Election funding disclosure

All candidates that have been elected or appointed as alternate members according to the confirmed election results must submit an election funding disclosure.

A candidate who has been standing at the same time in both the county elections and the municipal elections and who has been elected as a council member or an alternate member in both or only one of these elections is obliged to disclose their election funding for both elections in one disclosure.

Example: A candidate who is elected as a council member in the municipal elections but who is not elected in the county elections is subject to the disclosure obligation for both elections. In this case, the candidate should file one disclosure to disclose the funding and costs of both election campaigns.

They must submit the disclosure to the NAOF within two months of the confirmation of the election results.

An election funding disclosure is submitted primarily via the electronic service portal of the oversight of election campaign and political party funding. The disclosure may also be made on a form approved by the NAOF.

Content of the election funding disclosure

The election funding disclosure must contain the following information:

  • the elections involved
  • the candidate’s name, title, occupation or position
  • the name of the political party that nominated the candidate or an indication that the candidate was nominated by a constituency association
  • the candidate’s electoral district or the municipality in which the candidate ran for office
  • total election campaign expenses incurred by the candidate and itemisation of the expenses
  • total election campaign funding raised by the candidate and itemisation of the funding
  • any other information on election funding and campaign costs that the discloser considers necessary.

The discloser is responsible for the accuracy of the information contained in the disclosure. When requested, the discloser must provide supplementary information (in the form of campaign bank statements or other similar documents) so that the accuracy and completeness of the disclosure can be verified.

Campaign period

The election campaign period begins six months before the election day and ends two weeks after the election day.

A candidate's support group

The law does not specify the meaning of the term “a candidate's support group” separately, but the expression “a candidate's support group or other entity operating exclusively for the purpose of promoting the candidate” covers all the groups of people that are active and participate in the election campaign. The form in which the group operates is irrelevant. The support group can be a registered or non-registered association.

Only a group that only supports the candidate is considered the candidate's support group or other similar entity. An entity that supports several different candidates is not a support group or a similar entity referred to in the law.

The term “a candidate's support group or other entity operating exclusively for the purpose of promoting the candidate” does not refer to registered associations of political parties. If an entity has an official relationship with a political party, it is not a support group or other similar entity referred to in the law. This limitation is necessary despite the fact that, for example, a local party association can in practice act in an election campaign in the same manner as the support group of an individual candidate. Even if a party association is small, its activities usually also have other aims than supporting an individual candidate.

Support provided by the candidate's own company or spouse

A company owned by the candidate may support the candidate's campaign. If the candidate receives support from their own company, the support is regarded as support provided by the company in question, and the candidate should disclose it in their election funding disclosure.

Limited liability companies are independent legal persons, and the shareholders are irrelevant from the point of view of election campaign funding.

If a candidate receives a direct monetary gift from their spouse to cover election campaign costs, the candidate should disclose the monetary gift in their election funding disclosure. The monetary gift is disclosed under “Support from private individuals” on the election funding disclosure form.

The name of the payer of an advertisement should be indicated on the advertisement

It should be indicated on a paid advertisement that is part of an election campaign or that is published to support an election campaign who has paid for the advertisement. A candidate, the candidate's support group and any other entity operating exclusively to promote the candidate should ensure that the name of the payer of the advertisement is indicated on the advertisement.

However, if the payer of the advertisement is a private individual, their name may only be published with their express consent if the value of the advertisement paid by them is

  • less than EUR 800 in municipal elections (also if the advertisement is directed at both the county and the municipal elections)
  • less than EUR 1,500 in parliamentary elections, county elections, European Parliament elections or presidential elections.

Joint advertising

Joint advertising refers to advertising where

  • several candidates are presented in an advertisement
  • the advertising is targeted equally at different candidates and
  • the advertising is not controlled by the candidate.

As a rule, joint advertising falls outside the scope of the candidate's disclosure obligation. The applies to all advertising by a political party or its local associations where all or at least several candidates are presented equally, such as outdoor advertisements and newspaper advertisements. A candidate's participation in the political party's joint advertising does not provide voters with additional information on the candidate's ties to third parties.

Drawing a line between a candidate's personal campaign and the party's campaign is not always unambiguous in joint advertising. In principle, it is possible to divide joint advertising by a political party and other external parties between all candidates, but this cannot be considered appropriate. A candidate may, if they so wish, also provide information on joint advertising in their election funding disclosure.

When determining whether an advertisement is part of the candidate's campaign, it should be assessed whether the advertising has been controlled by the candidate themselves. As a general rule, if the candidate has not been able to influence the advertising, a joint advertisement is not considered to be part of the candidate's personal campaign and does therefore not fall within the scope of the candidate's disclosure obligation.

This applies also to advertising by a political party's women's and youth associations when the association has paid for the advertisement on behalf of all its members. Such an advertisement would not be regarded as part of the candidate’s personal campaig

However, if a candidate receives financial support from a political party or a party association for their personal advertising, the financial support received from the party or party association falls within the scope of the disclosure obligation. However, if the candidate participates in the costs of joint advertising, for example by paying a candidate's contribution, the candidate can disclose the contribution as their campaign cost. The same also applies to such joint advertising by other external actors (such as trade unions and other non-governmental organisations) that is targeted at several candidates.