PROGRAM OPERATIONS MANUAL SYSTEMPart GN – GeneralChapter 017 – Totalization BenefitsSubchapter 31 – Agreement With FinlandTransmittal No. 2, 04/12/2023
The Office of International Programs, which was responsible for negotiating and implementing bilateral social security agreements with other countries, merged with various different SSA components in 2018. The totalization negotiation and implementation workloads have been merged with the previous Office of Data Exchange and Policy Publications to form the new Office of Data Exchange, Policy Publication, and International Negotiations (ODEPPIN). Accordingly, we are revising existing POMS sections to account for the new component names, addresses, and workload processes. We also updated the instructions to meet the agency's plain language requirements. Finally, we updated this section to reflect current Finnish social security benefits and terminology.
Summary of Changes
GN 01731.001 Overview of Agreement With Finland
We updated this subsection to comply with the plain language initiative.
GN 01731.010 Overview of the Finnish Social Security System
We updated this subsection to comply with the plain language initiative. We also updated the names of Finland's pensions schemes/systems.
GN 01731.015 Coverage and Contributions Under the Finnish System
We updated this subsection to comply with the plain language initiative. We also added Finland's updated pension system names (Kansanelake, KEL) for the National pension system, and (Tyoelake) for the Earnings Related pension system.
GN 01731.020 Finnish Social Security Benefits
We updated this subsection to comply with the plain language initiative. We replaced the word "widow" with the phrase "spouse or registered civil partner." We updated the official contact information for information requests in part C.
GN 01731.105 Effective Date of the U.S. - Finnish Agreement
GN 01731.110 Scope of the U.S. - Finnish Agreement
GN 01731.120 U.S. Totalization Benefits Under the U.S.- Finnish Agreement
We changed the title of this subsection to reflect that the agreement between the United States and Finland. We also updated this subsection to comply with the plain language initiative.
GN 01731.125 Eligibility for Finnish Benefits Under the U.S.- Finnish Agreement
We changed the title of this subsection to reflect that the agreement is between the United States and Finland, and updated this subsection to comply with the plain language initiative. We also replaced the word "widower" with the phrase "surviving spouse".
GN 01731.140 Exception to Section 202(t)(1) Alien Nonpayment Provision Under the U.S.- Finnish Agreement
We changed the title of this subsection to reflect that the agreement is between the United States and Finland, and updated this subsection to comply with the plain language initiative.
GN 01731.145 Exception to Section 202(t)(11) Alien Nonpayment Provision Under the U.S.- Finnish Agreement
GN 01731.150 Filing Appeals of Decisions on U.S. or Finnish Claims
GN 01731.210 Developing Evidence in Claims for Finnish Benefits
We updated this subsection to comply with the plain language initiative, and incorporated the information in GN 01731.205, archiving that subsection.
GN 01731.215 Application for Benefits Under the U.S.- Finnish Agreement
GN 01731.220 Additional Applications for Finnish Benefits
We added this subsection to provide consistent instruction for Field Office (FO) personnel in handling Finnish benefits claims inquiries.
GN 01731.225 State of Applications for Finnish Benefits
The social security agreement between the United States and Finland:
eliminates dual social security coverage and taxation of the same work, and
permits workers (and their family members) to qualify for partial U.S. or Finnish benefits, or both, when they do not meet the normal insured status requirements.
The following sections provide:
a brief overview of the Finnish system,
an explanation of the agreement provisions, and
instructions on how to take and process claims for both U.S. and Finnish benefits filed under the agreement.
For more information on the Finnish social security system, visit the International
Programs webpage. This webpage has various links to Social Security Administration (SSA) publications on U.S. bilateral international social security agreements with foreign countries, including the agreement with Finland, and to the websites of foreign social security agencies around the world. To find out how the agreement eliminates dual coverage, see sections RS
02001.700 through RS
The Finnish social security system provides a wide range of benefits including old-age retirement, survivors and disability benefits through two separate programs, which together make up a two-tier social insurance system:
The first tier, called the National Pensions System, provides flat-rate benefits for people who reside in Finland.
The second tier, called the Earnings-Related Pension
pays benefits based on a worker's earnings level and years of coverage.
To qualify for Finnish benefits, a person must meet minimum residence or coverage requirements that vary depending on the type of benefit.
The National Pension bases coverage on residence in Finland, while the Earnings-Related Pension credits coverage based on a worker's earnings.
In general, the National Pension covers all persons who reside in Finland, regardless of nationality.
The Earnings-Related Pension compulsorily covers all private sector employees age 14 and over, self-employed persons, and farmers. The Earnings-Related Pension excludes civil servants and seamen, but those workers have separate pension systems.
