Reporting data to the Incomes Register: employer’s separate report

This instruction is intended for payers. It describes:

• the cases in which the employer's separate report must be submitted;
• when and how it is submitted;
•  what information is reported; and
• the cases in which a household must submit the employer’s separate report.

These instructions replace the earlier instructions titled Reporting data to the Incomes Register: employer’s separate report.

The following additions and clarifications have been made to the instructions:

•  Clarified foreign employers’ reporting obligation in Section 2.1.
•  Clarified the definition of the reporting period in Sections 4.1 and 4.3.
• Added a new example of the difference between the reporting period and pay period in Section 4.3.

Some technical specifications have also been made. Otherwise, the contents of these instructions match the previous instructions.

1 About the employer’s separate report

Employers and other payers use the earnings payment report to submit almost all earnings payment data to the Incomes Register. If necessary, the payer also uses the employer’s separate report to submit data that does not concern an individual income earner.

The payer uses the employer’s separate report to submit:

• the total amount of employer's health insurance contribution calculated based on the wages paid during the month in question and any deductions from that amount; and the
• No wages payable data item, if the payer is registered with the Tax Administration’s Employer Register and has made no wage payments during the month in question.

While the payer must submit an earnings payment report for each income earner, only one employer’s separate report is required per payer. The employer must therefore submit at least two reports to the Incomes Register for each month in which wages were paid: an earnings payment report and the employer's separate report. Only one employer’s separate report can be submitted for each relevant month.

Employers must pay and report the employer’s health insurance contribution on their own initiative. Such data is reported to the Incomes Register on a monthly basis. Further information on paying the employer's health insurance contribution and the payment deadlines is provided on the Tax Administration’s website at vero.fi.

For taxation purposes, an employer is considered either as a regular or casual employer. This determines when and what kind of data is submitted using the employer’s separate report. There are specific requirements concerning a household’s obligation to submit the employer's separate report, which are described later in chapter 6.

The Income earner is a person or business to whom a contribution is paid.

Temporary employer and contract employer are concepts used by earnings-related pension providers, describing whether or not the payer has taken out a pension insurance policy from an earnings-related pension provider.

• A temporary employer pays no more than EUR 9,348in wages over a period of six months (in 2023) and does not have any permanent employees. A temporary employer does not have a valid pension insurance policy with an earnings-related pension provider.

• An employer who has a permanent employee or pays more than EUR 9,348 in wages over a period of six months (in 2023) must take out a pension insurance policy from an earnings-related pension provider. In such a case, the employer becomes a contractual employer.

The concepts of casual employer and regular employer are related to the Tax Administration’s employer registration.

• A payer is regarded as a regular employer in the following situations:
  • The payer regularly pays wages to at least two employees
  • The payer regularly pays wages to one employee and also pays wages to at least one other employee whose employment is fixed-term or short-term.
  • The payer pays wages to at least six employees whose employment contracts are fixed-term and short period.
• Employers who pay wages regularly must register with the Tax Administration’s employer register before they begin wage payments. A regular employer must submit the employer’s separate report to the Incomes Register for each month.

• A payer is regarded as a casual employer if one of the following is true:
  • The payer only has one employee.
  • The payer has up to five employees whose employment contracts do not cover an entire calendar year.
• Employers who pay wages sporadically do not have to register with the employer register. Casual employers are only obliged to submit the employer’s separate report to the Incomes Register for the months during which they pay wages or reimbursement of expenses.
• However, casual employers may register with the employer register voluntarily. If they do so, they will be considered equivalent to regular employers and must submit the employer's separate report each month.

Maintained by the Finnish Tax Administration, the Employer Register is a public register of employers who pay wages regularly. Provisions on the Employer Register are given in the Prepayment Act. Further information on employers who pay wages regularly or casually is provided on the Finnish Tax Administration’s website at vero.fi.

Household employer is, for the purposes of this instruction, a natural person or an estate that pays wages that are unrelated to the trade or other activities carried out by the household to earn income. A household employer can be a casual or regular employer. More information on a household’s reporting obligation is described in the instruction Reporting data to the Incomes Register: households as employers.

