This statement has been sent to the Parliament's Administrative Committee's meeting held on 25th of May.
Moniheli ry’s statement on the Government proposal to Parliament for an Act amending the Act on the Promotion of Immigrant Integration and related Acts, HE 74/2026 vp
Moniheli ry thanks the Administration Committee for the opportunity to submit a statement on the proposal. Moniheli considers language learning, support for employment and the clarification of integration pathways to be worthwhile objectives. However, the proposal contains a fundamental contradiction: faster and more binding results are expected from integration at the same time as funding for services is being reduced and responsibilities for organising services are being changed.
In many respects, the proposal has been written from the perspective of central government finances, administrative steering and the efficiency of the service system. The perspective of the end user of the services, that is, the integration client, is identified in the impact assessments, but in several respects it remains secondary to savings targets, the reform of the funding system and an approach that emphasises the individual’s obligations. Moniheli considers that, in connection with the legislative reform, the perspective of service users should be taken into account more strongly than at present.
Integration must not be narrowed down to individual obligations
Integration is not solely a process for which the individual is responsible, but requires a functioning service system, sufficient language and education provision, accessible public authority services, non-discriminatory labour markets and a receptive society. If the resources of the service system are reduced at the same time, emphasising individual responsibility may lead to those in the most difficult situations being left outside services or becoming subject to sanctions in situations where the obstacle is not a lack of individual motivation but the accessibility of services.
Moniheli considers it problematic that integration is viewed primarily through employment, formal education and obligations imposed on the individual. Employment is an important part of integration, but alone it does not describe whether a person becomes attached to society, is able to use services, participates in communities or feels that they belong in Finland.
Voluntary activities can, particularly in a difficult labour market situation, be the only realistic path for many immigrants to participate in society. Immigrants carry out a tremendous amount of voluntary work in associations, which strengthens participation in society, language skills, knowledge of society and social networks. Civic activity taking place in associations is an effective pathway for integration, and should be recognised more strongly than at present in integration structures. For integration to succeed, it is important that legislation and its implementation also recognise forms of participation that are not immediately visible in employment statistics.
Changes to responsibility for education and the implementation schedule
Moniheli draws particular attention to changes in the responsibility for organising education that promotes integration and language skills. This is not merely a technical reform of funding, but a significant systemic change. According to the proposal, the employment authority would be assigned responsibility for organising literacy training. At the same time, funding for education that promotes integration and language skills would be brought together under one channel, the central government transfer for basic public services to municipalities.
Educational institutions providing liberal adult education and basic education for adults have played a significant role, especially in the education pathways of integration clients who have gaps in literacy skills, basic skills or previous education. The expertise of these education providers must be preserved as part of the new system.
Moniheli considers that the proposed entry into force on 1 January 2027 is tight in relation to the scale of the change. Municipalities and employment areas already have a considerable number of new tasks following the 2025 reform of employment services. Sufficient time must be reserved in implementation for procuring education, planning service pathways, ensuring staff competence and building cooperation with current education providers.
Regional accessibility and equality of services
The resources, expertise and education provision of municipalities vary significantly, and changes to funding responsibility and responsibility for organising services may increase regional inequality. The effects of the proposal depend essentially on the actual capacity of municipalities and employment authorities to organise sufficient integration, language and literacy training. The risk of inequality particularly affects integration clients who need long-term and individualised support, such as people with no literacy skills, people with little education, people with a refugee background, disabled integration clients and parents of young children.
Equality of services is not realised if initial-stage integration support, literacy training, multilingual guidance or integration services in Swedish are in practice available only in some municipalities. An integration client’s opportunity to learn a language, receive education that strengthens basic skills and participate in society must not depend unreasonably on their municipality of residence.
Moniheli considers it positive that the proposal strengthens the possibility of integrating in both national languages. However, integration in Swedish is a positive objective only if it is realised in practice as services, education pathways and support for employment.
The position of immigrant women
Moniheli considers it important that the Government proposal identifies specific issues related to immigrant women’s labour market position and access to integration services. Immigrant women’s access to language teaching, education, early guidance and working life is a key issue of gender equality. However, the proposal approaches the position of women with an emphasis on obligations and steering towards the labour market.
Gender equality is not realised merely by imposing the same obligations on women as on men if the service system does not at the same time take into account care responsibilities, the need for childcare, insufficient language and literacy skills, trauma and health backgrounds, and regional differences in the availability of services.
The 40-year age limit for basic education for adults
Moniheli considers problematic the proposal to introduce an upper age limit of 40 years for basic education for adults supported as self-motivated study under the Integration Act. Opportunities to acquire basic skills, literacy skills and complete basic education must not be restricted on the basis of age for people whose education pathway has already been interrupted, for example due to conflict, forced displacement, poverty, gender-based discrimination, care responsibilities or a lack of educational opportunities in the country of origin.
The age limit may have a particularly harmful impact on immigrant women whose education pathway may have been delayed due to childcare, pregnancy and parental leave or other family responsibilities. If a person needs basic education for adults in order to access further education, working life or to strengthen their literacy skills, the need cannot be assessed solely on the basis of age.
Moniheli’s proposed amendment to the legislative proposal
Moniheli proposes that the proposed upper age limit of 40 years for basic education for adults in section 30 of the Integration Act be abandoned. If the age limit is retained, the grounds for derogation in the section should be clarified so that supporting basic education for adults as self-motivated study under the Integration Act is possible whenever it is necessary for the person’s basic skills, literacy skills, further education or employment.
In closing
Moniheli draws attention to the combined effects of changes related to immigration, integration, social security and permanent residence. During the current government term, several reforms have been implemented and prepared that tighten the legal, economic and social position of immigrants. When savings are simultaneously targeted at integration services and individual responsibility is emphasised, the overall effect may be an increase in uncertainty, strain and people falling out of services.
Successful integration does not arise from obligations alone. It arises from a person having a genuine opportunity to learn a language, acquire education, participate in society, be heard, build networks and find their place in Finnish society. Moniheli considers it essential that, in amendments to the Integration Act, this whole is placed ahead of savings and efficiency targets.
Moniheli ry