Reporting data to the Incomes Register: employer’s separate report

This instruction is intended for payers. It describes:

• the cases in which the employer's separate report must be submitted;
• when and how it is submitted;
• what information is reported; and
• the cases in which a household must submit the employer’s separate report. 

These instructions replace the earlier instructions titled Reporting data to the Incomes Register: employer’s separate report. The texts in these instructions have been clarified. These instructions are similar in outline to the earlier instructions.

1 About the employer’s separate report

Employers and other payers use the earnings payment report to submit almost all earnings payment data to the Incomes Register. If necessary, the payer also uses the employer’s separate report to submit data that does not concern an individual income earner.

The payer uses the employer’s separate report to submit:

• the total amount of employer's health insurance contribution calculated based on the wages paid during the month in question and any deductions from that amount; and the
• No wages payable data item, if the payer is registered with the Tax Administration’s Employer Register and has made no wage payments during the month in question.

While the payer must submit an earnings payment report for each income earner, only one employer’s separate report is required per payer. The employer must therefore submit at least two reports to the Incomes Register for each month in which wages were paid: an earnings payment report and the employer's separate report. Only one employer’s separate report can be submitted for each relevant month.

Employers must pay and report the employer’s health insurance contribution on their own initiative. Such data is reported to the Incomes Register on a monthly basis. Further information on paying the employer's health insurance contribution and the payment deadlines is provided on the Tax Administration’s website at vero.fi.

For taxation purposes, an employer is considered either as a regular or casual employer. This determines when and what kind of data is submitted using the employer’s separate report. There are specific requirements concerning a household’s obligation to submit the employer's separate report, which are described later in chapter 6.

The Income earner is a person or business to whom a contribution is paid.

Temporary employer and contract employer are concepts used by earnings-related pension providers, describing whether or not the payer has taken out a pension insurance policy from an earnings-related pension provider.

• Temporary employers pay no more than EUR 8,346 in wages over a period of six months (in 2018) and do not have any permanent employees. Temporary employers do not have a valid pension insurance policy with an earnings-related pension provider.

• Employers who have permanent employees or pay more than EUR 8,346 in wages over a period of six months (in 2018) must take out a pension insurance policy from an earnings-related pension provider. In such a case, the employer becomes a contract employer.

The concepts of casual employer and regular employer are related to the Tax Administration’s employer registration.

• Regular employers pay the wages of two or more employees, or pay the wages of six or more employees simultaneously, even though their employment contracts were temporary and intended for a short period of time. Employers who pay wages regularly must register with the Tax Administration’s Employer Register before they begin wage payments. A regular employer must submit the employer's separate report to the Incomes Register for each month.

• Casual employers have only one employee over the tax year, or alternatively no more than five employees whose employment contract is not intended to continue for the full calendar year. Employers who pay wages casually do not have to register with the Employer Register. Casual employers are only obliged to submit the employer’s separate report to the Incomes Register for the months in which they pay wages  or reimbursement of expenses.

However, casual employers may register with the Employer Register voluntarily. If they do so, they will be considered equivalent to regular employers and must submit the employer's separate report each month.

Maintained by the Finnish Tax Administration, the Employer Register is a public register of employers who pay wages regularly. Provisions on the Employer Register are given in the Prepayment Act. Further information on employers who pay wages regularly or casually is provided on the Finnish Tax Administration’s website at vero.fi.

Household employer is, for the purposes of this instruction, a natural person or an estate that pays wages that are unrelated to the trade or other activities carried out by the household to earn income. A household employer can be a casual or regular employer. More information on a household’s reporting obligation is described in the instruction Reporting data to the Incomes Register: households as employers.

2 Who submits the employer’s separate report?

Regular employers must submit the employer’s separate report for each month, including when they have made no wage payments.

Casual employers submit the employer’s separate report only for the wage payment months, i.e. for the months when they must also submit an earnings payment report for each income earner. Casual employers do not have to submit the employer’s separate report for the months when they do not pay wages or reimbursement of expenses.

Households that are sporadic employers must submit the employer’s separate report for the wage payment months only when they pay the same income earner more than EUR 1,500 in total over a calendar year. If a household employer pays an income earner EUR 1,500 or less over a calendar year, it does not have to pay the employer’s health insurance contribution or submit the employer’s separate report. For more information, see chapter 6 When does a household submit the employer's separate report?

3 When and how is the report submitted?

The employer’s separate report is submitted electronically. It can be submitted directly to the Incomes Register from the payroll system, via the technical interface. The report can also be submitted via the Income Register’s e-service, either by uploading it as a file or entering the data from each individual report into an online form. Alternatively, the report can be submitted at Palkka.fi.

Data can be submitted in paper format only in special circumstances. Special circumstances can be regarded as situations in which the electronic submission of the data could not reasonably be required, such as when a natural person, estate, casual employer or foreigner does not have the possibility to submit data electronically. 

