Benefits: reporting data to the Incomes Register

The instructions have been updated on 4 June 2020:

  • In Section 4.3, removed instructions concerning the reporting of a deduction under section 23 of the act on social assistance (laki toimeentulotuesta 1412/1997).
  • In Example 10, corrected the deduction type 'Demand for payment (not a recourse situation)' by replacing it with 'Recourse from tax-exempt income'.
  • In Example 11, corrected the deduction income type code 'Other benefit' by replacing it with 'Daily allowance (occupational accident insurance)'.
  • Removed Example 12 because it was erroneous.
  • In Example 45, corrected the deduction type 'Demand for payment (not a recourse situation)' by replacing it with 'Recourse from tax-exempt income', and added the data 'One-off remuneration – Yes'.

The instructions have been updated on 6 April 2020:

  • In Example 41, corrected the payment date or other report date of the replacement report-
  • In Example 41, specified the instructions for the replacement report.

The instructions have been updated on 20 February 2020:

  • Changed the years in the instructions to match the changed deployment schedule of benefits.
  • Added instructions to Section 1.1 on the correction of benefits payment data from before the year 2021. The reporting of the earnings period is also described in more detail in the section for reporting recovered income or unprompted refunds.
  • Removed Section 1.2 concerning the transition periods, because the transition period will not occur due to the changed schedule.
  • Clarified the reporting of the earnings period in Section 3.4.
  • Clarified the reporting of a One-off remuneration in Section 3.5.
  • Corrected Example 4 in Section 3.6, Deduction of employee contributions, to match the changed order of deductions.
  • Clarified the instructions in Section 4.1, Payment reported under section 28 of the act on inheritance and gift tax, and added examples 7 and 8 of the share paid to a pledgee.
  • Clarified the instructions on reporting the deduction type in Section 4.3. Also added Example 12 to illustrate the period of calculation.
  • In Section 5.2, added information on the grounds for pension paid to a non-resident taxpayer to Example 17.
  • Clarified the instructions on reporting the grounds for pension paid to a non-resident taxpayer in Section 5.7, Non-resident taxpayer's pension income.
  • Clarified the correction instructions in Section 6, when the income earner's identifying information changes.
  • In Section 6.5, added date of birth to the data that must be corrected by cancelling.
  • In Section 7.5, corrected the name of the deduction type ‘Collection of a guarantee liability’ to ‘Recovery of guaranteed student loan debt’.
  • In Example 10, corrected the deduction type ‘Other deduction from net income’ to ‘Demand for payment (not a recourse situation)’.
  • In Example 24, corrected the information on the number of rehabilitation allowance units.
  • In Example 45, corrected the deduction type ‘Recourse on tax-exempt income’ to ‘Demand for payment (not a recourse situation)’.
  • The numbering of the examples has changed from the previous version of the instructions.

Added the following sections:

  • 4.5 Benefit changes to pension in taxation once it has been paid for a year
  • 4.6 Income changes retroactively, and a benefit paid earlier is taken into account as a partial payment
  • 6.7 Returning of withholding to an income earner

1 General information on reporting

1.1 Reporting obligation for benefits payment data

This document describes, on a general level, the reporting of Incomes Register benefits payment data on benefits and pension income (or benefits payment data in short) to the Incomes Register. The document uses examples to describe the most common Incomes Register reporting situations. The examples do not take all the data to be submitted into consideration, only the data that is relevant for resolving the matter in question. In the examples, the values of different data items do not correspond to the technical forms allowed in benefits payment reports – income types, for example, are given using names instead of codes. Data-related checks are described in more detail in the document 'Technical interface – Delivering data to the Incomes Register' and in the benefits payment report schema.

Only benefits and pension income paid on 1 January 2021 or later are reported to the Incomes Register, along with any corrections made to such income. If data on benefits paid prior to 2021 is corrected, the corrections are reported directly to each data user; for example, on a replacement annual information return to the Finnish Tax Administration. The exceptions are recovery and recourse deduction performed on 1 January 2021 or later. These must be reported to the Incomes Register even if the original income was paid prior to 2021. The instructions Benefits: recovery and recourse describe the reporting of recoveries and recourse deductions to the Incomes Register in more detail.

A benefits payment report submitted to the Incomes Register contains the data on pension and benefits income reported to the instances specified as data users in section 13 of the act on the incomes information system (laki tulotietojärjestelmästä 53/2018) in order that they could perform the duties decreed to them in the section. The data can be disclosed only to the data users specified in the law. The Incomes Register will forward data submitted to the Incomes Register to data users entitled to receive it in accordance with their individual statutory right to receive information. The Incomes Register does not create new data access rights for data users.

The deployment of the Incomes Information System will change the benefit and pension payers' obligations to report and provide information. Several data streams submitted to the Tax Administration at different times and in different formats will be replaced by reporting taking place in one go and in a uniform format. The data streams entirely replaced by the benefits payment report from 2021 onwards are the itemisation of retroactive pensions (VSTAKELE), the unemployment benefits payment days (VSKORVPV) and the annual information return on the pension of benefits payer's contact person (VSELVYHT). The benefits payment report will partially replace the data streams non-resident taxpayer's annual information return (VSRAERIE), tax return on self-assessed taxes, and the itemisation of pensions and benefits (VSELERIE).

In addition to these, the data contents of the benefits payment report include data that an insurance company or other benefit payer should report to the Tax Administration under section 28 a of the act on inheritance and gift tax (perintö- ja lahjaverolaki 378/1940) for tax assessment purposes. When the data is reported to the Incomes Register, there is no need to report the same data separately to the Tax Administration.

The Incomes Register benefits data is used for example for the following purposes:

  • tax assessment
  • granting basic social assistance
  • settling a claim
  • investigating a recourse collection
  • assistance in the determination and coordination of the right to benefits
  • detection of disqualifying benefits
  • identification of benefit periods to be bypassed;
  • statistics
  • determination and deciding of customer fees
  • research.

The benefit payer reports the data to the Incomes Register once. The total amount of benefits and pensions paid during the tax year is no longer reported separately on the annual information return. The data users require the benefits payment data to be reported to the Incomes Register with a precision of one day. This accuracy requirement has been implemented in benefits payment reports by making the income earning period mandatory data. When a recovery or an unprompted refund of income is reported, the earnings period is reported in the ‘Additional repayment details’ data group. The earnings period is specified with a precision of one day. The amount of compensation granted for each hour, day or for example month in a benefit decision can be indirectly deduced from the Incomes Register data by comparing the data given for the payment in the Benefit unit data group with the reported euro amount of the payment.

The paid benefits and pensions are reported to the Incomes Register separately for each income earner. A report refers to data on one payment transaction paid to a single income earner. Several income types can be reported for one income earner on the report for the same payment date. Even if several income types are specified, income types comparable to deductions can be reported as a total amount. These include, for example, tax withholding or tax at source. Deductions that must be connected to an individual income item reported are itemised in more detail in the Deductions data group. More information available on more specific deductions, for example, in the ‘Benefit payment to a substitute recipient’ section of this guide.

1.2 The time of reporting data

1.2.1 Date of payment and reporting deadline

The data is reported to the Incomes Register in real time, that is, as a rule, no later than on the fifth day after the payment date. The date of payment refers to the date on which the payment is available to the income earner, for example withdrawable from the income earner's account. The five-calendar-day deadline specified in the act on the incomes information system applies to the regularly reported mandatory data specified in sections 6 and 8 of the act.

Benefits and pension payments made on 1 January 2021 or later are reported to the Incomes Register, along with any corrections made to such income. The retention period of the benefits payment data submitted to the Incomes Register is based on the statutory rights of the Incomes Register's data users to receive information. The data is stored in the Incomes Register for ten years from the beginning of the year following the year in which the data was saved. After ten years, the data stored in the Incomes Information System will be deleted.

If the benefit has been paid in advance, each payment should be reported according to the payment date on which the benefit has become available to the income earner (see example 3).

1.2.2 Date of reporting unjust enrichment and recovery

The obligation to report unjust enrichment is connected to the procedure used for correcting an incorrect benefit decision. If a factual error has occurred when making the benefit decision, the correction to this may require the income earner’s consent. Finding that a benefit is to be an unjust enrichment may also be preceded by the revocation or dismissal of the decision, for example by a judgement ruling of the Insurance Court. Information on unjust enrichment must be submitted no later than one month after the party's consent to the recovery of the unjust enrichment has been obtained or a decision has been issued on the dismissal of an incorrect benefit or compensation decision. Such decisions may be called, for example, revision decision, adjustment decision or termination decision.

In some situations, no decision on the termination of a pension or a benefit is issued even if there has been an overpayment, for example when the benefit recipient has died. If a recovery decision is the only decision to be made regarding the case, the time limit for reporting unjust enrichment is counted from the date the decision is issued.

If the income earner is repaying a payment to which they were entitled and the repayment does not become unjust enrichment at any stage, the repayment is reported using the ‘Unprompted refund – Yes’ entry. When reporting unjust enrichment, the ‘Unprompted refund – Yes’ entry should not be used.

Stating unjust enrichment is an independent occurrence. Reporting unjust enrichment is not influenced by whether the benefit is cancelled for some part or whether it can ever be recovered.  Forgiving or modification of unjust enrichment is not reported to the Incomes Register. This is seen in the Incomes Register only indirectly when a recovery report is not submitted or the recovered amounts cover only part of the unjust enrichment.

When recovery proceedings are initiated, the amounts paid back must be reported no later than on the fifth day after the day of receiving a notification of the payment of the recovered amount, the payer and the benefit to which the payment relates and the benefit payer has been able to allocate the recovery in the benefit payer’s own system.

1.2.3 Reporting data in advance

The data can also be submitted to the Incomes Register before the payment date. Reporting data in advance is, however, limited in such a manner that payments can be reported to the Incomes Register no earlier than 45 days prior to the payment date. The values for the start and end date of the earnings period of the payments reported to the Incomes Register are not limited in this way. Thus, a payment far in the future can be reported if the payment is made within 45 days.

1.2.4 Electronic reporting only

Benefits and pensions cannot be reported to the Incomes Register on paper. If a taxable pension or benefit is exceptionally paid by a private person or some other payer that is not deemed a benefits payer in the act on the incomes information system, the payer must, as a rule, fulfil their reporting obligation by reporting their payments directly to the competent authority.

The electronic reporting methods used by the Incomes Register are the technical SFTP and Web Service interfaces as well as the e-service where data can be submitted via an online form or a separate record upload service. Submitting a benefits payment report via the e-services requires that the payer has specified themselves as the benefits payer in the service settings. This option is not available to private individuals. For more information on the concept of benefits payer, see the ‘Concepts’ section of this guide.

1.3 Regularly submitted mandatory data

The majority of the benefit data reported to the Incomes Register is mandatory to report; it must be reported, and it must be present in each record. The mandatory data includes, for example, the payer’s identification information, the payment date and the technical record information. The last-mentioned data is mandatory when reported via the technical interface or by uploading a file. The reports contained in the record should also identify the income earners either by Finnish identifiers or, if they are not available, by other identification information.

See the benefits payment report schema for a more detailed description of what data is mandatory. As a rule, the mandatory data corresponds with the data currently collected by the Tax Administration. However, data is collected from a wider range of income types for the purposes of other data users.

1.4 Administrative consequences for neglecting to submit data

The penalty fee system provided in the act on the incomes information system applies to the data specified in sections 6 and 8 of the act, i.e. the mandatory data to be reported to the Incomes Register. The penalty fees are imposed by the Tax Administration.

A late-filing penalty replaces the benefit payer's late-filing penalty laid down in the act on assessment procedure for self-assessed taxes (laki oma-aloitteisten verojen verotusmenettelystä 768/2016) and the negligence penalty laid down in the act on assessment procedure (laki verotusmenettelystä 1558/1995) insofar as a late-filing penalty is imposed based on the late submission of data that must be reported to the Incomes Register.

According to the applicable act, a late-filing penalty is imposed only based on the mandatory data that a party with a reporting obligation reports late to the Incomes Register. When the benefit payer does not report any data to the Incomes Register of the taxable payments they have made, or the data is incomplete, and the benefit payer does not correct the neglect of their own volition before taxes and contributions are levied, no late-filing penalty is issued. In such a situation, the consequences for neglecting the reporting obligation laid down in the provisions of the act on assessment procedure and the act on assessment procedure for self-assessed taxes, such as a punitive tax increase, are applied.

The provisions of the tax laws on the consequences of neglect do not apply to tax-exempt benefits. If data reported to the Incomes Register has a deficiency or error that has no significance for the taxation of the income earner, no negligence penalty is imposed.

1.4.1 Late submission of the first report

The late-filing penalty for late submission of the first report containing data to be reported for a calendar month is, as a rule, determined based on how late the report is. Although as a rule the data must be submitted within five days of the payment date, the late-filing penalty is not linked to the same deadline. Under section 22(1) of the act on the incomes information system, a late-filing penalty is imposed based on the lateness of the reporting of benefits payment data, if all data on the benefits paid during the calendar month is not reported by the eighth day of the next month.

According to the law, the consequence for a late submission of the first report would be EUR 3 for each day the report is late for a period of 45 days, or a maximum of EUR 135. If the report is submitted more than 45 days late, the late-filing penalty is EUR 135 plus one per cent of the amount of the taxable payment reported late. No late-filing penalty is imposed for late reporting of a tax-exempt benefit.

1.4.2 Correcting submitted data

No late-filing penalty is imposed if data submitted on time is corrected within 45 days of the deadline. If previously submitted data is corrected more than 45 days after the deadline, a late-filing penalty of one per cent of the amount of the taxable payment reported late is imposed. However, no late-filing penalty is issued if the above-mentioned amount does not increase due to the correction.

The percentage-based late-filing penalty imposed based on the payment amount is adjusted if the payment amount is reduced due to the correction of data, adjustment of a decision, appeal or other such reason.

2 Concepts

2.1 Benefit payer

In the act on the incomes information system, benefit payer means a legal person governed by public or civil law whose status, as decreed by Finnish law, is a payer of benefits, pensions or other equivalent payments, or whose actions as the payer of these payments is decreed to be supervised by a Finnish authority, such as the Financial Supervisory Authority. A benefit payer may also be a similar foreign actor with a permanent establishment in Finland for the purpose of income taxation. The benefit payer is obliged to use for reporting the Incomes Information System and always have a Finnish Business ID due to the benefit payer’s obligation to register.

The benefits payment report submitted to the Incomes Register will replace the benefit payer's reports on benefits and pension payments currently required to be submitted to the Tax Administration. With respect to the payer's other obligations to provide information, the benefits payment reports are supplementary, not replacement data.

2.2 Income earner

In section 3 of the act on the incomes information system, income earner means a natural person, estate or a legal person to whom or which a payment has been made or who or which has received a non-monetary benefit, as referred to in this act. The benefits payment report’s income earner, i.e. the benefit recipient, must always be a natural person or a death estate. The benefit recipient can also be a foreign estate treated as an organisation in taxation. In the role of a benefit recipient, the income earner may only receive benefits paid in cash. In this guide, the benefit recipient is mainly referred to as an income earner.

2.3 Substitute recipient

The term ‘substitute recipient’ refers to the payment recipient in situations where the payment recipient is a party other than the benefit recipient. Substitute recipient is used for reporting, amongst other things, in recourse situations and situations in which the benefit recipient’s income is paid in full or in part to another party. In the benefits payment report, the substitute recipient may be Kela, the Employment Fund, an earnings-related pension provider, a non-life insurance provider, or the employer. The substitute recipient may also be the benefit payer.

2.4 The concepts of pension and benefit

Statutory pensions that are based on an employment relationship or a voluntary pension insurance or paid from some other insurance, and other payments that are deemed to be pensions in legislation or in the established taxation and judicial practice and are paid by a benefit payer referred to in the act on the incomes information system, are reported to the Incomes Register.

A compensation or financial support (benefit) that is based on such a law, insurance, membership in a fund, decision of a public sector organisation or some other factor that is taxable as personal income or taken into account when basic social assistance is granted and that is paid in money by a benefit payer referred to in the act on the incomes information system to a party entitled to the benefit or to their substitute recipient, is also reported to the Incomes Register. Hence, tax-exempt income that does not have an effect on the social assistance is primarily not reported to the Incomes Register.

In addition, the following income types or payments are deemed to be benefits stored in the Incomes Register:

  • damages for personal injury under chapter 5, section 1 of the Tort Liability Act, with the exception of damages to cover medical costs and other necessary costs referred to in section 2 of chapter 5;
  • payments to be reported to the Tax Administration referred to in section 28 a of the act on inheritance and gift tax, even if they are tax-exempt in income taxation and do not affect the granting of basic social assistance; and
  • income from a capital redemption policy.

As an exception to the definitions above, a payment based on a long-term savings agreement or other agreement related to investment activities is not regarded as a benefit, not even if the payment is made by a benefit payer as referred to in the act. Payments considered to be sensitive in nature, such as strike pay, disability allowance for a person of the age of 16 or over or social assistance, are also not deemed to be benefits to be reported to the Incomes Register.

The set of pensions and benefits to be reported to the Incomes Register is also limited by the concept of benefit payer in the act on the incomes information system. The instances that have an obligation to provide information on the payments they have made but that are not covered by the definition of payer (such as private persons) do not report pensions and benefits to the Incomes Register; instead, they report them directly to the competent authority. However, it is technically possible to report income types included in the data contents of the Incomes Register on behalf of a payer with no Business ID or obligation to report data.