Public funds finance the National Pension. Contributions from private insurance companies and pension funds finance the statutory Earnings-Related Pension.
Although Finland pays many different categories of benefits, this section describes only the retirement, disability, and survivors benefits. These are the only Finnish benefits included within the scope of the agreement.
This chart describes the eligibility requirements for Finnish retirement, disability, and survivors benefits.
Age 65, with reduced benefit payable as early as age 63.
Full benefit for persons age 65 residing in Finland 80% of the period from age 16 to 64. Partial benefits payable for persons residing in Finland for at least 3 years, but less than 80% of the period from age 16 to age 64.
Benefit no longer payable as of January 1, 1996.
Supplement for each child under age 16.
Age 16 - 64
Impairment prevents regular occupation or similar work.
NOTE: The disability requirements for persons over age 60 are less strict.
Must reside in Finland for 80% of the period from age 16 to time of benefits award. Partial benefit for persons residing in Finland for at least 3 years, but less than 80%, from age 16 to time of benefits award.
Note: Benefit is subject to recovery based on other benefit income.
The deceased worker must be residing in Finland at the time of death, be currently or previously insured at the time of death, and have at least 3 years of Finnish residence after age 16.
Spouse or registered civil partner
Surviving spouse or registered civil partner (same sex only) must have at least 3 years of Finnish residence after age 16. Benefits cease if the surviving spouse or registered civil partner remarries or re-registers before age 50. Benefits then convert to a lump sum equal to 3 years of benefits if the beneficiary received benefits for at least 1 year.
Surviving spouse or registered civil partner must be under age 65 and either:
have a child in common with the deceased worker, or
be under age 50 at the time of the marriage or civil partnership registration and at least age 50 at the deceased worker's death, and the marriage or registered civil partnership must be for at least 5 years.
under age 18, or age 18-20 and full time student
must live in Finland at the date of the deceased's death or move to Finland in the year following death. There are no citizenship or length-of-residence requirements for orphan's benefits.
Additional supplement for orphans under age 18, but supplement is subject to recovery based on other source income limits.
Flexible retirement age, from age 63, rising to age 65 gradually by 2027. From 2030, based on life expectancy at age 62. Partial pension at age 61. Employment must cease at retirement, but may continue after entitlement. Payable abroad for up to 1 year, or under an international agreement. No dependent benefits.
Age 20 - retirement age (age 63, gradually rising to age 65 by 2027. From 2030, based on life expectancy at age 62). Pre-age 20 disability benefits subject to rehabilitation assessment.
Disability expected to last at least 1 year
Partial benefits with at least 40% loss of work capacity.
Full benefits with at least 60% loss of work capacity.
(Deceased worker must be currently or previously insured at the time of death)
Spouse or Registered Civil Partner
Must be married to (or in a registered civil partnership with) the deceased worker before he or she reached age 65 and either:
they had a child in common, or
the surviving spouse or registered civil partner was at least age 50 or receiving disability benefits at the time of the deceased worker's death, was under age 50 at the time of the marriage or civil partnership registration, and marriage must be for at least 5 years.
Divorced Spouse or Registered Civil Partner
Same as surviving spouse or registered civil partner if entitled to alimony payments from the deceased prior to death.
Under age 18.
Advise persons that SSA cannot give official information about Finnish benefits. Refer those who want official information to one of the following:
For more information about the NATIONAL PENSION (residence-based):
KELAP.O. Box 7800381 HelsinkiFINLAND
Telephone: +358 20 634 0200
For more information about the EARNINGS RELATED PENSION (earnings-based):
Finnish Centre for PensionsCustomer ServiceFI 00065 ELAKETURVAKESKUSFINLAND
Telephone: +358 29 411 2110
The agreement with Finland became effective on November 1, 1992.
Periods of Finnish and U.S. Social Security coverage a worker earns, including those earned prior to November 1, 1992, may be used to establish entitlement to U.S. or Finnish Totalization benefits. However, the earliest possible month of entitlement to such benefits is November 1, 1992.
The provisions of the agreement that permit people to qualify for benefits based on combined U.S. and Finnish coverage credits apply to the following types of benefits:
U.S. retirement, survivors, and disability benefits. The agreement does not apply to Medicare benefits, or Supplemental Security Income payments.
Finnish old-age, survivors, and disability benefits under the National Pensions and under the Earnings-Related Pension.
