improve the monitoring programmes, 
including by extending biological monitoring in certain regions or in certain water body types and to 
further integrate data collected through remote sensing in the monitoring programmes.  

There are two types of monitoring: i) operational monitoring to determine the status and which covers 
all water bodies at risk and ii) surveillance monitoring aimed rather at identifying impacts and long-
term changes and design monitoring programmes. The nationally set, common part of the RBMPs set 
out the principles on which the monitoring programmes are based, while the RBD specific part of the 
RMPBs include maps of the monitoring programmes, as required by WFD.  

Operational monitoring sites are set in water bodies at risk of not achieving good status or potential 
and where priority substances are released, or where diffuse pollution causes significant impacts, or 

7 Finland - Countries & Regions - IEA 

12 

 
 
in water bodies subject to significant hydromorphological pressures. National legislation establishes 
a list of 15 river basin specific pollutants8.  

In addition, supervisory monitoring on point source pollution and on fragmentation is conducted by 
operators  of  plants  where  the  point  source  pollution  derives,  or  by  permit  holders  (for  example 
hydropower operators). In particular, river continuity is monitored, and a national register of dams is 
in place. Finally, the RBMPs set the monitoring frequency, which is in line with the WFD requirements.  

Status classification 

All of Finland’s water bodies have been classified for ecological status or potential, which is positive, 
but regrettably no information on the confidence in the assessments is provided in the Finnish RBMPs. 
The RBMPs report that all biological quality elements have been intercalibrated and progress has 
been made in the use of biological quality elements in the status assessment. Finland has established 
a list of river basin specific pollutants. As for the hydromorphological quality elements, the RBMPs 
report progress in the assessment, due to improved monitoring coupled with better use of modelling 
and remote sensing. 

While the surface water bodies in good or higher status or potential represent a good proportion of 
the total (almost 75%), not much progress has occurred since the 2nd RBMP (Figure 2). Worryingly, 
there has been a decrease in the area of coastal waters in good status (from 27% to less than 15%), 
signalling a deterioration, which may be due to improved monitoring and to the fact that River Basin 
Specific Pollutants were not monitored in coastal waters in the 2nd RBMP. The RBMPs indicate that 
the lack of progress in ecological status/potential of water bodies is mainly due to diffuse pollution 
from  agriculture  and  forestry  that  have  remained  high.  Furthermore,  challenges  to  address 
hydromorphological alterations have also been identified.  

Figure 2. Ecological status or potential of surface water bodies, as reported in 1st, 2nd, and 3rd RBMPs.  

Source: WISE electronic reporting and data mining for the 3rd RBMP 

8 Chlorobenzene, 1,2-dichlorobenzene, 1,4-dichlorobenzene, benzyl butyl phthalate, dibutyl phthalate, resorcinol, methyl 
isocyanate, benzothiazole-2, bronopol, dimethoate, 2-methyl-4-chlorophenoxyacetic acid, metamitron, prochloraz 
(imidazole), ethylene thiourea and tribenuron-methyl. 

13 

 
 
 
3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

As it was the case in the previous reporting cycle, the level of human intervention in the water system 
in Finland remains very low and clearly one of the lowest in the EU. Figure 3 sets out the proportion 
of heavily modified and artificial water bodies per water category. Highly modified water bodies only 
represent 2 % of total water bodies and only a very small share (0.6 %) are artificial water bodies.  

Figure 3. proportion of heavily modified and artificial water bodies per water category 

100%

80%

60%

40%

20%

0%

Rivers (% of
total rivers)

Lakes (% of
total lakes)

Transitional
Waters (% of total
TWs)

Coastal
Waters (% of total
Coastal waters)

NATURAL

HEAVILY MODIFIED

ARTIFICIAL

It must be noted that the RBMPs do not include information on main water uses associated with 
heavily modified and artificial water bodies, so there is no link with what is triggering the level of 
human  intervention.  Information  on  water  uses,  including  agriculture, flood  protection  and  energy 
production, is available through an open data portal giving access to a national data register9, but 
aggregated data is not available, making it difficult to evaluate which are the main uses. 

Finland has a national methodology in place for the designation of heavily modified water bodies and 
artificial water bodies. The methodology is based on information on the assessment of substantial 
change in character and whether good ecological status could be achieved with measures that do 
not  have  significant  adverse  effects  on  use  and  wider  environment.  It  also  considers  whether  the 
benefits can be achieved at cost that is not disproportionate by other means that are significantly 
better environmental option.  

In  those  HMWBs,  the  Member  States  can  set  less  ambitious  objectives  and  aim  to  reach  good 
ecological  potential,  rather  than  good  ecological  status.  Finland  defines  good  ecological  potential 
using  a  national  methodology,  based  on  mitigating  measures:  all  measures  that  do  not  cause 
significant adverse effects on the use or wider environment have been reviewed and their effect on 
biological quality elements have been assessed to define whether a water body is in good ecological 
potential. 

In  addition,  for  the  surface  water  bodies  that  are  important  migratory  routes  for  migratory  fish 
species, the evaluation of the mitigation measures explicitly considers the effect these measures will 
have on the migratory fish and their lifecycle. This is useful to help achieve the freshwater restoration 
goals of the EU, as set out in the Biodiversity Strategy 2030.  

9 Open environmental information systems - syke.fi  

14 

 
 
 
Over a third of water bodies classified as either heavily modified or artificial  have achieved good 
ecological potential (about 33%). 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Finland has many groundwater bodies: 3918 in total.  

Monitoring 

There  has  been  good  progress  in  monitoring,  with  now  more  than  16%  of  groundwater  bodies 
covered,  up  from  the  3.8%  monitored  in  the  2nd  RBMPs.  Yet  this  remain  low,  compared  to  other 
countries, in  percentage but  maybe  not in  actual  number  of  groundwater bodies  monitored  since 
there are so many. Finland generally uses grouping of groundwater bodies, based on broad geological 
criteria, in the assessment of quantitative status, but this is not done for groundwater bodies at risk 
of  failing  to  achieve  good  quantitative  status.  In  its  assessments,  Finland  also  considers  water 
balances  and  long-term  groundwater  level  trends,  as  well  as  an  assessment  of  the  needs  of 
groundwater associated surface waters and of groundwater dependent ecosystems, and the impacts 
of saline or other intrusions. 

Status assessment  

It is welcome that in this cycle there are no unknowns. This is a positive result, also considering that 
in the 2nd RBMP a proportion of groundwater bodies, albeit a small one (1.6%) remained in unknown 
status. Based on the information reported in the RBMPs, almost all groundwater bodies are in good 
quantitative status. All except two groundwater bodies, located in the Kokemäenjoki-Saaristomeri-
Selkämeri RBD, which are in poor quantitative status. In at least one of these cases, this is due to 
draining practices in the adjacent areas, which lowered the water table.   