The employer's separate report is submitted monthly, no later than on the fifth day of the calendar month following the payment month. If the report deadline is a regular Saturday or holiday, the data can be reported on the following banking day. If the separate report is submitted exceptionally in paper format, it must be submitted no later than on the eight day of the calendar month following the wage payment month.

Employers who cancel their registration with the Employer Register must submit their final employer’s separate report for the wage payment month during which the registration was cancelled. A report must be submitted, even if wages were not paid during that month.

4 What kind of data is reported?

The following data must be included in the employer’s separate report:

• details of the payer, contact person, date of reporting and the reporting period;
• technical information on the record if the data is submitted via the technical interface or by uploading it as a file via the e-service;
• employer’s health insurance contribution in total, if wages have been paid;
• any deductions made from the total amount of the health insurance contribution; and
• the No wages payable data item if wages have not been paid and the payer is a regular employer.

If the report contains the No wages payable data item, it must also include:

• information on the payer’s earnings-related pension insurance (pension policy number and earnings-related pension provider code); and
• information on the payer’s occupational accident insurance policies (occupational accident insurance company identifier and policy number), if the payer has more than one valid occupational accident insurance policy.

4.1 Reporting period

The period for which the data is reported is identified in the report. Reporting period data comprises the calendar month and the year.

The No wages payable data item can be reported for six months ahead. The reported payment year can therefore be the current or the next year.

The employer’s health insurance contribution in total and any deductions made from the employer’s health insurance contribution can be reported for no more than one month before the beginning of the reporting period. For example, data for March can be reported no earlier than on 1 February.

4.2 No wages payable data item

Employers registered with the Tax Administration's Employer Register, i.e. regular employers, who do not make any wage payments over the month in question, must include the No wages payable data item in the employer’s separate report.

This data is submitted only when the employer has not made any payments whatsoever during the month in question. For example, if the employer has paid only tax-free reimbursements of expenses, such as tax-free kilometre allowances, the No wages payable data item is not submitted. The amount of health insurance contribution given in the separate report is EUR 0.

The No wages payable data item is submitted separately for each such month during which the payer has not paid any wages. The data can be reported in advance for six calendar months, if it is known that there is no intention of paying wages over the next six months. However, if wage payments are nevertheless made during this period, the correct data must be submitted using a replacement report for the wage payment month.

When the report includes the No wages payable data item, information must also be submitted on the payer’s earnings-related pension policy and the occupational accident insurance policy. Based on this information, the Incomes Register can notify the earnings-related pension providers and accident insurance pension providers that the payer does not have any wage payments for that month.

A casual employer who does not make any wage payments over a month does not have to submit the employer’s separate report or the No wages payable data item for that month.

The No wages payable data item cannot be submitted separately for each suborganisation.

4.3 Employer's health insurance contribution (total)

Because the employer's health insurance contribution is a self-assessed tax, the employer must calculate and report the total amount for this using the employer’s separate report. The employer will calculate the employer's health insurance contribution based on the wage payments the employer has made over the month, and submit it using the employer’s separate report under Employer's health insurance contribution (total). The total amount of wages is not reported in this section.

If, based on the wages and other payments made, it is not necessary to pay the employer's health insurance contribution for a certain month, the employer should enter EUR 0 under Employer's health insurance contribution (total). For example, if the employer has only paid tax-free reimbursements of expenses over the month, the employer should enter EUR 0 under the Employer’s health insurance contribution (total).

If all income the employer submits for the month using the earnings payment reports is not subject to earnings-related pension insurance contribution, the employer does not have to include the earnings-related pension provider code or pension policy number in the report. However, because income has been paid, this is not a case of No wages payable.

The deductions reported under the 'Deductions to be made from the employer's health insurance contribution' income type are not deducted from the total amount of the employer's health insurance contribution. The amount of the employer’s health insurance contribution must therefore be given in full. Any deductions made from the employer’s health insurance contribution are reported under a different income type.

The actual employer also reports and pays the employer’s health insurance contributions for any wages that a substitute payer has paid and for which the substitute payer has withheld tax. Any wages paid by the substitute payer are taken into account in the amount of the employer’s health insurance contribution for the month when the substitute payer paid the wages. For further instructions, see Reporting data to the Incomes Register: payments made by substitute payer.

4.4 Deductions to be made from the employer’s health insurance contribution

Under certain conditions, the employer may be reimbursed for the employer’s health insurance contribution. Such a situation may arise if the employer has made a wage payment to an employee while having been paid a statutory pension, daily allowance or a benefit compensating for the loss of the income granted to the employee. The employer is entitled to claim back the employer’s health insurance contribution from the Tax Administration up to the amount corresponding to the payment made to the employer.

