3. Finland

3.1. Governance structure

National adaptation policy-landscape

National adaptation policy has been developing during the past 20 years in Finland. Finland was the first country in Europe to publish a National Adaptation Strategy (NAS) in 2005

While the NAS is more like a plan than a strategy, and could thus better be described as a NAP, we adhere to the official designated terminology by both the Finnish government and the EU.

(see Table 3.1 below). In 2014, the NAS was supplemented with a National Adaptation Plan (NAP), which was revised in 2023. In addition, many ministries have published sectoral implementation plans based on the NAS. Both the NAS and the 2014 NAP have gone through an interim evaluation and a final evaluation. To support the planning of national climate policy, there have been several research programmes and projects, funded through the Finnish government’s financial instruments.

The first Climate Act entered into force in 2015 and the revised Climate Act (423/2022) in 2022. It lays down the provisions on climate change policy planning and related monitoring and sets the national climate objectives. The Act also imposes obligations on the authorities on climate change adaptation, including the requirement for a national adaptation plan. The aim of the planning system is to make sure that Finland will reach the targets with respect to both climate change mitigation and the preparations for this. The Act denotes that each Ministry prepares the part of climate policy plans respective to their own administrative branch.

In addition to adaptation-specific policy developments, adaptation has been advanced in relevant sectoral regulation. For example, the Land Use and Building Act and the National Land Use Guidelines, which give guidance to municipalities on land use, include adaptation as one of the goals.

Table 3.1: Timeline for adaptation policy in Finland

Year	Item	Description
2005	National Adaptation Strategy (NAS)	First comprehensive strategy for national adaptation that was developed jointly with all ministries
2006	Climate Change Adaptation Research Programme ISTO	A research programme (2006–2011) developed to support the implementation of NAS by addressing knowledge gaps.
2006	Management group of the adaptation research programme	An inter-ministerial group to support the implementation of national level adaptation.
2007–2009	Midterm evaluation of NAS	First evaluation of NAS
2008	Action Plan on adaptation of the environmental administration	First sectoral implementation plan of NAS by the Ministry of Environment (2008, 2011)
2009	Climate policy programme for the administrative branch of the Ministry of Transport and Communications	First sectoral implementation plan of NAS by the Ministry of Transport and Communications (2009, 2013)
2011	Climateguide.fi portal	Launch of the adaptation portal that is directed at municipalities and citizens with the aim to disseminate knowledge and information related to climate change and adaptation
2011	Action Plan for the Adaptation to Climate Change of the Ministry of Agriculture and Forestry	First sectoral implementation plan of NAS by the Ministry of Agriculture and Forestry (2011–2015)
2013	Final Evaluation of NAS	Final evaluation of NAS (2011–2013)
2014	National Adaptation Plan (NAP)	The first National Adaptation Plan
2015	Climate Act	First Climate Act, stating that the Government has to report annually on adaptation (alongside mitigation) and has to produce a risk assessment and a national plan
2019	Midterm evaluation of NAP	First evaluation report that assesses the implementation of the 2014 NAP
2022	Climate Act	Revision of the Climate Act, laying down the provisions on climate change policy planning and related monitoring and setting the national climate objectives
2023	National Adaptation Plan (NAP)	Publication of the second NAP, alongside a risk assessment

Division of responsibility

Finland is a parliamentary representative democracy with the government having executive power. As of 2023, there are 12 ministries that function as administrative and political units and prepare Government decisions within their mandates. The presence of the state at the regional level is concentrated in 6 regional state administrative agencies (AVI) and 15 Centres for Economic Development, Transport, and the Environment (ELY). Regional state administrative agencies have mostly law enforcement, rescue, and judicial duties: police, fire and rescue, emergency readiness, basic services, environmental permits and enforcement and occupational health and safety protection. The ELY Centres implement labour and industrial policy, provide employment and immigration services, and promote culture; maintain highways, other transport networks and infrastructure; and protect, monitor and manage the environment, land use and water resources (ELY Centre, 2021). There are 309 municipalities that have a large degree of autonomy in terms of decision-making, including allocation of resources and land use. With the healthcare 2023 reform, many of the adaptation-related functions (such as rescue services, health, and social care) have been transferred to wellbeing services counties (Finnish Ministry of Social Affairs and Health, n.d.), while municipalities’ functions relevant for adaptation are more related to areas such as the built environment (Interviews, Finland).