Figure  4  shows  the  quantitative  status  of  groundwater  bodies  in  2015  and  in  2021.  Regrettably, 
Finland did not make projections for 2027 available. Except in very few cases, water quantity is not 
a problem for recharging groundwater bodies. For the two in poor status, measures will be needed 
to redress the situation. 

Figure 4. Quantitative status of groundwater bodies in the 1st, 2nd and 3rd RBMPs  

Source: Data mining from 2nd and 3rd RBMPs data 

15 

 
 
3.4 Protected Areas (identification, monitoring, objectives and measures) 

There are different reasons why certain water bodies are protected under the law.  

In accordance with WFD, Finland has designated protected areas of all relevant types for both surface 
and  groundwater  bodies:  drinking  water  protection  areas,  Natura  2000  sites,  freshwater  fish 
protected areas and bathing water areas (Table 3). Finland applies a whole country territory approach 
to the designation of Nitrates Vulnerable Zones under the Nitrates Directive and Nutrient Sensitive 
Areas under the Urban Waste Water Treatment Directive, thus no specific protected areas of this type 
have been designated.  

Overall, the number of drinking water protected areas has remained stable.  

When  it  comes  to  areas  protected  for  habitats  and  species,  Finland  has  designated  13.3%  of  its 
terrestrial areas as protected area, which is well below the EU average (26.4%). Most of the protected 
areas are designated as Natura 2000 areas, and a smaller percentage is nationally designated (about 
5%). It is welcome that the number of water bodies associated with Natura 2000 protected areas 
has increased. 

Table 3. Number of water bodies associated with protected areas in Finland 

Number of Water Bodies Associated with protected areas  

Surface waters 

Groundwater 

1780 

277 

49 

Protected area type 

Drinking water 
protection area 

60 

Natura 2000 

1213 

Bathing waters  

250 

Freshwater fish 

24 

Source: RBMP reports 

Because electronic reporting was not available for Finland for the 3rd RBMPs, it was not possible to 
establish how many water bodies associated with protected areas are monitored, but Finland sets 
out the monitoring programmes for its territory in national legislation10, which includes the monitoring 
of protected areas. Additional monitoring is required for Natura 2000 sites that do not meet their 
environmental objectives. The RBMPs report that additional objectives are set for all protected areas, 
but detailed information is lacking. Only for Natura 2000 areas and drinking water protected areas, 
the Finnish RBMPs provide some more details. For the Natura 2000 areas the RBMPs set additional 

10 Water and Sea Management Act. 

16 

 
 
 
objectives if species or habitat in that area requires higher than good water status, but in most cases 
it is considered that the objectives of WFD are sufficient.  

As regards drinking water protected areas, safeguard zones have been designated with measures to 
protect the quality of water abstracted for human consumption, but unfortunately the RBMPs do not 
provide further details on the exact measures taken. Similarly, the information on status of protected 
areas  was  not  reported  separately  from  the  overall  status  information,  making  it  impossible  to 
establish whether progress in the status of protected areas has been made since the 2nd RBMPs. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

Finland  reports  significant  hydromorphological  pressures  in  all  RBDs,  with  hydropower,  flood 
protection  and  agriculture  cited  as  the  most  common  pressures.  Drainage  is  not  mentioned  as  a 
hydromorphological pressure and, regrettably, no specific measure to reduce the impact of drainage 
on hydromorphology are mentioned. However, some measures to manage drainage in agriculture, 
forestry and peatland exploitation sectors seem to be in place.  

Other  measures,  including  on  the  ecological  restoration  of  rivers,  on  the  development  of  water 
regulation practices and improvement of fish migration though restoration of continuity, are included 
in the RBMPS. This is positive but the information provided is not very detailed. It is reported that 
physical modifications are subject to the national Water Act and require pre-authorisation, but no 
more details are given.  

According to background documents, rules on the review of permits related to water flows should be 
applied  in  the  future.  Worryingly,  however,  the  RBMPs  do  not  report  any  information  on  whether 
permits  for  hydropower  are  subject  to  thorough  and  periodic  reviews,  to  take  into  consideration 
concerns related to ecological flows, fish passes and other mitigation measures. Given the role of 
hydropower in Finland and the serious hydromorphological impact that hydropower installations can 
have on the status of water bodies, the lack of clear provisions on the review of permits, or at least 
the lack of information on such provisions, is a cause of serious concern. In this respect, it is worth 
mentioning that the Commission has initiated an infringement procedure against Finland.  

It is however mentioned that new projects or modifications of existing ones such as flood protections 
or dams, have been adapted to respect the WFD’s objectives.  

Finland’s  RBMPs  report  that  measures  for  reducing  hydromorphological  pressures  consider  flood 
protection  needs,  especially  in  areas  in  southern  Finland  which  are  more  prone  to  flooding.  It  is 
indicated  that  they  include  measures  to  improve  the  natural  water  retention  capacity  in  the 
catchments and other nature-based solutions. However, from the information reported in the RBMPs 
there does not seem to be a national strategy nor a well-developed strategic approach to using such 
measures.  

Overall,  regrettably,  the  RBMPs  provide  little  details  on  measures  to  address  hydromorphological 
pressures.  While  national  guidance  documents  for  the  preparation  of  programmes  of  measures 
provide more details, the RBMPs do not seem to present a well-articulated and comprehensive plan 
to address such pressures.  Finally, while some attention seems to have been devoted to improving 
some aspects related to hydromorphology, such as fish migration, there does not appear to have 
been much progress on the recommendations issued on the 2nd RBMPs, notably on ecological flows 
and on revising hydropower permits. 

17 

 
3.6 What Finland is doing for abstractions and water scarcity 

As mentioned  earlier, Finland is a water rich country and water abstractions are not a significant 
pressure in any RBD. Therefore, in its RBMPs, Finland does not really focus on adaptation measures. 
Nevertheless, a National Plan for Adaptation to Climate Change was published in 2023, which sets 
out goals and measures, including for drought risk management, in the event of seasonal worsening 
conditions due to climate change.  

The RBMPs only qualitatively address possible impacts, such as earlier snow melting, or dropping 
water levels in late summer. However, Finland does report some data on water abstraction for mining 
and quarrying, industry, and energy cooling at the national level, albeit without distinguishing whether 
from surface water or groundwater. Abstractions for agriculture and households and services are not 
reported.  

According to data collected from the European Environment Agency11, in 2019 Finland abstracted 
almost  2500  million  m3  of  water  (see  Figure  5).  Most  of  the  water  was  abstracted  for  the 
manufacturing sector (1556 million m3), followed by electricity cooling and public supply. Agriculture 
only accounted for 31 million m3. 

