Some businesses that work with guarantees, letters of credit or deposits come to the conclusion that they need a bank of their own. This guide sets out what establishing a new credit institution in Estonia or Bulgaria involves, who decides, and how our Package C works.
The guide is general information, not legal advice.
First question: is a bank really needed?
Whether a banking licence is needed depends on the actual business model. Intending to arrange SBLC or LC transactions does not automatically mean that a bank must be established. Many guarantee businesses can use a non-bank financial institution with an FIU authorisation together with partner banks. See the guarantee institution guide and the guide on SBLC and bank partners.
What a new bank needs
- Capital. The initial regulatory capital is generally at least five million euros (Directive 2013/36/EU, Article 12).
- People. Qualified management and supervisory board members, key function holders who pass the suitability assessment, and independent control functions (risk management, compliance, internal audit).
- Substance. Genuine premises and personnel in the country, and suitable banking IT systems.
- Frameworks. Corporate governance, capital and own funds management, ICAAP and ILAAP, liquidity, credit, counterparty and operational risk, AML/CTF and sanctions, and information security under the Digital Operational Resilience Act (Regulation (EU) 2022/2554, DORA).
Who decides
The competent supervisory authorities decide on the authorisation and set its time. In Estonia that is Finantsinspektsioon together with the European Central Bank; in Bulgaria the Bulgarian National Bank together with the European Central Bank. Final submission readiness depends on capital verification, suitability assessments, independent confirmations and the operational arrangements. No service provider can promise the authorisation.
What Package C contains
- The incorporation documentation, the banking licence application and its supporting documents, and a three-year business plan with financial projections.
- Documentation of the shareholders, beneficial owners, capital and own funds, and suitability files for the management, the supervisory board and key function holders.
- The governance, risk, ICAAP and ILAAP frameworks, the AML/CTF, KYC, sanctions, compliance and internal audit frameworks, and procedures for guarantees, SBLCs and LCs.
- DORA and information security documentation, business continuity and crisis plans, and outsourcing, remuneration, conflicts of interest and regulatory reporting policies.
- Compilation of the application dossier, and coordination with local legal and regulatory specialists.
Price
Package C: from €175,000. The final professional fee is agreed according to the country and the banking business model before the service agreement is signed, so you order it with a price request. The following are not included:
- the capital;
- state and supervisory fees;
- independent legal and audit services;
- personnel, premises and IT.
Official sources
The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.
- Regulation (EU) 2022/2554 — EUR-Lex
To see which of our services your company needs, open the Business Navigator.
Frequently asked questions
How much capital does a new bank need?
The initial regulatory capital of a credit institution is generally at least five million euros (Directive 2013/36/EU, Article 12). Capital, people, premises and IT are the client's own; they are not in our fee.
Who decides on a bank licence in Estonia or Bulgaria?
The competent supervisory authorities: in Estonia Finantsinspektsioon together with the European Central Bank, in Bulgaria the Bulgarian National Bank together with the European Central Bank. They also set the time of the procedure; no service provider can promise the authorisation.
Why is Package C ordered with a price request?
Because the final professional fee is agreed according to the country and the banking business model before the service agreement is signed.