The set of pensions and benefits to be reported to the Incomes Register is also limited by the fact that data used only by the data provider is not submitted to the Incomes Register. It would violate the principle of data minimisation relating to the processing of personal data to register data with no purpose of use. This exception mainly applies to some payments paid by Kela.

3 Basic reporting situations

Examples of basic situations of reporting data are given below. The examples do not include all mandatory data, only the data necessary for processing the matter.

3.1 Reporting pension income

All pensions paid by Finnish payers are reported to the Incomes Register. The benefits payment report can only be submitted electronically. The report includes information on the income earner, the payment and the grounds for the payment. One record may contain reports regarding pensions paid to many different income earners. Nonetheless, all reports in one record must have the same payment date.

Example 1: On 2 May 2023, the benefit payer (1234567-8) pays thousands of pensions, the benefits payment reports of which are collected into one record. One of the benefit payer’s clerical workers acts as a contact person for the record. The report in the example applies to a person (ddmmyy-1234) living in Finland whose pension for May has been paid as a continuous pension. In the ‘Earnings period’ section, report the earnings period for which the pension is paid on the payment date.

Example 1, table 1
Record data Values
Date of payment or other report date 02.05.2023
Contact persons for the record  
Name Toni Toimihenkilö
Telephone number 0201009999
Payer details  
Type of identifier Business ID
Identifier 1234567-8
Report data  
Type of action New report
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
General income type details  
Income type code Old-age pension
Amount 2000.00
Earnings period  
Start date 01.05.2023
End date 31.05.2023
General income type details  
Income type code Withholding tax
Amount 400.00
Earnings period  
Start date 02.05.2023
End date 02.05.2023

3.2 Reporting benefits income

The Benefit unit data group is mandatory when unemployment benefits are reported in order that the days qualifying for unemployment benefits could be determined. The benefit payers must report to the Tax Administration the number of days in the tax year for which the taxpayer has been paid the unemployment benefits referred to in section 93(4) of the income tax act (tuloverolaki 1535/1992) (decision of the Tax Administration on information-reporting requirements). Unemployment benefits include the unemployment allowance and the labour market subsidy.

The unemployment benefit income types for which it is mandatory to specify the Benefit unit data group and on the basis of which the number of qualifying days is determined are listed in the Incomes Register's document Benefits – Income types – Codes. For these unemployment benefits, the benefit unit is day. The number of units entered is the number of qualifying days in the earnings period of the income type in question.

When reporting the above-mentioned unemployment benefit to the Incomes Register, the benefit payer must specify the income data separately for each year if the earnings period applies to several years. If, in example 2, the benefit payer also paid a labour market subsidy to the income earner for the period between 2 and 3 January 2021, the benefit payer should specify a separate ‘Income type details’ data group for these days in the report. In this income type itemisation, the number of benefit units would be 2, and the amount paid would be the portion based on these days of the full amount paid. The qualifying days of 2020 are reported in accordance with example 2, although the benefit payer also has to submit an annual information return on the days qualifying for unemployment benefits (VSKORVPV).

Example 2: On 3 January 2021, the benefit payer pays a person the labour market subsidy for the last month of 2020, with 20% tax withheld.

Example 2, table 1
Record data Values
Date of payment or other report date 03.01.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Labour market subsidy
Amount 550.00
Earnings period  
Start date 01.12.2020
End date 31.12.2020
Benefit unit  
Unit Day
Number of units 18
General income type details  
Income type code Withholding tax
Amount 110.00
Earnings period  
Start date 03.01.2021
End date 03.01.2021

3.2.1 Advance and additional payment

It is not separately reported in the Incomes Register's benefits payment report if the reported amount is not equal to the final amount of the benefit decision. The Incomes Register is based on registering of payment transactions and contains only a limited amount of so-called benefit decision data.

Example 3: On 11 November 2021, the benefit payer pays EUR 900 to an income earner as an earnings-related allowance. The benefit payer handles the payment as an advance that is approximately 70% of the estimated final earnings-related allowance. The rest of the allowance is paid when the final amount of the adjusted allowance can be calculated. The income earner has a zero-rated tax card for the benefit.

The benefits payment report for the November payment:

Example 3, table 1/2
Record data Values
Date of payment or other report date 11.11.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Earnings-related allowance
Amount 900.00
Earnings period  
Start date 27.09.2021
End date 29.10.2021
Benefit unit  
Unit Day
Number of units 25

The income earner is later found to be entitled to an additional payment of EUR 300 for a previously reported earnings period. The rest of the granted benefit will be paid on 3 December 2021. Because the payment is an additional payment that has not added to the number of days qualifying for unemployment benefits, the number of units reported is, exceptionally, zero (0).

The benefits payment report for the December payment:

Example 3, table 2/2
Record data Values
Date of payment or other report date 03.12.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Earnings-related allowance
Amount 300.00
Earnings period  
Start date 27.09.2021
End date 29.10.2021
Benefit unit  
Unit Day
Number of units 0

The use of Incomes Register data for purposes defined in section 93 of the act on income tax and for other purposes requires that the benefit unit be not reported cumulatively. Attention to this must be paid particularly when a benefit accrued over a specific earnings period is paid in several instalments. Only such benefit units on which a payment is based that have not been previously reported are reported to the Incomes Register. If the benefit unit is a day, the total number of units on the same benefit payer's reports must therefore not exceed 31 units per month or, for example, 7 units in a one-week period. On the other hand, an income earner may receive more than one pension during the same month. In this case, the different benefit payers use Month as the unit value and enter 1 as the number of units. 

3.4 Reporting the earnings period

When reporting income to the Incomes Register using the benefits payment report, the benefit payer must always enter the ‘Earnings period’ information for the income type. The actual uninterrupted earnings period is reported as the earnings period with an accuracy of one day. Only one ‘Earnings period’ entry can be made for each reported income type. When reporting a recovery or income that is refunded unprompted, the earnings period is reported in the ‘Additional repayment details’ data group.

Payments made simultaneously on different earnings periods are thus reported in different income type itemisations. An earnings period is the period over which the income has been accrued. In some cases, the earnings periods of benefits or pension income can be very long, for example over one year.

If the advance lump sum applies to an indefinite moment in the future, the income payment date should be reported as the end date of the earnings period. If the period of time applicable to the one-off income paid in advance is known, it should be reported as the income earnings period.

When it comes to retrospective one-off income, the paid income should be allocated at the level of calendar year. It is recommended that the income type itemisations of a retroactive payment be always allocated to an annual level – even if a period of less than three months of the earnings period occurs during the previous year. Annual revisions and index raises to benefit amounts make it more difficult to use data in which the reported income is allocated to more than one year.

If the income earnings period cannot be defined, the payment date should be entered as the earnings period. Income that lacks the earnings period includes, for example, most types of compensation for a temporary or permanent functional limitation paid from personal insurances. No data is collected in the Incomes Register on the times of insurance events such as traffic accidents or deaths, so the payment date of the income is reported as the start and end date of the earnings period. The procedure is the same for one-off benefits such as baby money, funeral allowance, or surrender of insurance policy.

The payment date should always be entered as the earnings period for deduction-like income types. Such income types include, for example, ‘Withholding tax’ and ‘Tax at source’. The payment date can also be used as the earnings period, if unjust enrichment is reported to the Incomes Register using the ‘Unjust enrichment’ income type. There is more information about unjust enrichment in the ‘Reporting unjust enrichment and recovery’ section.

3.5 Reporting one-off remuneration data

The 'One-off remuneration' information has three purposes:

  • occasional isolated income (so-called actual one-off remunerations)
  • retroactive income, with at least three months of its earnings period in the previous tax year
  • income paid in advance, accrued over more than one year.

The 'One-off remuneration' information is specified for these types of income, because, for instance, the Finnish Tax Administration needs the information to carry out the income spreading (section 128 of the income tax act (tuloverolaki 1535/1992)) and deferral of retirement income (section 112 of the income tax act).

In case of occasional isolated income that is not recurring, ‘One-off remuneration – Yes’ is specified for the income type in addition to the earnings period. The earnings period of such random payment can be one day or, for example, one year.

A one-off remuneration is typically a payment paid only once, not on a recurring basis. In some situations, income may be a one-off remuneration even if it were paid again later. It is essential that there is no knowledge or decision of a new payment at the time of payment. Payments of a continuous nature, such as unemployment allowances or partial sickness allowances, are not one-off remunerations, even if the next payment is not yet known. Income types of a deduction type, such as withholding or distraint, are not one-off remunerations. A benefit paid once a year or at some other regular intervals is not a one-off remuneration because it is paid on a recurring basis. When paying a late payment increase, the 'One-off remuneration' information must always be used, because a late payment increase is a one-off remuneration by nature.

The one-off remuneration data should be used when paying retrospective income, if the earnings period applies to a period of three or more than three months preceding the tax year. The reviewed period may comprise individual months or a time period that does not last three consecutive months but as a whole exceeds the above-mentioned limit. If the earnings period of retroactive income extends to both the year before the tax year (for at least three months) and the current tax year, the retroactive income is divided in accordance with the tax years, and is reported as two payments. The 'One-off remuneration' information must be specified for both payments.

The ‘one-off remuneration’ data should be used for income paid in advance, if the income paid in advance has accumulated for more than a year. In this case, a period exceeding one year refers to a period of time that is at least 12 months and one day.

If recovery is being reported, the 'One-off remuneration' information must be specified if the information was also specified on the original report related to the recovery.

3.6 Deduction of employee contributions

A certain part of the total of the employee's earnings-related pension insurance contribution, the employee's unemployment insurance contribution and the daily allowance contribution of health insurance is deducted from the daily allowance under the Workers' Compensation Act. Employee contributions can also be deducted in a similar manner from patient injury insurance, motor liability insurance and liability insurance payments, and from the rehabilitation allowance under the Workers' Compensation Act. When the employee contributions are deducted from the work income on which a benefit is based before the amount of the benefit is confirmed, the deduction is not reported to the Incomes Register.

Even though most of the benefits data users need the post-deduction amount of employee contributions, some of the benefits data users require the amount before the deduction of the employee contributions. The deduction is reported by using the ‘Deductions’ data group where the amount of deduction is reported using a specific deduction type. When using the deduction of employee contributions, report the gross amount prior to the deduction as the amount of the income type.

Income reported to the Incomes Register may also be subject to other calculated deductions similar to the deduction of employee contributions. Such deductions include Kela deductions and contributory deductions. There are no grounds for the data use of such deductions, so they are not reported to the Incomes Register. 

Example 4: The income earner is paid a daily allowance of EUR 110 per day for a total of seven days during the period 29 February 2021–6 March 2021. The payment is made to the income earner on 8 March 2021. First, the 65% Kela deduction is made from the payment (EUR 770 x 0.65 = EUR 500.50), after which the 50% contributory deduction (EUR 269.50 × 0.5 = EUR 134.75) and the 4.6% deduction of employee contributions (EUR 134.75 × 0.046 = EUR 6.20) are made.

Because no other imputed deductions but the deduction of employee contributions need to be reported to the Incomes Register, the reported amount of the payment reported does not include these other deductions (EUR 770 - EUR 500.50 - EUR 134.75 = EUR 134.75), so EUR 134.75 is reported to the Incomes Register. The amount of the employee contribution deduction is reported in the deduction details.

Example 4, table 1
Record data Values
Date of payment or other report date 08.03.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Daily allowance
Amount 134.75
Earnings period  
Start date 29.02.2021
End date 06.03.2021
Benefit unit  
Unit Day
Number of units 7
Deductions  
Deduction income type code Daily allowance
Deduction type Deduction of employee contributions
Amount of deduction 6.20
Earnings period of original benefit  
Start date 29.02.2021
End date 06.03.2021
Substitute recipient’s details  
Period of calculation  
Start date 29.02.2021
End date 06.03.2021

4 Other reporting situations

4.1 Payments reported under section 28 a of the act on inheritance and gift tax

When reports under section 28 a of the act on inheritance and gift tax are submitted to the Incomes Register, the details of the policy holder and the policy number or other identifier must be submitted in the report in addition to the income earner (insurance beneficiary). In situations where the payment reported to the Incomes Register is a gift as defined in Section 18 a of the act on inheritance and gift tax, the policy holder is the gift giver. When the policy holder's identifying information is reported for inheritance taxation (section 7 a of the act on inheritance and gift tax), the policy holder is, as a rule, the deceased. However, when reporting a death compensation or a funeral grant to the Incomes Register, the ‘Policyholder details’ data group is also used to enter the details of the deceased when the compensation is based, e.g. on the employer’s group life insurance policy.

By entering the inheritance and gift tax specifier for the ‘Taxability of benefit’ data, the benefit payer states that the income type in question including its data are subject to a report under section 28 a of the act on inheritance and gift tax. However, if part of the payment were taxable based on income taxation, the benefit payer should report the part subject to income tax in a separate income type itemisation using a different ‘Taxability of benefit’ entry (e.g. ‘Taxability of benefit – Capital income’).

If a payment belonging to a report submitted under section 28 a of the act on inheritance and gift tax is made to a pledgee instead of the beneficiary, the specifiers must also be entered as described above (see also Example 7). The details of the pledgee acting as a substitute recipient are specified in the report's ‘Deductions’ data group. Report ‘Deduction based on the right of pledge’ as the deduction type, enter the pledgee's details as the substitute recipient details, and report the substitute recipient type as ‘Other payment recipient’ (Example 7). Payments to substitute recipients are explained, for example, in the ‘Benefit payment to a substitute recipient’ section of this guide.

Example 5: On 1 June 2021, the benefit payer pays the group life insurance payment including the child increases to the beneficiary of a scholarship recipient (ddmmyy-1235) who died on 3 May 2021. The basic amount and child increase of the group life insurance payment are itemised as separate income types on the benefits payment report. On the report, the benefit payer uses the ‘Taxability of benefit’ entry ‘Tax-exempt, data according to the act on inheritance and gift tax is given’.

Example 5, table 1
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Basic amount
Amount 11000.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.06.2021
End date 01.06.2021
Insurance information  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1235
Policy number or other identifier 000-21-00
General income type details  
Income type code Child increase
Amount 7500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.06.2021
End date 01.06.2021
Insurance information  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1235
Policy number or other identifier 000-21-00

Example 6: On 1 June 2021, the benefit payer pays the income earner EUR 10,000 in benefits. The whole income is the income earner’s taxable capital income. A report in accordance with the act on inheritance and gift tax, section 28 a, of the income must be submitted to the Tax Administration. It is such a rare case of income that is taxable subject to both the income tax act and the act on inheritance and gift tax. On the report, the benefit payer should enter the ‘Taxability of benefit’ data ‘Capital income, and data according to the act on inheritance and gift tax is given’.

Example 6, table 1
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code (Benefit)
Amount 10000.00
Taxability of benefit Capital income, and data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.06.2021
End date 01.06.2021
Insurance information  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1235
Policy number or other identifier 000-21-00
General income type details  
Income type code Withholding tax
Amount 3000.00
Start date 01.06.2021
End date 01.06.2021

If, instead of the ‘Taxability of benefit’ data ‘Capital income, and data according to the act on inheritance and gift tax is given', the benefit payer enters the ‘Taxability of benefit’ data ‘Capital income’ and attaches the voluntary ‘Insurance information’ data group, the Tax Administration does not receive the information in the ‘Insurance information’ data group.

Example 7 (beneficiary is a close family member): Person A died, and an insurance company pays an insurance indemnity of EUR 17,000 due to the death. Half of the indemnity, or EUR 8,500, is paid to the pledgee, i.e. the bank. The estate is reported as the income earner. The rest is paid to the beneficiary later.

First report:

Example 7, table 1/2
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Life insurance indemnity
Amount 8500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.06.2021
End date 01.06.2021
Insurance details  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Policy number or other identifier 000-21-15
Deductions  
Deduction income type code Life insurance indemnity
Type of deduction Deduction based on the right of pledge
Amount of deduction 8500.00
Earnings period of original benefit  
Start date 01.06.2021
End date 01.06.2021
Substitute recipient details  
Type of identifier Business ID
Identifier 1234567-8
Type of substitute recipient Other payment recipient
Period of calculation  
Start date 01.06.2021
End date 01.06.2021

The insurance company commissions a genealogical investigation and determines that the rest is paid to the child of the deceased person. The child of the deceased person is reported as the income earner.

Second report:

Example 7, table 2/2
Record data Values
Date of payment or other report date 01.07.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Life insurance indemnity
Amount 8500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.07.2021
End date 01.07.2021
Insurance details  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Policy number or other identifier 000-21-15

Example 8 (beneficiary is not a close family member): Person A died, and an insurance company pays an insurance indemnity of EUR 17,000 due to the death. Half of the indemnity, or EUR 8,500, is paid to the pledgee, i.e. the bank. The estate is reported as the income earner. The rest is paid to the beneficiary later.