2 Who submits the employer’s separate report?

Regular employers must submit the employer’s separate report for each month, including when they have made no wage payments.

Casual employers submit the employer’s separate report only for the wage payment months, i.e. for the months when they must also submit an earnings payment report for each income earner. Casual employers do not have to submit the employer’s separate report for the months when they do not pay wages or reimbursement of expenses.

Households that are sporadic employers must submit the employer’s separate report for the wage payment months only when they pay the same income earner more than EUR 1,500 in total over a calendar year. If a household employer pays an income earner EUR 1,500 or less over a calendar year, it does not have to pay the employer’s health insurance contribution or submit the employer’s separate report. For more information, see chapter 6 When does a household submit the employer's separate report?

2.1 Foreign employer's separate report

A foreign employer that is a non-resident taxpayer is obligated to submit the employer’s separate report to the Incomes Register if any of the following conditions is met:

• The company has a permanent establishment in Finland.
• The company has registered as a regular wage-paying employer with the Tax Administration’s Employer Register.
•  The company voluntarily pays the employer’s health insurance contribution.

The company has a reporting obligation, regardless of whether its employees are covered by health insurance in Finland. A foreign corporate entity that is a resident taxpayer in Finland is considered a Finnish employer. In this case, the corporate entity has the same obligation to submit reports to the Incomes Register as Finnish employers.

If a foreign employer is obligated to submit an employer’s separate report, the employer submits the report to the Incomes Register in the same way as a Finnish employer (see Section 4.3 for instructions on how to report the health insurance contribution).

Foreign employers submit one employer’s separate report per month. If, based on the wages and other payments made during a reporting period, it is not necessary to pay the employer’s health insurance contribution for a certain month, the employer should enter EUR 0 under ‘Employer’s health insurance contribution (total)’.

3 When and how is the report submitted?

The employer’s separate report is submitted electronically. It can be submitted directly to the Incomes Register from the payroll system, via the technical interface. The report can also be submitted via the Income Register’s e-service, either by uploading it as a file or entering the data from each individual report into an online form. Alternatively, the report can be submitted at Palkka.fi.

Data can be submitted in paper format only in special circumstances. Special circumstances can be regarded as situations in which the electronic submission of the data could not reasonably be required, such as when a natural person, estate, casual employer or foreigner does not have the possibility to submit data electronically. 

The employer's separate report is submitted monthly, no later than on the fifth day of the calendar month following the payment month. If the report deadline is a regular Saturday or holiday, the data can be reported on the following banking day. If the separate report is submitted exceptionally in paper format, it must be submitted no later than on the eight day of the calendar month following the wage payment month.

Employers who cancel their registration with the Employer Register must submit their final employer’s separate report for the wage payment month during which the registration was cancelled. A report must be submitted, even if wages were not paid during that month.

4 What kind of data is reported?

The following data must be included in the employer’s separate report:

• details of the payer, contact person, date of reporting and the reporting period;
• technical information on the record if the data is submitted via the technical interface or by uploading it as a file via the e-service;
• employer’s health insurance contribution in total, if wages have been paid;
• any deductions made from the total amount of the health insurance contribution; and
• the No wages payable data item if wages have not been paid and the payer is a regular employer.

If the report contains the No wages payable data item, it must also include:

• information on the payer’s earnings-related pension insurance (pension policy number and earnings-related pension provider code); and
• information on the payer’s occupational accident insurance policies (occupational accident insurance company identifier, i.e. Business ID, and policy number), if the payer has more than one valid occupational accident insurance policy.

4.1 Reporting period

The reporting period is the month for which the data on the employer’s separate report is submitted to the Incomes Register. Reporting period data comprises the calendar month and the year. The reporting period is other than the pay period or the period when income was earned. The difference between these concepts is described in more detail in Example 1 in Section 4.3.

The No wages payable data item can be reported for six months ahead. The reported payment year can therefore be the current or the next year.

The employer’s health insurance contribution in total and any deductions made from the employer’s health insurance contribution can be reported for no more than one month before the beginning of the reporting period. For example, data for March can be reported no earlier than on 1 February.

