Reporting data to the Incomes Register: payments made by substitute payer

Date of issue
12/23/2019
Record no.
VH/6322/00.01.00/2019
Validity
12/23/2019 - Until further notice

These instructions are for parties acting as substitute payers and for actual employers.

They describe:

  • the obligation of substitute payers and actual employers to report data to the Incomes Register
  • reports submitted by a substitute payer to the Incomes Register
  • reports submitted by an actual employer to the Incomes Register in situations involving a substitute payer.

In addition, examples are provided to describe the reporting of the most common situations involving a substitute payer: reporting of payments made by Kela, a bankruptcy estate, municipalities and pay security.

The examples in these instructions do not depict all mandatory data, only the data required in situations involving a substitute payer. The sums used in the examples are examples only and the amount of social insurance contributions and the withholding rate must be checked for each year. The withholding is determined on the basis of the withholding rate of each recipient.

More information on households' obligation to report income is provided in the instruction Reporting data to the Incomes Register: households as employers.

These instructions replace the earlier instructions titled Reporting data to the Incomes Register: payments made by substitute payer.

Instructions on reporting in bankruptcy situations were updated in Section 2.4. A table illustrating the submitting of reports in bankruptcy situations has been added to the end of the instructions.

1 General information on situations involving a substitute payer

Substitute payer means a payer who pays wages or other remuneration from their own funds on behalf of a party with the actual liability to pay (actual employer). Further, the substitute payer reports data to authorities on behalf of the actual employer based on either law or agreement (e.g. reports to the Incomes Register). As a rule, the substitute payer pays the wages and withholds tax while the actual employer pays the employer’s social insurance contributions. 

Usual substitute payers include enforcement agencies, municipalities, Kela, Centres for Economic Development, Transport and the Environment (ELY Centres) and bankruptcy estates. Other potential substitute payers include creditors, guarantors or other payers acting on behalf of an employer who is in financial difficulties. Group companies and foreign employers can also use substitute payers.

A substitute payer is not the same as an agent. Agents act in, and under, the name of the actual payer (e.g. the employer). Their actions are usually based on an authorisation. They can also use the funds of the principal to make payments. The agent and the actual employer can also agree that the agent should handle all the employer obligations on behalf of the actual employer. Detailed information about being an agent is not provided in these instructions.

The municipality's role as a substitute payer is significant when the municipality is in charge of paying wages to a personal assistant and reporting data on behalf of a person requiring assistance.

The substitute payer can report the data on all the employees of one actual employer in one record. Payments made as a substitute payer and payments made by the same party to its own employees cannot be reported in one and the same record. More information on reporting is provided in other detailed instructions concerning the Incomes Register.

1.1  Substitute payer’s obligations

The substitute payer pays an employee or other income earner on behalf of the actual employer from their own funds. Under the prepayment act (ennakkoperintälaki 1118/1996), the substitute payer is obligated to withhold tax even if the work paid for was carried out in the name of the actual employer. If, instead of the payer, the payer's guarantor, creditor or other payer (substitute payer) pays wages to the income earner, the party who makes the payment has the obligation to withhold tax on the paid amount if no tax has been withheld previously. Correspondingly, the enforcement authority is liable to withhold tax on the funds accrued through enforcement, and a bankruptcy estate on payments made from the estate's assets.

The substitute payer must submit a report to the Incomes Register on all the wages paid and taxes withheld. The substitute payer must also report to the Incomes Register the earnings-related pension insurance contributions and unemployment insurance contributions collected from an employee, if the substitute payer has collected and deducted the employee's social insurance contributions from the wages paid to the employee. Income tax is levied in the income earner's tax assessment on the basis of the substitute payer's report. Correspondingly, the guarantor, creditor or other payer is obligated to report to the Incomes Register any payments they have made as a substitute payer. Social insurance contributions can be imposed on the actual employer on the basis of the substitute payer’s reports.

The substitute payer’s obligations may vary according to what has been agreed between the substitute payer and the actual employer. As a rule, the substitute payer is not obligated to pay the employer’s social insurance contributions – paying them is the responsibility of the actual employer.

1.2  Employer obligations

Although the substitute payer pays wages on behalf of the employer, the actual employer is obligated to report the wages paid by the substitute payer on an earnings payment report using a separate form for each income earner. Specific income types for situations involving a substitute payer are used to report this data. If the substitute payer has paid income that does not constitute grounds for social insurance contributions, the actual employer need not submit reports.

The actual employer is obligated to pay the employer’s social insurance contributions on the basis of the wages paid by the substitute payer. This means that the actual employer must see to it that they arrange statutory earnings-related pension insurance with an authorised pension provider (i.e. take out insurance with an authorised pension company or provide insurance through an industry-wide pension fund or a company pension fund) and, as a result, have a pension policy number required for pension insurance purposes.

The employer has the obligation to take out occupational accident and occupational disease insurance by signing an insurance contract with an accident insurance provider. Insurance must be taken out before the commencement of work. As a policy holder, the employer is obligated to pay the insurance contributions. On the Incomes Register's earnings payment report the employer must report the occupational accident insurance company identifier and the policy number, if the employer has concurrent occupational accident insurances.

The employer is also obligated to pay the unemployment insurance contributions and submit earnings payment reports to the Incomes Register. Similarly, the employer is obligated to pay and report the employer's health insurance contributions to the Incomes Register using the employer's separate report.

1.3  Deadline for reporting

As a rule, substitute payers must submit reports on monetary payments no later than on the fifth calendar day after the date of payment. The date of payment refers to the date on which the payment is available to the income earner, for example withdrawable on the income earner's account.

Actual employers must submit an earnings payment report and the employer's separate report to the Incomes Register for each wage payment month no later than on the fifth day of the calendar month following the payment month (section 12(9) of the act on the Income Information System; laki tulotietojärjestelmästä 53/2018). If the actual employer itself has also made payments to the income earner, they must be reported in addition to the payments made by the substitute payer. However, it must then be taken into account that, as a rule, the deadline for reporting payments made by the actual employer is the fifth calendar day after the date of payment.

Reporting deadlines and penalties for failing to meet deadlines are described in more detail in the instructions Reporting income data: penalty fees and Reporting data to the Incomes Register.

1.4  Terminology

Terminology
Term Description
Substitute payer A payer who pays wages or other remuneration from their own funds on behalf of a party with the actual liability to pay (actual employer).
Actual employer A party who has a legal obligation to pay wages and take out insurance for employees. The actual employer is the party who has hired the employee and in whose name the employee works.
Agent A party who acts in, and under, the name of the actual payer. Agents usually act based on an authorisation. They can also use the funds of the principal to make payments.
Contractual employer A term used in the earnings-related pension sector to refer to the employer in the following situation: The employer has at least one employee on a continuous basis or the amount of wages paid by the employer over a period of six months is at least EUR 8,676 (in 2020). A contractual employer has a contract with an authorised pension insurance company and provides statutory pension coverage under the Employees Pension Act (TyEL insurance; pension policy number NN-xxxxxxxx).
Temporary employer A term used in the earnings-related pension sector to refer to the employer in the following situation: The employer has arranged pension coverage for employees without taking out an insurance policy. Operating as a temporary employer is possible only if the employer does not continuously have at least one employee on the payroll and if the total wages paid by the employer to fixed-term employees over a period of six months are below EUR 8,676 (in 2020).
Personal assistant Personal assistant means an employee who has been hired as an assistant for a person with severe disability, for example.
Person requiring assistance (PRA) PRA refers to a person who requires assistance, i.e. the actual employer.
Substitute payer’s report The substitute payer's report means an earnings payment report that the substitute payer is obligated to submit to the Incomes Register on each income earner on the basis of the payments made.
Actual employer's report The actual employer's report means the earnings payment report submitted by the actual employer to the Incomes Register on the wages paid by a substitute payer. Additionally, the actual employer must report any other payments it has made to the income earner. The actual employer’s report also means the employer's separate report on the total amount of health insurance contributions submitted by the actual employer.