The provisions of the agreement that eliminate dual social security coverage and taxes apply to:
U.S. Social Security taxes (Federal Insurance Contributions Act (FICA) and Self-Employed Contributions Act (SECA)), including the Medicare portion, and
Finnish social security taxes that finance old-age, survivors, disability, sickness and maternity insurance, and child allowances.
RS 02001.700 - RS
Agreement provisions for the elimination of dual coverage and taxation.
Under the agreement, if a number holder (NH) has
at least six quarters of U.S. coverage, but not enough
to be insured for regular U.S. benefits, the NH's credits under the Finnish Earnings-Related Pension system can be added to his or her U.S. coverage to permit the NH (and any eligible dependents or survivors) to qualify for U.S. Totalization benefits. Residence-based credits under the National Pension are not usable to determine entitlement to U.S. Totalization benefits.
The Social Security Administration (SSA) will credit one U.S. quarter of coverage (QC) for every 3 months of Finnish coverage in a year. Finland measures coverage in months. However, SSA will not credit coverage for:
any month in a calendar quarter that is already credited as a U.S. QC, or
more than 4 QCs for any calendar year
When SSA establishes U.S. insured status based on combined U.S. and Finnish coverage, SSA will determine the amount of the U.S. Totalization benefit using the computation method described in GN
The field office (FO) technicians must take an initial claim and process an initial insured status denial (see GN
01702.315 - GN
01702.325 ) when the worker has at least six QCs, but is not insured based on U.S. coverage alone. This denial will produce a notice advising the claimant that he or she does not meet insured status based on U.S. coverage alone and that SSA is requesting the foreign coverage record.
The Division of International Operations (DIO) will request the Finnish coverage record. When DIO receives the record, it will convert the Finnish coverage to QC's and finally adjudicate the claim.
GN 01702.315, Processing Totalization Insured-Status Notices in Claims for U.S. Benefits
GN 01702.325, Summary of Field Office Development and Processing of U.S. Totalization Claims and Foreign Claims (Regular and Totalization)
The agreement liberalizes the residence requirements that apply to National Pension benefits (see GN 01731.020). Under the agreement, U.S. citizens residing in the United States or Finland, and Finnish citizens residing in the United States, may qualify for National Pension benefits if they meet the following residence requirements.
Under Finnish law, a person must reside in Finland to qualify for a National Pension disability benefit. The agreement does not change this requirement. However, a person who qualifies and subsequently moves to the United States may continue receiving National Pension disability benefits if he or she resided in Finland for at least 5 continuous years after age 16.
Finland does not need to take U.S. coverage into account in determining Earnings-Related Pension benefit eligibility. A person's right to a benefit under the Earnings-Related Pension is immediately vested once the person begins to work in covered employment or self-employment.
However, when determining the amount of an Earnings-Related Pension survivor or disability benefit, Finland may count the years between the date of death or disability onset and age 65 (called future years) as actual years of coverage. This will increase the amount of the Earnings-Related Pension benefit. To receive credit for future years, the worker must reside in Finland for at least five years. In addition, the death or disability must occur while the worker is engaged in a covered work activity or within one year thereafter.
Under the agreement, Finland will count U.S. coverage to meet the Finnish residence and coverage requirements for granting future years when determining the amount of an Earnings-Related Pension survivors or disability benefit.
Under the agreement, Finland will count each U.S. quarter of coverage (QC) as three months of Earnings-Related Pension coverage. However, Finland will not count:
Any U.S. QC earned before 1961 (the year the Earnings-Related Pension began), or
Any months in a quarter that are already months of Earnings-Related Pension coverage.
GN 01731.020, Finnish benefit eligibility requirements
GN 01731.215, Application for benefits under the Finnish agreement
Section 202(t)(1) of the Social Security Act (ANP) generally provides that the Social Security Administration (SSA) does not pay benefits to a beneficiary who:
is not a U.S. citizen or national; and
has been outside the United States for more than six consecutive calendar months.
Finnish citizen number holders (NHs) were already exempt from the ANP prior to the effective date of this agreement as described in RS 2610.015. Under the agreement, non-U.S. citizen beneficiaries who are residents of Finland are exempt from the ANP.
If a claimant who does not meet another exception to the ANP alleges Finnish residence, develop residence status to verify that the exemption provided by the agreement applies.
RS 02610.010, Exceptions to Alien Nonpayment
GN 01702.105D, Developing Residence Status
RS 2610.015, Status of Countries for Applying Exceptions Based on Citizenship
Section 202(t)(11) of the Social Security Act requires certain non-U.S. citizen dependent and survivor beneficiaries who have been outside of the United States for more than six consecutive calendar months to satisfy a 5-year U.S. residency requirement to receive benefits. During this 5-year U.S. residency, the dependent or survivor must have been in a family relationship with the number holder (NH).
