Observations from the Finnish FDI Authority’s Annual Report 2025, with Reflections on the Upcoming FDI Reform

Authors: Riikka Kuha, Mikko Huimala, Niko Haarahiltunen, Niko Ojala, Niilo Melkas Read time: 3 min

Finland’s FDI screening regime is currently undergoing significant reform, with preparations ongoing and a draft government proposal anticipated shortly. Entry into force of the new regime is currently targeted for early 2027.

Against this backdrop, the recently published Finnish FDI Authority’s annual report for 2025 provides a useful snapshot of the current framework in practice, giving rise to three observations:

1. Increase in filing activity. The number of new filings rose from 31 in 2024 to 41 in 2025 (approx. +32%), though the regime continues to capture a relatively limited share of the 234 foreign acquisitions recorded in Finland. Inadmissibility filings (i.e. requests for formal confirmation that a transaction falls outside the regime) doubled to 12 in 2025 (from 6 in 2024, +100%), suggesting increased use of the process to obtain upfront certainty in borderline cases. As in previous years, no formal prohibition decisions were adopted. This is consistent with broader European practice where outright prohibitions remain rare and more sensitive cases are typically addressed through conditions or do not proceed to a formal decision stage.

2. Lengthening of review periods. Average review periods increased from approximately 8 weeks in 2024 to approximately 10 weeks in 2025, representing an increase of around 22%. This may in part reflect the absence of statutory review deadlines for the majority of cases, as well as a variation in the complexity of individual filings.

3. Stable geographic distribution of applicants. Sweden remained the top filing jurisdiction in 2025 with 6 filings, followed by the United States, the United Kingdom, and Norway (4 each), based on the country of the ultimate controller. A similar concentration was observed in 2024, when Sweden and the United States were the most common jurisdictions (4 each).

Certain Key Elements of the Upcoming Finnish FDI Reform Expected to Affect the Above Trends

Three of the proposed reform elements are particularly relevant in light of the trends observed above.

1. Number of filings. The reform proposes to broaden the scope of the regime through the inclusion of additional sectors and, for specified critical sectors, also greenfield investments. Illustrative examples of newly covered greenfield activities include, for instance, port and airport infrastructure, certain data centers with a potential capacity of at least 100 MW, and EU strategic raw materials in mining and processing projects. The broadened scope is expected to translate into a notable increase in mandatory filings.

2. Procedural timelines. The reform is expected to introduce a more structured two-phase review process, with a statutory 45-day timeline for Phase I review. This is expected to enhance predictability for investors, particularly where transactions do not raise substantive concerns. No fixed Phase II timeline is proposed.

3. Origin of applicants. The reform proposes to remove the current EU/EFTA carve-out, under which investors domiciled in EU or EFTA states are largely excluded from mandatory prior authorisation outside the defence sector. If adopted, this would bring a materially wider range of EU and EFTA-based investors within scope, with likely consequences for the geographic distribution of applicants.

The Finnish reform is substantially driven by the new EU FDI Regulation, adopted by the European Parliament on 19 May 2026 and currently awaiting formal Council approval before entering into force.