2 Reporting of substitute payers payments to the incomes register in different situations

2.1 Basic situation

As a rule, a substitute payer reports monetary payments and other benefits to the Incomes Register no later than on the fifth calendar day after the date of payment using an earnings payment report. All the income types used in the Incomes Register are at the substitute payer's disposal. Monetary wages, for example, are reported by the substitute payer using either a method with lower level of detail (reporting method 1) or a method with greater level of detail (reporting method 2). The reporting of wages is described in more detail in the instructions Reporting data to the Incomes Register: monetary wages and items deducted from wages. The substitute payer reports their substitute payer status and the actual employer's customer identifier in the “Substitute payer” data group.

The income and the tax withheld are taken into account in the income earner’s tax assessment on the basis of the report submitted by the substitute payer. In contrast, the employer’s social insurance contributions are determined on the basis of the actual employer's earnings payment report and the employer's separate report.

The actual employer must submit to the Incomes Register an earnings payment report and the employer's separate report on the wages paid by the substitute payer. Also, if the actual employer itself makes payments to the income earner, they must be reported as well. The actual employer's report can also be submitted by another party, such as a substitute payer, if this has been agreed separately between the substitute payer and the actual employer. Even in this case the responsibility for reporting falls on the actual employer.

If the substitute payer has paid income that does not constitute grounds for social insurance contributions, the actual employer need not submit reports.

The actual employer must submit an earnings payment report to the Incomes Register using income types specified for situations involving a substitute payer (see the list below). If the wages paid to the income earner are subject to all social insurance contributions, the actual employer reports the wages under the income type: ”Wages paid by substitute payer: employer pays for the employer's social insurance contribution (earnings-related pension, health, unemployment, and occupational accident and disease insurance contributions)”. If the wages are subject only to a certain employer's contribution, the income is reported under the income type for that particular contribution. For example, if the income were subject only to the employer's health insurance contribution, it would be reported under the income type “Wages paid by substitute payer, employer pays for employer's health insurance contribution”. More than one income type intended for situations involving a substitute payer can be used for the same payment (see Section 2.1, example 3, table 2 and Section 2.4, example 9, table 2).

The actual employer can use the following income types in its reports:

Actual employer's income types
Code* Income type name
321 Wages paid by substitute payer: the employer pays for the employer's social insurance contributions (earnings-related pension, health, unemployment, and accident and occupational disease insurance)
322 Wages paid by substitute payer: employer pays for employer's earnings-related pension insurance contribution
323 Wages paid by substitute payer: employer pays for employer's unemployment insurance contribution
324 Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution
325 Wages paid by substitute payer, employer pays for employer's health insurance contribution

* The code in front of the name of the income type is the code value used for the income type in the earnings payment report.

Any payments made are reported according to the employer's obligations regarding the income in question.

The actual employer must report all the data about the employer and the income earner that are needed by data users. This means that, for example, if the actual employer is a temporary employer, they must report the detailed contact information needed by the authorised pension provider. Correspondingly, the data needed by data users about the income earner must be reported; for example, if the income earner is a non-resident taxpayer. Furthermore, it is recommended that the actual employer should report the necessary employment relationship data about the income earner and any absence data available.Reporting earnings periods is recommended, as the information is needed by many data users.

If a substitute payer has paid wages two times in a month, either payment date can be entered in the actual employer's earnings payment report. The priority is that the report is allocated to the correct payment month. Alternatively, the actual employer can submit two separate reports for each payments made by the substitute payer.

In addition to the payments made by a substitute payer, the actual employer must report any payments it has made to the income earner. However, it must then be taken into account that, as a rule, the deadline for reporting payments made by the actual employer is the fifth calendar day after the date of payment. If a payment is made by a natural person or an estate that is not registered in the Tax Administration’s Employer Register, the data on the payments made by the employer itself can be submitted by the same deadline as the data on the substitute payer's payments, i.e. by the fifth day of the calendar month following the month of payment.

The payment periods of the actual employer and of the substitute payer may be different.

The actual employer must also submit to the Incomes Register the employer's separate report, reporting the total amount of the employer’s health insurance contribution and a deductible amount calculated on the basis of any items deductible from the employer’s health insurance contribution. Households must submit the employer's separate report if the amount of wages paid to one employee is more than EUR 1,500 a year. More information on households' obligation to report income is provided in the instructions Reporting data to the Incomes Register: households as employers.

The need for submitting an employer's separate report depends on whether the actual employer pays wages regularly or casually and whether the payment was income subject to a health insurance contribution or other income.

  • Over the month, the substitute payer makes payments subject to a health insurance contribution and the actual employer is a regular employer:
    • The actual employer reports the total amount of the employer's health insurance contribution every month.
  • Over the month, the substitute payer makes payments subject to a health insurance contribution and the actual employer is a casual employer:
    • The actual employer reports the total amount of the employer's health insurance contribution for the months during which wages have been paid.
  • Over the month, the substitute payer only makes payments not subject to a health insurance contribution and the actual employer is a regular employer:
    • If the payment was, for example, non-wage compensation for work, a meeting fee paid to an outsider, or reimbursement of expenses, the actual employer reports EUR 0 as the amount of the employer's health insurance contribution.
  • Over the month, the substitute payer only makes payments not subject to a health insurance contribution and the actual employer is a casual employer:
    • If the payment was, for example, a meeting fee paid to an outsider or reimbursement of expenses, the actual employer reports EUR 0 as the amount of the employer's health insurance contribution.
    • If the payment was, for example, non-wage compensation for work, an employer's separate report does not need to be submitted.

The reporting of payments made as pay security and payments made by a bankruptcy estate is described separately in section 2.4.

Example 1: Basic case, the actual employer is a contractual employer.

On 15 August, a substitute payer has paid an income earner on behalf of the actual employer EUR 1,500 in time-rate pay and EUR 500 in evening shift allowance, withheld EUR 400 in taxes and collected the employee’s social insurance contributions.

The substitute payer reports to the Incomes Register the following details:

Earnings payment report submitted by substitute payer

Example 1, table 1/3

Earnings payment report submitted by substitute payer

Type of action: New report

Pay period

Payment date: 15.08.20xx

The start date of the pay period:01.08.20xx

The end date of the pay period:31.08.20xx

Payer (=substitute payer's) details

Type of identifier: Business ID

Identifier: 1234567-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type:Business ID

Employer identifier: 8765432-1 (actual employer's customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Code Income type details EUR
201 Time-rate pay 1500.00
207 Evening shift allowance 500.00
402 Withholding tax 400.00
413 Employee's earnings-related pension insurance contribution 143.00
414 Employee's unemployment insurance contribution 25.00

The substitute payer does not collect and deduct the employee’s social insurance contributions from wages in all situations. To determine and verify the employer's social insurance contributions, the actual employer must report on its own report the wages paid by the substitute payer on which the employer pays the social insurance contributions.

The actual employer reports to the Incomes Register the wages paid to the income earner by the substitute payer:

Example 1, table 2/3

Actual employer’s report (earnings payment report)

Type of action: New report

Pay period

Payment date: 15.08.20xx

The start date of the pay period:01.08.20xx

The end date of the pay period: 31.08.20xx

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 8765432-1 (actual employer’s customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information: Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR

321

Wages paid by substitute payer: employer pays for employer's social insurance contribution

Earnings period 01.08.–15.08.20xx

2000.00

Additionally, the employer must report on the employer's separate report the total amount of health insurance contributions it has paid on the basis of the wages paid by the substitute payer.