Figure 3.1. Organization of adaptation in Finland

National

The Finnish Government has the main responsibility for promoting adaptation actions necessary for securing functions vital to society, and the overall promotion of adaptation in cooperation with the municipalities, business operators, citizens and various organisations representing these. Currently, the Climate Act does not allocate responsibilities for adaptation beyond the central government authorities.

The Ministry of Agriculture and Forestry (MAF) has the coordination responsibility and was the Ministry in charge of leading the preparation of the 2023 NAP, with the practical work steered by a broadly-based preparatory group appointed by the ministry. The various ministries are responsible for the implementation, monitoring and evaluation of the plan within their respective administrative branches.

Additionally, the National Emergency Supply Agency operating under the Ministry of Economic Affairs and Employment performs functions that contribute to adaptation, more specifically those related to the maintenance and development of national security of supply.

A national monitoring group was appointed to follow and evaluate the implementation of 2014 NAP, with representatives from the relevant ministries, research institutions, regional and local bodies, and actors. The group met 4–5 times a year and was responsible for following the implementation and communication relating to the adaptation plan, promoting the cooperation between sectors in adaptation actions, and supporting the overall awareness raising on adaptation. In the period of 2020–2022, the group consisted of members from:

Ten ministries: Agriculture and Forestry (3), the Environment (1), Transport and Communications (1), Defence (1), the Interior (1), Health and Social Care (1), Economic Affairs and Employment (1), Finance (1), Foreign Affairs (1) and the Prime Minister’s Office (1).
Eight agencies, institutes and associations of which National Emergency Supply Agency (1), Natural Resources Institute Finland (1), Finnish Meteorological Institute (1), Finnish Environment Institute (1), Finnish National Agency for Education (1), Finnish National Rescue Association (1) and Finance Finland (1) are governmental agencies and Association of Finnish Municipalities (1), which is an interest organisation,
Three regional entities: regional Centres for Economic Development, Transport and the Environment (1), which is a governmental agency, and regional councils (1), and Helsinki Region Environmental Services Authority (1), which represent regional authorities.
And experts from the Finnish Institute for Health and Welfare (2), the Finnish Transport Infrastructure Agency (1) and the Ministry of Agriculture and Forestry (1) (Finnish Ministry of Agriculture and Forestry 2020).

The group will be reassembled for the monitoring of the 2023 NAP, but the composition of the group is yet to be determined.

The Finnish Climate Change Panel, which was established based on the Climate Act, is an expert panel that brings together high-level researchers on climate change and has some resources to carry out synthesis work. The Climate Panel is legally mandated to comment on the government’s climate plans annually. It is also able to carry out synthesis work on climate policy issues, which it considers important to inform the government’s action. The Panel has a rotating membership with a strong multidisciplinary expertise selected from universities and research institutes (The Finnish Climate Change Panel, n.d.).

Sub-national

At the sub-national level, Centres for Economic Development, Transport, and the Environment (ELY) (15 in total) are responsible for the regional implementation and development tasks of the central government. From the adaptation perspective, more specific areas of work include land use, transportation, environmental protection, biodiversity protection, construction and built environment, cultural environment, flood management, water resources use and management, as well as agriculture and fisheries related tasks. Additionally, the ELY Centres advance adaptation as part of regional development, and advisory, funding, development services for the private sector, as well as promotion of competence and lifelong learning, and agricultural and rural development. Important tasks in terms of adaptation also include monitoring the public interest in environmental and water matters, producing, and distributing environmental information, and improving environmental awareness (MAF, 2022). Many of the tasks carried out by the Centres require taking into account the adaptation needs, even though all the work is not necessarily recognized as adaptation (MAF, 2022).