4.2 No wages payable data item

If an employer is registered with the Tax Administration’s employer register, i.e. is a regular employer, but does not make any wage payments or reimburse any expenses during the month in question, the employer must enter the No wages payable data item (income type 101) on the employer’s separate report. The ‘No wages payable’ data item cannot be submitted if the total amount of health insurance contributions is reported with the same report.

This data is submitted only when the employer has not made any payments whatsoever during the month in question. For example, if the employer has paid only tax-free reimbursements of expenses, such as tax-free kilometre allowances, the No wages payable data item is not submitted. The amount of health insurance contribution (income type 102) given in the separate report is EUR 0.

The No wages payable data item is submitted separately for each such month during which the payer has not paid any wages. The data can be reported in advance for six calendar months, if it is known that there is no intention of paying wages over the next six months. However, if wage payments are nevertheless made during this period, the correct data must be submitted using a replacement report for the wage payment month.

When the report includes the No wages payable data item, information must also be submitted on the payer’s earnings-related pension policy and the occupational accident insurance policy. Based on this information, the Incomes Register can notify the earnings-related pension providers and accident insurance pension providers that the payer does not have any wage payments for that month.

Information on the payer's earnings-related pension insurance and accident insurances is not submitted if the payer is not under obligation to provide insurance. This is the case when, for example, wages are paid to an income earner who is only insured under the self-employed persons' pensions act (yrittäjän eläkelaki 1272/2006 (YEL)) or the farmers' pensions act (maatalousyrittäjän eläkelaki 1280/2006 (MYEL)). The payer must then report the total amount of health insurance contributions calculated based on the wages paid to the self-employed person, but no insurance information is specified. If the payer is not under obligation to provide insurance and pays no wages at all for the reporting period, the payer reports the No wages payable data item without insurance information.

A casual employer who does not make any wage payments over a month does not have to submit the employer’s separate report or the No wages payable data item for that month.

The No wages payable data item cannot be submitted separately for each suborganisation.

4.3 Employer's health insurance contribution (total)

The employer will calculate the employer's health insurance contribution based on the wage payments the employer has made over the month. The calculation includes the payments whose payment or reporting date takes place during the month in question. The employer reports the amount on the employer’s separate report under Employer’s health insurance contribution (total) (income type 102). The total amount of wages is not reported in this section. The employer must pay and report the amount of the employer’s health insurance contribution separately.

The employer’s separate report must always be submitted for one calendar month, even if the payment period for the employer’s self-assessed taxes were a quarter. The reporting period for the separate report is other than the pay period or the period when specific income was earned. The pay period and earnings period can be longer or shorter than one month.

If, based on the wages and other payments made, it is not necessary to pay the employer's health insurance contribution for a certain month, the employer should enter EUR 0 under Employer's health insurance contribution (total). For example, if the employer has only paid tax-free reimbursements of expenses over the month, both regular and casual employers should enter EUR 0 under the Employer’s health insurance contribution (total).

If an employer has only paid non-wage compensation for work during a month:

• A regular employer reports EUR 0 as the health insurance contribution amount. The ‘No wages payable’ data item is not submitted because payments have been made.
• A casual employer does not submit the employer’s separate report (no EUR 0 as the total amount and no ‘No wages payable’ data item).

If all income the employer submits for the month using the earnings payment reports is not subject to earnings-related pension insurance contribution, the employer does not have to include the earnings-related pension provider code or pension policy number in the report. However, because income has been paid, this is not a case of No wages payable.

The deductions reported under the 'Deductions to be made from the employer's health insurance contribution' income type are not deducted from the total amount of the employer's health insurance contribution. The amount of the employer’s health insurance contribution must therefore be given in full. Any deductions made from the employer’s health insurance contribution are reported under a different income type.

The income type 102 Employer’s health insurance contribution (total) cannot be reported as a negative sum.

The actual employer also reports and pays the employer’s health insurance contributions for any wages that a substitute payer has paid and for which the substitute payer has withheld tax. Any wages paid by the substitute payer are taken into account in the amount of the employer’s health insurance contribution for the month when the substitute payer paid the wages. For further instructions, see Reporting data to the Incomes Register: payments made by substitute payer.