The employer reports:

Example 1, table 3/3

Actual employer’s report (employer’s separate report)

Type of action: New report
Reporting date: 05.09.20nn

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 8765432-1 (actual employer’s customer ID)

Report information

Payment month: 08

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 26.80

Example 2: Basic case, the actual employer is a temporary employer.

The substitute payer pays EUR 1,650 to the income earner. The amount contains EUR 1,000 in contract pay, EUR 500 in compensation for termination and EUR 150 in compensation for waiting time.

The substitute payer withholds taxes (EUR 375) from the income earner's pay. In addition, the substitute payer collects the employee’s social insurance contributions from the pay subject to earnings-related pension and unemployment insurance contributions (EUR 1,000). The compensations for waiting time and termination are not subject to social insurance contributions.

The substitute payer reports the data to the Incomes Register on an earnings payment report.

Example 2, table 1/4
Earnings payment report submitted by substitute payer (reporting method 2 for monetary wages)
Type of action: New report

Pay period

Payment date: 15.02.20xx

The start date of the pay period:01.02.20xx

The end date of the pay period: 10.02.20xx

Payer (=substitute payer's) details

Type of identifier: Business ID

Identifier: 77885544-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID or personal identity code

Employer identifier: 01010101-1 (actual employer's customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Code Income type details EUR
227 Contract pay 1000.00
208 Notice period compensation 500.00
217 Waiting time compensation 150.00
402 Withholding tax (on EUR 1,650) 375.00
413 Employee's earnings-related pension insurance contribution (on EUR 1,000) 71.50
414 Employee's unemployment insurance contribution (on EUR 1,000) 12.50

Alternatively, the substitute payer can report the monetary wages it has paid in accordance with reporting method 1. The different ways of reporting monetary wages are described in greater detail in the instructions Reporting data to the Incomes Register: monetary wages and items deducted from wages. In such a case, the substitute payer reports the data as follows:

Example 2, table 2/4
Earnings payment report submitted by substitute payer (reporting method 1 for monetary wages, alternative method)
Type of action: New report

Pay period

Payment date: 15.02.20xx

The start date of the pay period: 01.02.20xx

The end date of the pay period: 10.02.20xx

Payer (=substitute payer's) details

Type of identifier: Business ID

Identifier:77885544-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID or personal identity code

Employer identifier: 01010101-1 (actual employer's customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Code Income type details EUR
101

Total wages

Type of insurance information:     

Subject to social insurance contributions:

Basis for insurance contribution: No

1650.00
103 Total wages subject to social insurance contributions 1000.00
402 Withholding tax (on EUR 1,650) 375.00
413 Employee's earnings-related pension insurance contribution (on EUR 1,000) 71.50
414 Employee's unemployment insurance contribution (on EUR 1,000) 12.50

The actual employer is obligated to report the income earner's wages on which the employer has paid social insurance contributions. Since only the contract pay (EUR 1,000) included in the wages paid by the substitute payer is subject to the employer's social insurance contributions, this is the amount that the actual employer must report on the actual employer's report:

Example 2, table 3/4

Actual employer’s report (earnings payment report)

Type of action: New report

Pay period (actual employer can report its own pay period)

Payment date: 15.02.20xx

The start date of the pay period:01.02.20xx

The end date of the pay period: 10.02.20xx

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 01010101-1 (actual employer’s customer ID)

Payer type: Temporary employer

Income earner's details (+ name and address details and contact language)

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321 Wages paid by substitute payer: employer pays for employer's social insurance contribution
Earnings period: 01.02.–28.02.20xx
1000.00

If a casual employer reports earnings payment data on a paper form or via the online form of the e-service, the employer submits only the earnings-related pension provider code on the report. If the data is reported via the technical interface or the upload service, the earnings-related pension provider's pension policy number intended for a casual employer must be submitted, in addition to the pension provider code.

Additionally, the employer must report on the employer's separate report the total amount of health insurance contributions it has paid on the basis of the wages.

The employer reports:

Example 2, table 4/4
Actual employer’s report (employer’s separate report)

Type of action: New report

Reporting date:05.03.20nn

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 01010101-1 (actual employer’s customer ID)

Report information

Payment month: 02

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 13.40

 

Example 3: Basic case, income is paid to a 16-year-old person.

The substitute payer pays a 16-year-old summer worker EUR 2,250 in time-rate pay on behalf of the actual employer. Since the income earner is 16, the income is not subject to earnings-related pension insurance or unemployment insurance contributions. However, the income is subject to the health insurance and occupational accident and occupational disease insurance contributions.

When submitting the substitute payer’s report, the substitute payer need not take a stand on social insurance, because the substitute payer is not responsible for paying the contributions.

The substitute payer reports:

Example 3, table 1/3

Substitute payer's earnings payment report

Type of action: New report

Pay period

Payment date: 01.04.20xx

The start date of the pay period: 01.04.20xx

The end date of the pay period: 30.04.20xx

Payer (=substitute payer's) details

Type of identifier: Business ID

Identifier: 1234567-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID or personal identity code

Employer identifier: 11223344-5 (actual employer's customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1111

Code Income type details EUR
201 Time-rate pay 2250.00
402 Withholding tax 450.00

Although the substitute payer need not take a stand on the social insurance contributions, the actual employer must provide all the relevant information needed for social insurance purposes on its report. Since the income is paid to a 16-year-old person, it is not subject to earnings-related pension insurance or unemployment insurance contributions. However, the income is subject to the health insurance and occupational accident and occupational disease insurance contributions. For this reason, the actual employer reports the data as follows:

Example 3, table 2/3
Actual employer’s report (earnings payment report)
Type of action: New report

Pay period (actual employer can report its own pay period)

Payment date: 01.04.20xx

The start date of the pay period: 01.04.20xx

The end date of the pay period: 15.04.20xx

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier:11223344-5 (actual employer’s customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1111

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Type of exception to insurance: No obligation to provide insurance (unemployment insurance)

Type of exception to insurance: No obligation to provide insurance (earnings-related pension insurance)

Code Income type details EUR
324

Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution

Earnings period: 16.03.–31.03.20xx

2250.00
325

Wages paid by substitute payer, employer pays for employer's health insurance contribution

Earnings period: 16.03.–31.03.20xx

2250.00

Additionally, the employer must report on the employer's separate report the total amount of health insurance contributions paid on the basis of the wages.

The employer reports:

Example 3, table 3/3

Actual employer’s report (employer’s separate report)

Type of action: New report

Reporting date: 05.05.20nn

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 8765432-1 (actual employer’s customer ID)

Report information

Payment month: 04

Payment year:20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 30.15

 

If the actual employer itself makes payments to the income earner in addition to the payments made by the substitute payer, the actual employer must also report those payments, the taxes withheld, and the employee's social insurance contributions collected.

Example 4: Actual employer itself also pays wages to the income earner.

A substitute payer has paid the income earner EUR 1,750 in time-rate pay on behalf of the actual employer. In addition to this, the actual employer has paid EUR 175 in overtime compensation.

The substitute payer reports to the Incomes Register the payments it has made:

Example 4, table 1/3

Earnings payment report submitted by substitute payer

Type of action: New report

Pay period

Payment date: 30.11.20xx

The start date of the pay period: 01.11.20xx

The end date of the pay period: 30.11.20xx

Payer (=substitute payer's) details

Type of identifier: Business ID

Identifier:1234567-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID

Employer identifier:8765432-1(actual employer's customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-3322

Code Income type details EUR
201 Time-rate pay 1750.00
402 Withholding tax 350.00
413 Employee’s earnings-related pension insurance contribution (on EUR 1,750) 125.12
414 Employee’s unemployment insurance contribution (on EUR 1,750) 21.87

The actual employer must report the wages paid to the income earner by the substitute payer. If the substitute payer and the actual employer have paid income to the income earner on the same payment date, the actual employer can also report the payments it has made itself on the same report on which the wages paid by the substitute payer are reported. The taxes withheld from the payments made by the actual employer and the employee's social insurance contributions collected must also be reported:

Example 4, table 2/3

Actual employer’s report (earnings payment report)

Type of action: New report

Pay period

Payment date: 30.11.20xx

The start date of the pay period: 01.11.20xx

The end date of the pay period: 31.11.20xx

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 8765432-1 (actual employer’s customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-3322

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321

Wages paid by substitute payer: employer pays for employer's social insurance contribution

Earnings period 01.11.–30.11.20xx

1750.00
325

Overtime compensation

Earnings period 16.11.–17.11.20xx

 
402 Witholding tax (on EUR 175) 35.00
413 Employee’s earnings-related pension insurance contribution (on EUR 175) 12.51
414 Employee’s unemployment insurance contribution (on EUR 175) 2.18

Additionally, the employer must report on the employer's separate report the total amount of the health insurance contributions paid on the basis of the wages paid by the substitute payer and the actual employer itself.