First report:

Example 8, table 1/2
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Life insurance indemnity
Amount 8500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
One-off remuneration Yes
Earnings period  
Start date 01.06.2021
End date 01.06.2021
Insurance details  
Policyholder's identifier  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Policy number or other identifier 000-21-15
Deductions  
Deduction income type code Life insurance indemnity
Type of deduction Deduction based on the right of pledge
Amount of deduction 8500.00
Earnings period of original benefit  
Start date 01.06.2021
End date 01.06.2021
Substitute recipient details  
Type of identifier Business ID
Identifier 1234567-8
Type of substitute recipient Other payment recipient
Period of calculation  
Start date 01.06.2021
End date 01.06.2021

The insurance company discovers that the rest will be paid to the goddaughter of the deceased, who is not a close relative. The goddaughter is reported as the income earner.

Second report:

Example 8, table 2/2
Record data Values
Date of payment or other report date 01.07.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Life insurance indemnity
Amount 8500.00
Taxability of benefit Capital income
One-off remuneration Yes
Earnings period  
Start date 01.07.2021
End date 01.07.2021
General income type details  
Income type code Withholding tax
Amount 2550.00
Start date 01.07.2021
End date 01.07.2021

4.2 Remunerations paid to an income earner when the benefit payment is delayed

Should a benefit payment be late, the income earner can be paid late payment interest that is independent of the taxation of the main payment and taxed as capital income, or an increase for late payment that is taxed according to section 61 a of the act on income tax in the same way as the main payment. The late payment interest is not included in the data contents of the Incomes Register; it will continue to be reported to the Tax Administration on annual information return 7805, which includes interest income in accordance with the income tax act. Increases for late payment, however, are reported to the Incomes Register using the income type of the main payment and a special ‘Late payment increase – Yes’ entry on the report.

Sometimes, increases due to late payments also have to be paid separately from the main payment if, for example, the main payment has already been made and the need to pay the increase is not noticed until later. Even then, the late payment increase is reported according to the payment date. The main payment is always determined on the basis of the income type code. The ‘Late payment increase – Yes’ entry is used to report the amount of the late payment increase. When paying a late payment increase, the 'One-off remuneration' information must always be used, because a late payment increase is a one-off remuneration by nature.

Example 9: On 2 June 2021, the income earner is retrospectively paid EUR 3,500 in care allowance for the period 1 June 2020–31 December 2020. At the same time, a EUR 150 increase for late payment is paid for a period starting from the date on which the insurance company should at the latest have made the first payment. In its entirety, the period is from 28 July 2020 to 2 June 2021. Both payments are tax-exempt income for the income earner. Because the increase for late payment concerns a time period of which more than three months were before the payment year, it is reported separately for years 2020 and 2021.

Example 9, table 1
Record data Values
Date of payment or other report date 02.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Care allowance
Amount 3500.00
One-off remuneration Yes
Earnings period  
Start date 01.06.2020
End date 31.12.2020
General income type details  
Income type code Care allowance
Amount 50.00
Late payment increase Yes
One-off remuneration Yes
Earnings period  
Start date 28.07.2020
End date 31.12.2020
General income type details  
Income type code Care allowance
Amount 100.00
Late payment increase Yes
One-off remuneration Yes
Earnings period  
Start date 01.01.2021
End date 02.06.2021

4.3 Benefit payment to a substitute recipient

A substitute recipient is reported, for example, in case of recourse or when the income earner’s income is paid in full or in part to a party other than the income earner. On a benefits payment report, the type of substitute recipient can be specified as, for example, a municipality or a social welfare organisation, the employer, or the Patient Insurance Centre. From the perspective of the Incomes Register, the enforcement authorities and the Finnish Tax Administration are not considered to be substitute recipients. Items paid to them (distraint, withholding) have their own income types.

The Deductions income type code is used to indicate the original income type to which the deduction applies. If part of the income is paid to a substitute recipient and it is not allocated to any previously paid income type, the same income type is used for the deduction and for the income. The earnings period of the ‘Deductions’ data group is also often the same as that of the payment's income type.

If an instalment paid to a substitute recipient is assigned to a previously paid income type (in recourse situations, for example), the same income type is used for the deduction. The earnings period of the previously paid income type is reported as the earnings period of the ‘Deductions’ data group, and it can differ from that of the income type paid.

If there is no applicable income type code for the income type of the deduction, either ‘Other benefit’ or ‘Other pension’ can be used as income type for the deduction. This may be the case, for example, if the deduction applies to a previously paid income type that should not have been reported to the Incomes Register (such as social assistance or some other benefit of a sensitive nature).

The ‘Deductions’ data group is not meant to be used for reporting the income earner’s debt (e.g. unpaid insurance premiums) or for covering the income earner’s living expenses. The deduction types of the data group are used to report deductions paid to another benefit payer or the employer. If the income earner’s income is subject to a deduction for which a deduction type is not listed, it should be considered whether the deduction should be reported to the Incomes Register. The ‘Other deduction from taxable income’ and ‘Other deduction from net income’ deduction types should only be used to report deductions referred to in the benefit details instructions.

Example 10: A total of EUR 3,000 in disability pension for June is paid to the municipality instead of the income earner under section 122 of the Employees Pensions Act. First EUR 600 is withheld from the benefit to be paid. Furthermore, EUR 100 is deducted from the net income in accordance with a payment ban issued by the enforcement authority. Once the municipality has received the remaining EUR 2,300, the income earner does not pocket any income at all. However, a benefits payment report on the income is still submitted to the Incomes Register.

Example 10, table 1
Record data Values
Date of payment or other report date 02.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Disability pension
Amount 3000.00
Deductions  
Deduction income type code Disability pension
Deduction type Recourse from tax-exempt income
Amount of deduction 2300.00
Earnings period of original benefit  
Start date 01.06.2021
End date 30.06.2021
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234567-8
Substitute recipient type Municipality or another social welfare body
Period of calculation  
Start date 01.06.2021
End date 30.06.2021
General income type details  
Income type code Withholding tax
Amount 600.00
General income type details  
Income type code Distraint
Amount 100.00

The Tax Administration uses the value given in the Type of deduction field to determine whether the deduction affects the income earner's taxable income. For example, if the deduction type is ‘MATA and MYEL collection’, the deduction is made from the net income, not the amount of taxable income.

Example 11: An employee has an occupational accident at the end of August 2021 and receives EUR 2,050 in sick pay for September. Based on the occupational accident insurance, the insurance company pays a daily allowance equalling the sick pay directly to the employer. The daily allowance paid to the employer is not subject to an employee contribution deduction or withholding. The employee's benefit paid to the employer is reported on the benefits payment report indicating the employer as a substitute recipient. The 'Daily allowance (occupational accident insurance)'income type is used as the deduction income type.

The insurance company will submit the following report on the payment to the Incomes Register:

Example 11, table 1/2
Record data Values
Date of payment or other report date 01.10.2021
Payer details  
Type of identifier Business ID
Identifier 1001000-9
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Daily allowance (occupational accident insurance)
Amount 2050.00
Earnings period  
Start date 01.09.2021
End date 30.09.2021
Benefit unit  
Unit Day
Number of units 30
Deductions  
Deduction income type code Daily allowance (occupational accident insurance)
Deduction type Other deduction from taxable income
Amount of deduction 2050.00
Earnings period of original benefit  
Start date 01.09.2021
End date 30.09.2021
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234123-4
Substitute recipient type Employer
Period of calculation  
Start date 01.09.2021
End date 30.09.2021

One month after the occupational accident, the insurance company starts paying a daily allowance to the injured person based on their annual earnings. The employee has provided the company with a tax card (10%) for the payment of the benefit. Before tax is withheld, the employee contributions are deducted from the daily allowance in accordance with section 62 of the Workers' Compensation Act. When reporting the payment to the Incomes Register, the insurance company will link the deduction to the gross amount of the daily allowance by using the ‘Deductions’ data group in the benefits payment report.

The insurance company will submit the following report on the payment to the Incomes Register:

Example 11, table 2/2
Record data Values
Date of payment or other report date 02.11.2021
Payer details  
Type of identifier Business ID
Identifier 1001000-9
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Daily allowance (occupational accident insurance)
Amount 2000.00
Earnings period  
Start date 01.10.2021
End date 31.10.2021
Benefit unit  
Unit Day
Number of units 31
Deductions  
Deduction income type code Daily allowance (occupational accident insurance)
Deduction type Deduction of employee contributions
Amount of deduction 90.00
Earnings period of original benefit  
Start date 01.10.2021
End date 31.10.2021
Substitute recipient’s details  
Period of calculation  
Start date 01.10.2021
End date 31.10.2021
General income type details  
Income type code Withholding tax
Amount 191.00

The earnings period of original benefit and the period of calculation are not necessarily always the same time period. The period of calculation means the period of time from which income is transferred to a substitute recipient, or the period of time for which the substitute recipient was entitled to the income.

Example 12: The example is being updated and will be published at a later date.

4.4 Reporting a partially taxable and partially tax-exempt benefit

The Finnish tax legislation decrees that in some cases, a certain euro amount or percentage of a benefit is tax-exempt. The full amount of such a benefit is still reported to the Incomes Register, because even the tax-exempt part affects the basic social assistance.

If part of each benefit payment is taxable and part tax-exempt, the benefit is reported to the Incomes Register in two separate income type itemisations. The ‘Taxability of benefit’ data in the itemisations is used to indicate which part is tax-exempt and which is taxable. Such payments include one-off pension payments. If the benefit payer first pays the tax-exempt part of income that is partially taxable and then the taxable part, they must report accordingly.

Example 13: Each month, the benefit payer pays EUR 855 in assistance pension to a family member of a person who died in an occupational accident prior to 1993. According to section 80, paragraph 1(2) of the act on income tax, EUR 3,400 of the annual amount of the pension is tax-exempt. The benefit payer pays the first EUR 3,400 to the family member exempt from tax, reporting the payments to the Incomes Register using ‘Tax-exempt’ as the ‘Taxability of benefit’ data. When the limit for tax exemption is reached in April, the benefit payer reports the taxable part using a separate income type itemisation and states that tax (5%) has been withheld.

The benefit payer’s report for April:

Example 13, table 1
Record data Values
Date of payment or other report date 05.04.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Assistance pension
Amount 835.00
Taxability of benefit Tax-exempt
Earnings period  
Start date 01.04.2021
End date 30.04.2021
General income type details  
Income type code Assistance pension
Amount 20.00
Taxability of benefit Earned income
Earnings period  
Start date 01.04.2021
End date 30.04.2021
General income type details  
Income type code Withholding tax
Amount 1.00

From the next month's report until December, the accident insurance company reports the entire monthly payment as taxable income. By December, the Incomes Register has accumulated data indicating that EUR 3,400 in tax-exempt assistance pension and EUR 6,860 in taxable assistance pension have been paid to the income earner. 

The submitted reports should be corrected if the person dies before the annual tax-exempt income limit has been reached and the benefit payer deems that the income paid to that person should have been processed differently. The correction is made by way of a replacement report in which the information regarding the paid income types is provided and the ‘Taxability of benefit’ data is changed to correspond to the correct specifier. If the benefit payer refunds excessive tax withheld during the same year, a new report should be submitted to the Incomes Register for the refund. The refund is indicated by a negative amount in the new report.

Example 14: The benefit payer pays the income earner a continuous assistance pension of EUR 900 per month. The benefit payer pays the income in such a way that the withholding is made on a monthly basis from the part in excess of EUR 283.33 (3,400/12 months = 283.33). The income earner has submitted a tax card (15%) for the payment of the benefit. The income earner dies in the middle of the year, and the benefit payment stops after March. As the payments made to the income earner between January and March do not exceed the annual tax-exempt income limit, the benefit payer is planning to refund the income earner for the excess tax withheld.  The tax withholding may be refunded to the income earner as long as it is paid during the same year. The January–March reports should be corrected to correspond to the data referred to by the benefit payer.

The benefit payer’s report for January (equivalent reports have been submitted for February and March):

Example 14, table 1/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Payer's report reference 00001
Income earner details  
General income type details  
Income type code Assistance pension
Amount 283.33
Taxability of benefit Tax-exempt
Earnings period  
Start date 01.01.2022
End date 31.01.2022
General income type details  
Income type code Assistance pension
Amount 616.67
Taxability of benefit Earned income
Earnings period  
Start date 01.01.2022
End date 31.01.2022
General income type details  
Income type code Withholding tax
Amount 92.50

A benefit payer’s report on the refund of tax withheld:

Example 14, table 2/3
Record data Values
Date of payment or other report date 20.04.2022
Report data  
Type of action New report
Payer's report reference CCC
Income earner details  
General income type details  
Income type code Withholding tax
Amount - 277.50
Earnings period  
Start date 20.04.2022
End date 20.04.2022

The previously submitted reports for January–March should be corrected so that the data users receive correct information about the tax treatment applied by the benefit payer to the paid income in the benefit payer’s own process. Because tax has been withheld from the January income, it may not be removed from the report. Instead, the payment data should be reported as implemented:

Example 14, table 3/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action Replacement report
Payer's report reference 00001
Income earner details  
General income type details  
Income type code Assistance pension
Amount 900.00
Taxability of benefit Tax-exempt
Earnings period  
Start date 01.01.2022
End date 31.01.2022
General income type details  
Income type code Withholding tax
Amount 92.50

4.5 Benefit changes to pension in taxation once it has been paid for a year

Certain benefits automatically change into a pension corresponding to the benefit once one year has passed from the injury, even if the benefit payer does not make a separate pension decision. Before the year has passed, the benefit is reported to the Incomes Register using the income type for the paid benefit (for example, Compensation for loss of earnings), and taxed accordingly. Once the year has passed and the benefit has changed into a pension from the perspective of taxation, it is reported to the Incomes Register using the corresponding income type for a pension (for example, Compensation for loss of earnings over one year after the injury). The payment is taxed correctly based on the income type.

This practice applies to, for example, compensation for loss of earnings paid based on a motor liability insurance or patient injury insurance, which is considered to be a pension in taxation once one year has passed after the injury, even if no pension decision has been made. A compensation for loss of earnings can also be a pension earlier, if a separate decision of this has been made. In such a case, the compensation is reported after the decision was made using the income type for the new pension, such as Disability pension (motor liability insurance). 

Example 15: The benefit payer pays the income earner compensation for loss of earnings based on a motor liability insurance for the period 1 January 2021 − 31 December 2021. Before one year has passed from the day of the injury, the compensation is reported to the Incomes Register as compensation for loss of earnings.

The benefit payer's report for December (corresponding reports have been submitted for the other months of the year):

Example 15, table 1/2
Record data Values
Date of payment or other report date 02.12.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Compensation for loss of earnings
Amount 2000.00
Earnings period  
Start date 01.12.2021
End date 31.12.2021
Benefit unit  
Unit Day
Number of units 31

A compensation for loss of earnings paid based on a motor liability insurance has been considered to be a pension in taxation practice after one year has passed from the day of the injury, though no pension decision has been made. Once one year has passed from the injury, the payment is reported on the following new reports using an income type considered to be a pension, Compensation for loss of earnings over one year after the injury.  The previous reports are not corrected.

The benefit payer's report for January:

Example 15, table 2/2
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Compensation for loss of earnings over one year after the injury
Amount 2000.00
Earnings period  
Start date 01.01.2022
End date 31.01.2022
Benefit unit  
Unit Day
Number of units 31
If a pension decision made before the benefit had been paid for one year, the income would have been reported to the Incomes Register after the decision, using income type Disability pension.

4.6 Income changes retroactively, and a benefit paid earlier is taken into account as a partial payment

In certain situations, income previously paid may change retroactively, but is not considered to be unjust enrichment or recourse. A decision is made for the income earner of a new benefit that is granted for at least partially the same period as the previously paid benefit. The previously paid income is taken into account as partial payment of the benefit paid later. The income earner has been entitled to the previously paid income, so the income was correct at the time of payment. The reported income type is therefore not corrected, because the income is taxed according to the originally reported income type.

This kind of a situation occurs when, for example, an income earner receiving partial early old-age pension is granted a disability pension, years-of-service pension or old-age pension for the same period for which partial early old-age pension has already been paid. The previously paid partial early old-age pension is taken into account as partial payment of the pension granted later.

The retroactive change to the income is reported to the Incomes Register on a replacement report. Specify 'Income type changed, new income type code' for the original income type, and enter the new income type code as its value. This allows the data users to be informed that the previously paid income has been taken into account as partial payment of the later payment. However, the income is taxed according to the original income type, for which reason the original income type must not be changed in these situations.

These situations do not constitute unjust enrichment or recourse. In cases of unjust enrichment, the income earner is not entitled to the payment and pays it back to the benefit payer. In cases of recourse, different benefits are paid in an overlapping manner, and the payer of the secondary benefit may recover the amount paid earlier from the payer of the primary benefit. When income changes retroactively, the previously paid pension or benefit is not recovered; instead, it is taken into account as partial payment of the benefit paid later.

Example 16: As of 1 January 2021, the income earner is paid partial early old-age pension of EUR 1,200 every month until 28 February 2022. Table 1 shows the new report submitted for March 2021. Corresponding reports have been submitted for the other payment months.

Example 16, table 1/3
Record data Values
Date of payment or other report date 01.03.2021
Report data  
Payer's report reference 1
Type of action New report
Income earner details  
Income type details  
Income type code Partial early old-age pension
Amount 1200.00
Earnings period  
Start date 01.03.2021
End date 31.03.2021
Income type details  
Income type code Withholding tax
Amount 240.00
Earnings period  
Start date 01.03.2021
End date 01.03.2021

The income earner is granted a disability pension on 2 February 2022 so that the start date of the disability pension is 1 March 2021, and the amount paid is EUR 2,200 each month. The benefit payer reports the change to the Incomes Register using a replacement report. The payer specifies ‘Income type changed, new income type code’ for the original income type, and enters 'Disability pension' as its value. Table 2 shows the replacement report submitted for March. Correspondingly, the payer corrects all reports for the time after 1 March 2021.

