Report: Finnish Immigration Service’s application guidelines comply with the law but can be improved further

The Finnish Immigration Service has commissioned an external audit concerning its guidelines for application of law. According to the audit report, the agency’s guidelines comply with the law but they are also difficult to understand. The Finnish Immigration Service will use the results of the audit to improve its guidelines.

The application guidelines are used in the decision-making process in situations where the decision-makers cannot find a direct answer in the legislation. The guidelines have a significant impact on the consistency and quality of the decisions made by the Finnish Immigration Service.

“It was very important to have the audit carried out, because the Finnish Immigration Service exercises considerable public power while applying the law. The guidelines must ensure equal treatment of our customers and uniform quality in our work,” says Ilkka Haahtela, Director General of the Finnish Immigration Service.

The Finnish Immigration Service commissioned the audit from the consulting firm Deloitte to get an external assessment of the present state of the guidelines and their level of customer orientation.

“The external report promotes transparency in our work and provides information that helps us develop the agency. Over the years, the application guidelines have not been created as a coherent whole, so we needed a separate report that is not tied to the agency’s previous practices,” says Haahtela.

According to the audit report, the agency’s application guidelines comply with the law but are too open to interpretation. The guidelines also repeat sections of laws and passages from government proposals word for word and do not sufficiently contribute to uniform interpretation and quality.

“We will reform our guidelines as a whole and simultaneously reorganise the agency to further a uniform application of law and consistent quality in our work. We have already started to work on this at the beginning of the year, and we are making rapid progress,” says Haahtela.

Finnish Immigration Service reforming its application guidelines

The Finnish Immigration Service will reform the structure and contents of its application guidelines with the help of the results of the audit and the feedback gathered from the agency’s personnel through workshops.

Understandable and up-to-date guidelines that are of high quality also help to ensure that the agency complies with the law in its operations. They also contribute to uniform processing and the equal treatment of customers. In addition, clear guidelines increase efficiency in the processing of permits.

“We have already started to create a new set of guidelines this spring. Our strategy should be visible in our application guidelines so that it benefits our employees and thus also our customers. The new guidelines can include, for example, entries on practical principles and customer-oriented application practices,” says Haahtela.

The audit revealed overlaps in the guidelines as well as vagueness in the way the relationship between general acts and special acts is expressed. This also applies to international statutes and decisions based on them. The terminology in the guidelines is consistent but there are considerable differences in their structure. The guidelines are also stored in different places, which makes it difficult for the user to navigate between the guidelines.

While reforming its guidelines, the Finnish Immigration Service will create a clear guideline hierarchy, train its staff and consider the possibility of introducing a new technical platform where the guidelines can be organised more clearly by theme so that they are easy to find.

In addition to reforming its guidelines, the Finnish Immigration Service is also reorganising its permit services. As part of the reorganisation, the agency will develop a concept for providing legal support for permit services and decide how and in what format the application guidelines will be issued in the future.

“Our aim is to introduce the new organisational structure at the beginning of 2024,” says Haahtela.

Media enquiries

• Ilkka Haahtela, Director General, tel. +358 295 433 037, email: firstname.lastname@migri.fi
• The Finnish Immigration Service’s guidelines for application of law