The employer reports:

Actual employer’s report (employer’s separate report)

Example 4, table 3/3

Actual employer’s report (employer’s separate report)

Type of action: New report

Reporting date: 05.12.20nn

Payer (=actual employer's) details

Type of identifier: Business ID

Identifier: 8765432-1 (actual employer’s customer ID)

Report information

Payment month: 11

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 25.98

 

2.2. Municipality as a substitute payer (personal assistant and person requiring assistance)

Hiring a personal assistant involves employer obligations. Many municipalities have concluded agreements with persons requiring assistance (PRA) on the handling of employer obligations related to the payment of wages to a personal assistant.

A municipality acts as a substitute payer when it pays the personal assistant's wages from municipal funds. The municipality acting as a substitute payer reports in accordance with section 2.1. Often the municipality also handles other employer obligations on behalf of the PRA: for example, submits earnings payment reports and employer's separate reports to the Incomes Register and pays social insurance contributions to social insurance providers. The municipality here acts as an agent on behalf of the actual employer on the basis of an agreement, taking out insurances, paying insurance contributions and reporting data.

When the situation involves a substitute payer and the person requiring assistance is a minor, the details of the person requiring assistance are always reported to the Incomes Register as the actual employer details. This is done even if the possible contracts were made with the guardian.

In addition to municipalities, also joint municipal authorities can act as substitute payers.

Example 5: Municipality pays a personal assistant's wages.

In August, a municipality pays EUR 1,000 in wages to a personal assistant and withholds EUR 200 in tax. The municipality reports the payment to the Incomes Register as a substitute payer:

Example 5, table 1/3

Earnings payment report submitted by a municipality as a substitute payer

Type of action: New report

Pay period

Payment date: 15.8.20xx

The start date of the pay period:01.08.20xx

The end date of the pay period: 31.8.20xx

Payer (=municipality as a substitute payer) details

Type of identifier: Business ID

Identifier: 77885544-8 (substitute payer’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type:Personal identity code (Finnish)

Employer identifier: ddmmyy-9999 (customer ID of PRA)

Income earner data

Type of identifier: Personal identity code

Identifier:ddmmyy-4321 (customer ID of personal assistant = income earner)

Code Income type details EUR
201 Time-rate pay 1000.00
402 Withholding tax 200.00
413 Employee’s earnings-related pension insurance contribution 71.50
414 Employee’s unemployment insurance contribution 12.50

For the purposes of determining and verifying the employer's social insurance contributions, the actual employer must report, on its own report, the wages paid by a substitute payer on which the employer pays the social insurance contributions. A municipality can act on behalf of the actual employer and report data to the Incomes Register if this has been agreed with the actual employer.

Example 5, table 2/3

Actual employer’s report (earnings payment report) submitted by a person requiring assistance (PRA) or by the municipality

Type of action: New report

Pay period

Payment date: 15.08.20xx

The start date of the pay period: 01.08.20xx

The end date of the pay period: 31.08.20xx

Payer (= PRA acting as actual employer) details

Type of identifier: Personal identity code

Identifier: ddmmyy-9999 (customer ID of PRA)

Income earner data

Type of identifier: Personal identity code

Identifier: ddmmyy-4321 (customer ID of personal assistant = income earner)

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321

Wages paid by substitute payer: employer pays for employer's social insurance contribution

Earnings period: 01.08.– 15.8.20xx

1000.00

Additionally, the employer (or the municipality acting as an agent) must report on an employer's separate report the total amount of the employer’s health insurance contributions it has paid on the wages. Households must submit the employer's separate report if they pay more than EUR 1,500 to the same income earner in a calendar year.

The employer (or municipality acting as an agent) reports:

Actual employer’s report (employer's separate report), submitted by a PRA or the municipality

Example 5, table 3/3

Actual employer’s report (employer's separate report), submitted by a PRA or the municipality

Type of action: New report

Reporting date: 05.09.20nn

Payer (= PRA acting as actual employer) details

Type of identifier: Personal identity code

Identifier: ddmmyyyy-9999 (customer ID of PRA)

Report information

Payment month: 08

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 13.40

 

2.3 Private day care allowance (wages)

As a substitute payer, Kela reports data on the wages it has paid to a caregiver who has an employment relationship with a family. In the case of private day care allowance, Kela acts as a substitute payer and does not pay social insurance contributions on the allowance. Further, Kela does not withhold the employee’s social insurance contributions from the payment.

A family member (family) is responsible for the employer obligations and social insurance contributions relating to a caregiver with an employment relationship, even as regards the private day care allowance. “Family member” refers to the person who submitted the application for private day care allowance to Kela.

The family member is also obligated to take out earnings-related pension insurance for the caregiver with an employment relationship and to pay the unemployment insurance contributions. The family member must also take out occupational accident and occupational disease insurance from an accident insurance company before the caregiver’s work commences. In the above situation, Kela will report in the substitute payer's report the details of the family member who is responsible for the employer obligations as the actual employer's details. The family member will take care of the employer obligations and report the wages paid and other earnings payment report data using the actual employer report. The family member will use the income types designated for the actual employer.

The earnings-related pension insurance contribution is divided into the employer’s and employee’s shares, which are both given as a percentage of the wages. The employee’s share is calculated on the basis of the total amount formed by the gross wages paid by the family member and the private day care allowance paid by Kela. However, the entire employee’s share is withheld by the family member from the wages paid to the caregiver. The earnings-related pension provider charges the employer for the entire earnings-related pension insurance contribution, including both the employer’s and employee’s shares. The corresponding procedure is applied to the unemployment insurance contribution.

The family member must report a private day care allowance regarded as wages received by a caregiver with an employment relationship, using the income type “Wages paid by substitute payer, employer pays social insurance contributions”. Whether or not the family pays any other income to the caregiver is insignificant. The report must be submitted even if the family does not pay any other income. If the family pays other income to the caregiver during the same month, both the wages paid by the substitute payer and the payments made by the family can be reported on the same report.

Kela does not withhold the employee’s social insurance contributions from the payment it makes. The family withholds the employee’s contributions on the portion of the wages paid by the family and also on the portion paid by Kela. On the report it submits, the family must report the employee’s social insurance contributions both on the income it has paid and on the income paid by Kela.

Example 6: Kela pays private day care allowance to a caregiver hired by a family. The family does not make payments to the income earner.

Kela pays EUR 300 to the caregiver. The family does not pay any other income to the caregiver. Kela submits a substitute payer's report on the private day care allowance it has paid:

Example 6, table 1/3

Substitute payer's earnings payment report submitted by Kela

Type of action: New report

Pay period

Payment date: 15.02.20xx

The start date of the pay period: 01.02.20xx

The end date of the pay period: 10.2.20xx

Payer (=Kela as a substitute payer) details

Type of identifier: Business ID

Identifier: 11111111-1 (Kela's customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Personal identity code

Employer identifier: ddmmyy-9988 (family member’s customer ID)

Income earner data

Type of identifier: Personal identity code

Identifier: ddmmyy-6655(customer ID of caregiver = income earner)

Code Income type details EUR
355 Private day care allowance (wages) 300.00
402 Withholding tax 60.00

For the purposes of determining and verifying the employer's social insurance contributions, the family member acting as the actual employer must report, on its own report, the wages paid by Kela on which the employer pays the social insurance contributions.