Figure 5. water abstraction by economic sector in Finland 

Source: Water abstraction by source, 2000-2019 — European Environment Agency (europa.eu) 

In accordance with the WFD, Finland has a concession, authorisation, and permitting regime to control 
surface  and  groundwater  abstractions  and  impoundments,  as  well  as  a  register  of  abstractions. 
Permits are issued by the regional authorities for either an indefinite or time limited period, but the 
RBMPs do not report criteria for granting a time-limited or indefinite period. It is not clear whether 
there is a periodic review of such permits as required by EU law. Permits can however be refused or 
revised under certain conditions to maintain or achieve the environmental objectives.  

11 Water abstraction by source, 2000-2019 — European Environment Agency (europa.eu) – data sources include EEA own 
data as well as data from Eurostat and OECD. 

18 

 
 
 
On  ecological  flows,  they  have  been  defined  and  implemented  for  some  river  sections,  but 
unfortunately not systematically nationwide. The stated intention is to implement ecological flows by 
2027, but not many details are provided as to the exact measures planned.  

Finally, Finland’s RBMPS include some measures to increase or preserve water supply, notably natural 
water retention measures, but no water reuse is foreseen12 

3.7 Adaptation to climate change 

Finland is not currently facing water scarcity issues and has not reported any surface or groundwater 
body  as  failing  to  reach  good  status  due  to  climate  change.  However,  it  has  experienced  several 
drought episodes in recent years (2002, 2006, 2013, 2018)13, and droughts are projected to increase, 
especially  in  the  southwestern  regions,  with  increasing  impacts  on  agricultural  productivity.  The 
RBMPs, and their background document, also reports other possible effects of climate change, like 
extreme or more frequent heavy rainfall, higher pressures from diseases and pests that may have 
consequences on water bodies, increased water temperatures, changes in distribution and abundance 
of aquatic organisms, nutrient loads, and turbidity.  

Climate  change  adaptation  measures  have  been  identified  in  all  RBMPs  assessed,  predominantly 
focusing on groundwater protection and water supply, and a National  Climate Change Adaptation 
Plan is in place. While no drought management plan is in place yet, the RBMPs report that drought 
management plans are in preparation.   

Finland has in place a national methodology for the climate-proofing of measures. In addition, Finland 
produced  industry  specific  guides  for  aquaculture,  agriculture  and  fur  production,  forestry,  water 
supply, peat  production,  and  water  infrastructure, to  help  sectors maintain  their  operations  under 
climate  change  conditions  and  help  planning  the  management  of  water  resources.  However,  the 
information reported in the RBMPs is not detailed.  

Flooding is a common occurrence in Finland, with climate change exacerbating the issue. The Floods 
Directive  requires  to  consider  the  impacts  of  climate  change  on  the  occurrence  of  floods,  and 
therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and Flood Risk Management 
Plans (FRMPs). More information on these can be found in Section B. However, considering the close 
relationship  between  overall  water  management  and  floods  management  and  the  importance  of 
climate change effects on both, climate change effects are jointly addressed in this section.  

Since the first cycle, Finland has updated its flood risk management process to also include the impact 
of climate change in PFRAs and FRMPs. In addition, new flood hazard and flood risk maps have been 
published  to include  climate  change  scenarios  for  certain  fluvial  floods.  These,  however,  were  not 
reported to the EU. While national or regional climate adaptation all five FRMPs considered climate 
change while developing the plans, in their objectives, targets, and the selection and description of 
measures policies are referred to only in four of the five plans assessed. In particular, all five plans 
refer to quantitative analyses of changes in potential flood levels.  

The five FRMPs considered scenarios with timeframes for climate change to the end of this century. 
All the plans expect the second Hamina and Kotka FRMP also refer to shorter scenarios, for example 

12 Finland has notified an Article 2(2) decision that water reuse is not appropriate in its territory, as per Regulation 
2020/741 on minimum requirements for water reuse. 
13 Blauhut and Stahl (2023) Drought Impact Database, Deliverable 1.4, Confidential report.  

19 

 
 
for 2040-2069. Four of the five FRMPs assessed (except the Kalajoki plan) mention a shift in the 
occurrence of extreme events and changes in numerical recurrence times. The shift (also mentioned 
in the first FRMPs) is expected to be from spring floods to summer/autumn and/or winter floods, due 
to the reduction of snow and ice cover due to climate change. However, the main sources of flooding 
are not expected to change under the long-term climate change scenarios. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

Finland’s RBMPs do not report separately the features of the monitoring for ecological and chemical 
status, making it difficult to assess the extent of monitoring specifically for chemical status. According 
to the common part of all RBMPs, set at national level, chemical status assessment has been based 
on expert judgement for 88% of water bodies and on monitoring for the rest. It seems therefore that 
the in-situ monitoring coverage for chemical status is rather limited. 

From the RBMPs it is not clear how many and which substances are monitored in different RBDs, but 
it is reported that the assessment is based on 53 substances, comprising 45 priority substances as 
well as 8 other substances listed under the EQS Directive. As regards the 12 new substances added 
to the EQS Directive in 2013, Finland has carried out a targeted monitoring campaign, which revealed 
exceedances for perfluoro octane sulphonic acid (PFOS). It is welcome that for all substances, detailed 
work has been completed to identify point sources and diffuse emissions. 

Compared to the previous cycle, a very positive development is that polybrominated diphenyl ethers 
(PBDEs) are monitored in biota (perch), while previously they were only monitored in water.  There 
have also been monitoring campaigns for mercury in biota (fish). For monitoring of trends in the 20 
Priority Substances of the EQS Directive, the Finnish RBMPs report that changes in sediments and 
biota occur extremely slowly. Because of this long time lag, a trend could be established only for very 
few  substances,  mercury,  dioxins,  and  furans,  that  have  been  monitored  since  the  1960s: 
concentrations of these substances are declining. Cadmium has also been monitored for decades, 
but the picture is mixed, with concentrations increasing in some locations and decreasing in others. 

Sampling is conducted monthly, a frequency in line with the WFD requirements.  

Status assessment 

Compared to the 2nd RBMPs, there has been a dramatic deterioration in the chemical status of surface 
water  bodies.  This  may  be  due  to  improved  monitoring  and  assessment  techniques  and  to  the 
inclusion in the 3rd cycle of monitoring of polybrominated diphenyl ethers (PBDEs, a uPBT substance 
used as flame retardants) in biota, which provides a more accurate picture of the chemical status, 
rather than signal an actual deterioration.  

Figure 6 provides the chemical status classifications for all three rounds of RBMP reporting.  

20 

 
Figure 6 . Evolution  of  chemical status for surface water bodies in Finland between the 1st, 2nd and 3rd 
RBMPs 

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Failing to achieve good

Unknown

Source: WISE electronic reporting (and RBMPs) and RBMPs documents for the 3rd RBMPs 

The  3rd  RBMPs indicate that  100%  of  surface  water  bodies  are in  poor  chemical  status including 
uPBTs. Finland did not report status without uPBTs. Failure is largely to be attributed to mercury (50% 
of water bodies) and to PBDEs (exceeding their biota EQS in 100% of water bodies). See Figure 7. 