Example 16, table 2/3
Record data Values
Date of payment or other report date 01.03.2021
Report data  
Payer's report reference 1
Type of action Replacement report
Income earner details  
Income type details  
Income type code Partial early old-age pension
Income type changed, new income type code Disability pension
Amount 1200.00
Earnings period  
Start date 01.03.2021
End date 31.03.2021
Income type details  
Income type code Withholding tax
Amount 240.00
Earnings period  
Start date 01.03.2021
End date 01.03.2021

Because the disability pension granted later is larger than the partial early old-age pension, the benefit payer reports the difference on a new report for the overlapping payment periods 1 March 2021 − 31 December 2021 and 1 January 2022 − 28 February 2022 (Table 3). The amounts in different calendar years are reported as two payments.

The income earner is paid the difference between the disability pension and the partial early old-age pension (EUR 2,200 − EUR 1,200 = EUR 1,000) for the period 1 March − 31 December 2021, or ten months (totalling EUR 10,000). Furthermore, the difference is paid for the time period 1 January 2022 − 28 February 2022, or two months (totalling EUR 2,000). The income earner is paid a total of EUR 12,000, of which the amount of 20% withholding is EUR 2,400. (Table 3.)

Example 16, table 3/3
Record data Values
Date of payment or other report date 01.03.2021
Report data  
Payer's report reference 18
Type of action New report
Income earner details  
Income type details  
Income type code Disability pension
Amount 10000.00
One-off remuneration Yes
Earnings period  
Start date 01.03.2021
End date 31.12.2021
Income type details  
Income type code Disability pension
Amount 2000.00
One-off remuneration Yes
Earnings period  
Start date 01.01.2022
End date 28.02.2022
Income type details  
Income type code Withholding tax
Amount 2400.00
Earnings period  
Start date 03.02.2022
End date 03.02.2022

5 Reporting data in international situations

5.1 Obligation to inform in international situations

The benefits and pension income paid to an income earner living in Finland as well as the other relevant data are reported to the Incomes Register. Corresponding obligations to inform also apply to Finnish benefit payers when the income earner lives abroad.

Income data must be reported to the Incomes Register in international situations whenever the benefit payer has an obligation to inform a user of the Incomes Register data. Foreign payers of benefits and pensions do not have an equally extensive obligation to inform as foreign employers. The third parties' obligation to inform laid down in the act on assessment procedure applies to foreign benefit payers only if the benefit payer has a permanent establishment in Finland for the purposes of income tax. They are then considered comparable to a benefit payer in Finland with respect to the tax-related obligation to inform.

Pensions and benefits must thus be reported on a benefits payment report when a benefit payer referred to in the act on the incomes information system makes payments regarded as pensions or benefits to a person living in Finland or abroad.

A benefit payer may report payments made to a non-resident taxpayer and a resident taxpayer in the same record. Persons whose residence and home are abroad and who do not reside in Finland for more than six months consecutively are deemed non-resident taxpayers. A report must be submitted on payments made to a person who is a non-resident taxpayer, regardless of whether the payment has been subject to tax at source or tax withholding or whether the person is insured in Finland. Such a report must also be submitted on compensation paid to a non-resident taxpayer for an accident that has occurred abroad.

5.2 Reporting data on an income earner living abroad

The data must be reported using a Finnish personal identity code. If the income earner does not have a Finnish personal identity code, the data is reported using a foreign identifier. If the income earner does not have a Finnish personal identity code, their first and last name, date of birth, gender and address details must also be provided. If the income earner has both a Finnish and a foreign identifier, it is recommended that both identifiers be reported. If the income earner is a non-resident taxpayer, the Tax Identification Number (TIN) of the country of residence must be reported if known. Furthermore, a non-resident taxpayer's address in the country of residence and the country code of the country of residence must always be reported.

Example 17: On 3 June 2022, a benefit payer pays an earnings-related pension for June to a person who lives in Sweden but has a Finnish personal identity code. The benefit payer reports the person’s Swedish Tax Identification Number at the same time.

Example 17, table 1
Record data Values
Date of payment or other report date 03.06.2022
Report data  
Type of action New report
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner details  
Type of identifier Tax Identification Number (TIN)
Identifier vvkkpp-4321
Country code SE
Street address Ylevsvägen 1
Postal code 10010
City Stockholm
Country code SE
International situations  
Non-resident taxpayer Yes
Country code of the country of residence SE
General income type details  
Income type code Old-age pension
Amount 2000.00
Grounds for pension paid to a non-resident taxpayer Other payment based on social security legislation
General income type details  
Income type code Withholding tax
Amount 500.00
Grounds for pension paid to a non-resident taxpayer Other payment based on social security legislation

Grounds for a pension paid to a non-resident taxpayer are specified in the additional income type details if the income earner is a non-resident taxpayer who is a recipient of a statutory pension. An earnings-related pension decision issued under the last benefit payer principle may contain different grounds: for example, part of the pension may have been earned in public sector business activities and another part in the private sector. In such a case, the portions are reported separately in their own income type itemisations, where the total pension amount is divided between the different grounds for pension. 

In some exceptional situations, the benefit payer may be unable to obtain the address in the country of residence of the income earner living abroad, and the person has not been registered in the Population Information System. In such situations, the person's Finnish address, if any, or the agent's address can be entered (using the c/o specifier). The 'Country code of the country of residence' of a non-resident taxpayer cannot be Finland (FI).

Example 18: An occupational accident insurance company pays a compensation to a Swedish family member of an injured person for participation in adjustment training. The insurance company can report the payment exceptionally using a virtual identifier, so they must specify the income earner in more detail by giving the date of birth, for example. The income earner has a tax-at-source card including a tax-at-source deduction.

Example 18, table 1
Record data Values
Date of payment or other report date 03.08.2021
Report data  
Type of action New report
Income earner details  
Type of identifier Other identifier
Identifier ddmmyy-9999
Country code FI
Last name Janssen
First name Jan
Date of birth dd.mm.yyyy
Gender Male
Street address Bölebågen 3 A
Postal code SE-40000:
City HAPARANDA
Country code SE
International situations  
Non-resident taxpayer Yes
Country code of the country of residence SE
General income type details  
Income type code Compensation for loss of earnings to a family member who joins in adjustment training
Amount 800.00
General income type details  
Income type code Tax-at-source deduction
Amount 510.00
General income type details  
Income type code Tax-at-source
Amount 101.50

5.3 Non-resident taxpayer's benefit subject to withholding

The Income subject to withholding data item can be submitted only when the income earner is a non-resident taxpayer and has, in accordance with the act on assessment procedure, applied for (progressive) taxation of income that would otherwise be subject to tax at source. The benefit payer can see from the non-resident taxpayer's tax card that the benefits income is subject to progressive taxation. Data is thus not submitted on those income types that are subject to withholding regardless of the tax liability status (e.g. pension income).

Example 19 (alternative to example 18): The income earner has applied for a non-resident taxpayer’s progressive tax card for their income prior to the income payment date. The income is now subject to withholding instead of tax at source. The income earner must have a Finnish personal identity code for the tax card. The insurance company reports the income to the Incomes Register using the personal identity code.

Example 19, table 1
Record data Values
Date of payment or other report date 03.08.2021
Report data  
Type of action New report
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Street address Bölebågen 3 A
Postal code SE-40000:
City HAPARANDA
Country code SE
International situations  
Non-resident taxpayer Yes
Country code of the country of residence SE
Income subject to withholding Yes
General income type details  
Income type code Compensation for loss of earnings to a family member who joins in adjustment training
Amount 800.00
General income type details  
Income type code Withholding tax
Amount 80.00

5.4 Tax at source changes to a resident taxpayer's withholding

The income earner's circumstances may change so that the original benefits payment report must be corrected retroactively using the replacement method. This may happen, for example, when an income earner living abroad moves to Finland and changes from a non-resident taxpayer to a resident taxpayer.

If, in the payment of a continuous benefit, an international situation occurs where both withholding and tax at source must be reported for the same income earner during the same year, the benefit payer must ensure that these instalments are never reported on the same benefits payment report.

Example 20: A person living in Haparanda has been working in Tornio and has been covered by Finnish health insurance. After falling ill, he has received a sickness allowance from Finland, and it has been subject to tax at source. He moves back to Finland on 1 April 2021, but the benefit payer has not been notified of this. A tax card has not been submitted to the benefit payer. The benefit payer reports the benefit for April based on the old information:

Example 20, table 1/3
Record data Values
Date of payment or other report date 02.05.2021
Report data  
Type of action New report
Payer's report reference 1234B05010099
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner details  
Type of identifier Tax Identification Number (TIN)
Identifier yymmdd-1234
Country code SE
Income earner's address (address in Sweden)
International situations  
Non-resident taxpayer Yes
Country code of the country of residence SE
General income type details  
Income type code Sickness allowance
Amount 1000.00
Earnings period  
Start date 01.04.2021
End date 30.04.2021
General income type details  
Income type code Tax at source
Amount 350.00

The system responds by sending the benefit payer the Incomes Register report reference 4270f21849364c093786291fh9809520.

A resident taxpayer's tax card (20%) comes into effect in April, but the person does not deliver it to the benefit payer until May. The already submitted benefits payment report for April must be corrected so that the collected tax at source is converted into withholding. The withheld taxes are reported as the amounts in which the tax was collected from the income earner. Due to the new tax card, the amount of tax will also be corrected, but because the payment already made cannot be changed, the correction is indicated on the following Incomes Register reports.

The benefit payer corrects the April report by submitting a replacement report from which they have removed the ‘Non-resident taxpayer – Yes’ entry. Once the entry has been removed, the income earner is considered to be a resident taxpayer. The data contents include no data item for resident taxpayer. The checks related to the original report's ‘Non-resident taxpayer – Yes’ entry are removed when the entry is deleted. Data such as address details thus become voluntary data.

On 16 May 2021, the benefit payer submits a replacement report for April:

Example 20, table 2/3
Record data Values
Time of record creation 16.05.2021
Date of payment or other report date 02.05.2021
Report data  
Type of action Replacement report
Incomes Register report reference 4270f21849364c093786291fh9809520
Payer's report reference 1234B05010099
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner details  
Type of identifier Tax Identification Number (TIN)
Identifier yymmdd-1234
Country code SE
Income earner's address (address in Sweden)
General income type details  
Income type code Sickness allowance
Amount 1000.00
Earnings period  
Start date 01.04.2021
End date 30.04.2021
General income type details  
Income type code Withholding tax
Amount 350.00

When the benefit payer submits a benefits payment report for May, they can reduce the withholding by the amount withheld in excess in April, i.e. EUR 150. The pre-assessment and the tax card are now in alignment. In the example, after the reduction of EUR 150 from May's EUR 200 withholding, EUR 50 remains. This amount is reported as Withholding tax on the report for May. 

If, however, the amount withheld in excess were refunded to the income earner separately, a separate, new report would be submitted. The refund is reported as a negative withholding.

Example 20, table 3/3
Record data Values
Date of payment or other report date 05.06.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Withholding tax
Amount -150.00
In accordance with the payment date, the refund is allocated to the benefit payer's tax liabilities for June and, in accordance with the payment year, to the taxes withheld from the income earner in 2021. The latter were EUR 150 too high as a result of the excessive withholding in May.

The excess amount withheld must be refunded during the same calendar year. This is because the negative withholding amount is recorded for the payment year indicated in the record data. For example, a negative withholding supposed to be allocated to the previous December's excessive withholding cannot be reported in January; instead, the excessive withholding will be credited to the income earner in taxation.

5.5 Health insurance contributions in international situations

Persons insured in Finland under the Health Insurance Act participate in funding the benefits under the social security legislation by paying the health insurance health care contribution and the health insurance daily allowance contribution, collected in connection with taxes. Together, the health care contribution and the daily allowance contribution form the health insurance contribution of the insured person.

Pension recipients who live abroad and for the compensation of whose medical expenses Finland is responsible under the EU's social security regulation (No. 1408/71) or 'basic Regulation' (No. 883/2004) pay the health care contribution to Finland even after they are no longer insured in Finland under the Health Insurance Act.

The benefit payer is obliged to withhold tax from all income items subject to withholding. If the person is insured in Finland, the withholding includes the person’s health insurance contribution.

The reporter of pension and benefits income does not need to include an itemisation on their Incomes Register benefits payment reports to indicate what part of the withholding is health insurance contribution. The correct contribution amount has been taken into consideration in the income earner's withholding rate.

5.6 Only health care contribution is collected from the income earner

In some international situations, a tax treaty may prevent Finland from taxing the income. However, tax treaties do not apply to the health insurance contribution. Health care contribution must thus be paid from pension income if Finland is responsible for compensating the pension recipient's medical expenses. If the income earner is a resident taxpayer, the benefit payer uses the ‘Taxability of benefit’ entry to specify, as per the tax card's instructions, that only the health care contribution is collected from the income. 

Example 21: A resident taxpayer who has moved to France has earned their pension in public sector business activities in Finland. Taxation of the pension is prevented by a tax treaty between France and Finland. Under the provisions of the basic Regulation, Finland is responsible for the person's medical expenses, however, so the health care contribution must be imposed on the income.

Based on the person's tax card, the benefit payer is aware of the obligation to collect the health care contribution. Each month, the payer submits a benefits payment report on which the payer specifies the ‘Taxability of benefit’ entry of the pension as ‘Earned income, only health care contribution collected’.

Report for March:

Example 21, table 1
Record data Values
Date of payment or other report date 03.03.2021
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Old-age pension
Amount 3500.00
Taxability of benefit Earned income, only health care contribution collected
Earnings period  
Start date 01.03.2021
End date 31.03.2021
General income type details  
Income type code Withholding tax
Amount 60.00

5.7 Non-resident taxpayer’s pension income

In international situations, different additional details of the pension reported to the Incomes Register are submitted on the benefits payment report depending on whether the income earner is a resident or non-resident taxpayer. Even when the pension of a resident taxpayer is paid to abroad, the reporting procedure corresponds to domestic situations. An exception to this are the situations specified above, where the decision of the Tax Administration on the income earner's pre-assessment specifically directs the benefit payer to withhold only an amount equal to the health care contribution from a non-resident pension recipient.

When a non-resident taxpayer is paid pension, the grounds for pension paid to a non-resident taxpayer must be reported as additional details for both the pension and the withholding. If the grounds for different portions of an earnings-related pension paid to a non-resident taxpayer are different, the withholding on the different portions must be reported to the Incomes Register using different income type itemisations. In the itemisations, the same additional data on the grounds for pension is given to the Withholding income type as to the income item that the withholding concerns. This ensures, for example, the successful automatic exchange of taxation information required by the European Union legislation.

Example 22: A Finnish citizen who is a resident taxpayer but lives in France has earned their statutory earnings-related pension as an entrepreneur (YEL portion), in the private sector (TyEL portion) and as an official of a Finnish public sector organisation (JuEL portion). The pension totals EUR 1,500, of which each portion is EUR 500. Taxation of the YEL and TyEL portions of the pension is prevented by the tax treaty between France and Finland. Under the provisions of the basic Regulation, Finland is responsible for the person's medical expenses, however, so the health care contribution must be imposed on all the income.

The benefit payer has received a tax card according to which the common average withholding rate (10%) applies to all the parts of the pension. The rate has been calculated in such a manner that in addition to the health care contribution, the tax collected on the JuEL portion is withheld. Each month, the benefit payer submits a benefits payment report to report the total amount of the monthly pension to the Incomes Register excluding the ‘Taxability of benefit’ entry. All parts of the pension are reported to the Incomes Register using the same income type and the same income type itemisation. The tax withholding is reported under a separate income type.

Report for January:

Example 22, table 1/3
Record data Values
Date of payment or other report date 03.01.2021
Report data  
Type of action New report
Payer's report reference 123400001
Income earner details  
General income type details  
Income type code Old-age pension
Amount 1500.00
Earnings period  
Start date 01.01.2021
End date 31.01.2021
General income type details  
Income type code Withholding tax
Amount 150.00

After the January payment, the benefit payer is informed that the income earner has been deemed to be a non-resident taxpayer as of the beginning of the year. As a non-resident taxpayer, the person has received two tax cards for the pension income. One is for the pension earned in the service of a public sector organisation (25%) and the other for other earnings-related pension (1.5%) including the YEL and TyEL portions.

The benefit payer submits a replacement report to the Incomes Register to report the TyEL and YEL portions using ‘Other payment based on social security legislation’ as ‘Grounds for pension paid to a non-resident taxpayer’. The JuEL portion, in turn, is reported using 'Earnings-related pension from a public body, not earned from business activities'.

