The Kotka refusal carries the other lesson. Where a property sits near a port, a garrison, a border crossing or critical supply infrastructure, assume the security review is genuine and that no volume of paperwork repairs a location the ministry dislikes. Imatra matters for a third reason: the applicant was a company registered in Italy, an EU member state, but its owners are from outside the EU and EEA, and the ministry treated the acquisition as a non-EU one requiring permission. An EU holding vehicle does not settle the ownership question, so assume the ministry will look through to the beneficial owners.
Settle the permit question before the deposit, not after.
What changed
The ministry announced six decisions on 7 October 2026 and refused every one. The properties are in Kotka, Viitasaari, Miehikkälä and Imatra. The individual applicants behind the Kotka, Viitasaari and Miehikkälä files were citizens of Russia, Montenegro and Israel. The Imatra application came from a company registered in Italy whose owners are from outside the EU and EEA. The stated intended uses were rental and recreational.
Only the Kotka decision rested on the merits of the transaction, which the ministry said could be considered a threat to national security and security of supply. The other five were refused procedurally, after the applicants failed to provide the information and statements the ministry asked for and did not answer reminders. The release states that the decisions are not yet final, which leaves the administrative appeal route open. It is the second large refusal round of the year: Minister of Defence Antti Häkkänen blocked 14 purchases in a decision announced in June.
The mechanism
The decisions were issued under the Act on Permit Requirements for Certain Real Estate Acquisitions. The five procedural refusals also cite the Administrative Procedure Act, the general statute governing how Finnish authorities handle applications and what follows when an applicant ignores a request for clarification. Under the Act, private individuals and entities from outside the EU and EEA need Ministry of Defence permission to acquire Finnish real estate, and permission can be refused on national security and related grounds. Buyers from inside the EU and EEA do not go through this step.
Parliament tightened the Act in April 2025. The amendment inserted a new Section 5 a setting absolute grounds for refusal: permission cannot be granted to individuals holding the nationality of a state the Council of the EU has identified as violating another state's territorial integrity, sovereignty and independence, where that state also poses a threat to Finland's national security and may use its nationals in a manner that endangers Finland. The bar extends to entities domiciled in such a state and to entities owned or controlled by its nationals. Holders of a Finnish permanent residence permit, or an EU residence permit issued by Finland, are excepted. The affected states are listed by government decree rather than named in the Act, so the list can be revised on an updated threat assessment without a new act of parliament, and with correspondingly little notice.
The amendment also closed a financial escape route. Where a buyer acquires property before permission is granted and a Section 5 a ground applies, the state does not reimburse the acquisition costs, so completing first and applying later leaves the buyer carrying the loss.
Context
Finland has required Ministry of Defence permission for non-EU and non-EEA property acquisitions since 2020, and the regime has tightened rather than loosened since. It is narrower than a blanket foreign ownership ban, because it screens transactions one at a time against security criteria rather than setting thresholds or quotas, which makes outcomes harder to predict from outside. The decisive factors are the applicant's nationality and ownership chain, the location of the land, and whether the file is complete. Europe is applying the same pressure through different instruments: Latvia closed its 250,000 euro property route to residence permits, and the Netherlands cut its second-home transfer tax to 7 percent while keeping non-resident buyers in the higher band. Security-driven limits on foreign land ownership are not only European, as Argentina's Supreme Court fight over its 15 percent foreign rural land cap shows.
Sources
- Six negative decisions on real estate transactions, Finnish Government, Ministry of Defence, 7 October 2026
- Finland blocks six foreign property purchases, Helsinki Times, 8 October 2026
- Amendment of the Act on Transfers of Real Estate Requiring Special Permission: What Are the Key Changes for Foreign Purchasers?, Hannes Snellman