Example 6, table 2/3

Actual employer’s report (earnings payment report) submitted by a family member

Type of action: New report

Pay period (Actual employer can report its own pay period)

Payment date: 15.02.20xx

The start date of the pay period: 01.02.20xx

The end date of the pay period: 28.02.20xx

Payer (= actual employer's) details

Type of identifier: Personal identity code

Identifier: ddmmyy-9988 (customer ID of family member = actual employer)

Income earner data

Type of identifier: Personal identity code

Identifier: ddmmyy-6655 (customer ID of caregiver = income earner)

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321 Wages paid by substitute payer: employer pays for employer's social insurance contribution 300.00
413 Employee's earnings-related pension insurance contribution (on EUR 300) 21.45
414 Employee's unemployment insurance contribution (on EUR 300) 3.75

A family member who acts as the employer must also use the employer’s separate report to report the total amount of the employer’s health insurance contribution they have paid on the basis of the wages paid by Kela if the household in question pays more than EUR 1,500 in wages to the same income earner  in a calendar year.

In such a case, the family member reports the amount of the employer’s health insurance contribution calculated from the wages (EUR 300) on which the health insurance contribution is based:

Example 6, table 3/3

Report by a family member acting as an actual employer (employer's separate report)

Type of action: New report

Reporting date: 05.03.20nn

Payer (= actual employer's) details

Type of identifier: Personal identity code

Identifier:ddmmyyyy-9988 (customer ID of family member = actual employer)

Report information

Payment month: 02

Payment year:20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 4.02

If the family also pays other income to the caregiver, that income must be reported to the Incomes Register as well. The family's other payments to the income earner can be reported on the same report that is used to report the wages paid by the substitute payer, if the payments are made  on the same payment date.

Example 7: The family pays wages to the caregiver in addition to the private day care allowance that is paid by Kela).

Kela pays EUR 300 to the caregiver. In addition, the family pays EUR 1,000 in wages to the caregiver. Kela submits a substitute payer's report on the private day care allowance it has paid:

Example 7, table 1/3

Substitute payer's earnings payment report submitted by Kela

Type of action: New report

Pay period

Payment date: 15.02.20xx

The start date of the pay period: 01.02.20xx

The end date of the pay period: 10.2.20xx

Payer (=Kela as a substitute payer) details

Type of identifier: Business ID

Identifier: 11111111-1 (Kela's customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Personal identity code

Employer identifier: ddmmyy-9988 (family member’s customer ID)

Income earner data

Type of identifier: Personal identity code
Identifier: ddmmyy-6655 (customer ID of nanny = income earner)
Code Income type details EUR
355 Private day care allowance (wages) 300.00
402 Withholding tax 60.00

For the purposes of determining and verifying the employer's social insurance contributions, the family member acting as the actual employer must report, on its own report, the wages paid by Kela on which the employer pays the social insurance contributions. The family must also report the wages it itself has paid to the income earner.

Actual employer’s report (earnings payment report) submitted by a family member

Example 7, table 2/3

Actual employer’s report (earnings payment report) submitted by a family member

Type of action: New report

Pay period (Actual employer can report its own pay period)

Payment date: 15.02.20xx

The start date of the pay period: 01.02.20xx

The end date of the pay period: 28.02.20xx

Payer (= actual employer's) details

Type of identifier: Personal identity code

Identifier: ddmmyy-9988 (customer ID of family member = actual employer)

Income earner data

Type of identifier: Personal identity code

Identifier: ddmmyy-6655 (customer ID of nanny = income earner)

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider:NN-XXXXXXXX

Code Income type details EUR
321

Wages paid by substitute payer: employer pays for employer's social insurance contribution

Earnings period: 01.02.–28.02.20xx

300.00
101 Total wages 1000.00
402 Withholding tax (on EUR 1,000) 200.00
413 Employee's earnings-related pension insurance contribution (on EUR 1,300) 92.95
414 Employee's unemployment insurance contribution (on EUR 1,300) 16.25

A family member who acts as the employer must also use the employer’s separate report to report the total amount of the employer’s health insurance contribution they have paid on the basis of the wages paid by Kela and the family, if the household in question pays more than EUR 1,500 in wages to the same recipient in a calendar year.

The family member reports the total amount of the employer’s health insurance contribution calculated from the wages (EUR 1,300) on which the health insurance contribution is based:

Example 7, table 3/3

Actual employer's report submitted by a family member (employer's separate report)

Type of action: New report

Reporting date: 05.03.20nn

Payer (= actual employer's) details

Type of identifier: Personal identity code

Identifier: ddmmyyyy-9988 (customer ID of family member = actual employer)

Report information

Payment month: 02

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 17.42

 

2.4 Pay security and cases of bankruptcy

Applications for pay security should be submitted to a the Uusimaa Centre for Economic Development, Transport and the Environment (ELY Centre). The pay security system ensures the payment of an employee's claims arising from an employment relationship in the event of the employer's insolvency. Pay security is paid on the basis of the employee’s claims arising from an employment relationship, when their grounds and amount have been settled. An application for pay security can be submitted by a bankruptcy estate, an employee or an employee organisation to which the employee has transferred its claims. If the employer is bankrupt, the bankruptcy estate can also apply for pay security on behalf of the employees in certain situations. The ELY Centre will recover the pay security paid from the employer, its bankruptcy estate and any other parties with liability to pay.

The ELY Centre withholds tax and deducts the employee’s earnings-related pension insurance contribution and unemployment insurance contribution from the claims paid as pay security. It is especially important to report the earnings periods of the income paid. If no earnings period is reported on the earnings payment report, the social insurance provider will not know, in the case of bankruptcy, whether the case involves lodged claims or liabilities of the bankruptcy estate (see section 2.4.2).It is of particular importance to ensure that the data is reported using the correct payer identifier. Social insurance providers will receive information from the Incomes Register on whether it is a question of a lodged claim or liabilities of the bankruptcy estate based on whether the Business ID of the debtor or the bankruptcy estate was reported as the payer's Business ID on the actual employer's report.

2.4.1 If the ELY Centre pays wages as pay security

When If the ELY Centre (pay security) pays the employees' wages as pay security and requests repayment of the pay security, the ELY Centre acts as a substitute payer. It will withhold taxes from the wages and deduct the employee's earnings-related pension insurance contribution and unemployment insurance contribution.

The ELY Centre withholds taxes and deducts the employee’s earnings-related pension insurance contribution and unemployment insurance contribution from the wages it pays to the employee.

Pay security submits earnings payment reports to the Incomes Register separately on every income earner no later than on the fifth day after the date of payment. The actual employer submits the income earner's earnings payment reports on the payment of pay securitywages paid by the ELY Centre as pay security to the Incomes Register, using the specific actual employer's income types for situations involving a substitute payer described in section 2.1. The actual employer also submits the employer's separate report. The actual employer’s reports (earnings payment reports and employer's separate reports) are submitted using the actual employer’s Business ID for each wage payment month no later than on the fifth day of the calendar month following the month of payment. The actual employer's reports are submitted using either the identifier of the actual employer (the debtor) or the identifier of the bankruptcy estate, depending on whether it is a case of lodged wage claims or wage claims included in the liabilities of the bankruptcy estate.

Example 8: The ELY Centre pays the lodged wages claims.

The Uusimaa ELY centre pays the employee a wage claim of EUR 2,000. EUR 500 in income tax is withheld from the income. The ELY Centre reports the payment it has made to the Incomes Register. The claims were established before the bankruptcy.