Because the person is a non-resident taxpayer, the replacement report in which the pension payments are itemised in detail must also include the ‘Non-resident taxpayer – Yes’ entry as well as the country of residence and address. Replacement report on the January payment:

Example 22, table 2/3
Record data Values
Date of payment or other report date 03.01.2021
Report data  
Type of action Replacement report
Payer's report reference 123400001
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner's address (address in France)
International situations  
Non-resident taxpayer Yes
Country code of the country of residence FR
General income type details  
Income type code Old-age pension
Amount 1000.00
Earnings period  
Start date 01.01.2021
End date 31.01.2021

Grounds for pension paid to a non-resident

tax payer

Other payment based on social security legislation
General income type details  
Income type code Old-age pension
Amount 500.00
Earnings period  
Start date 01.01.2021
End date 31.01.2021

Grounds for pension paid to a non-resident

tax payer

Earnings-related pension from public body, not earned from business
General income type details  
Income type code Withholding tax
Amount 15.00
Earnings period  
Start date 03.01.2021
End date 03.01.2021

Grounds for pension paid to a non-resident

tax payer

Other payment based on social security legislation
General income type details  
Income type code Withholding tax
Amount 125.00
Earnings period  
Start date 03.01.2021
End date 03.01.2021

Grounds for pension paid to a non-resident

tax payer

Earnings-related pension from public body, not earned from business
General income type details  
Income type code Withholding tax
Amount 10.00
Earnings period  
Start date 03.01.2021
End date 03.01.2021

In the example, the income earner's taxes and contributions have decreased as their tax liability status has changed. The benefit payer has originally withheld EUR 10 more than they should have according to the new tax cards. On a replacement report, the excessive withholding need not be allocated to the different pension items of the non-resident taxpayer.

The benefit payer refunds the excessive withholding to the income earner on 14 February of the same year. A separate benefits payment report is submitted on the refund. The day on which the refunded withholding is available to the income earner is reported as the payment date:

Example 22, table 3/3
Record data Values
Date of payment or other report date 14.02.2021
Report data  
Type of action New report
Payer's report reference 123400004
Income earner details  
General income type details  
Income type code Withholding tax
Amount -10.00
Earnings period  
Start date 14.02.2021
End date 14.02.2021

6 Correcting benefits data in the Incomes Register

6.1 General information on correcting data

According to section 4 of the act on the incomes information system, the benefit payer is responsible for the accuracy and correction of any data they have submitted to the Incomes Register. If incorrect information in the Incomes Register is based on the benefit payer's report, the income earner must submit a correction request to the benefit payer in question. Thus, the benefit payer has an obligation to correct any incorrect data they have reported.

Replacement has been selected as the data correction method. This means that the original report is corrected by resubmitting all the report data, both the data that was correct in the original report and the new and changed data. The replacement report replaces the report of the payment date that the error concerns.

If a foreign income earner later receives a Finnish personal identity code, the personal identity code is reported on the next report submitted after the change. Correspondingly, if the person's sex changes, the new identifier is reported on the next report submitted after the change. In these cases, the previous reports do not need to be corrected. The foreign customer ID must still also be reported for foreign income earners.

If the type of action is 'New report', the report does not replace a previously submitted report. Because the income earner can have several valid reports with the same payment date, it must be possible to allocate a correction to the correct report. For this reason, the Incomes Register uses report references, which allow corrections to be allocated correctly. When submitting a new report, the benefit payer always receives an Incomes Register report reference, which helps to allocate the corrections to the correct report. The benefit payer can also use their own internal report reference for corrections, if they do not want to, or are unable to, use the report reference generated by the Incomes Register. The benefit payer's report reference must be specified when a new report is submitted via the technical interface or the upload service. 

Benefits payments made on 1 January 2021 or later, and any corrections to them, are reported to the Incomes Register. If payments made prior to 2021 are corrected in 2021 or later, the corrections should not be reported to the Incomes Register. Corrections to payments made prior to 1 January 2021 should be submitted directly to each data user. However, payments recovered on 1 January 2021 or later are reported to the Incomes Register, even if the original income has been paid prior to 2021.

Data submitted to the Incomes Register is stored in the Incomes Information System for ten years from the beginning of the year following the year in which the data was registered. The data submitted to the Incomes Register can be maintained and corrected as long as it is retained in the Incomes Register.

6.2 Replacement or cancellation of submitted benefits payment reports

As a rule, data in the Incomes Register is corrected by way of a replacement report. However, there are situations where the replacement method cannot be used; instead, the previously submitted report must be cancelled and then a new report with corrected data submitted. These situations are listed in the ‘Cancellation of data’ section of this guide. The cancellation of data refers to deleting information from the Incomes Register.

When a benefits payment report is cancelled, the previously submitted report is deleted. The deletion is allocated to the correct report on the basis of the Incomes Register's report reference or the payer's report reference. When an entire record is cancelled, the record reference of the record in question is used.

6.3 Correcting an error in a report

The need to correct a report may arise from a payment error or a reporting error. Payment errors are situations where the report as such is correct, but the amount of income paid was too high or too low. Reporting errors refer for example to situations where the income was paid correctly but reported incorrectly to the Incomes Register due to mistyping, for example. The income may also have been reported using a wrong income type. When it comes to reporting errors, as a rule, the original data must be corrected using a replacement method.

The correction can be allocated to the correct report by using either the Incomes Register's report reference or the benefit payer's own report reference. Both references can also be submitted in the report. The recommendation is that the benefit payer specifies a version number on the replacement report to enable the correction to be allocated to the correct report.

The Incomes Register assigns version number 1 to the new report. The first replacement report is allocated to a previous report by providing this version number (1) on the replacement report. The first replacement report, in turn, is stored in the Incomes Register as version number 2. If a version number is not used when submitting a replacement report, the Incomes Register will always perform the action on the latest version of the report. The use of the version number is described in more detail in the ‘Technical interface – Delivering data to the Incomes Register’ document.

Example 23: An income earner is paid EUR 2,730 in disability pension in March. The benefit payer withholds tax (EUR 365) from the pension. The benefit payer makes an error when reporting the data and as a result, the amount is incorrectly reported to the Incomes Register as EUR 3,730.

First report before the error is detected:

Example 23, table 1/2
Record data Values
Date of payment or other report date 01.03.2021
Report data  
Type of action New report
Payer's report reference 20XX01201100
Income earner details  
General income type details  
Income type code Disability pension
Amount 3730.00
Earnings period  
Start date 01.03.2020
End date 31.03.2020
General income type details  
Income type code Withholding tax
Amount 365.00

The report submitter receives the report reference 4270f21849164c0937862978cc809500 from the Incomes Register.

The benefit payer may use the payer's report reference for the correction instead of the report reference generated by the Incomes Register.

The typing error is detected at the end of May. The benefit payer must correct the report submitted for March. All data, including the data that was correct, must be resubmitted on the replacement report.

Replacement report for March after the error is detected:

Example 23, table 2/2
Record data Values
Date of payment or other report date 01.03.2021
Report data  
Type of action Replacement report
Incomes Register report reference 4270f21849164c0937862978cc809500
Payer's report reference 20XX01201100
Income earner details  
General income type details  
Income type code Disability pension
Amount 2730.00
Earnings period  
Start date 01.03.2020
End date 31.03.2020
General income type details  
Income type code Withholding tax
Amount 365.00

6.4 Correcting payment errors

6.4.1 Insufficient amount of benefit has been paid

If an insufficient amount of benefit has been paid to the income earner but the amount matches the information on the benefits payment report, the original report will not be corrected. The original report remains valid, and a new report is submitted on the missing payment for the date on which the missing part is paid.

Example 24: In March, the benefit payer pays EUR 1,150 in rehabilitation allowance to a person who takes part in professional rehabilitation and submits a report on the payment to the Incomes Register:

Example 24, table 1/2
Record data Values
Date of payment or other report date 15.03.2021
Report data  
Type of action New report
Payer's report reference 1234567890
Income earner details  
General income type details  
Income type code Rehabilitation allowance
Amount 1150.00
Earnings period  
Start date 01.03.2020
End date 15.03.2021
Benefit unit  
Unit Day
Number of units 13

The Benefit unit entries can be used to provide more detailed information on the grounds for the benefit. In the example, the benefit payer explains that a benefit has been paid for March on the basis of 13 days.

At the beginning of April, the benefit payer notices that the number of rehabilitation days on which the payment was based was too low and that the payment was EUR 200 short.

It is agreed that the missing part of the rehabilitation allowance will be included in the next payment. The first report is not corrected, because the missing part will be paid on a different payment date. The benefit payer submits a new report to report both the rehabilitation allowance for April and the missing part of the rehabilitation allowance for March:

Example 24, table 2/2
Record data Values
Date of payment or other report date 15.04.2021
Report data  
Type of action New report
Payer's report reference 123456789099
Income earner details  
General income type details  
Income type code Rehabilitation allowance
Amount 1700.00
Earnings period  
Start date 01.04.2021
End date 30.04.2021
Benefit unit  
Unit Day
Number of units 24
General income type details  
Income type code Rehabilitation allowance
Amount 200.00
Earnings period  
Start date 23.03.2021
End date 31.03.2021
Benefit unit  
Unit Day
Number of units 8

6.4.2 Excessive amount of benefit has been paid

If an income earner has been erroneously paid too much, the benefit payer submits a replacement report. The overpayment is regarded as unjust enrichment, and the new report replaces the original report. Unjust enrichment is explained in greater detail in the ‘Reporting an unjust enrichment’ section of this guide.

Example 25: In February, an income earner was paid EUR 5,000 as a disability pension, of which amount EUR 1,000 was withheld.

Example 25, table 1/2
Record data Values
Date of payment or other report date 01.02.2021
Report data  
Type of action New report
Payer's report reference 123400089096
Income earner details  
General income type details  
Income type code Disability pension
Amount 5000.00
Earnings period  
Start date 01.02.2021
End date 28.02.2021
General income type details  
Income type code Withholding tax
Amount 1000.00

The benefit payer later detects that the amount of payment was too high. The income earner should only have been paid EUR 3,000. The benefit payer must submit a replacement report to the Incomes Register, indicating the overpayment (unjust enrichment):  

Example 25, table 2/2
Record data Values
Date of payment or other report date 01.02.2021
Report data  
Type of action Replacement report
Payer's report reference 123400089096
Income earner details  
General income type details  
Income type code Disability pension
Amount 3000.00
Earnings period  
Start date 01.02.2021
End date 28.02.2021
General income type details  
Income type code Disability pension
Amount 2000.00
Unjust enrichment Yes
Earnings period  
Start date 01.02.2021
End date 28.02.2021
General income type details  
Income type code Withholding tax
Amount 1000.00

6.4.3 Benefit has been paid to the wrong account

If an income earner’s benefit is paid to a third party and the income earner has provided an incorrect bank account number for the payment of the benefit, the benefit payer is not obliged to correct the mistake. Because it is a question of income to which the income earner is entitled, the payment details should be displayed in the Incomes Register as the income earner’s income. If it is a case of the benefit payer’s own mistake or if the benefit payer is otherwise obliged to correct the mistake, the information should be corrected according to the ‘Correcting data by cancelling a previously submitted report’ section of this guide.

6.4.4 Insufficient amount of benefit has been paid to a substitute recipient

Unjust enrichment should not be reported to the Incomes Register, if the error occurred in the forwarding of the payment to a substitute recipient instead of the income earner’s decision. A payment may be incorrectly forwarded so that the payment made to the substitute recipient is too low and, as a result, the income earner receives an overpayment. A so-called overpayment like this is not considered unjust enrichment.

What is of the essence here is that the amount granted to the income earner as well as the amount paid were both correct. The amount of benefit paid to the substitute recipient was too low as a result of a payment distribution error that occurred during the payment stage. When incorrect payment distribution information like this is corrected, the amount of the income earner’s taxable income may not be changed compared to the original reports.

Example 26: From 1 November 2021 onwards, an income earner is granted EUR 1,000 as a monthly benefit, of which amount EUR 600 should be paid to a substitute recipient. The income earner has a tax card with a withholding rate of 10%. The deduction type is ‘Recourse on taxable income‘, as a result of which the amount of income subject to tax is EUR 400. An error occurs during the payment, and the income is incorrectly distributed.

Instead of EUR 600, the substitute recipient receives EUR 500. The income earner receives an overpayment of EUR 100. Because of the incorrect payment distribution, the income earner’s taxable income is EUR 500. The benefit payer’s report to the Incomes Register before detecting the error:

Example 26, table 1/3
Record data Values
Date of payment or other report date 02.11.2021
Report data  
Type of action New report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on taxable income
Amount of deduction 500.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (500×10%) 50.00

In December, the substitute recipient requests the missing EUR 100 payment from the payer. The payer immediately corrects the erroneous payment to the substitute recipient in January 2022. The payer can be deemed to have paid the missing EUR 100 to the substitute recipient on behalf of the income earner, in which case a new report needs to be submitted to the Incomes Register. The ‘Payment reallocation – Yes’ entry is added to the payment to tell the data users that it is not a case of a payment made on the basis of a decision to grant a new benefit but the payment or reallocation of a missing payment.

Example 26, table 2/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Payer's report reference 00000002
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 100.00
Payment reallocation Yes
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on taxable income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  

If the report includes ‘Benefit unit’ details, the entry in this report should be ‘0’.

The EUR 100 paid to the substitute recipient is recovered from the income earner and refunded in February. Recovery information is provided for the refunded payment. The ‘Unprompted refund – Yes’ entry is not used for the refund of the overpayment. (In this report, the ‘Original payment date’ entry of the refund report should be 2 November 2021.)

Example 26, table 3/3
Record data Values
Date of payment or other report date 02.02.2022
Report data  
Type of action New report
Payer's report reference 00000003
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 100.00
Recovery Yes
Additional repayment details  
Repayment date 01.02.2022
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021

Example 27: From 1 November 2021 onwards, an income earner is granted EUR 1,000 as a monthly benefit, of which amount EUR 600 should be paid to a substitute recipient. The income earner has a tax card with a withholding rate of 10%. The deduction type is ‘Recourse on tax-exempt income’, as a result of which the amount of income subject to tax is EUR 1,000. An error occurs during the payment, and the income is incorrectly distributed.

Instead of EUR 600, the substitute recipient receives EUR 500. The income earner receives an overpayment of EUR 100. The incorrect distribution of the payment does not affect the amount of the income earner’s taxable income. The benefit payer’s report to the Incomes Register before detecting the error:

Example 27, table 1/3
Record data Values
Date of payment or other report date 02.11.2021
Report data  
Type of action New report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on tax-exempt income
Amount of deduction 500.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (1000x10%) 100.00
In December, the substitute recipient requests the missing EUR 100 payment from the payer. The payer immediately corrects the erroneous payment to the substitute recipient in January 2022. The payer can be deemed to have paid the missing EUR 100 to the substitute recipient on behalf of the income earner, in which case a new report needs to be submitted to the Incomes Register. The ‘Payment reallocation – Yes’ entry is added to the payment to tell the data users that it is not a case of a payment made on the basis of a decision to grant a new benefit but the payment or reallocation of a missing payment. Because the deduction type is a deduction made after tax, the amount of withholding should be added to the gross amount of the report.

Example 27, table 2/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Payer's report reference 00000002
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 111.00
Payment reallocation Yes
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on tax-exempt income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (111×10%) 11.00

If the report includes ‘Benefit unit’ details, the entry in this report should be ‘0’.

The overpayment of EUR 100 paid to the income earner as well as the amount of withheld tax of EUR 11 will be recovered from the income earner and refunded to the payer in February. The recovery information will be reported for the refunded payment. The ‘Unprompted refund – Yes’ entry is not used for the refund of the overpayment. (In this report, the ‘Original payment date’ entry of the refund report should be 2 January 2022.)

Example 27, table 3/3
Record data Values
Date of payment or other report date 02.02.2022
Report data  
Type of action New report
Payer's report reference 00000003
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 100.00
Recovery Yes
Additional repayment details  
Repayment date 01.02.2022
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021

6.4.5 Too much benefit has been paid to a substitute recipient

A payment forwarded to a substitute recipient may be incorrect also in the sense that the substitute recipient receives an overpayment. The unjust enrichment received by the substitute recipient is not reported to the Incomes Register. However, the payment of the missing income paid later to the income earner must be reported to the Incomes Register. Money transfers between the substitute recipient and the payer do not need to be reported to the Incomes Register. When correcting Incomes Register data, the amount of the income earner’s taxable income may not be changed due to the corrections compared to the original reports.

Example 28: From 1 November 2021 onwards, an income earner is granted EUR 1,000 as a monthly benefit, of which amount EUR 400 should be paid to a substitute recipient. The income earner has a tax card with a withholding rate of 10%. The deduction type is ‘Recourse on taxable income‘, as a result of which the amount of income subject to tax is EUR 600. An error occurs during the payment, and the income is incorrectly distributed.

Instead of EUR 400, the substitute recipient receives EUR 500. The income earner will miss EUR 100, and the substitute recipient will receive EUR 100 too much. Because of the incorrect payment distribution, the income earner’s taxable income is EUR 500. The benefit payer’s report to the Incomes Register before detecting the error:

Example 28, table 1/3
Record data Values
Report data  
Type of action New report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit B)
Deduction type Recourse on taxable income
Amount of deduction 500.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (500x10%) 50.00

The income earner requests the missing payment from the payer in December. The payer immediately corrects the incorrect payment. The previously submitted report must be corrected by submitting a replacement report to report the overpayment paid to the substitute recipient. The amount of the deduction will be divided in the next report to the correct amount of deduction (EUR 400) and the overpaid amount (EUR 100). The reported overpayment deduction type is ‘Payment reallocation from taxable income’. 