Under the terms of the Totalization agreement with Finland, alien dependent and survivor beneficiaries residing in Finland can receive U.S. Social Security benefits for which they qualify even if they do not meet the 5-year U.S. residency requirement. This applies to both ordinary and totalized U.S. benefits.
If an alien dependent or survivor beneficiary does not meet the 5-year U.S. residency requirement, and alleges that he or she is a resident of Finland, develop residence status.
Developing residence status GN
Alien Nonpayment Provisions RS
Residency requirements for alien dependents and survivors outside the U.S. RS
The agreement provides that persons who wish to appeal a decision on a claim for U.S. or Finnish benefits may file the appeal with either country.
01702.500 , Appeals of foreign claims
01702.505 , Representation of applicants in Totalization claims
When a person files for Finnish benefits, the applicant must submit certain types of evidence to support the claim.
Under the agreement with Finland, the Social Security Administration (SSA) will take applications for both regular and Totalization benefits on behalf of Finland and provide limited assistance in obtaining evidence required to support the claim.
The following subsections show the types of evidence SSA personnel may use to support claims for Finnish benefits.
Applicants do not need to resubmit the evidence previously used and verified to establish factors of entitlement for U.S. Social Security benefits. The evidence previously submitted is sufficient for Finland to establish the same factor for Finnish benefits.
The following indicates what entitlement factors claimants must establish in claims for Finnish benefits.
The entitlement factors claimants must establish for Finnish old-age claims are:
age of worker
citizenship (if National Pension benefit claimed)
The entitlement factors claimants must establish for Finnish survivors claims are:
age and death of worker
age and marriage of widow(er) and age and relationship of child (if widow's or widower's benefit claimed)
age and relationship of child (if orphan's benefit claimed)
The entitlement factors claimants must establish for Finnish disability claims are:
degree of disability (medical evidence)
Take the following actions when developing evidence to support claims for Finnish benefits.
Accept any evidence the applicant wishes to submit.
If the applicant does not want to release an original document, photocopy the evidence, return the original to the applicant, and certify the copy. See GN
Do not hold claims for Finnish benefits for prolonged periods pending receipt of evidence.
If an applicant is unable to obtain needed evidence within a reasonable time, transmit the claim to Division of International Operations (DIO) without the evidence.
Complete the Modernized Development Worksheet (MDW) screen to show the date the FO sent the Finnish claim to DIO. Show "Totalization" as the ISSUE; and
Advise the applicant that the responsible Finnish agency will contact him or her directly to obtain any evidence it needs.
00302.000 , Proof of age
00304.000 , Proof of death
00305.000 , Proof of marriage
00306.000 , Proof of parent/child relationship
Document the file to show when SSA already verified in a U.S. claim a factor of entitlement for a Finnish benefit.
Send the claim and a photocopy of the relevant evidence to the Program Service Center (PSC) of jurisdiction. Electronically send a certified photocopy of the relevant evidence with the Finnish claim to DIO.
Indicate on the Finnish benefit claim file any factor of entitlement verified previously for the U.S. claim.
Obtain a record of the NH's U.S. earnings in all claims for Finnish benefits.
When the claimant files for both U.S. and Finish benefits, complete the Modernized Claims System (MCS) screens. The MCS screens will automatically generate a separate U.S. earnings record for the Finnish claim.
When a claimant files for Finnish benefits only, which is a complex MCS exclusion, request an Informational/Certified Earnings Record (ICER) per MS ICER
If the claimant alleges U.S. covered work in the lag period (current and preceding year), obtain proof of unposted paid earnings in the lag period.
In addition to taking the actions in GN 01731.210 D and E above, take the following actions when developing medical evidence for Finnish disability claims.
Accept any medical evidence the applicant wishes to submit. Do not attempt to secure evidence for the claimant or offer advice as to what types of evidence Finland may need.
Send any medical evidence submitted along with the claims file to DIO at the address in GN
Complete the Modernized Development Worksheet (MDW) screen to show the date the FO sent the Finnish claim to DIO.
Transmit the file without medical evidence if it is not readily available.
Advise the claimant that the Finnish agency will contact him or her, if necessary, to obtain needed evidence.
Follow the instructions in GN
01702.415 to process claims for Finnish disability benefits and concurrent title II disability claims.