The 2014 NAP did not allocate responsibilities of adaptation to Finland’s 309 municipalities (average population size of 17 955 and a median population size of 5 967 residents, as of 2022). This was originally intended to be included in the revision of the Climate Act in 2022 but did not happen. Currently, all municipal stand-alone plans are voluntary or are a result of collaboration in city climate networks. These networks include national ones, which are predominantly mitigation-focused but also encourage adaptation (e.g., the 6-Aika cities and the HINKU network), or international networks (e.g., Covenant of Mayors), of which some of the larger cities have become members. Some cities have also established their own networks for private sector actors and companies to advance both mitigation and adaptation in the private sector (e.g., the Climate Partnership Network in Helsinki).

Under a health sector 2023 reform, a total of 21 self-governing wellbeing services counties have been established in Finland. The responsibility for organizing health, social and rescue services has been transferred from the municipalities and joint municipal authorities to the wellbeing services counties (Finnish Ministry of Social Affairs and Health, n.d.). The highest decision-making power in each wellbeing services county will be exercised by a county council, whose members and deputy members are elected in county elections. These services are also important in adaptation, and the outlining of responsibilities and adaptation needs within the counties’ work will be carried out (Interviews, Finland).

Policy themes

In the 2023 NAP, adaptation is also framed as an issue of comprehensive security, based on national cooperation. In this cooperation, critical societal functions are maintained through collaboration between public officials, private sector, third sector and citizens. The principles of the comprehensive security approach are described in the broader national security agenda, of which modelling of threats is updated regularly. In these scenarios, climate change is considered mainly as a threat multiplier (MAF, 2022).

The 2023 NAP identifies 12 themes that are central to adaptation in Finland, with 1–3 objectives identified for each theme (a total of 24 objectives). The themes are:

Governance.
Comprehensive security and general preparedness.
Food and nutrition security.
Infrastructure and built environment.
Drought risk management, use of and care for natural resources, biodiversity, and Nature-based Solutions (NbS).
Healthcare.
Cultural heritage and cultural environment protection.
Regional and municipal risk management.
Strengthening (and mobilizing) the knowledge base.
Communication and interaction.
International cooperation.
Monitoring and evaluation.

Besides these, other themes are emerging within the national adaptation discourse, such as justice in adaptation (see box 3.1).

Box 3.1. Justice in national adaptation as emerging policy theme

One of the objectives of the Climate Law (432/2022) and related adaptation policy is ensuring just climate action, both with regards to the content and to the methods of planning. During the project “Climate Justice” funded by the Finnish Climate Change Panel there was developed an index of adaptation justice in climate policy, which has been further used to analyze justice in Finland’s adaptation policy (Juhola et al., 2022). Adaptation justice is approached through four dimensions: restorative, distributive, procedural and recognitional. The results show that Finland has scored high on procedural justice, moderately on recognitional and distributive and low on restorative, with gaps identified across all dimensions of justice. The main areas for improvement are the distribution of costs and benefits (both in terms of climate risks and adaptation measures, distributive justice) and their compensation (restorative justice) (Ibid.).

The aspects of justice related to the impacts of climate change and adaptation actions are considered to be central to the national adaptation strategy (Hildén et al., 2022). The preparation of the 2023 NAP was carried out in consultation with a diverse group of stakeholders, including Sami population representatives, as well as associations for young and elderly people, and people with disabilities. The new plan also acknowledges that the risks are distributed unevenly and sets the objectives to include justice assessments for adaptation action. It has also been acknowledged, however, that restoring past injustices or addressing structural inequalities related to e.g., socioeconomic factors does not necessarily lie within the scope of the new adaptation strategy. Nevertheless, the starting point for any adaptation action should be that no new vulnerabilities or inequalities are created, or existing ones deepened (MAF, 2022).

Risk assessments

The Climate Act requires a risk and vulnerability assessment, and this will be carried out periodically in relation to the NAP. The previous one, a stand-alone assessment, was funded through government research and innovation funding (Tuomenvirta et al., 2018). Overall, the institutional set up for assessing climate vulnerability and risks is based on work by research institutes and universities that carry out research on climate change impacts, adaptation, and mitigation (see box 3.2 below).

The 2023 NAP is based on a scenario-based assessment of risks that is presented in a separate attachment to the plan. Sectors for which climate risks are examined include nature and ecosystems, natural resources, infrastructure and built environment, health, financial sector, indirect risks, individual and community level vulnerability and institutional vulnerability (MAF, 2022).

