23 Oct 2026
The Finnish Government issues proposal for new FDI Act
Related practises
The Finnish Government has on 22 October 2026 submitted its proposal for a new Foreign Direct Investment (FDI) Act to the Finnish Parliament. The Parliament is expected to consider the proposal and pass the Act in the coming months. The targeted entry into force of the new Act is on 1 April 2027. The new rules are expected to apply to all investments that are not completed or notified at the time the Act enters into force.
The reform broadens the material scope of investments subject to screening and introduces several procedural amendments. Below, we summarise the key changes between the current FDI Act and the proposal for the new Act.
Key changes: Proposed Finnish FDI reform
Notification triggers
| Current Finnish FDI Act | Proposed Finnish FDI Act | |
|---|---|---|
| Definition of foreign investor | Depending on the screened business, either: a) all entities and individuals not resident in Finland (including Finnish entities with ≥10% of the votes directly or indirectly held by such entity or individual); or b) all entities and individuals not resident in the EU or EFTA (including EU/EFTA entities with ≥10% of the votes directly or indirectly held by such entity or individual) | All entities not resident in Finland and all individuals who are not Finnish citizens (including Finnish entities with ≥10% of the votes directly or indirectly held by such entity or individual)
|
| Investment thresholds | Acquisitions of ≥ 10, 33 and 50% of the aggregate of all votes in a company (or an equivalent influence) | Acquisitions of ≥ 10, 33, 50, 66, and 90% of the aggregate of all votes in a company (or an equivalent influence) |
| Existing businesses subject to screening | 1) Production and supply of defence materiel and products important for national defence; 2) production and supply of dual-use products and use of dual-use technology; 3) supply of critical products and services to key security authorities; and 4) activities critical for securing functions vital to society | 1) Production and supply of defence materiel and products important for national defence; 2) production, supply and significant use of dual-use products; 3) supply of critical products and services to key security authorities; 4) access to certain classified information; 5) security critical ICT and information security services; 6) activities connected to security of supply, critical infrastructure and other functions vital to society; and 7) all entities within the scope of EU Foreign Investment Screening Regulation |
| Greenfield investments subject to screening | None | 1) Production and supply of defence materiel and products important for national defence; 2) production and supply of dual-use products; 3) port infrastructure and certain port services, 4) airport infrastructure and certain airport services; 5) certain logistics terminals; 6) certain data centres, including all projects with potential power demand of at least 100 MW; 7) certain energy projects, including solar and wind power projects with electric power of at least 300 MW, other electricity production and storage projects with electric power of at least 100 MW, hydrogen production with a yield of at least 2 tonnes per hour as well as district heating and cooling with a total production of at least 100 MW; 8) projects connected to natural gas networks; and 9) certain mining and refinement projects |
Filing process and penalties
| Current Finnish FDI Act | Proposed Finnish FDI Act | |
|---|---|---|
| Mandatory and suspensory filing | Mandatory for companies screened for defence or security activities, voluntary for others | Yes, for all investments within the scope of the Act |
| Procedural timelines | No statutory deadlines in mandatory filings; three months in voluntary filings | 45 days for Phase I; no statutory deadline for Phase II |
| Consequences in cases of failure to notify | Criminal fine for individuals responsible | Administrative fine with a maximum of EUR 10 million or 10% of global turnover (depending on which is larger); a smaller administrative fine for natural persons; the transaction may be declared null and void, if a request to file or restore the situation to a lawful state (e.g., by disposing of acquired shares or a board seat) is not complied with |
| Number of applications annually | Approximately 30–40 in recent years | Around 100 annually, according to authorities' estimates |
| Can clearance be conditional? | Yes | Yes |
Additional information
Our Competition & Regulatory practice will continue to follow the progress of the Government proposal. If you have any questions or would like to discuss the topic further, please feel free to contact the lawyers listed on this page.
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