Indeed,  water  bodies  are  affected  by  mercury,  even  though  domestic  mercury  emissions  have 
decreased by about 45% in the nineties14, due to improved gas cleaning equipment, process changes, 
automation,  the  installation  of  flue  gas  desulfurization  process  in  coal  fired  power  stations  and 
pollution control laws. The RBMPs report that more than 90% of the atmospheric deposition is from 
long range transport and from outside national borders. 

A  few  other  substances,  including  nickel,  cadmium,  PAHs,  tributyltin,  and  PFOS,  are  also  causing 
failure to achieve good status, but in a small proportion of water bodies.  Worryingly, it is unclear 
whether the status of water bodies will improve by 2027 due to the ubiquitous presence of uPBTs.  

Figure 7. Main Priority Substances causing failure to achieve good chemical status in SWBs in 2021  

14 2000, A.B. Mukherjee, M. Melanen, M. Ekqvist, M. Verta. “Assessment of atmospheric mercury emissions in Finland” 

21 

 
 
 
 
4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

Finland has not reported information on the number of groundwater bodies monitored for chemical 
status in its RBMPS. In the 2nd RBMP, monitoring was limited, with only 6.5% of groundwater bodies 
monitored for chemical status. Moreover, in the previous cycle, the monitoring of substances causing 
risk  of  deterioration  in  chemical  status  was  limited  and  not  all  substances  of  the  Groundwater 
Directive  were  monitored.  In  addition,  parameters  such  as  nitrates,  ammonium,  pH,  electrical 
conductivity, and oxygen, were not monitored systematically in all RBDs. There is limited information 
in the 3rd RBMPs to conclude whether Finland has improved the monitoring of groundwater bodies.  

Background  documents  to  the  3rd  RBMPs  describe  the  assessment  methodology  adopted,  which 
considers the assessment of general quality, the assessment of impacts on groundwater associated 
surface water and groundwater depended species and ecosystems, as well as the assessment of 
saline or other intrusions, and the assessment of impacts on drinking water protected areas (1780 
groundwater bodies). 

The  assessment  of  the  chemical  status  of  a  groundwater  body  is  based  on  the  harmonised 
methodology proposed in the EU Guidelines,15 which is considered as good practice. Threshold values 
have been set for all substances leading to risk of not meeting environmental objectives, including 
all  substances  of  Annex  II  (part  B)  of  the  Groundwater  Directive.  Background  levels  for  naturally 
occurring substances are considered in the development of the threshold values and in the chemical 
status assessment. 

Status assessment 

According  to  information  reported  in  the  3rd  RBMPs,  93.5%  of  groundwater  bodies  are  in  good 
chemical status in Finland. Of the rest, 2.3% groundwater bodies are in poor chemical status and 
4.2% are in unknown status. While the percentage of groundwater bodies in good chemical status is 
high, the situation has not significantly changed compared to the 2nd RBMPs (Figure 8).  

While  a  large  majority  of  groundwater  bodies  are  in  good  chemical  status,  there  remain  a  small 
proportion of groundwater bodies in poor status and some even in unknown status. Finland did not 
include a forecast of the situation in 2027 and the information about the substances responsible for 
failing to achieve good chemical status is not systematically reported, making it difficult to assess 
whether  Finland’s  groundwater  bodies  are  on  a  positive  trajectory.  Similarly,  no  information  was 
reported on the confidence in the classification. From the information available in the 3rd RBMPs, it 
appears  that  the  pollutants  affecting  groundwater  bodies  include  chloride,  nitrates,  pesticides, 
solvents  (e.g.  trichloroethylene),  polycyclic  aromatic  hydrocarbon  (PAH)  compounds  (deriving  from 
burning fossil fuels, waste, or other organic substances), methyl tert-butyl ether (MTBE, a gasoline 
additive). 

15 CIS Guidance document 18 (2009): Groundwater status and trend assessment, derived as a ‘conceptual model’ in line 
with point 3 of Annex III (Assessment of groundwater chemical status) of the Groundwater Directive. 

22 

 
 
Figure  8.  Evolution  of  chemical  status  for  groundwater  bodies  in  Finland  between  the  1st,  2nd  and  3rd 
RBMPs 

Source: WISE electronic reporting (and RBMPs) and RBMPs documents for the 3rd RBMPs 

4.3 What Finland is doing to combat pollution from agriculture 

Unfortunately, no quantitative gap analyses have been made about the reduction in nutrients and 
pesticides loads that should be achieved by the agricultural sector. In Finland measures to address 
pollution from agriculture are largely those included in the Nitrates Action Programme pursuant to 
the Nitrates Directive. However, for pesticides, measures consist rather of the implementation of the 
Directive on the Sustainable Use of Pesticides, as well as conditions under the Common Agricultural 
Policy. Such measures include the use of winter cover crops, farm advisory services, establishment 
of buffer strips, management of crops and grasses diversity, water conservation practices, pesticide 
reduction  measures,  establishment  of  wetlands,  environmentally  friendly  manure  application  and 
other  groundwater  protection  measures.  The  new  Finnish  CAP  Strategic  Plan16  focuses  on  the 
protection  of  natural  resources  and  biodiversity.  It  is  strengthening  the  protection  measures  for 
peatlands in agricultural areas, which is good for the water by limiting increased oxidation of the 
organic material (releasing N in the water too) and it increases water retention.  

Forestry is a large and important sector in Finland and represents a considerable pressure on water 
resources. Finland reports measures to address pollution from forestry including the establishment 
of protection zones for renewal  felling; enhancing forestry water conservation, measures to avoid 
groundwater pollution from drainage, training, and advisory services. 

The 3rd RBMPs describe the measures, for both agriculture and forestry, and the areas targeted by 
such measures. It also indicates the water bodies where measures are needed. It is positively noted 
that Finland also estimates the nutrient load from different sources and calculate the load reductions 
needed. However, the RBMPs indicate that it was not possible to estimate the effects of all measures 
combined and thus the remaining gap.  Furthermore, the gap for pesticides has not been assessed 
and there is little information on pesticides related measures.  

The RBMPs also report on the progress of implementation of the measures included in the 2nd RBMPs. 
Here progress is unequal. Good progress was achieved for measures on erosion control, management 

16 At a glance: Finland's CAP Strategic Plan (europa.eu); Mapping and analysis of CAP strategic plans” (2023-2027) 

23 

 
 
 
of  nutrients  and  farm  advisory  services.  Less  progress  was  achieved  for  manure  processing  and 
wetland management which are lagging behind. Overall, however, the level of progress is fairly high 
with 80% of the measures having been implemented. For the measures which were not put in place 
yet, the RBMPs argue that this was due to the low level of incentives offered to farmers which did 
not  secure  sufficient  uptake  of  the  voluntary  measures.  Unfortunately,  it  is  not  clear  whether the 
subsidies given to farmers have been raised during this cycle to ensure a higher uptake. Progress has 
regrettably been poorer in the forestry sector, and it is not clear whether the measures planned under 
the 3rd RBMPs will address the remaining issues.  