The plan itself includes the following considerations:

Consideration of climate change impacts (e.g., changes in temperature and precipitation).
Consideration of climate risks, including both the natural environment (e.g., ecosystems and biodiversity) and society (e.g., built environment, health, agriculture and cultural heritage), with a special consideration of the Indigenous Sami population.
Secondary (transboundary) effects of climate change in Finland (e.g., food production, raw materials and human migration).

While transboundary climate risks (TCR) are on the agenda, concrete actions towards transboundary risk management are rather difficult to plan and implement (Interviews, Finland). Additionally, with regards to the emergency supply (e.g., food security), most of its functioning is carried out by the private sector, and government has limited options to steer adaptation, mainly through e.g., information, guidance, and in exceptional crisis situations like e.g., COVID pandemic, with subsidies (Interviews, Finland).

Box 3.2. Research informing national climate risk assessments in Finland

The project ELASTINEN (2015–2016) examined the state of climate risk management, assessed ways to manage risks and examine the roles of different stakeholders, including municipalities and organisations (Gregow et al. 2016, Tuomenvirta et al. 2019). More specifically, the project examined the impacts of climate change and extreme weather events on the functioning of Finnish municipalities and organisations, sources of climate information the organisations and municipalities use and perception of climate and non-climate information services and usability (e.g., Räsänen et al., 2017).

The project SIETO (2017–2018) produced a national climate risk and vulnerability assessment, focusing on the vulnerabilities of different sectors to climate change related hazards and extreme weather events (Tuomenvirta et al., 2018). The results were used to support the implementation of the National Climate Change Adaptation Plan 2022 (NAP2). Additionally, the risk assessment carried out in the project was used to produce a governance model for future risk assessments.

The project SUOMI (2020–2022) is a Finnish Climate Change Panel project that produced synthesized information for the National Climate Change Adaptation Plan 2030 and the revisions of the Climate Law (432/2022). The project specifically focused on the regional accurate climate risk assessments for current and future risks, as well as on the instruments and costs and benefits of climate change adaptation (Gregow et al., 2021).

Systems for monitoring, reporting, and evaluation

The 2023 NAP sets out to establish a system for monitoring, reporting and evaluation (MRE), which will enable the monitoring and evaluation of each action based on designated goals, using quantitative indicators when sensible. The preparation work is to start in 2023. The interviewees did not provide further details on this. It is apparent that the creation of a large MRE system assessing risk reduction as in e.g., the UK, is not feasible nor reasonable (Interviews, Finland).

Despite the lack of a dedicated MRE system, both the Climate Act and the 2014 NAP have included reporting requirements. The Climate Act requires the government to publish an Annual Climate Report on climate adaptation progress. This means that the Government reports on any advances on adaptation in the yearly climate policy report, which also includes advances on mitigation.

The 2014 NAP required ministries to report to the coordinating ministry regarding the progress on implementation. Their tasks included:

Promoting the adaptation-related cooperation of state authorities and various industries.
Identifying adaptation-related research needs and making proposals for research development.
Promoting the practical application of research knowledge and guiding projects that serve adaptation.
Promoting communication and knowledge about adaptation.
Supporting the implementation of the EU’s adaptation strategy in Finland and the preparation of national policies related to EU affairs.
Monitoring and reporting the implementation of the adaptation plan and promoting the assessment of the effectiveness of adaptation measures.
Contributing to the preparation of the next adaptation plan.

Both NAS and the 2014 NAP have been reviewed. NAS had an interim review in 2009 (MAF, 2009) and final review in 2013 (MAF, 2013). The method for the 2009 review was based on Ministries self-reporting and an evaluation scheme (a scale of 1–5). The review found that adaptation as an issue was recognized in most ministerial sectors but that only a few adaptation measures had been identified or implemented (2 out of 5 on the evaluation scale). The 2013 final review of the national adaptation was based on reporting from the Ministries responsible for implementation. This was combined with a round of expert interviews, as well as two rounds of expert workshops that focused on specific thematic areas, such climate change and health, industry and insurance, and ecosystem-based adaptation. The evaluation found that adaptation measures had increased and that there was cross-checking of synergies and conflicts between adaptation and other policies. Managing the uncertainties related to the effects of climate change was found to require further knowledge of climate impacts.

