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      On 5 September 2025, the Finnish Immigration Service (Maahanmuuttovirasto or “Migri”) announced a review of its policy concerning the types of travel documents accepted for residence permit applications.1  The review responds to recent developments and feedback regarding the practical challenges faced by applicants who hold alternative travel documents, such as alien passports, refugee travel documents, or who are stateless.

      Following its reassessment, on 3 October 2025, Migri has adopted a new interpretation regarding what constitutes a “national travel document”.2  According to the agency, a national travel document under the “Aliens Act” (Ulkomaalaislaki) must be technically reliable and originate from the individual’s country of nationality.  This means that the issuing state must recognise the individual as its citizen based on its own laws.  However, the “Citizenship Act” (Kansalaisuuslaki) does not require that the state itself be officially recognised for a person to be regarded as a citizen of that state.    

      WHY THIS MATTERS

      The new interpretation enables certain individuals to apply for a residence permit in Finland without having to worry about their application’s auto refusal for not meeting the “valid travel document” requirement.  For instance, because of the new interpretation, Migri now considers travel documents issued by the Palestinian Authority as acceptable travel documents.  However, passports issued by Hamas in Gaza remain excluded.  

      Context

      With this change, Migri’s objective is to protect the rights of foreign nationals from being restricted more than necessary, while maintaining the integrity of the identity verification processes.  The agency also stated that the primary objective of the legislation is to strengthen reliable identification of applicants, rather than to exclude individuals due to technical interpretations of their nationality status.3

      More Details

      This reassessment follows concerns raised by the Ministry for Foreign Affairs and the Ministry of the Interior after legislative changes introduced in September 2024 tightened the requirements for residence permits, requiring applicants to hold a valid national travel document.  The earlier interpretation excluded stateless individuals, including Palestinians, from meeting this requirement, as they were not recognised as holding a “national” passport.4

      KPMG INSIGHTS

      Migri’s policy review broadens the scope of acceptable documents while maintaining compliance with existing legislation.

      KPMG Finland estimates that these changes may reduce the number of negative decisions and appeals.  This change is also expected to have a positive impact on employers by reducing administrative uncertainty in residence permit processes for individuals holding Palestinian Authority travel documents.

      Additionally, Palestinian nationals who applied for a residence permit with their Palestinian passport and received a negative decision during the period 1 September 2024 to September 2025, can now reach out to Migri for a re-evaluation of their residence permit application.5  

      FOOTNOTES:

      1  Maahanmuuttovirasto/Migrationsverket/Finnish Immigration Service (in English), “Finnish Immigration Service to review its policy on which travel documents can be accepted for a residence permit application,” (published on 5.9.2025) (also available in Swedish and Finnish at the noted link).

      2  Maahanmuuttovirasto/Migrationsverket/Finnish Immigration Service (in English), “Determination of citizenship status and definition of national travel document for residence permit applications reviewed by Finnish Immigration Service” (3.10.20205) (also available in Swedish and Finnish at the noted link).

      3  Ibid.

      4  Maahanmuuttovirasto/Migrationsverket/Finnish Immigration Service (in English), “Information about stricter requirements for issuing residence permits” (30.8.2024) (also available in Swedish and Finnish at the noted link).

      5  Maahanmuuttovirasto/Migrationsverket/Finnish Immigration Service (in English), “Finnish Immigration Service accepts passports issued by Palestinian Authority for residence permit applications” (3.10.2025) (also available in Swedish and Finnish at the noted link).    

      Contacts

      karoliina-nurmi
      Karoliina Nurmi

      Director

      KPMG in Finland

      Minna Pekkanen
      Minna Pekkanen

      Manager

      KPMG in Finland

      Alex Lehtinen
      Alex Lehtinen

      Global Mobility Advisor

      KPMG in Finland

      More Information

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      Disclaimer

      * Please note the KPMG International member firm in the United States does not provide immigration 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.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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