Finland's procurement data repository: what the open public-purchasing database means for suppliers

The procurement data repository (hankintatietovaranto) is a national data repository maintained by the State Treasury (Valtiokonttori). It will hold public procurement and purchasing data across the whole lifecycle of a procurement: contract notices from Hilma, tender documents with annexes, bid data from e-tendering systems and the purchase invoices of public bodies. The Government submitted Bill HE 230/2026 to Parliament on 8 October 2026, and the acts are intended to enter into force on 1 January 2027. The reform implements the Orpo Government Programme and the Hankinta-Suomi programme.

The need is well documented. Finnish public bodies buy goods and services for about EUR 38 billion a year, and almost EUR 50 billion including in-house entities. About EUR 15 billion of this is bought without competitive tendering. According to the Ministry of Finance, up to 60 per cent of tenders attract no more than two bids. Today the data is scattered: central government invoices sit in the Tutkihankintoja.fi service, around 65 per cent of municipalities publish invoice data on their own websites in incompatible formats, and tender documents disappear from e-tendering systems once a competition closes.

The new act changes this in three ways. First, invoice data must be delivered to the State Treasury without a separate request, and its public parts are published centrally on Tutkihallintoa.fi. Second, the State Treasury gains the right to collect tender documents and bid data directly from contracting authorities and e-tendering system vendors. Third, the Public Procurement Act is amended so that the State Treasury can prescribe which data must be filled in on Hilma notices. For suppliers this is the largest opening of procurement data since Hilma itself was created.

The bill's own estimates put annual savings at EUR 25–33 million through fewer direct awards and more competition. Hansel, the central purchasing body, called the savings theoretical and the administrative burden real. The Federation of Finnish Enterprises and the Confederation of Finnish Industries (EK) welcomed the reform as a public-spending transparency reform that opens markets, especially for SMEs.

The bill is a budget bill handled together with the 2027 state budget. The obligation to deliver invoice data starts in stages by invoice date, because central government agencies already have a working data pipeline through Tutkihankintoja.fi, while municipal and wellbeing-county finance systems need changes. The state compensates municipalities and wellbeing services counties for the system changes, estimated at about EUR 10 million.

The dates in the table come from the Government Bill. Parliament may change them, and we will update this guide when the committee report is published.

Section 3 of the proposed act gives the State Treasury a broad right to information: a contracting authority and its e-tendering system vendor must hand over, free of charge, tender documents with annexes and bid data, including the bidders, total and unit prices of bids, quality scores, ranking in the comparison and the winning bid. This covers all procurements under the Public Procurement Act and the Utilities Procurement Act, except security-classified ones.

Collecting and publishing are two different things. Under section 2, bid data and invoice product-line data received by the State Treasury are confidential as a category, without case-by-case assessment. The rationale notes that they contain trade secrets such as pricing structures, unit prices and technical know-how. Confidentiality in the repository does not extend confidentiality at the contracting authority: a party to the procedure still requests tender documents from the contracting authority under the Act on the Openness of Government Activities, as today.

Section 8 defines what is published. The State Treasury may publish online the procurement notice data and the header and accounting lines of purchase invoices, to the extent they are not confidential. In practice the web service will show which contracting authority bought, from whom, for what amount, when, under which accounting category, and the tender identifier that links the invoice to the Hilma notice. A sole trader's name and business ID are published; if the supplier is a natural person without a business ID, the name is withheld. Personal data can only be searched one record at a time.

The bill's business impact assessment (section 4.2.1.1) describes the supplier benefits directly. The first is contract expiry monitoring. When an invoice carries a tender identifier, the published data shows which tender a contracting authority is buying under, who supplies and how much. Combined with the contract period in the award notice, a supplier can estimate when a contract ends and a new tender is likely.

The second is analysis of lost tenders. According to the bill, expanding the content of contract and award notices and opening tender documents lets a company identify patterns in competitions it has previously lost. If the State Treasury prescribes that award notices list all bidders and attach the award decision, competitors' participation and the authority's reasoning become readable without a separate document request.