The 2014 NAP interim review was published in 2019 (Mäkinen et al., 2019). The review assessed the implementation of NAP and identified the needs for development. The review method included group interviews and regional stakeholder workshops, as well as a national survey and documentation based on self-evaluation. The review found that while the effects and risks associated with climate change are being discussed more broadly, measures to manage climate-related risks are still lacking. The most important needs for development have to do with increasing awareness of weather and climate- related risks and the possibilities to adapt to them, clarifying the roles and responsibilities related to adaptation and ensuring well-functioning coordination.

The KOKOSOPU project that was funded by the VN TEAS funding instruments assessed the progress made on adaptation (Hildén et al., 2022). The assessment covered all administrative branches and checked recent strategic and legal documents for evidence on recognition of climate change. The project also explored regional and local level adaptation activities through workshops and a survey targeted at municipalities and collected information on resources devoted to adaptation. Based on the analysis, all branches and levels of administration recognise climate change as a relevant topic – explicit references to climate change are made in numerous documents. The level varies, in some it is a mere statement whereas in others concrete action is foreseen. Many of the challenges that were noted have been observed in all countries working to strengthen adaptation: a lack of resources hinders progress and there is a need for knowledge on how to address climate change in specific local contexts and sectors. Some authorities, especially at the regional and local level, are also uncertain about which organisation should take the lead in adaptation activities that cross administrative borders (Hildén et al., 2022; Interviews, Finland).

3.2. Policy instruments

Capacity building

State funding for analysis, assessment and research activities is an instrument for supporting policy relevant analyses. The State has funded focused projects exploring aspects of climate change and assessments of vulnerability and risks. In addition, the Strategic Research Council and the Academy of Finland have funded several programmes and projects exploring adaptation to climate change. The Prime Minister’s Office also funds adaptation related research through the Government’s annual plan for analysis, assessment, and research instrument (VN-TEAS). Through this funding instrument, several projects, including ELASTINEN, SIETO and KOKOSOPU have been funded, which have contributed to actionable knowledge on adaptation.

The Climateguide.fi website is a climate change information portal that brings reliable, research-based information about climate change, its impacts, adaptation, and mitigation. The portal will be financially supported in the coming years as part of the implementation of the 2030 plan. The portal is a national, publicly available digital website that is regularly updated with the latest scientific information about climate change. The data and knowledge provided by the portal is aimed to support decision-making and risk management across sectors, and support climate communication and be a source for learning. The Climateguide.fi website and its main content is maintained by the Finnish Meteorological Institute, the Finnish Environment Institute, and Natural Resources Institute Finland. The website was originally created by the Finnish Meteorological Institute, the Finnish Environment Institute, and Aalto University (YTK Land Use Planning and Urban Studies Group) in an EU Life+ project in 2009–2011.

With regards to the capacity building of the private sector, the role of government is mainly in information dissemination and guidance in cases of e.g., preparing to transboundary risks or ensuring emergency preparedness (Interviews, Finland).

Incentive mechanisms

Overall, financial incentivizing can be carried out through taxation, subsidies, and general funding. Currently there are no financial incentives in use specifically for adaptation. There are sectoral incentives, for example, for agriculture (within the framework of the EU CAP) and forestry (Metka), which contribute to adaptation but are not necessarily intended as adaptation measures (Interviews, Finland). For example, the 2023 NAP contains a goal of mapping the condition of private roads and bridges, funded in accordance with the public funding plan until the end of 2024 (MAF, 2022).

Insurance can be considered an adaptation measure, particularly given that the state has withdrawn any compensation on flood damages (since 2014) and on damages to agricultural crops or forests (2016). Currently, individual house owners, farmers or forest owners are encouraged to take private insurance to cover their losses in case of damages. However, there is no data on what the coverage is and how often compensation is paid.

3.3. Best practices and main challenges

More specific ways to “improve” adaptation at the national/ministerial level could be establishing positions dedicated to adaptation specifically or including adaptation into existing positions’ responsibilities, however, ensuring that the responsible people have mandate and resources to coordinate adaptation at the ministry.