The funding of measures is primarily ensured through EU and national funding and the RBMPs report 
information on the costs of agricultural and forestry measures. 

4.4 What Finland is doing to combat pollution from other sectors 

Finland  has  defined  measures  relevant  to  tackle  pollution  from  sectors  other  than  agriculture, 
including  measures  to  improve  wastewater  treatment,  both  urban  and  industrial,  remediation  of 
contaminated  sites,  measures  to  tackle  priority  substances,  and  pollution  from  urban  areas  and 
transport. While the RBMPs report the number of water bodies that will be subject to the reported 
measures,  the  details  provided  do  not  allow  for  an  in-depth  assessment  of  how  effective  the 
measures will be in closing the gap towards good status in 2027.  

Finland treats 97% of sewage in line with the Urban Wastewater Treatment Directive, which is above 
the  EU  average  of  76%.  However,  more  efforts  are  needed  to  upgrade  some  of  the  treatment, 
especially for biological treatment with phosphorus removal. Given that almost 9% of surface water 
bodies  and  almost  8%  of  groundwater  bodies  are  under  pressure  from  wastewater  treatment, 
reinforced action is needed, including in tackling discharges from unconnected scattered dwellings. It 
is  positive  that  measures  to  upgrade  wastewater  treatment  and  to  connect  unconnected  and 
scattered dwellings are foreseen.  

The  RBMPs  also  include  measures  to  address  chemical  substances  responsible  for  the  failure  to 
achieve good status. Notably, they state the intention to revise discharge permits for wastewater 
treatment plants and for industrial discharges. It is also planned to further investigate the sources of 
pollution.  Measures  planned  to  address  mercury  and  other  ubiquitous  substances  which  are  the 
largest  cause  of  failure,  are  limited  to  a  revision  of  discharge  permits  and  further  studies  to 
investigate how to address such pollution.  

Some information on the costs is provided as well as a summary assessment of progress during the 
implementation of the 2nd RBMPs. Unfortunately, progress has been poorer than expected, especially 
when it comes to wastewater discharges from unconnected dwellings. It is not clear whether such 
shortcomings will be overcome with the measures planned under the 3rd RBMPs. 

4.5 What Finland is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

It  is  noted  positively  that  Finland  has  provided  a  breakdown  of  measures,  both  mandatory  and 
voluntary,  for  their  associated  pressures  in  all  RBMPs.  The  measures  proposed  aim  at  reducing 
nutrient  pollution  from  agriculture  as  well  as  from  forestry,  reduce  untreated  sewage  release, 
restoration  of  biodiversity,  including  the  restoration  of  fish  migration  routes,  and  soil  moisture 

24 

 
conservation,  remediation  of  contaminated  land,  reducing  road  and  rail  transport  run  off, 
maintenance of reservoirs. 

The  selection  of  the  most  cost-effective  measures  is  guided  by  national  sectoral  guidance  and 
supported by modelling. For example, a tool named “KUTOVA” has been developed for the evaluation 
of cost-effectiveness of water management measures aiming at the reduction of phosphorus load in 
catchment  areas.  Other models  have  been  developed  to  assess the  effectiveness  of  measures in 
particular sectors, using industry specific information.  

While the cost of measures has been estimated and reported in all RBMPs on an annualised basis, 
Finland  did  not  provide  detailed  information  on  the  financing  of  such  measures.  No  quantitative 
analysis of the gap to achieve the environmental objectives has been reported, however, the RBMPs 
mention that an assessment has been made to evaluate the need for reduction in impacts to achieve 
the environmental objectives.   

A positive aspect of the Finnish RBMPs is the coordination of measures with the Marine Strategy 
Framework Directive and the Floods Directive. The Marine Management Plans are developed in close 
cooperation with the RBMPs and both plans report the relevance of measures in respect to the goals 
of the other Directive. International cooperation in marine management is also emphasised in the 
RBMPs.  In  Finland  the  measures  to  manage  flood  risks  are  assessed  for  their  impact  on  the 
achievement of the WFD objectives. Finland also coordinates the implementation of its programmes 
of measures with the countries sharing its international RBDs.  

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Finland 

While Finland did not report data electronically, it was possible to retrieve information on exemptions, 
which is set out in Table 4.  

Table 4. number of water bodies subject to exemptions in the 3rd RBMPs  

Article  Justification 

SW ecological 
status 

SW chemical 
status  

GW quantitative 
status 

GW chemical 
status 

4(4) 

Technical feasibility  

752 

36 

2 

4(4) 

Disproportionate costs 

4(4) 

Natural conditions 

1553 

79 

4(5) 

Technical feasibility 

4 

4(5) 

Disproportionate costs 

25 

75 

25 

1 

 
 
 
 
 
 
 
 
 
 
 
 
Article 4 (4) time related exemptions apply on grounds of technical feasibility, disproportionate costs, 
or natural conditions.  

It is noted with concern that the number of exemptions under Article 4(4), allowing for time delays, 
have increased in Finland for the 3rd RBMPs. However, good progress has been made in justifying 
such exemptions, with detailed information provided for each exempted water body.  

Article 4(5) exemptions (lowered objectives)  

Equally concerning, is that, although there were none in the previous cycle, the 3rd RBMPs include now 
some Article 4(5) exemptions. It is noted that detailed information is provided for each water body 
justifying the use of the exemptions.  

The  main  pressures  on  water  bodies  requiring  exemptions  were  diffuse  nutrient  pollution  from 
agriculture and forestry, releases of wastewater, and chemical pollution, mainly due to mercury, flame 
retardants (PBDEs) and heavy metals (cadmium and nickel).  

Eutrophication issues, requiring longer times to clean and control, are often mentioned, as well as 
issue  related  to  water  infrastructure,  where  the  planning  and  financing  of  projects  require  long 
timescales.  

Finland does not foresee the use of other exemptions in the 3rd RBMPS. 

Article 4(6) exemptions – temporary deterioration resulting from natural causes or force majeure.  

Article 4(6) exemptions are not applied in Finland under the 3rd RBMPs.  

Article  4(7)  exemptions  -  exemption  to  the  obligation  of  non-deterioration/not  preventing  the 
achievement  of  good  status,  in  case  of  new  modifications  or  sustainable  human  development 
activities.  

While  Article  4(7)  has  not  been  used  to  exempt  any  deterioration  of  status  in  the  3rd  RBMPs, 
regrettably, the RBMPs reported that several projects (48) are undergoing assessments and may be 
potential  candidates for  Article  4(7)  exemptions  in  the  future.  Some  of these projects  will  not  be 
implemented by 2027, and therefore are not subject to exemptions in the 3rd RBMPs, while for others 
it is mentioned that the assessment has not been completed, due to missing information.  

