Summary of comments on the legislative proposal for a location survey service

Summary of comments on the legislative proposal for a location survey service

The Ministry of Transport and Communications requested comments on a draft government proposal for an act on location information for underground network infrastructure. The consultation period ran from 29 January to 12 March 2026. On 21 April 2026, the Ministry published a summary of the 58 comments received.

The draft proposal would make it easier to determine the location of underground network infrastructure. It would harmonise how network information needed for excavation work and planning is identified, processed and managed, the aim being to reduce excavation damage. The draft proposal would enable network information to be obtained through a single electronic information point. Location survey responses would not contain information about critical infrastructure. The proposal would also introduce several new security requirements.

Respondents welcomed the aim to prevent excavation damage, improve information security and harmonise working practices. However, critical views were expressed especially about the centralised model for the location survey service. Several respondents argued that the objectives of the legislative proposal could be achieved with a lighter, decentralised model, which would offer greater security and cost-effectiveness and be better suited for practical work processes.

Centralised system receives both support and criticism

Under the draft proposal, the network operator could choose whether to operate in a centralised or decentralised system. In a centralised system, network operators would submit their network information in advance to the Finnish Transport and Communications Agency Traficom's system.

In a decentralised system, network operators would manage their own network information. They would submit the requested information based on individual inquiries to Traficom's service. From there, the information would be forwarded to the requesting party as part of the response compiled by Traficom. Only information about the operator's network area would be stored in the authority's service in advance. Network information would be removed from Traficom's system after the location survey request ceased to be valid. Traficom would process and monitor the location survey requests made in the service. In addition, the proposal suggested improving the information security of network information systems.

The comments expressed concern that a centralised system would make Traficom's service more vulnerable in terms of information security due to information being stored in one place. In addition, the approach was believed to significantly increase the administrative work and costs of operators. According to the respondents, obligations would also be assigned unfairly, with the highest costs falling on operators gaining no benefit from the new system.

Many respondents found the time limits of the service to be impractical. From the perspective of network operators, the forecasting requirements and the short response times for providing network information are difficult to implement. Meanwhile, the minimum time limits for submitting a location survey request were considered too long, given the need for faster access to information, for example in construction, maintenance, water supply and incident management. In many comments, compliance with the proposed time limits was expected to delay projects and increase costs.

Several respondents argued that the objectives of the legislative proposal could be achieved with a lighter, decentralised model, which would offer greater security and cost-effectiveness and be better suited for practical work processes.

The comments included both positive and critical observations about obligations related to information security and security clearances. On the one hand, respondents highlighted the need to safeguard access to network information. On the other hand, they considered the proposed obligations to create an unreasonable administrative and financial burden especially for small operators.

What's next?

A compilation of the comments received is available via the Gateway to Information on Government projects. The Ministry of Transport and Communications will continue drafting the act in spring 2026 based on the comments received.

Inquiries:

Lauri Mustonen, Senior Specialist, tel. +358 295 342 252, [email protected]