00301.105 , Certifying evidence for Totalization claims
02101.004 , Informational/Certified Earnings Records - Totalization (ICIC)
03509.011 , Totalization (TOTL) screen
03507.001 , Introduction to SSA-2490 - Overview
00302.000 , Proof of Age
00304.000 , Proof of Death
00305.000 , Proof of Marital Relationship,
00306.000 , Child Relationship and Dependency
01301.000 , Living With, Contributions and One-Half Support
An applicant filing for benefits under the agreement with Finland must complete Form SSA-2490-BK (Application for Benefits Under a U.S. International Social Security Agreement). This is true whether the applicant is filing for benefits only from the United States, only from Finland, or from both countries.
The SSA-2490 is available through MCS, but claims-taking personnel may only use the MCS version when the number holder (NH) is filing for
U.S. retirement or disability Totalization benefits alone, or
U.S. retirement or disability benefits (regular or Totalization) and concurrently for Finnish benefits.
Claims-taking personnel may not
use the MCS version of the SSA-2490 to assist applicants in filing for
Finnish benefits only, or
U.S. or Finnish survivors benefits.
The applicant must use a paper SSA-2490-BK application form in the latter cases. It is not necessary to take an SSA-2490-BK in claims for U.S. auxiliary benefits in life cases since claims-taking personnel completed this form previously in connection with the NH's claim.)
Claimants may file applications for Finnish benefits up to six months in advance of the entitlement date.
Use the following information to determine which applications require completion when taking claims for U.S. Totalization benefits and/or Finnish benefits under the agreement with Finland.
Complete the appropriate retirement or disability benefit MCS application screens,
the TOTALIZATION (TOTL) screen (see MSOM MCS
03509.011 ), and
the SSA-2490 screens (see MSOM MCS
Complete the appropriate MCS application screens,
Part I of the paper or electronic form SSA-2490-BK.
These claims are MCS exclusions. Complete Parts I and II of the paper or electronic SSA-2490-BK application form.
the TOTALIZATION (TOTL) screen (see MSOM ), MCS
the TOTALIZATION (TOTL) screen (see MSOM MCS
03509.011 ), and
Parts I and II of the paper or electronic form SSA-2490-BK.
03507.001, Completing the SSA-2490-BK on MCS
03509.011, Totalization (TOTL)
01702.110, Completing the paper form SSA-2490
In addition to the Form SSA-2490-BK (Application for Benefits Under a U.S. International Social Security Agreement), an applicant for Finnish benefits must complete one or more special Finnish application forms. The forms to be completed vary depending on the type of benefit claimed.
Applicants use the SF/USA 3A to claim National Pension old-age benefits.
Applicants use the SF/USA 3B to claim National Pension survivor benefits.
Applicants use the SF/USA 3C to file claims for Earnings-Related benefits.
Social Security Administration (SSA) personnel do not take the special application forms in the Field Offices (FO). After the Finnish agency receives a claim for Finnish benefits filed with SSA, the Finnish agency with jurisdiction will mail the appropriate Finnish application forms to the applicant. The Finnish agency will include instructions asking the claimant to complete the forms and mail them directly to the Finnish agency at the address shown on the application form along with any needed additional evidence.
If an applicant brings one of the Finnish application forms to the FO, the FO should:
provide any necessary assistance in completing the forms,
photocopy and certify any documents (evidence) the Finnish agency has requested the applicant include with the Finnish claim, and
return the forms (and certified photocopies) to the applicant and advise him or her to mail them directly to the Finnish agency at the address shown on the application form.
Reminder: Do not mail the Finnish application forms to Division of International Operations (DIO).
When the Division of International Operations (DIO) forwards information about a Finnish claim, certified copies of evidence, and a copy of the worker's U.S. coverage record to Finland, the Benefit Earnings Technician (BET) electronically stores the claims material in the Paperless Processing Center (PPC) system in DIO before forwarding the claim to the Finnish agency. The system automatically generates a notice that the BET sends to the applicant.
If an applicant states that he or she has not received notification that DIO forwarded the claim to the Finnish agency and contacts the Social Security Administration (SSA) for the status of his or her claim for Finnish benefits, take the following actions:
Check the PPC system to see if DIO sent the claim to Finland. If PPC does not show whether DIO sent the claim to Finland, advise the applicant to write directly to DIO at the following address:
If PPC shows DIO forwarded the claim to the Finnish agency, advise the applicant to contact the Finnish agency. Applicants can find contact and other information online at:
Finnish Centre for Pensions
DIO is unable to determine the status of a Finnish benefits claim once a technician forwards the claim to Finland.
FOs are able to check PPC through Paperless ROQS (Read Only Query System), which is accessed through iMain.
For more information about status requests in Totalization claims, see GN