5.2 Use of economic analysis and water pricing – cost recovery 

Overall, the Finnish RBMPs do not report sufficiently detailed information to full assess the use of the 
economic analysis and the use of water pricing policies. The RBMPs however report that the economic 
analysis has been fully updated for the 3rd cycle and refer to background documents with further 
information. Some improvement has been made in the provision of information concerning future 
water  supply  and  demand  and  on  the  calculation  of  financial  cost  recovery,  but  the  RBMPS  lack 
detailed information on other aspects required by the Water Framework Directive.  

All  RBMPs  provide  information  on  long  term  water  supply  and  demand  forecasts,  although  with 
different timelines. It is not clear whether such forecasts are differentiated according to type of supply 
source or user types and sectors. Moreover, in some RBMPs there is little information on the scenario 
context.  There  are  also  estimates  of  the  potential  costs  of  relevant  measures,  but  with  little 

26 

 
information on the most cost-effective combination of measures in respect of water uses. The RMBPs 
also  provide  little  information  on  estimates  of  volume,  costs  and  prices  associated  with  water 
services (water supply and sanitation). 

The limited information provided in the RBMPs do not allow to assess the structure of water tariffs 
or  charges,  and  whether  pricing  policies  or  other  instruments  provide  adequate  incentives  to  use 
water  efficiently.  Similarly,  the  information  provided  on  financial  costs  and  revenues  of  the  water 
sector  is  not  detailed.  The  presentation  of  investment  needs  during  the  planning  period  remains 
consistent  with  the  approach  used  in  the  initial  two  cycles.  It  includes  the  annual  operation  and 
maintenance costs, and the annualised capital cost, but no clear overview of total investment costs 
for water services.  

Based on the forecasts, the RBMPs report the key structural changes to be taken into consideration 
and  addressed  in  relation  to  water  quality  and  availability,  such  as  regional  population  changes, 
expansion  of  farms,  centralisation  of  industry  in  larger  facilities  and  effects  of  climate  change. 
However, the RBMPs do not provide detailed information on specific investments to address possible 
seasonal  and  local  water issues.    The  RBMPs  provide  some  information  on  the  application  of  the 
polluter pays principle, mainly by assigning to the actors, whose activities impact on the status of 
water, the responsibility of implementing and paying for the necessary measures.  

6. WFD recommendations 

Recommendations - Finland should: 

1.  accelerate action and enhance the overall level of ambition to reduce the compliance gap as much as 

possible and to reach compliance by 2027.  This will require that Finland: 

a. 

b. 

reinforces measures, in accordance with Article 11(5), to be able to achieve the environmental 
objectives of WFD and in particular to redress the poor chemical status of surface water 
bodies. 

reconsiders its approach to agriculture and forestry. Many of the measures to reduce the 
impacts of these sectors are of a voluntary nature and it has been seen that progress is not 
sufficient. Finland should reconsider its approach and/or increase the incentives to farmers 
and foresters to secure the proper uptake of water friendly land management practices. 

c.  ensure full compliance with WFD provisions related to periodic review of permits/controls for 

all relevant activities impacting water bodies. 

d. 

reports quantitative gap indicators for all significant pressures and assesses the ability of the 
planned measures to address these gaps and report more information on the prioritisation 
exercise and on the role of a cost-effectiveness assessment in the selection. 

e.  provide more detailed information in relation to how planned measures related to pollution 
from sectors other than agriculture will contribute to close the gap, including on measures to 

27 

 
improve wastewater treatment and address unconnected settlements, forestry measures and 
industrial emissions. 

f.  ensuring adequate financing and provide more detailed information on this subject in the 
RBMPs, and sufficient resources to tackle the identified pressure (diffuse nutrient and chemical 
pollution and hydromorphological pressures). 

2. 

identify  and  put  in  place,  as  appropriate,  additional  measures  to  reduce  existing  persistent 
environmental challenges and pressures and make full use of the instruments agreed in the context 
of the European Green Deal to join up implementation efforts and increase effectiveness and efficiency, 
by exploiting synergies between actions to apply WFD as well as the Urban Wastewater  Treatment 
Directive, the Industrial Emissions Directive, the Nitrates Directive, or the new Nature Restoration Law. 
In particular, Finland should:  

a.  assess specific pesticides use reduction needs to address the gap in agricultural and forestry 

diffuse pollution and evaluate the ability of the planned measures to close the gap. 

b.  stepping up action to reduce nutrient pollution, both from agriculture and forestry, as from 
urban  settings  or  scattered  and  unconnected  dwellings,  including  through  the  setting  and 
achievement of maximum nutrient loads in all river basin districts to achieve the objectives 
of WFD, MSFD and NiD. 

c.  provide  more  detailed  information  on  the  pressures  on  river  basin  hydromorphology.  In 
particular,  more  should  be  done  about  the  measures  to  mitigate  hydromorphological 
pressures. Finland should especially provide information and carry out the periodical review 
of permits and ensure that hydropower installations, in particular, are subject to thorough 
and regular reviews of their permits. 

d. 

e. 

complete the definition and secure the implementation of ecological flows in all RBDs. 

take decisive action to continue to address and look for more effective solutions to reduce 
pollution from uPBTs. 

3. 

improve its economic analysis and the use of water pricing policies to help achieve the WFD objectives. 
In particular, Finland should: 

a.  provide more details on the long term forecast for supply and demand, differentiating by 

supply sources, use types and sectors. 

b.  provide comprehensive details on all water services and water uses, on the costs, revenues, 
and subsidies associated with water services / uses, as well as on overall investment needs 
for the provision of water services. 

c.  provide  more  information  on  water  tariffs  and  charges  and  better  analyse  whether  they 

provide an adequate incentive for more efficient water use. 

4.  maintain the good work done in providing detailed justifications for the planned exemptions. When it 
comes to the possible future use of Article 4(7) in relation to new projects, it is important that specific 

28 

 
details are provided on cumulative effects and on the assessment of better environmental options, 
and the measures taken to mitigate the adverse impacts of new developments. 

5.  assess more in details possible climate change impacts on water bodies and on their status and devise 

more specific and detailed climate change adaptation measures. 

6.  provide, in its RBMPs, more comprehensive information on transboundary cooperation and in particular 
on whether cooperation on the establishment of reference conditions is in place with all countries 
sharing international RBDs. 

