Substitute-payer reporting for 2027: TyEL threshold rises to €10,638

Employers with no permanent staff cross into TyEL insurance duty for 2027 at a higher payroll figure. A contract employer (sopimustyönantaja) — one holding a TyEL policy with a pension provider — must take the policy where it has at least one permanent employee or pays its fixed-term employees at least 10,638 euros over six monthsVero; below that, with no permanent staff, it may operate as a temporary employer (tilapäinen työnantaja). The 2026 figure was 10,272 euros.Vero The guidance sets the contract-employer line at 10,638 euros for 2027Vero, and the official table of TyEL euro amounts lists 10,638.00 euros for TyEL 147 § 1 momentti at the 2027 wage coefficient of 1.773.

Substitute payers pick up a new mandatory flag for nonresident recipients. Where the recipient is subject to limited tax liability, the substitute payer must report "Rajoitetusti verovelvollinen: Kyllä" in the recipient data of the pay reportVero, because the income and the withholding assessed on it flow into the recipient's taxation from the substitute payer's filing. That filing carries the tax-relevant recipient data and additional data; the income types for substitute-payer situations stay as before.

Occupation data harden on the actual employer's report. The actual employer must state the occupation classification and occupation class (ammattiluokitus ja ammattiluokka) wherever the recipient carries statutory occupational-accident insuranceVero, and insurance exception-type data are reported where the payer has no duty to insure. Where the actual employer must report pay-transparency data, the employment-relationship data behind it turn mandatory rather than recommended; otherwise the recommendation stands to file employment data, absences and income earning periods on the employer's own report.

The bankruptcy examples are reworked around the notice-period question. A corrected example covers the "roikkolomautus" case where the employee resigns after a layoff of at least 200 days: KEHA-keskus files the wage-guarantee payment with income type 208 (irtisanomisajan korvaus), the compensation is outside social insurance, and the estate files no actual-employer pay report for it while the separate employer report goes under the estate's identifier. Two new examples split the dismissal-during-layoff case: with no work duty during the notice period the same 208 treatment applies, while a dismissed employee called back to work is paid under normal wage types such as 201 (aikapalkka), the wage is subject to social insurance, and the estate files the actual-employer pay report with the substitute-payer income types plus the separate employer report under the estate identifier.

Smaller reporting points change with the same validity date. Where the substitute payer has paid wages more than once in a month, the actual employer may report any one of that month's pay dates as long as the report lands on the right pay month, or file a separate pay report for each payment. Kela private-care-support cases now point to the household-as-client guidance (chapter 5, Kotitalous ja yksityisen hoidon tuki) for the family member's employer duties, and payers correcting data after a recipient's appeal are pointed to the correction guidance's appeal procedure. The reissued guidance applies from 1 January 2027VeroVero until further notice. Legal basis: TyEL 147 §, applied through Vero guidance Tietojen ilmoittaminen tulorekisteriin: sijaismaksajan maksamat suoritukset.