Example 8, table 1/3

Substitute payer’s earnings payment report submitted by ELY Centre

Type of action: New report

Pay period

Payment date: 03.12.20xx

The start date of the pay period: 01.12.20xx

The end date of the pay period: 31.12.20xx

Payer (= ELY Centre) details

Type of identifier: Business ID

Identifier: 77885544-8 (Uusimaa ELY Centre’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID or personal identity code

Employer identifier: 02020202-1 (actual employer's, i.e. debtor's, customer ID)

Paid as pay security: Yes

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Code Income type details EUR
201 Time-rate pay 2000.00
402 Withholding tax 500.00
413 Employee's earnings-related pension insurance contribution 143.00
414 Employee's unemployment insurance contribution 25.00

The ELY centre delivers the pay security decision to the Finnish Centre for Pensions. The Finnish Centre for Pensions delivers the pay security decision to the correct insurance provider on the basis of the actual employer’s customer ID (e.g. Business ID) and pension policy number.

The actual employer submits the earnings payment report and employer's separate report as follows:

Actual employer’s report (earnings payment report)

Example 8, table 2/3
TYPE OF ACTION

Type of action: New report

Pay period

Payment date: 03.02.20xx

The start date of the pay period: 01.12.20xx

The end date of the pay period: 31.12.20xx

Payer (= actual employer's) details

Type of identifier: Business ID

Identifier: 02020202-1 (actual employer's , i.e. debtor's, customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321 Wages paid by substitute payer: employer pays for employer's social insurance contribution 2000.00

The pension and accident insurance information on the debtor (the actual employer) should be submitted on the report. The occupational accident insurance policy number must be submitted on the report only if the employees are insured with more than one accident and occupational disease insurance.

Actual employer’s report (employer’s separate report)

Example 8, table 3/3

Actual employer’s report (employer’s separate report)

Type of action: New report

Reporting date:05.01.20nn

Payer (= actual employer's) details

Type of identifier: Business ID

Identifier: 02020202-1 (actual employer's , i.e. debtor's, customer ID)

Report information

Payment month: 12

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 26.80

 

2.4.2 The bankruptcy estate pays the wages (expedited pay security)

A bankruptcy estate can apply for pay security on behalf of the employees by submitting a joint application to the Uusimaa ELY Centre. Both lodged wage claims and wage claims included in the liabilities of the bankruptcy estate can be applied for as expedited pay security. Lodged wage claims comprise the receivables established before the bankruptcy until the date of the declaration of bankruptcy, including that date. In practice, lodged claims comprise all receivables normally paid in the final account such as holiday compensation. Wage claims included in the liabilities of the bankruptcy estate comprise receivables established after the declaration of the bankruptcy, i.e. in practice generally only the wages for the two-week period of notice including any incidentals. Holiday compensation is included in the liabilities of the bankruptcy estate only if it has been determined on a percentage basis during the employment.

The bankruptcy estate applies for the gross amount of the wage receivables as pay security, with the employee's earnings-related pension and unemployment insurance contributions deducted. The pay security is paid to the account of the bankruptcy estate. The estate pays the wages to the employees, withholds taxes from the wages, and carries out any other remittances. The employer contributions and the employee's earnings-related pension and unemployment insurance contributions are either the employer's lodged claims or the bankruptcy estate's liabilities, depending on the receivables.

The bankruptcy estate submits the actual employer's reports using the identifier of the actual employer (the debtor) in the case of lodged wage claims and using the identifier of the bankruptcy estate in the case of wage claims included in the liabilities of the bankruptcy estate. If the bankruptcy estate continues the debtor's business activities and pays wages for work performed after the declaration of bankruptcy, the bankruptcy estate acts as the actual employer. In such a case, the bankruptcy estate submits both earnings payment reports and employer's separate reports using its own identifier (with the exception of the reporting of lodged wage claims described later in these instructions).

If the bankruptcy estate does not have the terminated employee work at all during the period of notice, the bankruptcy estate must submit two earnings payment reports to the Incomes Register so that the data is correctly delivered to the different insurers. See Section 2.4.2.3. for more detailed information on this exception.

2.4.2.1 Lodged wage claims

When a bankruptcy estate submits an application for the lodged wage claims of the income earners from the Uusimaa ELY Centre as an expedited procedure, the ELY Centre will pay the total amount of the receivables to the account of the bankruptcy estate. The bankruptcy estate pays the wages to the income earners, withholds taxes from the pay, and submits reports to the Incomes Register. In this case, the Uusimaa ELY Centre which granted the pay security will not submit any reports. In this situation, the bankruptcy estate acts as a substitute payer on behalf of the actual employer, i.e., the debtor. The ELY Centre deducts the employee's earnings-related pension and unemployment insurance contributions from the pay security paid to the bankruptcy estate, so the bankruptcy estate does not deduct them from the wages. However, they must be reported on a substitute payer's earnings payment report submitted by the bankruptcy estate.

The bankruptcy estate submits the reports to the Incomes Register as a substitute payer using its own Business ID (see Example 9, Table 1). The bankruptcy estate also submits the actual employer's reports. On the actual employer's report, the identifier of the actual employer that went bankrupt is submitted as the payer (see Example 9, Table 2).

When the bankruptcy estate pays wages in a situation involving expedited pay security, lodged wage claims and wage claims included in the liabilities of the bankruptcy estate cannot be reported on the same report, because the payer details that must be submitted are different. In the case of expedited pay security, some of the following reports are submitted depending on the circumstances:

  1. Substitute payer's earnings payment report (lodged wage claims)
  2. Actual employer's earnings payment report using the debtor's identifier (lodged wage claims)
  3. Actual employer's earnings payment report using the bankruptcy estate's identifier (wage claims included in the liabilities of the bankruptcy estate, see Section 2.4.2.3)
  4. Employer's separate report using the debtor's identifier
  5. Employer's separate report using the bankruptcy estate's identifier

See below for a description of the situations in which the reports must be submitted and which identifier is used.

Example 9: Expedited pay security, bankruptcy estate pays lodged wage claims.

The company was declared bankrupt on 1 March 2019, and the wages for 2019 have not been paid to the employees. The wages for the period 1 January to 1 March 2019 are lodged wage claims, while the notice period wages from 2 March to 15 March are wage claims included in the liabilities of the bankruptcy estate. An income earner is paid EUR 2,000, of which EUR 1,700 are lodged wage claims for the period from 1 January to 1 March 2019, and EUR 300 are wage claims included in the liabilities of the bankruptcy estate for the period from 2 March to 15 March 2019. (See Example 10 for a description of how to report wage claims included in the liabilities of the bankruptcy estate.)

The bankruptcy estate has applied for pay security for paying the lodged wage claims and the wage claims included in the liabilities of the bankruptcy estate on behalf of the employees, by submitting a joint application to the Uusimaa ELY Centre. The pay security is paid to the account of the bankruptcy estate. The estate administrator pays the net wages to the recipients on 15 March and remits the withheld taxes to the Tax Administration.

The lodged wage claims are from the time before the bankruptcy. The substitute payer's report is submitted using the bankruptcy estate's Business ID (Example 9, Table 1). The actual employer's earnings payment report is submitted using the Business ID and insurance information of the actual employer, i.e., the debtor (Example 9, Table 2).

