Decree on Certain Documents Related to Export Control of Dual-Use Items enters into force
The Decree of the Ministry for Foreign Affairs on Certain Documents Related to Export Control of Dual-Use Items entered into force on 15 April 2026. The decree supplements the Act on the Export Control of Dual-Use Items (500/2024), which entered into force in 2024, and clarifies the reporting and notification obligations for exporters. The provisions of the decree concern reporting on the use of the global export authorisations and the content of the notifications and reports related to the internal compliance programme and the use of the Union general export authorisations.
The decree lightens and harmonises the reporting obligations for exporters using the global and European Union general export authorisations. It supports companies in meeting their obligations by clarifying the EU Regulation's reporting obligations for exporters and provides guidelines on how operators are to notify the Ministry for Foreign Affairs, Finland's licensing authority. In this way, the decree helps the authorities gain a clearer view of Finland's exports of dual-use items.
Reporting requirements for users of the global and European Union general export authorisations
Section 2 of the decree lays down more detailed provisions on the obligation to report on the use of the global and Union general export authorisations.
Exporters who use a global export authorisation must report on its use to the Ministry for Foreign Affairs annually. If the total value of the user’s exports and transfers during the previous calendar year is less than EUR 5,000,000, the user needs only to notify the Ministry that the total value of exports and transfers has not been exceeded.
The reporting obligation applies to users of the European Union general export authorisations when the total value of the user’s exports and transfers of dual-use items during the previous calendar year exceeds EUR 5,000,000. By excluding smaller exports from the reporting obligation, the decree seeks to reduce the administrative burden, particularly for small and medium‑sized operators.
The reports must be submitted to the Ministry for Foreign Affairs no later than 1 April each year, using either the Ministry’s reporting template (in Finnish) or the exporter's own template. The reports can be submitted via the security email service to [email protected]. Earlier in the spring of 2026, the Export Control Unit contacted operators it had identified as potentially subject to the reporting obligation with a request for reporting for 2025.
Minimum requirements for the internal compliance programme
Section 3 of the decree specifies the minimum content of the Internal Compliance Programme (ICP), which is required of exporters using the global export authorisations. The purpose of the ICP is to ensure that exporters have in place appropriate procedures to facilitate compliance with export control provisions. The decree defines the minimum requirements for the programme, but operators retain discretionary powers regarding the structure and contents of the programme.
Procedure for notifying the use of the European Union general export authorisations remains unchanged
The procedure for notifying the use of the European Union general export authorisations is specified in section 4 of the decree. The current practice of notifying and keeping registers of the use of the general export authorisations will remain unchanged. Exporters must notify, among other information, the Ministry for Foreign Affairs of the general export authorisation’s number and the user’s contact details when the authorisation is used for the first time. The notification is submitted via the Ministry’s e-services.
The decree only applies to the EU general export authorisations, not to the national general export authorisations.
No new obligations
The decree issued by the Ministry for Foreign Affairs does not impose any new substantive obligations for exporters; rather, it clarifies existing obligations under EU regulation and national legislation. The aim is to improve predictability and the operator’s legal certainty and to streamline official processes.
In addition, the harmonisation of reported information supports Finland’s annual reporting to the EU and provides a clearer overall picture of Finland's exports of dual-use items.