Digital tags are not automatically part of the audit

Digital financial-statement reporting extends to sustainability reporting companies from 2026Tilintarkastajat, and the digital tags do not automatically become part of the statutory auditTilintarkastajat. The extension rests on the Accounting Act's digital-reporting provisions (KPL 7 luku 22–25 §) and the Patentti- ja rekisterihallitus decision on registering digital accounts. Auditors, audit firms and the finance teams of reporting companies should separate the registration duty from the assurance duty when scoping engagements.

The registration duty starts with financial periods beginning on or after 1 January 2026Tilintarkastajat. Companies that become sustainability reporting companies on or after 1 July 2026 join from the financial periods beginning on or after that dateTilintarkastajat. The same digital requirements also reach companies that draw up the Accounting Act sustainability report voluntarily, so a voluntary reporter faces the same registration mechanics as a mandatory one.

Registration does not mean assurance.Tilintarkastajat An auditor's tasks are set by legislation and the engagement agreement with the client. Current legislation does not oblige the auditor to audit or assure the digital tags in a company's digital accounts where the digital accounts are a copy of the official accounts signed by managementTilintarkastajat: the tags are then part of the technical presentation of the copy. This matches the content of government proposal HE 96/2026 and the amendments parliament approved in its reply EV 140/2026; the amendments are expected to be confirmed at the presidential presentation on 27 November 2026Tilintarkastajat.

A file that is not the management-signed official accounts does not become an automatic audit object for that reason either. The audit does, however, assess as part of the governance audit whether the company complied with the registration duties imposed on it.Tilintarkastajat Assessing compliance with the registration duty does not mean checking or assuring the correctness of the digital identifiers.Tilintarkastajat

The two clocks run differently, which matters for engagement timing. The accounts must be prepared under the Accounting Act within four months of the end of the financial period (KPL 3 luku 6 §)Tilintarkastajat, while digital registration for limited companies must be completed no later than eight months after the end of the financial periodTilintarkastajat. Assurance work planned around the preparation deadline therefore cannot assume the registered digital file exists yet.

Listed ESEF group accounts are the exception. Group accounts under the ESEF regime are governed separately by the Securities Markets ActTilintarkastajat, which also provides for the audit or assurance of group accounts drawn up under that regime (7 luku 8 § 4 mom.)Finlex. That regime does not extend to the digital tags on the parent-company figures of listed sustainability reporting companiesTilintarkastajat: an assurance duty for those tags would require separate legislation of the kind enacted for ESEF accounts.

Legal basis: Kirjanpitolaki 7 luku 22–25 § on digital reporting duties, 3 luku 6 § on the preparation deadline, and the Patentti- ja rekisterihallitus registration decision, applied alongside Arvopaperimarkkinalaki 7 luku 8 § 4 momentti on ESEF group accounts.