On 11 June, the Finnish government outlined the rules for the new restriction period.¹  As of 15 June, the statutory restrictions on border traffic are lifted for travel to Finland from six adjacent countries, including Norway, Denmark, Iceland, Estonia, Latvia and Lithuania. Schengen internal border traffic from other than these six countries, as well as Schengen external border traffic, will continue to be restricted until 14 July 2020. The official decision concerning the new rules was taken by the government in its plenary session on 12 June.

The decision is part of the government's hybrid strategy with the aim of gradually lifting restrictions based on continuous monitoring of the COVID-19 epidemiological situation, while also taking social and economic aspects into consideration.

Cross-border traffic will be primarily facilitated between countries with similar epidemiological situations. The government will review the situation for the Schengen internal borders in two weeks' time. EU-level coordination of the measures is considered important.

The restrictions on entry since late March 2020 have had a considerable impact on mobile employees moving between Finland and other countries. The companies and organisations have previously been used to free movement especially across Schengen internal borders and therefore the introduction of COVID-19-related measures has disrupted the normal mobility of workforce in the Schengen area in a dramatic manner.

The decision by the government to lift cross-border traffic restrictions across Schengen internal borders for employment or commission-related travel in May already allowed companies bringing workforce from other Schengen countries. The further abolishment of border control from Norway, Denmark, Iceland, Estonia, Latvia and Lithuania starting 15 June allows tourism, but also exempts the employment-based travellers from these countries from presenting documentation at the border on their reasons for travel.

As travel from the neighbouring countries Sweden and Russia continues to be restricted, the situation remains challenging for many who are used to moving regularly between Finland and either of the two neighbours. Sweden being a Schengen country, travel is possible based on employment or commission, but in the north-western border between Finland and Sweden, people are – in normal conditions – used to travelling across the border in a daily manner without border controls being in place. The Finnish government has expressed its understanding of these challenges in travel that happens between Sweden and Finland. For the government the aim is to enable unrestricted travel from Sweden to Finland as quickly as the epidemiological situation allows.

The extension of border controls for Schengen external borders until 14 July may be concerning for many companies and organisations that have planned assignments and contracts with employees arriving from outside EU and Schengen countries. There is still no information on the schedule for opening up of Finnish missions for receiving residence permit applications, and therefore the planning of start dates for employment in Finland has become challenging for many companies inviting third-country nationals to join their teams.²

As of 15 June, travel to Finland is possible for the following groups of travellers:

• Finnish nationals and their family members;
• Nationals of EU and Schengen countries residing in Finland and their family members;
• Travel from Norway, Denmark, Iceland, Estonia, Latvia and Lithuania;
• Travel across other Schengen internal borders and from the United Kingdom for employment or commission-related commuting;
• Third-country nationals who have a valid residence permit granted by the Finnish authorities;
• Essential travel to work and other essential traffic.

When it comes to the travel across the Schengen internal borders for employment or commission-related commuting, the authorities have instructed that they will check the purpose and the conditions of the planned employment or commission in the context of the border inspection. For example, the border authorities may ask the traveller to present documents to prove he or she meets the entry requirements. Such documents may include proof of an employment contract or a commission.³

Other essential traffic may now, for example, include a family reason, a personal reason, or travel to a property, private residence or holiday residence in Finland. 

Starting 15 June, self-isolation is recommended for all those arriving in Finland who come from countries that are still subject to internal or external border control. Self-isolation is not required if the person arrives from Estonia, Latvia, Lithuania, Norway, Denmark or Iceland. The content of the 14-day period of self-isolation, as instructed by the Finnish Institute for Health and Welfare, will not change. Under self-isolation, the person is permitted to move between his or her work-place and place of residence. Other essential travel is also allowed.

The Finnish government announced the first decisions to restrict the country’s borders due to the spread of COVID-19 on 16 March (see previous coverage GMS Flash Alert 2020-076 (19 March 2020)). The first announcement covered the initial period of 19 March until 13 April. Further tightening and extension of the restrictions for traffic across Finland’s borders were announced on 7 April 2020 (see GMS Flash Alert 2020-179 (17 April 2020)) and the restrictions were at the time prolonged until 13 May. As for the necessary traffic, the list of critical occupations introduced by The Ministry of Economic Affairs and Employment was also adopted on 7 April.⁴ The tasks listed are characterised as critical to the security of the supply chain or for the specific industry.

Furthermore, on 7 May, the Finnish government decided on the gradual lifting of restrictions on border traffic (see GMS Flash Alert 2020-222 (7 May 2020)). As of 14 May, the statutory restrictions on border traffic were lifted in cross-border traffic across the Schengen internal borders by allowing employment or commission-related commuting and other essential traffic. Border controls were, at the time, extended for all internal and external borders until 14 June.

The KPMG International member firm in Finland continues to monitor these matters closely, as further instructions can be expected from the authorities in the forthcoming days to clarify the newly-introduced measures.

1  11 June government news release: Restrictions on local tourism will be partially dismantled, restrictions at external borders remain unchanged (in English). 12 June government news release: Government decided on restrictions on border traffic starting from 15 June.  

2  Ministry for Foreign Affairs of Finland Press Release: Finland suspends the reception and processing of ordinary visa and residence permit applications in the missions.

3  Border authorities guidelines for border traffic from 15 June 2020.

4  The list and assessment of essential tasks set by The Ministry of Economic Affairs and Employment (in English). Employer’s justification for the necessity of an employee entering the country during the state of emergency: PDF form (in English and Finnish).

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*  Please note that KPMG LLP (U.S.) does not offer immigration services or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

The information contained in this newsletter was submitted by the KPMG International member firm in Finland.

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