With regards to the integration of adaptation and other themes, a good development has been framing adaptation as a matter of comprehensive security and emergency supply/preparedness, thus steering adaptation as part of other than adaptation-specific discussions in other administrative branches. On the other hand, including other themes in the 2023 NAP (e.g., biodiversity) ensures that adaptation is part of biodiversity-related discussions, while not being “outsourced” to other ministries and the coordinating Ministry can follow up on that (Interviews, Finland).

At the sub-national level, more dedicated and more active networks for adaptation, perhaps, funded or supported ones (as are e.g., mitigation-focused), have been pointed out as a useful tool to further build capacity and steer peer learning (Interviews, Finland).

Similarly, a comprehensive evaluation of risks, adaptation and clear responsibilities assignments could be beneficial from the sub-national perspective, as indeed the sequence of responsibilities is not always clear (e.g., heat risks could be first managed by the construction departments and standards, whereas the impacts are already the responsibility of healthcare. Shifting responsibilities due to e.g., healthcare and social services reform also (from municipalities to wellbeing services counties) require further delineation in terms of adaptation (Interviews, Finland). Overall, the delineation of responsibilities could be improved and clarified also in the legal frameworks.

Planning adaptation to be integrated as part of sectoral work and decision-making at sub-national level and plans is considered to be working better than e.g., separate adaptation. Separate adaptation plans are at the risk of not being integrated into existing frameworks and processes or being in conflict with other decision-making (Interviews, Finland). According to one of our informants, this is especially prominent in light of recent health and social care reform, where a major part of adaptation-related functions (rescue services, social and health care) has been transferred from the municipalities to wellbeing services counties. While municipalities’ adaptation can now mainly be seen in zoning and land use planning and has already been integrated into it since 2005, further delineation of adaptation-related responsibilities between the municipalities and wellbeing services counties is needed (Interviews, Finland).

In terms of the legal frameworks, the Climate Act from 2015 did not fundamentally change the process or outcomes of the national adaptation plan since the process already existed. The NAP itself is consistent in its approach in mainstreaming across the existing planning processes. The Climate Act is a framework law that lays down the obligations to the government to produce more detailed plans for both mitigation and adaptation. In addition to the Climate Act, it is worth noting that there are several adaptation concerns that have been addressed in specific laws, for example, in relation to building codes, land use that have been enacted.

The current NAP only requires actions to be taken by the central government authorities and does not substantially consider the role of the private sector in adaptation. In Finland, adaptation has been set to be integrated into the work of administrative branches and sectors. However, it is apparent that there is a challenge of responsibility division here and the progress on adaptation mainstreaming varies (Interviews, Finland; Hildén et al., 2022). Since NAS, the approach has been to mainstream adaptation across existing planning and development processes. Each of the interim and final evaluations of both NAS and NAP has highlighted that there are some ministerial sectors where progress has been faster, for example the environment, agriculture and forestry and transport and communications, while there are some sectors within which the uptake of adaptation has been slower, for example, health and economy and employment (Hildén et al., 2022). As the responsibility for implementation is allocated to each ministry with the Ministry of Agriculture and Forestry assuming a coordinating role, there are no mechanisms to accelerate the process. It is within the consideration of each ministry to when and how they incorporate adaptation into their planning and activities.

Furthermore, the past evaluations of the NAP have also stressed that the allocation of responsibilities continues to hamper the effective implementation of adaptation. The 2023 NAP addresses this by identifying responsible instances for each of the 24 goals over different time periods (MAF, 2022).

Mitigation and adaptation are reported together annually in the annual climate report that is prepared by the government to the parliament, detailing how mitigation and adaptation have been progressing. But there is no cross-checking of the GHG impact of adaptation measures, nor the climate “proofness” of mitigation measures.

Related to the absence of financial incentives from the national to municipal actors, informants pointed out whether it is reasonable to set adaptation goals for municipalities without providing financial support as municipalities do not necessarily continue with the implementation in the absence of resources and raised criticism on the absence of financial steering of the municipalities in the NAP3 and unclear division of adaptation responsibilities at the sub-national level (Interviews, Finland).