The payer must use the employer’s separate report to submit the deduction to be made from the employer's health insurance contribution under Deductions to be made from the employer's health insurance contribution. The amount is submitted in the separate report for the month when the deduction was made. The employer's health insurance contributions for the month will then be reduced and the Tax Administration will refund the excess amount to the employer with interest.

Example: Based on the wage payment made in May 2010, the employer has received a daily allowance benefit for February 2021. The employer submits a replacement employer’s separate report for May 2020, including both the deductions under Deductions to be made from the employer's health insurance contribution and the previously submitted Employer's health insurance contribution (total).

The payer may also make the deduction during the current pay period, i.e. when the payer is notified of the benefit decision. The amount of the health insurance contribution for the current period will then be reduced, but the payer will not receive the compensatory interest that would have been paid if the deduction had been paid in arrears for the original period. 

5 How is the employer’s separate report corrected?

The data in the employer's separate report is corrected in the same way as the earnings payment data submitted to the Incomes Register. For more information on this, see Correcting data in the Incomes Register, especially chapter 7 Correcting an employer's separate report.

The instruction also explains how data can be corrected when the income earner was not entitled to a payment that was made and submitted earlier to the Incomes Register (Correcting data in the Incomes Register, section 3.1 Unjust enrichment). In most cases, an unjust enrichment is notified by submitting a replacement report. This supersedes the original earnings payment report, for the payment date, which was used to submit the income to the Incomes Register. An employer’s separate report submitted for the wage payment month in question must also be corrected by submitting a replacement report, because the unjust enrichment is not subject to the employer’s health insurance contribution.

In certain situations, the replacement procedure cannot be used, but the employer's separate report must be cancelled and a new report submitted with the correct data.

The data must be corrected by cancelling the previous report and then submitting a new one in the following situations:

• correction of the reporting period;
• correction of the payer's customer identifiers;
• correction of the pension provider code or pension policy number; and
• correction of the occupational accident insurance company identifier or policy number.

6 When does a household submit the employer’s separate report?

A household employer does not have to collect the tax to be prepaid or pay the employer’s health insurance contribution, if the wages paid to an income earner do not exceed EUR 1,500 during the calendar year and the payment is unrelated to the payer’s trade or other income-earning activities. To ensure that a household that is a casual employer does not have to submit empty (EUR 0) employer's separate reports when it does not to have to pay the employer's health insurance contribution, the same EUR 1,500 threshold is applied to the household reporting procedure.

If the wage payments a household employer makes to an income earner come to EUR 1,500 or less over a calendar year, the household employer does not have to pay the employer’s health insurance contribution or submit the employer’s separate report.

Example: A household employer has made a wage payment of EUR 200 to a childminder in March. The household has not paid the same childminder any wages before and estimates that, over the calendar year, the childminder's wages will come to no more than EUR 1,000. The household submits an earnings payment report for March for the amount of wages paid. The household does not pay the employer's health insurance contribution and does not therefore have to submit the employer’s separate report for March.

However, if – during the first wage payment month – the household already knows that it will go over the annual threshold of EUR 1,500, the household must withhold tax and pay the employer's health insurance contribution based on the wage payments, starting from the first payment month. The household must submit the employer's separate report for each wage payment month.

The estimated amount of wages may change during the year. If the household estimated that the wages paid to the income earner would be no more than EUR 1,500 per year, the household has not had to withhold tax or pay the employer's health insurance contributions.

However, if the annual wage payments come to more than EUR 1,500, the household must withhold tax from the month when the EUR 1,500 is exceeded. The household does not have to withhold tax in arrears for wages paid earlier. However, the employer’s health insurance contribution must be paid for the total amount of wages paid over the year.

The household can use the employer’s separate report to submit the full amount of the employer's health insurance contribution payable for the total wages paid over the year. The household must submit the separate report for the month when the annual threshold of EUR 1,500 was exceeded. The household does not have to pay any penalties for submitting the full amount of the employer's health insurance contribution at this stage.

Example: A household employer makes a wage payment of EUR 400 to a childminder in November. As the earlier wages the household has paid to the childminder came to EUR 1,200, the November payment goes over the threshold of EUR 1,500. The household submits an earnings payment report for November, reporting the amount of wages paid (EUR 400) and the tax withheld. The household submits an employer’s separate report for November, reporting the full amount of the employer's health insurance contribution, based on the EUR 1,600, under Employer's health insurance contribution (total). The household does not have to submit the employer’s separate report for the earlier months when it made wage payments to the childminder. The household pays the full amount of the employer's health insurance contribution by 12 December. Further information on paying the employer's health insurance contribution and the payment deadlines is provided on the Tax Administration’s website at vero.fi. The household submits the employer's separate report to the Incomes Register by the fifth day of the calendar month following the payment month.