7. 

further improve its monitoring, assessment, data management and reporting. In particular, Finland 
should: 

a.  maximise its efforts to ensure electronic reporting of WFD data, to facilitate comparisons 
between implementation cycles and allow for easier monitoring of progress. Finland should 
also provide more information on forecasts of status for 2027. 

b.  strengthen 

the  assessment  of  significant  pressures,  especially 

to 
hydromorphological  pressures  and  impacts  from  sediments  and  organic  matter,  by 
decreasing reliance on expert judgement and expanding the modelling toolbox to cover such 
pressures. 

relation 

in 

c. 

keep up the good work on the assessment methodology for ecological status and should 
provide  further  information  on  the  assessment  method  for  hydromorphological  quality 
elements, on how River Basin Specific Pollutants are used in the classification and on the 
confidence in the classification of ecological status / potential. 

d.  provide detailed information, in its RBMPs, on the additional objectives and measures being 
set for the protection of water bodies associated with protected areas in Finland, and on the 
status of water bodies associated with protected areas. 

e.  provide more information on spatial and substance coverage of monitoring in sediment and 

biota and strive to complete trend analysis for the required substances. 

f. 

g. 

strongly reinforce its in-situ monitoring and rely much less on expert judgement to assess 
the chemical status of surface water bodies. Equally, Finland should provide information on 
the confidence level in their status assessments, for both surface and groundwater. 

improve  the  groundwater  chemical  status  assessment  methodology,  in  particular  by 
monitoring all substances causing risk of deterioration in chemical status. 

29 

 
SECTION B: 
FLOODS DIRECTIVE 

30 

 
 
 
 
7. Flood risk management under floods directive (FD) 

The  Floods  Directive  requires  each  Member  State  to  scan  its  territory  for  flood  risks;  assess  the 
potential adverse consequences of future floods for human health, the environment, cultural heritage, 
and economic activity; identify the significant risks; map the flood extent and the potential adverse 
consequences; and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. The preliminary assessments, mapping 
and planning for flood risk are repeated in six-yearly cycles. 

There are eight Units of Management (UoMs) in Finland, which are corresponding to the River Basin 
Districts (RBDs), established for the Water Framework Directive. In six of these UoMs, Finland has 
designated 22 Areas of Potential Significant Flood Risk (APSFRs). 

Fluvial, pluvial and sea water floods are considered as potentially significant sources of flooding in 
Finland. The impact of climate change on the occurrence of floods was considered at the time of the 
second preliminary flood risk assessment. For the second PFRA a report, published in 2018 and titled 
“Flood risks in Finland now and in the future”, was prepared. The report is based on a new method 
which uses data from past floods, building stock, changes in population, economic growth and the 
development of the climate and the water regime. Different climate and socio-economic scenarios 
are considered; in particular, different scenarios were developed on the predicted sea lever rise. 

7.1 Flood hazard and risk maps 

Finland uses a national map viewer17 for their FHRMs. FHRMs were prepared at the national level and 
show the whole country. Maps for floods with low probability (1/250 years and 1/1 000 years in all 
coastal APSFRs), with medium probability (1/50 years and 1/100 years in all coastal APSFRs) and 
with high probability (various return periods) are provided. All maps show: flood extent; water depth; 
number of inhabitants potentially affected; type of economic activity; and IED installations. Potentially 
affected  protected  areas  identified  in  accordance  with  Annex  IV(1)(i),  (iii)  and  (v)  to  Directive 
2000/60/EC are also shown in the FHRMs. 

Since the first FHRMs, Finland has developed preliminary pluvial flood hazard maps18, but these have 
not yet been published (and no APSFRs for pluvial floods have been identified yet by Finland). 

The  contextual  information,  i.e.  the  way  in  which  information  about  the  maps  is  conveyed  to  the 
public, has changed since the first FHRM. The biggest change is that three separate services now 
exist:  the  full  viewer;  a  reduced  version  without  so-called  “special  scenarios”;  and  one  simplified 
version for the public. Some of the explanatory information regarding the use of the maps and their 
interpretation has been moved from the map viewer to the national Waterinfo website19, which gives 
information on flood mapping in general and links to all versions of the map viewer.  

17https://paikkatieto.ymparisto.fi/tulvakartat/Viewer/Viewer.html?Viewer=Tulvakartathttps://paikkatieto.ymparisto.fi/tulvakar
tat/Viewer/Index.html?Viewer=Tulvakartat_suppea 
18 http://wwwi9.ymparisto.fi/i9/fi/trhs/Tulvariskien_alustava_arviointi_Suomessa_vuonna_2018.pdf , page 7. 
19 https://www.vesi.fi/vesitieto/tulvakarttapalvelu/, accessed 23.6.2023. 

31 

 
 
When it comes to the methodologies used to prepare flood hazard maps, Finland has made some 
progress in flood mapping since the first FHRM. Some fluvial maps were prepared using 2D modelling, 
although  methodologies  used  to  prepare  fluvial  and  coastal  flood  hazard  maps  for  most  APSFRs 
remain largely the same as in the first FHRMs. Moreover, more scenarios to also include yearly or 
other common floods and preliminary pluvial floods maps were prepared. Finally, Finland prepared 
flood maps depicting so-called “special scenarios”, such as floods caused by ice jams and frazil ice20, 
and climate change scenarios.  

The methodology used to prepare flood risk maps remains largely unchanged compared to the first 
FHRM,  although  some  data  sources  have  changed  due  to  database  updates  or  changes  in  which 
public authority is responsible for maintaining the data.  Additionally, some flood risk management 
measures are displayed on the map as point features. 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’. 

7.2 Flood risk management plans 

Objectives and measures 

Four of the five assessed FRMPs were PDF documents. One FRMP, for the Kalajoki catchment within 
the Oulujoki-Iijoki UoM, was produced as a web page. The FRMPs can be downloaded from a national 
webpage21. General objectives are set at national level, and all five FRMPs assessed then set their 
own specific objectives.  

All five FRMPs have specific objectives that explicitly refer to the reduction of adverse consequences 
and identify non-structural measures to achieve their objectives. These objectives address human 
health, economic activities, the environment, and cultural heritage. Three of the five FRMPs assessed 
have  objectives  that  refer  to  raising  public  awareness  and  ensuring  that  authorities  have  the 
necessary expertise. Two FRMPs assessed have set a timeframe for their objectives, an element that 
was missing in the first FRMPs. More generally, the objectives are more specific and measurable than 
in the first FRMPs; for example, objectives are now linked to measures.  

The measures are more specific and measurable in the second FRMPs, providing, for example, more 
information on the timetables of the measures, though the amount of information varies across the 
plans. 

All the FRMPs assessed identify and describe their protection, prevention, preparedness and recovery 
and review measures, including measures for flood forecasting and early warning systems. Finland 
reported  653  such  measures  to  EIONET.  For  all  653  measures,  protection,  preparedness,  and 
prevention measure aspects are similarly distributed: there are 214 protection measures (33% of 
the total); 176 preparedness measures (27% of the total); and 166 prevention measures (25% of 
the total). Finland reported 97 recovery and review measures (15% of all measures).  