Example 28, table 2/3
Record data Values
Date of payment or other report date 02.11.2021
Report data  
Type of action Replacement report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit B) 
Deduction type Recourse on taxable income
Amount of deduction 400.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
Deductions  
Deduction income type code (Benefit B)
Deduction type Payment reallocation from taxable
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (500x10%) 50.00
When a missing payment is made to an income earner, a new report must be submitted to the Incomes Register. The report should include the ‘Payment reallocation – Yes’ entry to indicate to the data users that it is a question of a payment of missing income and not a payment based on a decision to grant a new benefit. The refund paid by the substitute recipient will not show in the Incomes Register.

Example 28, table 3/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Payer's report reference 00000002
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 100.00
Payment reallocation Yes
Earnings period  
Start date 01.11.2021
End date 30.11.2021
General income type details  
Income type code Withholding tax
Amount (500x10%) 10.00

If the report includes ‘Benefit unit’ details, the entry in this report should be ‘0’.

Example 29: From 1 November 2021 onwards, an income earner is granted EUR 1,000 as a monthly benefit, of which amount EUR 400 should be paid to a substitute recipient. The income earner has a tax card with a withholding rate of 10%. The deduction type is ‘Recourse on tax-exempt income’, as a result of which the amount of income subject to tax is EUR 1,000. An error occurs during the payment, and the income is incorrectly distributed.

Instead of EUR 400, the substitute recipient receives EUR 500. The income earner will miss EUR 100, and the substitute recipient will receive EUR 100 too much. The incorrect distribution of the payment does not affect the amount of the income earner’s taxable income. The benefit payer’s report to the Incomes Register before detecting the error:

Example 29, table 1/3
Record data Values
Date of payment or other report date 02.11.2021
Report data  
Type of action New report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit B)
Deduction type Recourse on tax-exempt income
Amount of deduction 500.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (1000x10%) 100.00

The income earner requests the missing payment from the payer in December. The payer immediately corrects the incorrect payment. The previously submitted report must be corrected by submitting a replacement report to report the overpayment paid to the substitute recipient. The amount of the deduction will be divided in the next report to the correct amount of deduction (EUR 400) and the overpaid amount (EUR 100). The reported overpayment deduction type is ‘Payment reallocation from net income’. The amount of the income earner’s taxable income remains at EUR 1,000. 

Example 29, table 2/3
Record data Values
Date of payment or other report date 02.11.2021
Report data  
Type of action Replacement report
Payer's report reference 00000001
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 1000.00
Earnings period  
Start date 01.11.2021
End date 30.11.2021
Deductions  
Deduction income type code (Benefit B)
Deduction type Recourse on tax-exempt income
Amount of deduction 400.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
Deductions  
Deduction income type code (Benefit B)
Deduction type Payment reallocation from net income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.11.2021
End date 30.11.2021
Substitute recipient’s details  
Period of calculation  
General income type details  
Income type code Withholding tax
Amount (1000x10%) 100.00

When a missing payment is made to an income earner, a new report must be submitted to the Incomes Register. The report should include the ‘Payment reallocation – Yes’ entry to indicate to the data users that it is a question of a payment of missing income and not a payment based on a decision to grant a new benefit. The report should also include the ‘No effect on taxation – Yes’ entry because the Tax Administration should be notified of the fact that the income has already been taxed. If this information is not provided, the income earner will be taxed twice for the same income. The refund paid by the substitute recipient will not show in the Incomes Register.

Example 29, table 3/3
Record data Values
Date of payment or other report date 02.01.2022
Report data  
Type of action New report
Payer's report reference 00000002
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 100.00
Payment reallocation Yes
No effect on taxation Yes
Earnings period  
Start date 01.11.2021
End date 30.11.2021
If the report includes ‘Benefit unit’ details, the entry in this report should be ‘0’.

6.5 Cancellation of data

If need be, the record or report may be cancelled, that is, removed from the Incomes Register. Cancellation is not made with the same benefits payment report record type as is used when new and replacement benefits payment reports are submitted. Cancellation has been separated into a dedicated schema.

For example, if the type of the record uploaded to the Incomes Register is ‘Cancellation of benefits payment reports’, the following information must be provided in addition to the technical record data:

  • record owner's (payer's) identification details
  • The ‘Payer's report reference’ or ‘Incomes Register report reference’ of the cancelled report

The report's version number may also be provided. The version number is optional supplementary data.

The cancellation record types can be used to cancel, for instance, an individual benefits payment report (record type 107) or the entire record comprising the benefits payment reports (111). Cancellation has been separated into its own schema structure. When a report is cancelled, the previously submitted report is deleted. The deletion is allocated to the correct report on the basis of the Incomes Register's report reference or the payer's report reference. When an entire record is cancelled, the record reference of the record in question is used.

A benefits payment report must always be cancelled when you correct data on which data distribution is based. The following information is used as a basis for distribution (data group in brackets):

  • Date of payment or other report date (Record data)
  • Identifier (Payer’s identifiers)
  • Identifier (Income earner's identifiers)
  • Identifier (Substitute recipient identifiers)
  • Date of birth (Basic income earner details)
  • Start date/End date (Earnings period)
  • Start date/End date (Original earnings period)
  • Start date/End date (Earnings period of original benefit)

The report will also be cancelled in case of so-called refunded money, which is explained in greater detail in the ‘Refunded money’ section of this guide.

6.6 Correcting data by cancelling a previously submitted report

This subsection gives examples of situations where data must be corrected by cancellation. The cancellation method must be used so that data users who have received an incorrect report from the Incomes Register learn when the report is changed.

6.6.1 Correction of a payment date

An incorrect payment date or other reporting date must always be corrected by cancelling the previously submitted report. If other payments made to the same income earner have been reported on the same report, all data on the cancelled report must be resubmitted on one or several new reports and corrected where necessary. This must be done even when some of the reported payments have actually been paid on the reported payment date.

An incorrect payment date is not always caused by inadvertence or oversight. The benefit payer may make a payment and submit a report to the Incomes Register correctly, and yet the payment may be returned from the bank, in which case it will not reach the income earner. In this case, the report should be cancelled. The benefit payer will submit a new report including the new information once the income has been successfully paid.

Example 30: A benefit payer has incorrectly reported that an income earner has received a funeral grant on 22 February 2022, even though in actuality, the income earner did not receive the payment until 25 February 2022. First report before the error is detected:

Example 30, table 1/3
Record data Values
Date of payment or other report date 22.02.2022
Report data  
Type of action New report
Payer's report reference 87250001
Income earner details  
Type of identifier Business ID
Identifier 1231234-9
Company name Morris Mary Death estate
General income type details  
Income type code Funeral grant
Amount 1500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
Insurance information  

The Incomes Register report reference is 2ecf7de328dc464f85b2191d44906076.

Upon noticing the mistake, the benefit payer immediately cancels the incorrect report. The following data is submitted in a cancellation record:

Example 30, table 2/3
Cancellation information  
Record type Cancellation of benefits payment reports
Record owner 1234567-8
Payer's report reference 87250001
Incomes Register report reference 2ecf7de328dc464f85b2191d44906076

The benefit payer then submits a new benefits payment report, repeating all of the data:

Example 30, table 3/3
Record data Values
Date of payment or other report date 25.02.2022
Report data  
Type of action New report
Payer's report reference 87250002
Income earner details  
Type of identifier Business ID
Identifier 1231234-9
Company name Morris Mary Death estate
General income type details  
Income type code Funeral grant
Amount 1500.00
Taxability of benefit Tax-exempt, data according to the act on inheritance and gift tax is given
Insurance information  

6.6.2  Correcting the earnings period

An incorrect earnings period must always be corrected by cancelling the previously submitted report. This applies to the earnings periods submitted in all of the data groups: ‘Earnings period’, ‘Deductions’ and ‘Additional repayment details’. If several payments made to the same income earner have been reported on the report, all data on the report must be resubmitted and corrected where necessary.

Unlike the earnings payment report, the Incomes Register's benefits payment report does not include period data on the entire record. The only data indicating the time of benefit payment that applies to the entire record is "Date of payment or other report date". At report level, the precise earnings period of the type of income paid must be submitted.

Example 31: A benefit payer has reported 22 September 2021 as the end date of the earnings period, although the benefit was actually only paid until 20 September 2021. First report before the error is detected:

Example 31, table 1/3
Record data Values
Date of payment or other report date 02.05.2022
Report data  
Type of action New report
Payer's report reference 1234B05019900
Income earner details  
General income type details  
Income type code Sickness allowance
Amount 1000.00
Earnings period  
Start date 01.09.2021
End date 22.09.2021

The Incomes Register report reference is 2ccf7de328dc464f85b2191d44906086.

Upon noticing the mistake, the benefit payer immediately cancels the income earner’s incorrect report:

Example 31, table 2/3
Cancellation information  
Record type Cancellation of benefits payment reports
Record owner 1234567-8
Payer's report reference 1234B05019900
Incomes Register report reference 2ccf7de328dc464f85b2191d44906086

The benefit payer resubmits a new report including all of the data:

Example 31, table 3/3
Record data Values
Date of payment or other report date 02.05.2022
Report data  
Type of action New report
Payer's report reference 1234B05019901
Income earner details  
General income type details  
Income type code Sickness allowance
Amount 1000.00
Earnings period  
Start date 01.09.2021
End date 20.09.2021

6.6.3 Correcting the benefit payer’s identifiers

If the benefit payer’s identifiers contain an error, all of the reports included in the record must be resubmitted because, in all probability, the incorrect benefit payer identifier is found in all of them. One record must never contain data on payments made by several different benefit payers, such as the payment data of two different customer companies. In the cancellation of an entire record, the item to be cancelled is specified using the payer's record reference or the Incomes Register's record reference rather than report references.

6.6.4 Correction of income earner's identifier or substitute recipient identifiers

An incorrect income earner's identifier or substitute recipient identifier must always be corrected by cancelling the previously submitted report. An income earner may have several identifiers that can be reported. If even one of the submitted identifiers is incorrect, the report must be cancelled and all data on the report must be resubmitted and corrected where necessary.

Example 32: The benefit payer has reported the income earner's Finnish personal identity code and foreign identifier, which is also known. The check character (E) in the foreign identifier is later detected to be incorrect, and the error is corrected.

First report before the error is detected:

Example 32, table 1/3
Record data Values
Date of payment or other report date 01.08.2022
Report data  
Type of action New report
Payer's report reference 33350001A
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner details  
Type of identifier Other identifier
Identifier 12341234E
Country code AR
Last name Fabre
First name Chris
Date of birth dd.mm.yyyy
Gender Male
Street address Country road 2
Postal code 100100
City Santamaria
Country code AR
General income type details  
Income type code Student grant
Amount 300.00

The Incomes Register report reference is 3ecf7de328dc464f85b2191d44944556.

Upon noticing the mistake, the benefit payer cancels the incorrect report:

Example 32, table 2/3
Cancellation information  
Record type Cancellation of benefits payment reports
Record owner 1234567-8
Payer's report reference 33350001A
Incomes Register report reference 3ecf7de328dc464f85b2191d44944556

The benefit payer resubmits a new report including all of the data:

Example 32, table 3/3
Record data Values
Date of payment or other report date 01.08.2022
Report data  
Type of action New report
Payer's report reference 33350001B
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-1234
Income earner details  
Type of identifier Other identifier
Identifier 12341234R
Country code AR
Last name Fabre
First name Chris
Date of birth dd.mm.yyyy
Gender Male
Street address Country road 2
Postal code 100100
City Santamaria
Country code AR
General income type details  
Income type code Student grant
Amount 300.00

6.6.5 Refunded money

Paid income may be refunded by the bank, for instance, because it never reached the income earner. This may occur, for example, if the income has been paid to the wrong recipient, the income earner’s account has been terminated, the income has been calculated in the wrong currency or the income earner has not withdrawn the payment from the bank. If the paid income is refunded, the benefit payer should correct the data so that it corresponds with the realised payment.

In some cases, the bank may deduct transaction fees before returning the payment to the benefit payer.  It is not practical to report the bank charges using the ‘Deductions’ data group data. If the benefit payer writes off the fees charged by the bank as its own losses, the reports can be submitted in accordance with example 33. If the share of the fees charged by the bank is deemed to be the income earner’s taxable income, the reports to the Incomes Register should be corrected in accordance with example 35.

Example 33: An income earner (ddmmyy-123A) has been granted a continuous pension of EUR 1,000 per month. The income earner has a tax card with a withholding rate of 20%. Soon after the payment, the income is returned to the payer by the bank. The reason provided for the refund is that the income earner’s account has been terminated. As the income did not reach the income earner, the benefit payer must correct the Incomes Register data so that it corresponds with the actual situation. Once the benefit payer has received the income earner’s current account number and repaid the income to the income earner, the benefit payer must submit a new report to the Incomes Register.

Report on the first payment prior to the bank’s refund:

Example 33, table 1/3
Record data Values
Date of payment or other report date 04.04.2022
Report data  
Type of action New report
Payer's report reference 50XX00222334
Income earner details  
General income type details  
Income type code Old-age pension
Amount 1000.00
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 200.00

The Incomes Register report reference is 2abc7de328dc464f85g2191h12345678.

The benefit payer cancels the submitted report because the payment never reached the income earner:


Example 33, table 2/3
Cancellation information  
Record type Cancellation of benefits payment reports
Record owner 1234567-8
Payer's report reference 50XX00222334
Incomes Register report reference 2abc7de328dc464f85g2191h12345678
The benefit payer repays the income to the income earner’s current account. In connection with the account number, the income earner has provided the benefit payer with a new tax card (10%). A new report is submitted for the payment including the correct payment date:

Example 33, table 3/3
Record data Values
Report data  
Type of action New report
General income type details  
Income type code Old-age pension
Amount 1000.00
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 100.00

Example 34: An income earner (ddmmyy-123A) has been granted a continuous pension of EUR 1,000 per month. The income earner has a tax card with a withholding rate of 20%. Soon after the payment (4 April 2022), the income earner contacts the benefit payer because the payment has not arrived in the income earner’s account. The benefit payer finds out that a minor typing error had occurred when the account number was entered. The payment has ended up in the wrong person’s account by mistake. Upon discovering the mistake, the benefit payer corrects the Incomes Register data so that it corresponds with the realised payment. The reports of the income earner (ddmmyy-123A) are corrected as per example 33.

If the benefit payer has the details of the incorrect account holder and the incorrect recipient is a natural person, the payment made to said person (ddmmyy-456C) must be reported to the Incomes Register. The payment is reported to the Incomes Register as unjust enrichment and the payment date should be the date when the unjust enrichment was paid.

Example 34, table 1/2
Record data Values
Date of payment or other report date 04.04.2022
Report data  
Type of action New report
Payer's report reference 50XX00454221
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-456C
General income type details  
Income type code Unjust enrichment
Amount 1000.00
Earnings period  
Start date 04.04.2022
End date 04.04.2022

Had tax been withheld in the example case, it should also be reported in the amount collected.

If the payment made to the wrong account remains the benefit payer’s loss, it will not be shown in the Incomes Register in any way. If the account holder of the wrong account is not known, the reports in accordance with example 34 cannot be submitted to the Incomes Register. In the example, the person notices that they have received the unjust enrichment and returns it via the bank in May. The benefit payer is able to process the refund in its own system on 10 May 2022 and submits the following report to the Incomes Register:

Example 34, table 2/2
Record data Values
Date of payment or other report date 10.05.2022
Report data  
Type of action New report
Income earner details  
Type of identifier Personal identity code
Identifier ddmmyy-456C
General income type details  
Income type code Unjust enrichment
Amount 1000.00
Recovery Yes
Additional repayment details  
Repayment date 05.05.2020
Earnings period of original benefit  
Start date 04.04.2022
End date 04.04.2022

Example 35: An income earner has been granted a continuous pension of EUR 1,000 per month and has a 20% tax card. Soon after the payment (4 April 2022), the bank returns the payment because the income earner’s account has been terminated. The bank charges a EUR 50 processing fee. The benefit payer processes the bank’s fees as the income earner’s taxable income, which will be deducted from the repayment made to the income earner later. First report when the bank returns the payment:

Example 35, table 1/4
Record data Values
Date of payment or other report date 04.04.2022
Report data  
Type of action New report
General income type details  
Income type code Old-age pension
Amount 1000.00
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 200.00

The Incomes Register report reference is 2abc7de328dc464f85g2191h87654321.

When the bank returns the payment to the benefit payer, the benefit payer cancels the report submitted. The bank has deducted EUR 50 from the amount as a processing fee.

Example 35, table 2/4
Cancellation information  
Record type Cancellation of benefits payment reports
Record owner 1234567-8
Incomes Register report reference 2abc7de328dc464f85g2191h87654321

The benefit payer processes the refund in its system. Because the benefit payer deems the bank’s processing fee of EUR 50 as being the income earner’s taxable income, a new report will be submitted to the Incomes Register using the original payment date:

Example 35, table 3/4
Record data Values
Date of payment or other report date 04.04.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Old-age pension
Amount 62.50
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 12.50

When the rest of the payment is later made to the income earner, a new report will be submitted to the Incomes Register:

Example 35, table 4/4
Record data Values
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Old-age pension
Amount 937.50
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 187.50

6.7 Returning of withholding to an income earner

If the benefit payer has withheld too much tax from the benefit paid to the income earner, it can return the excess amount to the income earner. The returning of the withholding is reported to the Incomes Register on a new report where the amount of withholding is negative.