The third is assessing the state of competition by sector and region. The repository shows how many bids tenders typically attract and where authorities buy without tendering. The bill expects companies to expand into regions where competition has been weak. The fourth is market intelligence without your own market analysis: there is currently no comprehensive source on national-threshold tenders other than taking part, and an open data service levels this information advantage between large and small companies.

All four benefits concern past purchases and closed competitions. The repository is a source of market data, not a notice channel. New tenders are still published on Hilma and e-tendering platforms, and they still have to be spotted in time.

The core of the repository is the tender identifier (kilpailutustunniste), which links a purchase invoice to the competition published on Hilma. The identifier is generated in Hilma when a notice is published, without any action by the contracting authority. Under section 4(2) of the proposed act, the invoice data a contracting authority delivers to the State Treasury must include the tender identifier where one exists. The obligation rests on the contracting authority, but in practice the easiest way to get the identifier onto the invoice is through the supplier.

According to State Treasury guidance, contracting authorities ask their suppliers to add the identifier to invoices relating to contracts tendered under the Public Procurement Act or the Utilities Procurement Act. In an e-invoice the identifier travels in the TenderReference field of the Finvoice 3.0 format, and Peppol BIS 3 invoices have an equivalent field. The identifier can be carried from the purchase order, or the authority can ask for it to be added to the invoice separately. The authority can also ask for a confidentiality marking on invoices containing information that is confidential under section 24 of the Openness Act.

The act imposes no direct duty on suppliers to add the identifier. In practice contracting authorities will require it in contract terms and purchase orders, because their own reporting depends on it. The key finding of the State Treasury's municipal pilot was precisely that suppliers do not add the requested identifiers to invoices. The scale is large: by Kuntaliitto's estimate the identifier would need to be added to about 250,000 central government invoices, about one million wellbeing-county invoices and about two million municipal invoices each year.

Accountants and invoicing staff should check three things before 2027: whether the invoicing system or e-invoice operator can populate the TenderReference field per invoice, how public-sector contracts and their tender identifiers are stored in the customer register, and who adds the confidentiality marking when an authority requests one. The State Treasury publishes the invoice data taxonomies and content descriptions on avoindata.fi.

Alongside the repository act, the bill amends section 60(6) of the Public Procurement Act, adds a new subsection 4 to section 101, and makes a matching change to section 64 of the Utilities Procurement Act. Notices published on Hilma must contain the mandatory data defined in the Hilma service, and the State Treasury may issue regulations on the data to be reported in a procurement procedure, the forms used and the content and publication of notices. This covers both EU-threshold and national procurements.

According to the bill's rationale, a regulation could require, for example, that a contract award notice lists the bidders and attaches the award decision and its reasoning memorandum. This is a possibility, not yet a decision: before issuing a regulation the State Treasury must assess its effect on published data together with an expert group of security authorities. If the regulation is issued, the change for suppliers is significant. Today an award notice gives the winner, the contract value and the number of bids; in future it would show who took part, why the winner was chosen and on what grounds the others lost.

The change builds on the Public Procurement Act amendment in force since 18 June 2026, under which an award notice must be published for national-threshold procurements within 30 days of contract signature. Hilma also reminds contracting authorities of missing award notices. Together these mean that from 2027 tender outcomes will be available more completely and faster than ever, linked through the tender identifier to actual purchases.

Finnish public bodies buy about EUR 15 billion a year without competitive tendering. Some of this is lawful direct awards, some is below-threshold small purchases, and some is purchases from in-house entities that an authority may use without tendering. The repository shows these purchases for the first time in the same dataset as tendered procurements, because invoices are collected regardless of whether the purchase was tendered. Minister Ikonen stated at the bill's launch that invoice collection has no lower euro limit.

For suppliers this is a new source of information in two situations. If a contracting authority repeatedly buys large volumes without tendering in goods or services your company supplies, the data can open a market dialogue and support the case for a tender. If an above-EU-threshold direct award has been published as a direct award notice, an appeal to the Market Court must be filed within 14 days of the notice. Invoice data does not extend the appeal period, but it helps identify the authorities whose practices are worth monitoring.

