Finland to significantly tighten its FDI screening regime

Finland is preparing a major overhaul of its foreign direct investment (FDI) screening framework to more effectively address risks to national security, security of supply, and undue foreign influence. The reform aims to respond to the changed geopolitical environment and rapid technological developments. In addition to national objectives the reform will implement the EU’s new Screening Regulation. The new regime is expected to enter into force in early 2027.

While the preparations of the government proposal are still ongoing the following provides a summary of the main proposed changes which have been presented by the Ministry of Economic Affairs and Employment in a stakeholder consultation event in late March 2026.

In brief (what you need to know):

• All non-Finnish investors would need to apply for a prior approval when making an investment which exceeds any of the thresholds in the relevant sectors, whether to an existing company or a greenfield investment.
• The scope would be expanded and defined more explicitly.
• Additional thresholds are proposed: 10%, 33.3%, 50%, 66.6% and 90%.
• The review would be two-phased: (i) initial review (45 days) and (ii) in-depth review (no statutory deadline).
• Enforcement would shift to administrative sanctions (up to EUR 10 million or 10% global turnover for undertakings).
• Timeline: stakeholder comments planned April 2026; Government Proposal expected September 2026; entry into force planned early 2027.

1 Significantly expanded and more explicit scope 

The planned new FDI act ─ expected to be formally proposed in autumn 2026 ─ would replace the current Act on the Screening of Foreign Corporate Acquisitions (2012). 

The new FDI act would aim to address situations where a genuine and sufficiently serious threat exists to a fundamental interest of society, including cases where the effects concern the security of another EU Member State.

While the main principles of the current FDI act would remain, the new FDI act would more precisely define the sectors and activities subject to monitoring. In practice, this would (i) codify critical targets already monitored and (ii) bring certain additional industries into the regime where significant security implications may arise.

Monitored entities would include those that:

1. Defence: produce or supply, or intend to produce or supply, defence equipment or other products or services important to military national defence or the Finnish defence industry;
2. Dual-use: produce, develop, or utilise dual-use items subject to export controls;
3. Key Security Authorities: provide critical products or services to key security authorities related to societal security for the performance of their statutory tasks;
4. Confidential information: have products or services involving access to classified, security-classified, or otherwise nationally sensitive information;
5. ICT: produce or supply ICT or information security products or services relevant to national security, security of supply, or overall societal security;
6. Security of supply: are involved in ensuring security of supply, critical infrastructure, or other vital societal functions or services; and
7. EU Screening Regulation categories: fall within the categories required under the EU Screening Regulation (e.g., certain critical technologies such as semiconductors, quantum technologies, and specific AI solutions; key functions of transport, energy, or digital infrastructure; strategic raw materials value chains; actors critical to the financial and payment system; and IT systems designed for electoral processes).

The new FDI act would also bring certain greenfield investments (new businesses established in Finland) into scope in specified critical areas, including:

• defence projects,
• port and airport infrastructure, certain logistics terminals, qualifying data centres (≥100 MW), qualifying energy infrastructure projects (≥100 MW), and strategic raw materials (mining/refining).
• defence sector projects
• production or development of dual-use goods
• construction and maintenance of port infrastructure as well as operation and cargo handling services of ports
• construction and maintenance of airport infrastructure and ground handling services
• establishment of a logistic terminal in the field of business relevant for the security of supply or serving the needs of national defence and the defence industry
• data centres with a potential capacity of at least 100 MW intended to carry out activities that are listed in subsections 4-7 in section 3 of the new FDI act  
• energy infrastructure projects with a production capacity of at least 100 MW, covering baseload and balancing power in the electricity system, renewable energy production, hydrogen projects, and electricity grid operations
• mining and refining projects related to the EU’s strategic raw materials.

2 Mandatory filings and a broader definition of foreign investor

A key proposed change is the introduction of a mandatory pre‑closing permit requirement for all covered monitored entities, replacing the current partly voluntary notification system. 

The definition of a “foreign investor” would include:

1. natural persons who are not Finnish citizens, who have no citizenship, whose citizenship is unknown, or whose citizenship cannot be reliably verified; and
2. (ii) enterprises, business units, or other entities domiciled outside Finland (with the current EU/EFTA carve‑out removed); Finnish entities subject to foreign influence—typically at or above 10% of voting rights or equivalent de facto influence; and other investment structures in which a foreign investor holds at least 10% of voting rights or equivalent de facto influence.

“Foreign investment” would mean any measure taken directly or indirectly by a foreign investor to establish direct links with the investment target for the purpose of carrying out economic activities in Finland which is a broader concept than the current definition of corporate acquisition.

3 Additional ownership thresholds and a two‑phase review process

Ownership and de facto influence thresholds would be set at 10%, 33.3%, 50%, 66.6%, and 90% (with 66.6% and 90% being new). The authority could also require a filing in cases where influence increases without crossing a threshold. 

The review process would consist of two phases:

• Initial review by the National Emergency Supply Agency (45‑day deadline), and
• In‑depth review, where necessary, led by the Ministry of Economic Affairs and Employment (no statutory deadline).

Cases with significant implications could be escalated to a plenary session of the Government. Permit decisions could include conditions, as under the current regime. The plenary session of the Government could decide not to grant a permit or to restrict foreign ownership. 

4 Enforcement and sanctions

Investments made intentionally or negligently without a required permit could be subject to an administrative penalty fee, replacing the current criminal sanctions. The maximum penalty for undertakings would be EUR 10 million or 10% of the foreign investor’s global turnover for the preceding financial year, whichever is higher (and up to EUR 0,5million for natural persons). This increases the importance of early screening assessment and compliance controls. 

If an investment requiring a permit is completed without one, the investment could be declared invalid if the authority has requested a permit application within a set period and none has been submitted. The Ministry would determine the measures required to unwind the investment. 

5 Timeline

A request for stakeholder comments with a draft Government Proposal is planned for April 2026. The Government Proposal is expected to be submitted to Parliament in September 2026 as part of the budget legislative package. Entry into force is planned for early 2027. 

The suggested reform is expected to increase the number of authorisation applications considerably. We would be happy to discuss how the proposed FDI reform may affect your contemplated investments or transactions in the future, while continuing to monitor the legislative process closely.

Get in touch to discuss how the proposed FDI reform may affect your business.