The extraneous amount withheld must be returned during the same calendar year. This is because the negative amount of withholding is taken into account in the taxation for the year of the payment date. Therefore, extraneous withholding carried out during the previous year can no longer be returned to the income earner in the next January. If the payer does not return the extraneous withholding during the same year, the extraneous withholding is accredited to the income earner in taxation.

Example 36: The income earner was paid a pension of EUR 1,000 per month for the time period 1 January 2022 – 31 March 2022, totalling EUR 3,000. The income earner did not present a tax card to the payer, so the benefit payer withholds 50%. EUR 500 per month was collected in taxes, totalling EUR 1,500. The income earner provides a tax card, valid retroactively from the start of the year, showing a 10% withholding rate. With the new tax card, the amount of withholding is EUR 100 per month (totalling EUR 300 for the period 1 January – 31 March 2022), so the benefit payer returns the extraneous withholding to the income earner. The amount returned is EUR 1,500 – EUR 300 = EUR 1,200.

Table 1 shows the report for March. The benefit payer has submitted corresponding reports for January and February.

Example 36, table 1/3
Record data Values
Date of payment or other report date 02.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Pension
Amount 1000.00
Earnings period  
Start date 01.03.2022
End date 31.03.2022
General income type details  
Income type code Withholding tax
Amount 500.00
Start date 02.03.2022
End date 02.03.2022

With the new tax card, the extraneous withholding is returned to the income earner. A new report is submitted of the return of the withholding, specifying the amount of the return as a negative number.

Example 36, table 2/3
Record data Values
Date of payment or other report date 16.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Withholding tax
Amount -1200.00
Start date 16.03.2022
End date 16.03.2022

As of April, the withholding is carried out in accordance with the tax card.

Example 36, table 3/3
Record data Values
Date of payment or other report date 01.04.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Pension
Amount 1000.00
Earnings period  
Start date 01.04.2022
End date 30.04.2022
General income type details  
Income type code Withholding tax
Amount 100.00
Start date 01.04.2022
End date 01.04.2022

If a mistake is made in returning the withholding, the data must be corrected in the Incomes Register.

Example 37: The benefit payer returns the extraneous withholding to the income earner. The amount returned is EUR 1,500 – EUR 300 = EUR 1,200.

The benefit payer submits a new report concerning the return of the withholding. However, the payer mistakenly returns EUR 1,500 to the income earner instead of EUR 1,200.

Example 37, table 1/3
Record data Values
Date of payment or other report date 16.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Withholding tax
Amount -1500.00
Start date 16.03.2022
End date 16.03.2022

Once the mistake is detected, it is corrected by submitting a replacement report where the EUR 300 paid in excess by the benefit payer is reported as unjust enrichment.

Example 37, table 2/3
Record data Values
Date of payment or other report date 16.03.2022
Report data  
Type of action Replacement report
Income earner details  
General income type details  
Income type code Unjust enrichment
Amount 300.00
Start date 16.03.2022
End date 16.03.2022
General income type details  
Income type code Withholding tax
Amount -1200.00
Start date 16.03.2022
End date 16.03.2022

Once the income earner has paid back the unjust enrichment, the payer submits a new report of the recovery. In the example, the income earner returned the unjust enrichment on 20 March 2022, but the benefit payer did not manage to allocate it in its system until 23 March 2022.

Example 37, table 3/3
Record data Values
Date of payment or other report date 23.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Unjust enrichment
Amount 300.00
Recovery Yes
Additional repayment details  
Repayment date 20.03.2022
Earnings period of original benefit  
Start date 16.03.2022
End date 16.03.2022

If the returned withholding is distrained, this must be reported to the Incomes Register.

Example 38: The benefit payer returns EUR 1,200 of withholding to the income earner, and EUR 200 is distrained from the return.

Example 38, table 1
Record data Values
Date of payment or other report date 16.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Withholding tax
Amount -1200.00
Start date 16.03.2022
End date 16.03.2022
General income type details  
Income type code Distraint
Amount 200.00
Start date 16.03.2022
End date 16.03.2022

If the returned withholding or part of it is paid to a substitute recipient, the deduction data must be reported to the Incomes Register.

Example 39: EUR 1,200 of withholding is returned to the income earner, with EUR 70 deducted as a YEL collection. Because the deduction does not apply to any income previously reported to the Incomes Register, the income type used for the deduction is the same income type used for the paid income.

Example 39, table 1
Record data Values
Date of payment or other report date 16.03.2022
Report data  
Type of action New report
Income earner details  
General income type details  
Income type code Withholding tax
Amount -1200.00
Start date 16.03.2022
End date 16.03.2022
Deductions  
Deduction income type code Withholding tax
Type of deduction YEL collection
Amount of deduction 70.00
Earnings period of original benefit  
Start date 16.03.2022
End date 16.03.2022
Substitute recipient details  
Period of calculation  
Start date 16.03.2022
End date 16.03.2022

7 Reporting unjust enrichment and recovery

7.1 Reporting an unjust enrichment

In some situations, the income earner is not entitled to a payment made to them and reported to the Incomes Register. A case of unjust enrichment occurs when, for example, a benefit has been granted or paid groundlessly, for example to the wrong person or in an incorrect amount. Unjust enrichment may also occur when the circumstances of the benefit change at a later date. Once the unjust enrichment is detected, the data must be corrected in the Incomes Register without undue delay and in any case no later than within one month of the time when the decision regarding the unjust enrichment is made. When an overpayment is in dispute, the decision on unjust enrichment means the final decision on the adjustment or removal of the benefit.

The unjust enrichment may be recovered from the gross amount of a benefit paid later, or a payment request may be sent to the income earner. The payment can also be recovered from the net amount. There are two different ways of reporting unjust enrichment, depending on whether the income was already reported to the Incomes Register as other income before the error was detected, or whether the payment error was detected before the report was submitted.

If the error is detected before the report is submitted, the separate Unjust enrichment income type is used. This income type is used only when a groundless payment is detected before the first report is submitted, and the income has not been previously reported to the Incomes Register as other income.

Example 40: Due to the benefit payer's error, a pension of EUR 2,500 intended for income earner A has been paid to B (ddmmyy-123B) as a net payment of EUR 2,250. The mistake was noticed on the very next day, before the report had been submitted to the Incomes Register. The benefit payer knows the identity of B but has been unable to recover the income from B. Income earner A receives the pension on the next payment date, with EUR 250 withheld, and the payment is reported to the Incomes Register in the normal manner. However, the benefit payer reports the amount paid to B as follows:

Example 40, table 1
Record data Values
Date of payment or other report date 03.01.2022
Report data  
Type of action New report
Payer's report reference 20XX00161900
Income earner details  
General income type details  
Income type code Unjust enrichment
Amount 2250.00

If it is not just a case of using the wrong account number, but the payment made to an incorrect income earner has been entered into the payment system including the withholding, the withheld amount must also be reported on the incorrect recipient's benefits payment report in the amount collected. However, the payment is often just entered in the name of the actual income earner and paid to them. In such a case, the withholding is reported only on the actual income earner's benefits payment report. Ungrounded payments to legal persons or unidentified parties are not reported on the benefits payment report.

If the unjust enrichment has already been reported to the Incomes Register as other income, the data must be corrected by using the income type specified in the report and the separate ‘Unjust enrichment – Yes’ entry provided in connection with it.

Example 41: EUR 1,100 was paid to income earner C on 15 September 2022. The payment was reported to the Incomes Register as labour market subsidy. However, the benefit payer accidentally paid EUR 550 too much in addition to the normal benefit amount of EUR 550. EUR 275 of tax (25%) was withheld from the payment. The benefit payer submits a report in accordance with the amount of benefit paid and does not notice the mistake before submitting the report.

First report before the error is detected:

Example 41, table 1/2
Record data Values
Date of payment or other report date 15.09.2022
Report data  
Type of action New report
Payer's report reference 20XX00221000
Income earner details  
General income type details  
Income type code Labour market subsidy
Amount 1100.00
Earnings period  
Start date 01.08.2022
End date 31.08.2022
Benefit unit  
Unit Day
Number of units 23
General income type details  
Income type code Withholding tax
Amount 275.00

The error is detected in October. The previously submitted report must be corrected using the replacement method by specifying the overpayment (previously paid and reported to the Incomes Register using the ‘Labour market subsidy’ income type) as unjust enrichment. Because the income has already been reported to the Incomes Register as other income, the ‘Unjust enrichment’ income type is not used; instead, a separate ‘Unjust enrichment – Yes’ entry connected to the income type is made for the previously reported income.

The benefit payer’s replacement report:

Example 41, table 2/2
Record data Values
Date of payment or other report date 15.09.2022
Report data  
Type of action Replacement report
Payer's report reference 20XX00221000
Income earner details  
General income type details  
Income type code Labour market subsidy
Amount 550.00
Earnings period  
Start date 01.08.2022
End date 31.08.2022
Benefit unit  
Unit Day
Number of units 23
General income type details  
Income type code Labour market subsidy
Amount 550.00
Unjust enrichment Yes
Earnings period  
Start date 01.08.2022
End date 31.08.2022
Benefit unit  
Unit Day
Number of units 0
General income type details  
Income type code Withholding tax
Amount 275.00

Based on the submitted data, the income earner's amount of unemployment benefit for August is considered to be EUR 550, and the erroneous overpayment (EUR 550) is regarded as unjust enrichment. Based on the report, the data users learn that the overpayment was previously reported to the Incomes Register as labour market subsidy. In the case of unjust enrichment, the value given at Benefit unit, which is mandatory data for the Unemployment benefit income types, is zero (0) days. The tax withheld from the income earner is reported on a replacement report, stating the actual amount collected from the income earner. 

7.2 General information about the recovery of benefits

When the income earner pays back unjust enrichment or another groundless payment made, this must be reported to the Incomes Register. The procedure is the same if the recovery is conducted so that the payment is offset against a later benefit payment. The recovered amount is not corrected on the original benefits payment report; the recovered amount is reported on a new report and allocated to the payment date on which the income was recovered. The procedure is the same when the payment is returned to the benefit payer, for example, if the employer or spouse pays back the benefit on behalf of the income earner.

There is more information on recovery or offsetting reporting in the ‘Benefits – Recovery and recourse’ instructions.

A recovery report is created by submitting the ‘Recovery – Yes’ entry linked to the income type and the related additional data for the payment date on which the income earner pays the overpayment back or the overpayment is offset against a later benefit payment.

Reporting the ‘Original payment date’ data is not mandatory but, in some cases, it is necessary in order to allocate the income earner’s taxation. Reporting the payment date is particularly necessary in situations where the tax year is changing and the amount recovered should not be taken into account as deducted income in the current tax year, but should be allocated to the correct tax year as a so-called special recovery deduction.

If the income is recovered from the income earner in net, the tax withholding applicable to the amount is reported in the ‘Withholding from the repayment’ section. If the income is recovered from the income earner in gross, the benefit payer should not report the previous tax withholdings submitted for the recovered payment. The previous withholdings are credited to the income earner in taxation.

The ‘Tax at source from the repayment’ data is submitted, if the income is recovered from the income earner in net and the tax at source is deducted from other taxes at source transferred to the Tax Administration. If the income is recovered from the income earner in gross, the benefit payer should not report the previous tax at source exacted from the recovered payment.

Benefits recovered can be reported to the Incomes Register with a precision of one calendar year, when it comes to specifying the start and end dates of the original earnings period. If the original payment date is not specified, the Tax Administration has to use the data on the original earnings period in the adjustment of self-assessed taxes transferred to it. The data submitter may thus lose interest benefit by fulfilling only its minimum reporting obligation.

The recovery data must be submitted no later than on the fifth day after receiving notification of the payment of the recovered amount, the benefit payer and the payment or compensation to which the payment is linked and the recovery has been allocated in the benefit payer’s own system. Of this allocation data, the actual repayment date is reported as the repayment date in the ‘Additional repayment details’ data group.

7.3 Waiving the recovery

Legal sources on the recovery of benefits typically include a provision on the possibility of the benefit granter to waive the recovery either partially or in full in certain situations. When the granter considers waiving the recovery, they take into account, for example, considerations of equity and the income earner's sincere intentions. In addition to the waiving of recovery, there are situations where a decision is made to continue the payment of a benefit of a continuous nature even though the benefit has been found to be groundless. 

If income has been groundlessly paid to an income earner, a report on unjust enrichment must be submitted to the Incomes Register regardless of how the recovery will be carried out or, for example, whether it will be waived in full or in part. In some cases, therefore, more unjust enrichment may be registered as income for an income earner than has been or ever will be recovered from them. If the paying of income continues without a decision granting the benefit, the income is reported to the Incomes Register using the Unjust enrichment income type.

7.4 Benefit recipient's unprompted repayment of benefit

An income earner may repay a received benefit unprompted even if the benefit does to comprise unjust enrichment for the income earner. The repaid benefit will not comprise unjust enrichment for the income earner later. In this case, the benefit payer does not report an ungrounded benefit.

The refunded amount is reported to the Incomes Register using a new report on the basis of the ‘Unprompted refund – Yes’ data and by allocating it to the payment date on which the income was refunded. The ‘Additional repayment details’ data group enables the Tax Administration to correctly allocate the income earner’s taxation. In some cases, the original payment date may be required in order to correctly allocate the income earner’s taxation. These cases are similar to the recovery cases.

In this case, unjust enrichment refers both to a decision made by the process itself regarding unjust enrichment (e.g. a decision to reallocate, change, correct, cancel or remove) and unjust enrichment due to a payment error resulting in an overpayment to the income earner. If an income that was refunded unprompted is later deemed to be unjust enrichment in the benefit payer’s process, the benefit payer must correct the original report by submitting a replacement report in which the ‘Unjust enrichment – Yes’ entry is linked to the paid income type and the ‘Unprompted refund – Yes’ entry is changed to ‘Recovery – Yes’.

The net and gross refunds of the refunded amount are subject to the same regulations and measures as in recovery.

Example 42: A student has been paid a study grant of EUR 320 per month from 1 January 2021 to 31 May 2021. Tax has been withheld from the study grant (10%) in accordance with the tax card submitted by the student (EUR 32/month). The benefit payer has reported the payment on a monthly basis in accordance with the payment date.

On 29 May 2022, the student repays EUR 500 of the study grant in gross allocated to the period 1 January 2021–31 May 2021 (EUR 100/month). The benefit payer allocates the recovery to its payment system on 31 May 2022.

In the past, the benefit payer has submitted reports to the Incomes Register on the study grant paid. The payer does not submit a replacement report on unjust enrichment because the refunded study grant is not processed as unjust enrichment in the benefit payer’s process. Nor is it a question of a payment error (overpayment).

A new report submitted for the repayment:

Example 42, table 1
Record data Values
Date of payment or other report date 31.05.2022
Report data  
Type of action New report
Payer's report reference 20YY00090720
Income earner details  
General income type details  
Income type code Study grant
Amount 500.00
Unprompted refund Yes
Additional repayment details  
Repayment date 29.05.2022
Earnings period of original benefit  
Start date 01.01.2021
End date 31.05.2021

7.5 Reporting the reallocation of a payment that does not affect taxation

The ‘No effect on taxation – Yes’ data is forwarded to the Tax Administration, and it will directly affect the income earner’s taxation. The payer should report this data in two cases:

  • To prevent the same income from being taxed twice: when paying an income that has already previously been reported as taxable income
  • To prevent an ungrounded deduction: when reporting a repaid income that was not originally subject to tax.

The same income may be reported twice as taxable income if an overpayment has been made to a substitute recipient. However, such occurrences are rare. The income is entirely taxable if the substitute recipient’s deduction is reported using any of the following deduction types: ‘Collection of maintenance debt’, ‘Demand for payment (not a recourse situation)’, ‘MATA and MYEL collection’, ‘Other deduction from net income’, ‘Recourse on tax-exempt income’, ‘Recovery of guaranteed student loan debt’ or ‘YEL collection’. All of these deductions are deductions effected after tax. When an income earner is paid an overpayment already paid to a substitute recipient, the payment of the missing income must be reported to the Incomes Register. This duty to report will result in the same income being reported twice. When reporting the payment, the ‘No effect on taxation – Yes’ entry should be added in order to prevent the same income from being taxed twice. There is more information on reporting as well as examples in the ‘Too much benefit paid to a substitute recipient’ section of this guide.

An ungrounded deduction received by the income earner in taxation may occur in rare situations where the benefits payment report is used to report the repayment of the income earner’s income, said income has not been originally taxed and it is not a case of a tax-exempt income type. As a result of recovery or unprompted refund, the benefit payer is refunded for a payment that, when it was paid, had the ‘Recourse on taxable income’, ‘Other deduction from taxable income’ or ‘Deduction of income earner payments’ deduction type. If the ‘Additional repayment details’ data group is used to report refunded income, the data user cannot know whether the refunded income had previously been taxed or not. This is why the payer should use the ‘No effect on taxation – Yes’ entry, so as to make the Tax Administration ignore the recovered amount in the income earner’s taxation.