4.4 Deductions to be made from the employer’s health insurance contribution

An employer may be reimbursed for the employer’s health insurance contribution under certain conditions. Such a situation may arise if the employer has made a wage payment to an employee while having been paid a statutory pension, daily allowance or a benefit compensating for the loss of the income granted to the employee. The employer is entitled to claim back the employer’s health insurance contribution up to the amount corresponding to the payment made to the employer. The payer calculates the sum of the health insurance contribution from the compensation it has received and reports the sum as a deduction to be made from the employer’s health insurance contribution.

The payer must use the employer’s separate report to report the deduction to be made from the employer's health insurance contribution under Deductions to be made from the employer’s health insurance contribution (income type 103). The amount must be reported in the separate report for the month during which the employer’s health insurance contributions for the absence period was originally reported. The employer’s health insurance contributions for the month in question will then be reduced, and the Tax Administration will refund the excess amount to the employer with interest or use it to cover other contributions.

The payer can also make the deduction during a later period in the same calendar year. For example, the deduction can be reported for the period during which the payer is informed of the benefit decision entitling it to claim back the employer’s health insurance contributions paid earlier in the year. The amount of the health insurance contribution for the employer will then be reduced for the period for which the deduction is reported, but the payer will not receive the compensatory interest that would have been paid if the deduction had been paid retroactively for the original period.

5 How is the employer’s separate report corrected?

The data in the employer's separate report is corrected in the same way as the earnings payment data submitted to the Incomes Register. For more information on this, see Correcting data in the Incomes Register, especially chapter 7 Correcting an employer's separate report.

The instruction also explains how data can be corrected when the income earner was not entitled to a payment that was made and submitted earlier to the Incomes Register (Correcting data in the Incomes Register, section 3.1 Unjust enrichment). In most cases, an unjust enrichment is notified by submitting a replacement report. This supersedes the original earnings payment report, for the payment date, which was used to submit the income to the Incomes Register. An employer’s separate report submitted for the wage payment month in question must also be corrected by submitting a replacement report, because the unjust enrichment is not subject to the employer’s health insurance contribution.

In certain situations, the replacement procedure cannot be used, but the employer's separate report must be cancelled and a new report submitted with the correct data.

The data must be corrected by cancelling the previous report and then submitting a new one in the following situations:

• correction of the reporting period;
• correction of the payer's customer identifiers;
• correction of the pension provider code or pension policy number; and
• correction of the occupational accident insurance company identifier or policy number.

6 When does a household submit the employer’s separate report?

A household employer does not have to collect the tax to be prepaid or pay the employer’s health insurance contribution, if the wages paid to an income earner do not exceed EUR 1,500 during the calendar year and the payment is unrelated to the payer’s trade or other income-earning activities. To ensure that a household that is a casual employer does not have to submit empty (EUR 0) employer's separate reports when it does not to have to pay the employer's health insurance contribution, the same EUR 1,500 threshold is applied to the household reporting procedure.

If the wage payments a household employer makes to an income earner come to EUR 1,500 or less over a calendar year, the household employer does not have to pay the employer’s health insurance contribution or submit the employer’s separate report.

However, if – during the first wage payment month – the household already knows that it will go over the annual threshold of EUR 1,500, the household must withhold tax and pay the employer's health insurance contribution based on the wage payments, starting from the first payment month. The household must submit the employer's separate report for each wage payment month.

The estimated amount of wages may change during the year. If the household estimated that the wages paid to the income earner would be no more than EUR 1,500 per year, the household has not had to withhold tax or pay the employer's health insurance contributions.

However, if the annual wage payments come to more than EUR 1,500, the household must withhold tax from the month when the EUR 1,500 is exceeded. The household does not have to withhold tax in arrears for wages paid earlier. However, the employer’s health insurance contribution must be paid for the total amount of wages paid over the year.

The household can submit the total employer’s health insurance contribution to be paid for the wages during the early year using the separate report for the month during which the annual limit of EUR 1,500 is exceeded. The household does not have to pay any penalties for submitting the full amount of the employer's health insurance contribution at this stage.

Households must enter Household as the payer type when submitting an employer’s separate report. If the submitter represents a pool of household employers, the payer type Pool of household employers must also be entered.