Example 9, table 1/3

Substitute payer's earnings payment report using the bankruptcy estate's identifier

Type of action: New report

Pay period

Payment date: 15.03.20xx

The start date of the pay period: 01.01.20xx

The end date of the pay period: 01.03.20xx

Payer (=bankruptcy estate's) details

Type of identifier: Business ID

Identifier: 01010101-2 (bankruptcy estate’s customer ID)

Substitute payer data group

Acts as substitute payer: Yes

Employer's identifier type: Business ID or personal identity code

Employer identifier: 02020202-1 (actual employer's , i.e. debtor's, customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Code Income type details EUR
201 Time-rate pay 1700.00
402 Withholding tax 500.00
413 Employee's earnings-related pension insurance contribution 121.55
414 Employee's unemployment insurance contribution 21.25

On the actual employer's report, the bankruptcy estate submits the Business ID and insurance information of the actual employer, i.e., the debtor, as the payer details (Example 9, Table 2).

Example 9, table 2/3

Actual employer's report submitted using the identifier of the debtor in bankruptcy (earnings payment report)

Type of action: New report

Pay period

Payment date: 15.03.20xx

The start date of the pay period: 01.01.20xx

The end date of the pay period: 01.03.20xx

Payer (= actual employer's) details

Type of identifier: Business ID

Identifier: 02020202-1 (actual employer's , i.e. debtor's, customer ID)

Income earner data

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
321 Wages paid by substitute payer: employer pays for employer's social insurance contribution 1700.00

The actual employer, i.e., the debtor, is liable to pay the health insurance contributions for the lodged wage claims. The bankruptcy estate submits an employer's separate report using the Business ID of the actual employer (debtor):

Example 9, table 3/3

Actual employer's report: bankruptcy estate’s identifier (employer’s separate report)

Type of action: New report

Reporting date: 05.04.20nn

Payer (= actual employer's) details

Type of identifier: Business ID

Identifier:02020202-1 (customer ID of debtor in bankruptcy)

Report information

Payment month: 03

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 18.36

 

2.4.2.2 Wage claims included in the liabilities of the bankruptcy estate

Wage claims included in the liabilities of the bankruptcy estate comprise receivables established after the declaration of the bankruptcy, i.e., in practice generally only the wages for the two-week period of notice including any incidentals. Holiday compensation is included in the liabilities of the bankruptcy estate only if it has been determined on a percentage basis during the employment.

When wage claims included in the liabilities of the bankruptcy estate are involved, it is not an actual substitute payer situation. The bankruptcy estate pays the wages from the estate assets and is also obligated to take out earnings-related pension and occupational accident insurances. The bankruptcy estate submits an earnings payment report to the Incomes Register using its own Business ID. The details (pension policy number and occupational accident insurance policy number) of the insurance policies taken out by the bankruptcy estate for the wage claims included in the liabilities of the bankruptcy estate are submitted on the report (however, see Section 2.4.2.3. if no work is performed during the period of notice). The occupational accident insurance policy number must be submitted on the report only if the employees are insured with more than one accident and occupational disease insurance. The data is reported on a regular earnings payment report in accordance with Example 10 (Table 1).

Example 10: The bankruptcy estate pays the wage claims included in its liabilities.

The company was declared bankrupt on 1 March 2019, and the wages for 2019 have not been paid to the employees. The wages for the period 1 January to 1 March 2019 are lodged wage claims, while the wages from 2 March to 15 March are wage claims included in the liabilities of the bankruptcy estate. An income earner is paid EUR 2,000, of which EUR 1,700 are lodged wage claims for the period from 1 January to 1 March 2019, and EUR 300 are wage claims included in the liabilities of the bankruptcy estate for the period from 2 March to 15 March 2019. (The lodged wage claims are reported in accordance with Example 9.)

The bankruptcy estate has applied for pay security for paying the lodged wage claims and the wage claims included in the liabilities of the bankruptcy estate on behalf of the employees, by submitting a joint application to the Uusimaa ELY Centre. The pay security is paid to the account of the bankruptcy estate. The estate administrator pays the net wages to the recipients on 15 March and remits the withheld taxes to the Tax Administration.

Example 10, table 1/2

The earnings payment report submitted by the bankruptcy estate

Type of action:New report

Pay period

Payment date: 15.03.20xx

The start date of the pay period: 02.03.20xx

The end date of the pay period: 15.03.20xx

Payer (= bankruptcy estate) details

Type of identifier: Business ID

Identifier: 01010101-2 (the bankruptcy estate's customer identifier)

Income earner details

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-4321

Occupational class: Statistics Finland's classification of occupations

Occupational class ID: NNNNN

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Code Income type details EUR
201 Time-rate pay 300.00
402 Withholding tax 50.00
413 Employee's earnings-related pension insurance contribution 21.45
414 Employee's unemployment insurance contribution 3.75

The bankruptcy estate also calculates the employer's health insurance contribution from the wage claims included in its liabilities, pays it out of the bankruptcy estate's assets, and submits an employer's separate report using the bankruptcy estate's Business ID.

For more information on this, see the Tax Administration's instructions (in Finnish): Payment and reporting procedure for employer contributions in a bankruptcy situation.

The employer's separate report submitted by the bankruptcy estate

Example 10, table 2/2

The employer's separate report submitted by the bankruptcy estate

Type of action:New report

Reporting date: 05.04.20nn

Payer (= bankruptcy estate) details

Type of identifier: Business ID

Identifier: 01010101-2 (the bankruptcy estate's customer identifier)

Report information

Payment month: 03

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 4.02

 

2.4.2.3  Exception: the bankruptcy estate does not have the terminated employee work

If the bankruptcy estate does not have the terminated employee work at all during the period of notice, the bankruptcy estate must submit two earnings payment reports to the Incomes Register so that the data is correctly transmitted to the various data users. The bankruptcy estate submits an earnings payment report using its own customer identifier, specifying that it does not have the obligation to provide occupational accident insurance (see Example 11, Table 1). From this report, the data is transmitted to, for example, the Tax Administration, the Employment Fund, and the earnings-related pension provider. The bankruptcy estate also submits a second earnings payment report using the debtor's customer identifier, reporting the same wages using income type 324 ‘Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution’ (see Example 11, Table 2). From this report, the data is transmitted to the accident insurance company.

Example 11: Wage claims included in the liabilities of the bankruptcy estate reported by the bankruptcy estate when it does not have the terminated employee work.

The bankruptcy estate submits two earnings payment reports: one using its own Business ID and the other using the debtor's Business ID.

The earnings payment report using the bankruptcy estate's identifier

The bankruptcy estate submits an earnings payment report to the Incomes Register using its own Business ID. Type of insurance exception: no obligation to provide insurance (accident and occupational disease insurance) entry is submitted on the report. The details of the insurance taken out by the bankruptcy estate, earnings-related pension provider code, and pension policy number are submitted on the report.

Example 11: Wage claims included in the liabilities of the bankruptcy estate reported by the bankruptcy estate when it does not have the terminated employee work.

The bankruptcy estate submits two earnings payment reports: one using its own Business ID and the other using the debtor's Business ID.

The earnings payment report using the bankruptcy estate's identifier

The bankruptcy estate submits an earnings payment report to the Incomes Register using its own Business ID. Type of insurance exception: no obligation to provide insurance (accident and occupational disease insurance) entry is submitted on the report. The details of the insurance taken out by the bankruptcy estate, earnings-related pension provider code, and pension policy number are submitted on the report.

Example 11, table 1/3

The earnings payment report using the bankruptcy estate's identifier

Type of action:New report

Pay period

Payment date: 15.03.20xx

The start date of the pay period: 02.03.20xx

The end date of the pay period: 15.03.20xx

Payer (= bankruptcy estate) details

Type of identifier: Business ID

Identifier: 01010101-2 (the bankruptcy estate's customer identifier)

Income earner details

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Earnings-related pension insurance information Employee's earnings-related pension insurance

Pension provider code: NN

Pension policy number of earnings-related pension provider: NN-XXXXXXXX

Type of exception to insurance:No obligation to provide insurance (accident and occupational disease insurance)

Code Income type details EUR
201 Time-rate pay 300.00
402 Withholding tax 50.00
413 Employee's earnings-related pension insurance contribution 21.45
414 Employee's unemployment insurance contribution 3.75

The earnings payment report using the debtor's identifier

The bankruptcy estate submits an earnings payment report to the Incomes Register using the debtor's Business ID for the occupational accident insurance company. The details of the debtor's occupational accident insurance policy are submitted on the report, and income type 324 ‘Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution’ is used. The occupational accident insurance policy number must be submitted on the report only if the employees are insured with more than one accident and occupational disease insurance.