The subject has also been discussed in the ‘Benefits – Recovery and recourse’ instructions.   

8 Reporting recourse situations to the Incomes Register

8.1 General information about recourse situations

The recovery of a benefit is usually targeted at the recipient. A recourse situation that arises as a result of a right of recourse is different from the other forms of recovery in this respect. In a recourse situation, the benefit payer can receive compensation for a groundlessly paid benefit from another social security institution or private actor, such as an accident, motor or patient insurance company. The right of recourse is regulated, for example, by the provision on the order of payment of substitute recipients laid down in section 123 of the Employees Pensions Act. In recourse situations, the benefit can be offset or collected without the income earner’s consent.

Recourse thus refers to the income earner's entitlement to receive compensation for the same damage or benefit on the same grounds under various legal bases. Generally, the different benefit payers are responsible for the benefits paid under different legal bases. In recourse situations, different benefits are paid simultaneously, and the payer of an earlier benefit is claiming back a benefit that has been detected to be secondary to a later benefit. Instead of the income earner, the recovered amount is paid to the payer of such secondary benefit. For example, when a person who receives a sickness allowance is also entitled to a disability pension for the same period, part of the retroactive disability pension can be has paid to the instance that paid the sickness allowance.

According to the benefits legislation, the payer of a secondary benefit must send an advance notice to the benefit payer granting a primary benefit in order that it can recover the overpayment from the payer of the primary benefit. As a rule, this advance notice will start the recourse process. Based on the advance notice, the payer of the primary benefit will withhold the benefit retroactively, notify the benefit payer that sent the advance notice and continue waiting for the actual recourse claim, i.e. recovery notification. In the recourse claim, the payer of the secondary benefit indicates the overpayment amount.

Data is reported to the Incomes Register on a recourse process on which data users referred to in section 13 of the act on the incomes information system are entitled to receive information. The data is only submitted insofar as the data user needs it for the purposes referred to in the ‘Reporting obligation for benefits payment data’ section of this guide.

Reporting a recourse has been described in greater detail in the ‘Benefits – Recovery and recourse’ instructions.

8.2 Right of recourse situations excluded from reporting to the Incomes Register

Right of recourse situations where no decision regarding the income earner is made, i.e. the income earner is not the concerned party in the decision, are not reported to the Incomes Register. Section 6 of the Incomes Register act states that: 'On the basis of the subsection, such data regarding retrospective payments between insurance institutions in which the income earner is not a concerned party shall not be stored. Such payments between institutions may occur, for example, between insurance institutions providing occupational accident and occupational disease insurances or motor insurances or pension institutions and the party liable for damages in accordance with the rail traffic liability act (raideliikennevastuulaki 113/1999).'

A 'concerned party' refers to a situation in which the income earner is granted a decision regarding a benefit in its entirety, but part of the benefit is paid to another benefit payer. This is a case of a recourse that is reported to the Incomes Register. If a decision regarding the income earner is not made and the whole payment or a part of it is paid to another benefit payer, the income earner is not a concerned party; instead, it may be a case of a right of recourse situation. In situations like this, the payment is not reported to the Incomes Register. If the income earner receives an additional payment subject to a separate decision, the additional payment must be reported to the Incomes Register in accordance with the payment.

Example 43: Vehicles A and B collide. The driver of vehicle A is injured. The liability is split evenly between the insurance companies of the vehicles (A and B).

The insurance company of vehicle A grants and pays full compensation for the personal injuries sustained by the driver of vehicle A.

Because the liability is split evenly, the insurance company (A) will recourse half of the compensation it has paid from the insurance company of vehicle B (B). Such a recourse payment transaction between the companies, where the income earner is not a concerned party in the decision, is not reported to the Incomes Register.

Only the reports on the compensation paid submitted by the insurance company (A) are visible in the Incomes Register.

Example 44: A traffic accident occurs during a commute. A cyclist on the way to/from work is hit by a car and injured. The damages will be covered on the basis of the statutory accident insurance.

The accident insurance company pays and reports the payments to the Incomes Register before the motor insurance company has made a decision regarding compensation to the income earner. The motor insurance company pays the difference in accordance with the benefits of the motor liability insurance act (liikennevakuutuslaki 460/2016) and the accident insurance act (tapaturmavakuutuslaki 608/1948) to the injured party. The accident insurance company will recourse the compensation paid from the motor insurance company. The motor insurance company’s recourse payment to the accident insurance company in no way affects the amount or nature of the benefits paid to the income earner.

When the motor insurer grants a compensation for the difference and makes a decision regarding it to the income earner, the recourse transactions do not show in the Incomes Register. The payments reported by the accident insurance company regarding the whole benefit as well the payments made by the motor insurer for the difference will show in the Incomes Register. On the other hand, payments made by the motor insurer to the accident insurance company on the basis of the right of recourse procedure will not show in the Incomes Register, because the income earner is not a concerned party in them.

From the point of view of the income earner, the income received by the income earner comprises both the accident insurance compensation and the motor insurance compensation.

8.3 Overlapping recourse claims

The payment of the same benefit may be subject to the recourse claims of several different parties. The claim recipient follows the priority order laid down in law and, for example, the payment ban imposed by enforcement authorities, when determining how much of the benefit should be paid to the different substitute recipients. In such a situation, the ‘Deductions’ data group occurs several times in the details of the income type where the payment of the later primary benefit is specified.

Example 45: On 1 September 2021, a person has to be absent from work due to illness, and they receive a sickness allowance from benefit payer A from that day onwards. The payment of the sickness allowance is stopped on 31 December 2021. The person becomes unemployed and starts to receive an unemployment allowance paid by benefit payer B from 1 January 2022 onwards. Furthermore, due to a difficult financial situation, the person receives social assistance from A for the period 1 September 2021–15 February 2022. 

On 19 February 2022, the person is paid a disability pension from 1 September 2021 onwards. However, the pension is subject to recourse claims from benefit payer A (sickness allowance and social assistance) as well as benefit payer B (unemployment allowance). Due to the recourse claims, benefit payer C does not pay the pension for the retroactive period, but starts to pay the continuous pension from 1 March 2022 onwards. For this continuous payment, benefit payer C submits a normal new benefits payment report to the Incomes Register with 1 March 2022 as the payment date.

Later, on 8 March 2022, benefit payer C pays the retrospective disability pension in compliance with the recourse claims received from A and B.

The amount of the person's disability pension is EUR 1,000 a month (index increase not taken into account). The pension for the retroactive period from 1 September 2021 to 28 February 2022 thus totals EUR 6,000. The person has not provided a valid tax card for the retroactive period, so C withholds 50% of the taxable part of the retroactive benefit.

Benefit payer C takes into account the following recourse information:

The pension payment for the period of 1 September 2021–30 September 2021

  • The total pension income is EUR 1,000.
  • A claims a total of EUR 900 in sickness allowance for the period of 1 September 2021–30 September 2021.
  • The part exceeding the sickness allowance claim, EUR 100, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 September 2021 to 30 September 2021. A total of EUR 50 is paid as social assistance compensation after withholding tax.

The pension payment for the period of 1 October 2021–31 October 2021

  • The total pension income is EUR 1,000.
  • A claims a total of EUR 900 in sickness allowance for the period of 1 October 2021–31 October 2021.
  • The part exceeding the sickness allowance claim, EUR 100, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 October 2021 to 31 October 2021. A total of EUR 50 is paid as social assistance compensation after withholding tax.

The pension payment for the period of 1 November 2021–30 November 2021

  • The total pension income is EUR 1,000.
  • A claims a total of EUR 900 in sickness allowance for the period of 1 November 2021–30 November 2021.
  • The part exceeding the sickness allowance claim, EUR 100, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 November 2021 to 30 November 2021. A total of EUR 50 is paid as social assistance compensation after withholding tax.

The pension payment for the period of 1 December 2021–31 December 2021

  • The total pension income is EUR 1,000.
  • A claims a total of EUR 900 in sickness allowance for the period of 1 December 2021–31 December 2021.
  • The part exceeding the sickness allowance claim, EUR 100, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 December 2021 to 31 December 2021. A total of EUR 50 is paid as social assistance compensation after withholding tax.

The pension payment for the period of 1 January 2022–31 January 2022

  • The total pension income is EUR 1,000.
  • B claims a total of EUR 800 in unemployment allowance for the period from 1 January 2022 to 31 January 2022.
  • The part exceeding the unemployment allowance claim, EUR 200, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 January 2022 to 31 January 2022. A total of EUR 100 is paid as social assistance compensation after withholding tax.

The pension payment for the period of 1 February 2022–28 February 2022

  • The total pension income is EUR 1,000.
  • B claims a total of EUR 800 in unemployment allowance for the period from 1 February 2022 to 28 February 2022.
  • The part exceeding the unemployment allowance claim, EUR 200, can be paid as compensation for the social assistance paid by A for the same period, i.e. from 1 February 2022 to 15 February 2022. A total of EUR 100 is paid as social assistance compensation after withholding tax.

Benefit payer C submits the following report on its retroactive payment:

Example 45 table 1/2
Record data Values
Date of payment or other report date 08.03.2022
Report data  
Income earner details  
General income type details  
Income type code Disability pension
Amount 4000.00
One-off remuneration Yes
Earnings period  
Start date 01.09.2021
End date 31.12.2021
Deductions  
Deduction income type code Sickness allowance
Deduction type Recourse on taxable income
Amount of deduction 3600.00
Earnings period of original benefit  
Start date 01.09.2021
End date 31.12.2021
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234567-8
Company name Benefit payer A
Period of calculation  
Start date 01.09.2021
End date 31.12.2021
Deductions  
Deduction income type code Other benefit
Deduction type Recourse from tax-exempt income
Amount of deduction 200.00
Earnings period of original benefit  
Start date 01.09.2021
End date 31.12.2021
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234567-8
Company name Benefit payer A
Period of calculation  
Start date 01.09.2021
End date 31.12.2021
General income type details  
Income type code Disability pension
Amount 2000.00
One-off remuneration Yes
Earnings period  
Start date 01.01.2022
End date 28.02.2022
Deductions  
Deduction income type code Earnings-related allowance
Deduction type Recourse on taxable income
Amount of deduction 1600.00
Earnings period of original benefit  
Start date 01.01.2022
End date 28.02.2022
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234567-9
Company name Benefit payer B
Period of calculation  
Start date 01.01.2022
End date 28.02.2022
Deductions  
Deduction income type code Other benefit
Deduction type Recourse from tax-exempt income
Amount of deduction 200.00
Earnings period of original benefit  
Start date 01.01.2022
End date 15.02.2022
Substitute recipient’s details  
Type of identifier Business ID
Identifier 1234567-8
Company name Benefit payer A
Period of calculation  
Start date 01.01.2022
End date 15.02.2022
General income type details  
Income type code Withholding tax
Amount 400.00

No part of benefit payer C’s payment remains to be paid to the income earner. After the recourse of the taxable sickness allowance and unemployment allowance, EUR 800 remains in the name of the income earner, of which half has been withheld and half recovered as social assistance paid in excess.

If something remains to be paid to the income earner's account after taxes and the instalments paid to substitute recipients, this is not reported on the benefits payment report. The data users themselves must calculate the benefit amount remaining in pocket and the taxable amount on the basis of the Incomes Register data they receive.

The recipients of recourse payments (such as in example 45) must submit replacement reports on those benefits reported to the Incomes Register for which a payment is received from the payer of the primary benefit. All data in the previous report, such as the benefit unit and withholding, remains unchanged. Only a new entry, ‘Recourse – Yes’, is added to the general income type details.

Example 45: (continued) B’s replacement report for February:

Example 45 table 2/2
Record data Values
Date of payment or other report date 01.03.2022
Report data  
Type of action Replacement report
Payer's report reference 01032021AA2
Income earner details  
General income type details  
Income type code Earnings-related allowance
Amount 800.00
Recourse Yes
Earnings period  
Start date 01.02.2022
End date 28.02.2022
Benefit unit  
Unit Day
Number of units 20
General income type details  
Income type code Withholding tax
Amount 160.00

8.4 Consecutive recourse claims

The same income earner may have overlapping benefits occurring during different time periods that are paid during the same time period. The consecutive recourse claims may overlap with other recourse claims, even if they were chronologically separated. Nonetheless, the income earner is only entitled to one benefit at a time. A party who receives a recourse payment on the basis of a recourse claim must always report the ‘Recourse – Yes’ data to apply to the payments received from another party on the basis of the recourse claim. The latter benefit payer must always report the data using the ‘Deductions’ data group so that the data users can utilise the deduction details and take into account the amount of the recourse payment.

Example 46: Benefit payer A has granted an income earner a benefit of EUR 100 for the period of 1 March 2021–31 March 2021. The benefit becomes available to the income earner on 10 March 2021 and is reported to the Incomes Register. Later, benefit payer B also grants the same income earner benefit B of EUR 100 for the same earnings period, paid on 1 June 2021. In reality, nothing is paid to the income earner’s account in June because the entire payment is made to benefit payer A on the basis of the recourse claim. Time passes, and benefit payer C also grants the same income earner benefit C of EUR 100 for the same earnings period, paid on 1 February 2022. In this case, too, nothing is paid to the income earner’s account in reality because the payment is made to benefit payer B on the basis of their recourse claim.

Benefit payer A’s report:

Example 46, table 1/5
Record data Values
Date of payment or other report date 10.03.2021
Report data  
Type of action New report
Payer's report reference A’s report A01
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 100.00
Earnings period  
Start date 01.03.2021
End date 31.03.2021

Benefit payer B’s report including the recourse deductions and benefit payer A’s replacement report on the received recourse payment:

Example 46, table 2/5
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action New report
Payer's report reference B’s report B01
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 100.00
Earnings period  
Start date 01.03.2021
End date 31.03.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on taxable income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.03.2021
End date 31.03.2021
Substitute recipient’s details  
Period of calculation  
Start date 01.03.2021
End date 31.03.2021
Example 46, table 3/5
Record data Values
Date of payment or other report date 10.03.2021
Report data  
Type of action Replacement report
Payer's report reference A’s report A01
Income earner details  
General income type details  
Income type code (Benefit A)
Amount 100.00
Recourse Yes
Earnings period  
Start date 01.03.2021
End date 31.03.2021

Benefit payer C’s report including the recourse deductions and benefit payer B’s replacement report on the received recourse payment:

Example 46, table 4/5
Record data Values
Date of payment or other report date 01.02.2022
Report data  
Type of action New report
Payer's report reference C’s report C01
Income earner details  
General income type details  
Income type code (Benefit C)
Amount 100.00
Earnings period  
Start date 01.03.2021
End date 31.03.2021
Deductions  
Deduction income type code (Benefit B)
Deduction type Recourse on taxable income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.03.2021
End date 31.03.2021
Substitute recipient’s details  
Period of calculation  
Start date 01.03.2021
End date 31.03.2021
Example 46, table 5/5
Record data Values
Date of payment or other report date 01.06.2021
Report data  
Type of action Replacement report
Payer's report reference B’s report B01
Income earner details  
General income type details  
Income type code (Benefit B)
Amount 100.00
Recourse Yes
Earnings period  
Start date 01.03.2021
End date 31.03.2021
Deductions  
Deduction income type code (Benefit A)
Deduction type Recourse on taxable income
Amount of deduction 100.00
Earnings period of original benefit  
Start date 01.03.2021
End date 31.03.2021
Substitute recipient’s details  
Period of calculation  
Start date 01.03.2021
End date 31.03.2021

8.5 Recourse on benefit outside the Incomes Register

A previous benefit referred to in a recourse claim is not found in the Incomes Register if it has been paid before the deployment of the Incomes Register or, for example, if the data is of sensitive nature and has therefore not been reported to the Incomes Register. In these situations, recourse is visible only in the data submitted in the ‘Deductions’ data group by a latter benefit payer. If the Incomes Register's set of income type codes does not include a code for the original benefit, ‘Other benefit’ or ‘Other pension’ can be used as the deduction income type code values in the details of the original benefit.

Reporting a recourse has been described in greater detail in the ‘Benefits – Recovery and recourse’ instructions.

Example 47: On 10 March 2021, an income earner is granted a disability pension from 1 January 2021 onwards. The pension for the period from 1 January to 28 February 2021 is paid to a Swedish party called Försäkringskassan, which has already paid a secondary benefit to the income earner. The recourse provision of the income tax act (tuloverolaki 1535/1992) does not apply to this situation, because the latter benefit payer does not know whether the previous income is taxable in Finland. Thus, the latter benefit payer reports the recourse using the ‘Recourse on tax-exempt income’ deduction type.

The report of the latter benefit payer on the retroactive pension paid to the substitute recipient:

Example 47, table 1
Record data Values
Date of payment or other report date 17.03.2021
Report data  
Income earner details  
General income type details  
Income type code Disability pension
Amount 2400.00
Earnings period  
Start date 01.01.2021
End date 28.02.2021
Deductions  
Deduction income type code Other benefit
Deduction type Recourse on taxable income
Amount of deduction 2000.00
Earnings period of original benefit  
Start date 01.01.2021
End date 28.02.2021
Substitute recipient’s details  
Type of identifier Foreign Business ID
Identifier 202100-0000
Country code SE
Company name Försäkringskassan
Substitute recipient type Foreign institution
Period of calculation  
General income type details  
Income type code Withholding tax
Amount 400.00