FinlandVero
Payment providers can appeal CESOP penalties in 60 days
Payment providers gain a stated appeal route: a written claim to the tax adjustment board within 60 days of the penalty decision.
By Taxxa AI OyPublished 3 November 2026
Payment service providers in the EU have had a disclosure duty for cross-border payment transactions since 1 January 2024, aimed at reducing VAT fraud in international e-commerce and securing fair competition. The duty implements the change to the EU Payment Data Directive (EU 2020/284). A provider means a payment or credit institution generally licensed for the activity, such as a bank, as well as an electronic-money issuer and a postal company with a universal-service obligation.
The duty covers cross-border payments where the payer is in an EU state and the payee in another EU state or outside the EU, with locations identified by IBAN or another equivalent identifier. Providers report on the payment services they offer in Finland and keep the data in electronic form for three years after the year in which the payment is dated. The payee provider reports where it is in the EU, otherwise the payer provider reports. Reported data include the payee name, the payee IBAN or other identifier, the BIC of the provider acting for the payee, and payment data such as amount and time, plus the provider own identifying BIC or other code such as the Business ID.
Reports are filed in Ilmoitin.fi or via an interface as a file based on the CESOP XML schema. Submission needs electronic authentication, and interface filing also needs a certificate. After filing the provider receives feedback on compliance, a deficient report is re-filed, and Verohallinto may also contact the provider directly on corrections.
Reports are quarterly, due within one month after the quarter ends, with no extension available: January-March by 30 April, April-June by 31 July, July-September by 31 October and October-December by 31 January. Data are reported only where more than 25 cross-border payments to the same payee occur in Finland during the quarter. Breaches for several quarters in one year can draw separate penalties per quarterly return. If the due date falls on a Saturday, Sunday or another public holiday, the report must reach Verohallinto on the next business day.
Neglect of the duty can lead to a third-party negligence penalty, graded by seriousness up to 15,000 euro, with a separate penalty possible for neglect of the retention duty. Under 22 a § of the laki verotusmenettelystä (VML, 1558/1995) the tiers run to 2,000 euro for minor remediable defects, 5,000 euro for substantially deficient or post-prompt filings and 15,000 euro for intentionally or grossly negligently false or missing filings, imposed in full hundreds with a 100 euro minimum and taking data volume into account. For provider reporting breaches the tables run from 200 to 5,000 euro by transaction count or euro value per quarter, with mitigation for justified reason and increase for repeated breaches. The penalty is not deductible and unpaid penalties accrue delay interest. Before imposition the person facing the penalty is always heard, and the penalty is imposed by separate decision.
A provider may seek change to the penalty decisionVero. Change is sought from the tax adjustment board (verotuksen oikaisulautakunta)
Vero by written claim, to be made within 60 days
Vero of the provider receiving notice of the decision
Vero. The Tax Recipients' Legal Services Unit has 60 days from the making of the decision, and the claim is delivered to Verohallinto in time.
The rules are stated in Verohallinto guidance CESOP-ilmoittaminen, with penalty practice in Sivullisilmoittajan laiminlyöntimaksu maksupalveluntarjoajien rajat ylittävistä maksuista.
If assessed a CESOP negligence penalty, file a written claim to the tax adjustment board within 60 days of receiving the decision.