Example 11, table 2/3

The earnings payment report using the debtor's identifier

Type of action:New report

Pay period

Payment date: 15.03.20xx

The start date of the pay period: 02.03.20xx

The end date of the pay period: 15.03.20xx

Payer (= debtor) details

Type of identifier: Business ID

Identifier: 02020202-1 (Customer identifier of the actual employer, i.e. debtor)

Income earner details

Type of identifier: Personal identity code (income earner's customer ID)

Identifier: ddmmyy-1234

Occupational class:Statistics Finland's classification of occupations

Occupational class ID:NNNNN

Koodi Tulolajien tiedot euroa
324 Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution 300.00

In an exceptional situation, the bankruptcy estate also has the obligation to pay the employer's health insurance contribution, so the employer's separate report is submitted using the bankruptcy estate's Business ID.

Employer's separate report using the bankruptcy estate's identifier

Example 11, table 3/3

Employer's separate report using the bankruptcy estate's identifier

Type of action:New report

Reporting date: 05.04.20nn

Payer (= bankruptcy estate) details

Type of identifier: Business ID

Identifier: 01010101-2 (the bankruptcy estate's customer identifier)

Report information

Payment month: 03

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 4.02
2.4.2.4 Employer's separate report in bankruptcy situations

When lodged wage claims are paid, the employer's separate report is submitted using the debtor's Business ID. When wage claims included in the liabilities of the bankruptcy estate are paid, such as wages for the period of notice, the report is submitted using the bankruptcy estate's Business ID.

Example 12: Submitting an employer's separate report for lodged wage claims and wage claims included in the liabilities of the bankruptcy estate

Example 12, table 1/2

Employer's separate report for lodged wage claims using the debtor's identifier

In the example, there were EUR 1,700 of lodged wage claims.

Type of action: New report

Reporting date: 05.04.20nn

Payer (=debtor) details

Type of identifier: Business ID

Identifier: 02020202-1 (the debtor's customer identifier)

Report information

Payment month: 03

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 22.78

 

Example 12, table 2/2

Employer's separate report for wage claims included in the liabilities of the bankruptcy estate using the bankruptcy estate's identifier

In the example, there were EUR 300 of wage claims included in the liabilities of the bankruptcy estate.

Type of action: New report

Reporting date: 05.04.20nn

Payer (=bankruptcy estate) details

Type of identifier: Business ID

Identifier: 01010101-2 (the bankruptcy estate's customer identifier)

Report information

Payment month: 03

Payment year: 20nn

Code Income type details EUR
102 Employer's health insurance contribution (total) 4.02

If a company is declared bankrupt in the middle of a month, two employer's separate reports must be submitted for the month during which the bankruptcy was declared. The debtor's Business ID is used to report the total amount of health insurance contributions until the declaration of bankruptcy, and the bankruptcy estate's Business ID is used to report the amount of health insurance contributions from the time after the bankruptcy.

Example 13: Submitting an employer's separate report when bankruptcy is declared in the middle of the month.

The company is declared bankrupt on 15 August 2020. The actual employer, i.e., the debtor, reports August as the reporting period of the employer's separate report and reports the total amount of health insurance contributions for the period from 1 to 15 August 2020. The bankruptcy estate also reports August as the reporting period of its own report, and reports the total amount of health insurance contributions for the period from 16 to 31 August 2020.

Table on submitting earnings payment reports for the Incomes Register's substitute payer instructions, Section 2.4. Pay security and bankruptcy situations

Table on submitting earnings payment reports.
Pay security pays the wages payable based on applications submitted by the employees themselves
1. Substitute payer's report (the Uusimaa ELY Centre pays the wages as pay security and submits the report)

Payer’s business ID:Business ID of the Uusimaa ELY Centre

Income type: 100 and 200 series income types

Pension policy number and accident insurance policy number*: Not provided.

Actual employer's report (time before bankruptcy, lodged claims)

Payer’s business ID:Business ID of the bankrupt employer

Income type: 321 Wages paid by substitute payer: the employer pays for the employer's social insurance contributions (earnings-related pension, health, unemployment, and accident and occupational disease insurance)

Pension policy number and accident insurance policy number*: The pension policy number and the accident insurance policy number of the bankrupt employer

Actual employer's report (time after bankruptcy, wage claims included in the liabilities of the bankruptcy estate)

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 321 Wages paid by substitute payer: the employer pays for the employer's social insurance contributions (earnings-related pension, health, unemployment, and accident and occupational disease insurance)

Pension policy number and accident insurance policy number*: Pension policy number of the insurance taken out by the bankruptcy estate and the accident insurance policy number

Expedited pay security, wages payable are pay security that the bankruptcy estate distributes to the employees: Lodged claims

1. Substitute payer's report (bankruptcy estate submits the report)

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 100 and 200 series income types

Pension policy number and accident insurance policy number*: Not provided.

2. Actual employer's report (bankruptcy estate submits the report on behalf of the debtor)

Payer’s business ID:Business ID of the bankrupt employer

Income type: 321 Wages paid by substitute payer: the employer pays for the employer's social insurance contributions (earnings-related pension, health, unemployment, and accident and occupational disease insurance)

Pension policy number and accident insurance policy number*: The pension policy number and the accident insurance policy number of the bankrupt employer

Expedited pay security, wages payable are pay security that the bankruptcy estate distributes to the employees: Claims included in the liabilities of the bankruptcy estate

1. Bankruptcy estate's earnings payment report

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 100 and 200 series income types

Pension policy number and accident insurance policy number*: The pension policy number of the insurance taken out by the bankruptcy estate and the accident insurance policy number

Exception: bankruptcy estate does not have the terminated employee work during the period of notice, but pays the wages for the period of notice as wage claims included in the liabilities of the bankruptcy estate

1. Bankruptcy estate's earnings payment report

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 100 and 200 series income types

Pension policy number and accident insurance policy number*: The pension policy number of the insurance taken out by the bankruptcy estate

Type of exception to insurance: No obligation to provide insurance: (accident and occupational disease insurance)

2. Debtor's earnings payment report

Payer’s business ID:Business ID of the bankrupt employer

Income type: 324 Wages paid by substitute payer, employer pays for accident and occupational disease insurance contribution

Pension policy number and accident insurance policy number*: The accident insurance policy number of the bankrupt employer

Wages payable, no pay security (bankruptcy estate pays the wages from its own assets)

1. Substitute payer's report (time before bankruptcy, lodged claims)

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 100 and 200 series income types

Pension policy number and accident insurance policy number*: Not provided.

2. Actual employer's report (time before bankruptcy, lodged claims)

Payer’s business ID:Business ID of the bankrupt employer

Income type: 321 Wages paid by substitute payer: the employer pays for the employer's social insurance contributions (earnings-related pension, health, unemployment, and accident and occupational disease insurance)

Pension policy number and accident insurance policy number*: The pension policy number and the accident insurance policy number of the bankrupt employer

3. Actual employer's report (time after bankruptcy, NB: this is not an actual substitute payer situation)

Payer’s business ID:Business ID of the bankruptcy estate

Income type: 100 and 200 series income types if the situation does not involve a substitute payer

Pension policy number and accident insurance policy number*: The pension policy number of the insurance taken out by the bankruptcy estate and the accident insurance policy number

* The occupational accident insurance policy number must be submitted on the report only if the employees are insured with more than one accident and occupational disease insurance policy.