The Finnish government introduced a resolution 11 September 2020 on a new operating model to manage COVID-19-related border traffic restrictions. The government is increasing the limit value for the incidence of COVID-19 as of 19 September, to lift border traffic restrictions on entry from countries with fewer than 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days. The government also adopted a decision on continuing internal Schengen border checks and amended other restrictions on border traffic, which will enter into force on 19 September and continue at least until 18 October.
On 11 September 2020, the Finnish government introduced a resolution on a new operating model to manage COVID-19-related cross-border travel restrictions.1 In the resolution, the government increased the limit value for the incidence of COVID-19, such that as of 19 September, border travel restrictions on entry will be lifted from countries with fewer than 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days. The new operating model will be introduced in stages and will require urgent legislative amendments. Additional amendments to internal and external cross-border travel restrictions will be introduced as of 19 September.
The government also adopted a decision on continuing internal Schengen border checks and amended other restrictions on border traffic, which will enter into force on 19 September and continue at least until 18 October.2
The travel restrictions have had a considerable impact on travellers and employees moving between Finland and other countries. Finland’s travel restrictions have been some of the tightest in Europe. The government believes that the new operating model will make it possible for different sectors of the economy to operate more freely than at present.
On 11 September, the government also announced further amendments to border traffic restrictions concerning Finland’s internal Schengen as well as external Schengen borders. Starting 19 September, restrictions on entry will be lifted for travel between Finland and Cyprus, Germany, Iceland, Norway, Poland and Sweden, as well as for residents of Australia, Canada and Japan who are travelling from their home country to Finland. The lifting of restrictions means that recreational travel to Finland is permitted for people from these countries.
Restrictions on entry into the country will be reintroduced between Finland and Italy and Hungary since the incidence of new COVID-19 outbreaks in those countries exceeds 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days. When entry into the country is restricted, recreational travel (except leisure boating) to Finland from these and other “higher incidence” countries is not permitted.
For all other countries, previous restrictions on entry remain in force for now. (For prior coverage, see GMS Flash Alert 2020-369, 25 August 2020). The authorities will review the list of countries weekly and update it as a necessary.
At the internal Schengen borders, restrictions on entry only allow return traffic to Finland, transit traffic, work-related travel and travel for other essential reasons. At the external Schengen borders, restrictions on entry only allow return traffic to Finland and other European Union (EU) and Schengen countries, transit travel at Helsinki Airport and other essential travel. Those travelling for work-related reasons or for essential reasons may be asked to present documents to verify that the entry requirements are fulfilled.
Travellers arriving in Finland from countries that are subject to restrictions on entry are subject to a 14-day self-quarantine. Everyone living in or visiting Finland has a joint responsibility to make sure that the COVID-19 epidemic does not accelerate uncontrollably. Travellers arriving in Finland may also be directed to a voluntary COVID-19 test at an airport or port. Based on a risk assessment, if deemed necessary, a doctor may place a person in quarantine. (For prior coverage, see GMS Flash Alert 2020-357, 18 August 2020.)
As of 19 September, border traffic restrictions on entry will be lifted from those EU and Schengen countries with fewer than 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days. This new limit value will also apply to the United Kingdom. Until the resolution, the limit value had been 8 per 100,000 inhabitants during the previous 14 days. (For prior coverage, see GMS Flash Alert 2020-369 ,25 August 2020.)
The government plans to categorise countries that have more than 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days as countries with a higher incidence of COVID-19.
The new operating model will eventually move to a testing-based operating model, meaning that travellers coming from countries with more than 25 COVID-19 infections per 100,000 inhabitants during the previous 14 days, will need to have a negative COVID-19 test prior to arriving in Finland.
Introducing the testing-based operating model will require urgent legislative amendments, along with an increase in testing capacity and reallocation of testing resources, and other measures to help ensure health security upon entry. Prior testing will be considered a prerequisite for entry from countries with higher incidence rates as soon as the relevant legislative amendment has entered into force.
Further instructions regarding the new operating model are expected in the forthcoming weeks as the authorities work on the implementation plan, which is likely to be introduced in stages.
The government aims to introduce the new testing-based model on 23 November 2020. The transition period for the new model begins on 1 October 2020.3
During the transition period, prior testing is likely to be required for certain travellers. Those travellers will need to present a certificate of a negative coronavirus test taken less than 72 hours prior to arrival.
In addition, residents of Finland returning from countries with higher incidence rates may shorten their period of self-quarantine by taking a test as soon as they arrive in Finland, followed by a second test after 72 hours. This aims to ease the conditions for work-related travel.
Internal Schengen border controls are expected to continue until a new testing-based approach is introduced on 23 November.
The government also issued a notice explaining that certain special groups, such as representatives of culture, sports and business, may be permitted entry due to justifiable reasons.4 These reasons are likely to include carrying out necessary tasks to secure the recovery, new growth or long-term operating conditions of certain sectors. The Finnish Border Guard is supposed to provide further detailed instructions related to entry applications for special groups very soon.
The KPMG International member firm in Finland continues to monitor these matters closely, and more information is expected to be received in the forthcoming weeks as the authorities further clarify the newly-introduced operating model.
1 11 September 2020 Finnish Government press release (in English): “Government adopts resolution on implementing the hybrid strategy for border traffic and travel .”
2 11 September 2020 Ministry of the Interior press release (in English): “Restrictions on entry into the country to be amended due to COVID-19 .”
3 See the Finnish Border Guard press release (14 September 2020) (in English), "Restrictions on border traffic change on 19 September - a new operating model will be introduced in November."
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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