Four of the five FRMPs assessed set priorities for their measures, using prioritisation methods that 
are more refined compared to the first FRMPs. Finland reported the prioritisation of measures ranging 

20 Loose ice accumulations with random three-dimensional shape. 
21 https://www.vesi.fi/tulvariskien-hallinta/  

32 

 
 
from critical to low. Of the 653 measures reported, 120 (18%) are categorised as critical, 353 (54%) 
as very high, 45 (7%) as high, 89 (14%) as moderate and 46 (7%) as low.  

All five FRMPs assessed provide information on their timetable for the measures. As in the first FRMPs, 
many  of  the  measures  are  indicated  as  continuous,  with  no  end  date.  For  other  measures,  the 
timeframe for completion is given either as an exact year or estimate of duration (number of years 
or planning periods). Most measures listed in the five FRMPs are expected to be completed by 2027.  

Each  of  the  five  assessed  FRMPs  have  a  dedicated  section22  describing  the  changes  or  progress 
compared to the first FRMPs. The five FRMPs assessed show progress towards the objectives mostly 
by reporting progress in the implementation of measures and include a dedicated section23 describing 
such progress. An overview of this information is provided in a national summary of FRMPs24 and it 
reports that of the 410 measures that were proposed in the first FRMPs, and in 2021, 78 measures 
were completed. Most of the completed measures are for flood protection or preparedness.  

Finland reported to EIONET that 72 measures (11% of the total of 653 measures) are completed. 
The largest share of all measures – 277 measures (42%) are reported as ongoing (recurrent e.g., 
maintenance  works).  A  further  11  measures (2%)  are  reported  as  ongoing  construction,  while  22 
measures (3%) are in preparation. Finland also reported that 140 (21%) measures are not started 
and 131 (20%) are abandoned/interrupted.  

Other measures are reported as not yet started: 35 out of 98 prevention measures (36%), 81 out of 
141 protection measures (57%), 62 out of 127 preparedness measures (49%)  and 33 out  of 88 
recovery and review measures (38%) have yet to start.  

Four of the five FRMPs assessed provide information on funding sources. They refer to funding from 
property owners and other stakeholders that are responsible for individual measures, as well as to 
funding through regional and local public budgets. 

Four of the five FRMPs assessed  refer to at least a qualitative assessment of costs and benefits, 
though  these  plans  provide  little  detail  on  the  approaches  followed.  Natural  water  retention  is 
discussed in some FRMPs, but water retention is more generally mentioned in the context of water 
regulation, including the use of lakes to hold flood waters.  

Finland  reported  to  EIONET  that  all  FRMPs  were  coordinated  with  the  RBMPs  and  considered  the 
WFD’s environmental objectives. The FRMPs assessed indicate that their measures are assessed in 
terms of how they affect the objective of the WFD. All five FRMPs assessed have measures related 
to spatial planning and land use.  

The five FRMPs assessed do not include specific measures targeted to nature conservation – however, 
all five FRMPs address the effects of individual flood measures on the environment in their SEAs. All 
five FRMPs considered climate change in the development of the plans, in their objectives, targets, 
and in the selection and description of measures. For more information on how climate change has 

22 Hamina and Kotka FRMP section 2.4, Kokemäenjoki FRMP section 2.3, Kalajoki FRMP section titled “Yhteenveto 

muutoksista, jotka ovat tapahtuneet edellisen kauden jälkeen”, Kemijoki FRMP and Tornionjoki FRMP section 7.2.3 

23 Hamina and Kotka FRMP section 2.4, Kokemäenjoki FRMP section 2.3, Kalajoki FRMP section titled “Yhteenveto 

muutoksista, jotka ovat tapahtuneet edellisen kauden jälkeen”, Kemijoki FRMP and Tornionjoki FRMP section 7.2.3 

24 https://vesi.fi/aineistopankki/wp-content/uploads/2021/12/Hallintasuunnitelmien_yhteenveto_2022-2027-1.pdf  
page 12 

33 

 
 
been taken into consideration in the preparation of the flood risk management plans, see section 3.7 
of this report.  

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘adaptation to climate change’. 

Governance 

Coordination has taken place at international level for the Tornionjoki UoM, with Sweden. The FRMP 
mentions close cooperation with Sweden on joint flood risk maps and states that the plan’s objectives 
and measures are similar or aligned with those of the corresponding Swedish plan. Coordination on 
climate change is mentioned in the context of joint actions to update the FHRM to include climate 
change scenarios. 

All five FRMPs assessed have a section describing public information and consultation25 and they all 
mention  the  use  of  multiple  methods  for  reaching  the  public  and  stakeholders.  All  the  assessed 
FRMPs refer to a 6-month consultation period and mention two public meetings arranged during the 
second cycle of implementing the FD: the first at the PFRA stage and the second for the draft version 
of FRMPs. These public meetings were carried out online. 

Progress identified in the second FRMPs 

Two FRMPs assessed have set a timeframe for their objectives, an element that was missing in the 
first  FRMPs.  Also,  the  second  plans  now  establish  a  clear  connection  between  the  objectives  and 
measures. In addition, the second FRMPs now describe – to some extent – how measures contribute 
to the achievement of objectives. Moreover, the methods for prioritising measures are more refined 
in the second FRMPs. While the first FRMPs assessed carried out a quantitative CBA for only some 
measures, for four of the five second FRMPs assessed, a qualitative assessment of costs and benefits 
was carried out for most of their measures. Four of the five plans assessed now refer national or 
regional  climate  adaptation  policies,  plans,  and  strategies; the  effects  of  climate  change  are  now 
explicitly explained in the plans, including via quantitative projections of changes in hydrology. Four 
of  the  five  FRMPs  assessed  provide  greater  information,  compared  to  the  first  FRMPs,  on  how 
consultation results were taken into account in the final drafting of the plan. Two of the second FRMPs 
assessed estimate that public awareness of floods has increased since first FRMPs, due to measures 
in the earlier plans. 

8. FD recommendations 

Based on the reported information and the FHRMs and FRMPs assessed, Finland should: 

• 

• 

consider pluvial flooding in the FHRM; 

provide, in the FRMP, details on how the FHRM was used in the choice of objectives and measures; 

25 Hamina and Kotka FRMP section 7, Kokemäenjoki FRMP section 7, Kalajoki FRMP no section number, Kemijoki FRMP 
section 8, Tornionjoki FRMP section 8. 

34 

 
 
• 

• 

• 

• 

• 

ensure that the increased accessibility to the public of the web-based FRMP does not have a negative 
impact on the level of detail included in the FRMP; 

ensure that the FRMP’s objectives are made more specific and where possible linked to quantitative 
indicators and be timebound; 

provide information on the costs of all measures included in the FRMPs; 

set out the methods used to monitor measures in the FRMPs; 

consider flow velocity or relevant water flow in the FHRM and the flood conveyance routes in the FRP, 
where appropriate, as these are relevant to emergency response. 

35