The bill acknowledges a gap. In-house entities' sales to their owners appear in the owners' invoices, but the in-house entities' own purchase invoices are not collected, so their untendered purchases remain hidden. On 8 October 2026 the Federation of Finnish Enterprises and EK demanded that the system be developed to include in-house entities' invoices, noting that Parliament had already required this in June. The act allows voluntary data delivery from 1 January 2029.

Central government purchase invoices are currently published on Tutkihankintoja.fi, maintained by Hansel: supplier name, invoice amount, date and purchasing category. The service is technically dated and does not cover municipalities or wellbeing services counties beyond individual datasets uploaded to avoindata.fi. The publication channel for the repository is the State Treasury's Tutkihallintoa.fi, which already presents public-sector finance, staffing and procurement data in Finnish, Swedish and English.

The public procurement section of Tutkihallintoa.fi is initially based on Hilma notice data and accounting data: procurement spend in euros, share of competitive tendering, state of competition by sector and sustainability in procurement. A development version opened in August 2026 at beta.tutkihallintoa.fi, and the renewed service launches in November 2026. Invoice data is planned to be added from autumn 2027. The service has an API section for downloading datasets, and under the bill the State Treasury is responsible for opening technical interfaces.

Section 11 of the proposed act contains a reservation suppliers should know about: on the recommendation of the security expert group, strong authentication may be introduced for using the published content, in which case the State Treasury would keep a user and access log. Open data may therefore not be fully anonymous to use if the risk assessment so requires.

After the consultation round, several changes were made to the bill to safeguard security. Under section 5, central government information classified at security level I, II or III must not be delivered to the repository at all, and level IV information may be withheld at the provider's discretion. The Defence Forces, the Border Guard, the Security Intelligence Service, the National Police Board, the National Bureau of Investigation, police departments, Customs and Defence Properties Finland may additionally withhold invoice data that is confidential under section 24 of the Openness Act, for example data concerning national defence and crime prevention.

Under section 10, the State Treasury appoints an expert group of security authorities to assess the risks the repository and its published data pose to national security and critical infrastructure. A risk assessment is also required before the State Treasury issues regulations on Hilma notice content. For a defence and security supplier this means that its public deliveries appear in the repository like everyone else's, but confidential procurements and procurements under the Act on Public Defence and Security Procurement largely stay outside the published data.

On 9 September 2026 the European Commission proposed a new Public Procurement Act that would require every Member State to set up a national public procurement data space (Article 134) collecting notices and procurement data across the lifecycle. The Government Bill refers to the proposal and notes that Hilma notice data is already available in structured form through open APIs. The procurement data repository is in effect Finland's national data space before the regulation requires one.

The Federation of Finnish Enterprises and EK demanded that the national solution be built to meet EU requirements directly, so that companies do not face duplicate reporting. For suppliers the direction is the same in both: procurement data becomes structured, tender identifiers become standard, and tender outcomes become machine-readable. We cover this development in more depth in our guide to the EU Public Procurement Act.

Make invoicing ready. Find out whether your invoicing system or e-invoice operator can populate the Finvoice 3.0 TenderReference field per invoice, and agree with your accountant where the tender identifier for each public-sector customer comes from. Record identifiers in the customer register alongside the contract.

Mark trade secrets in bids correctly. The repository does not publish bid data, but the contracting authority still assesses the openness of your bid when documents are requested. Identify trade secrets specifically, and do not mark the whole bid confidential, since the total price is public in any case.

Build your own contract calendar. Compile your sector's contracts and their estimated end dates from award notices. From 2027 you can supplement the calendar with repository invoice data and see who currently supplies each contracting authority.

Monitor award notices and direct award notices systematically. If the State Treasury prescribes bidder data and the award decision in award notices, you will learn from lost tenders without document requests. The appeal period for a direct award notice is 14 days, so monitoring cannot be monthly.

Automate monitoring of new tenders. The repository and Tutkihallintoa.fi tell you what was bought. Spotting the next tender in time remains the supplier's own responsibility, and that is exactly what Haavi does for you.