Consumer Credit Compliance Documents in Estonia

A creditor licence application under the Creditors and Credit Intermediaries Act (KAVS) is assessed not only on the company and its managers but on how it will lend: its credit agreements, its creditworthiness assessment and its treatment of consumers. The same documents are then checked in supervision. This guide explains the lending documents a consumer creditor needs in Estonia and what each of our add-ons delivers.

The guide is general information, not legal advice. The licence is decided by the Financial Supervision Authority; nobody can guarantee it.

Who needs these documents

Any company applying for an Estonian creditor or credit intermediary licence under KAVS needs them, because the application itself must contain credit agreement templates and the creditworthiness assessment methodology as part of its internal rules. A company that only lends to businesses is outside the core scope of KAVS, so it does not need these consumer-facing documents — see who needs a creditor licence for the distinction between consumer and business lending, and between a creditor and a credit intermediary.

The rules the documents implement

Law of Obligations Act §§ 402–416¹ — the consumer credit agreement: pre-contractual information in the standard European form (SECCI), the annual percentage rate of charge, the right of withdrawal within 14 days, early repayment, the rate cap on the APR, and the content of the agreement;
KAVS and the FSA's guidelines on responsible lending — assessing the consumer's creditworthiness from sufficient information, including income, obligations and credit history, before every agreement and before a material increase, and not lending where the consumer is unlikely to be able to repay;
advertising rules — the representative example and the information every credit advertisement must contain.

How the documents are prepared — step by step

We look at the credit product itself: the amount, term, pricing, and whether it is sold as a loan, an instalment plan, leasing or deferred payment, since the form of the product does not change its treatment as consumer credit.
We draft the credit agreement templates and the SECCI pre-contractual information for that product.
We draft the responsible lending policy and, where ordered, the credit scoring rules, matched to the data sources the creditor actually has available.
We draft the consumer credit compliance pack: advertising, the withdrawal and early repayment processes, complaints handling and the treatment of arrears.
The documents are reviewed together so that the agreement, the scoring rules and the compliance pack describe the same lending process consistently, ready to go into the licence application.

The documents and our add-ons

credit agreement templates — from €1,800: consumer and business credit agreements, SECCI, general terms;
responsible lending policy — from €2,600: the creditworthiness assessment rules, data sources, affordability tests and exceptions;
credit scoring set-up — from €5,200: the scoring rules, their documentation and validation, written so the Financial Supervision Authority can follow them;
consumer credit compliance pack — from €3,500: advertising, APR calculation, withdrawal and early repayment processes, complaints and the handling of arrears;
introduction to a debt collection partner — from €2,500: an introduction only, so that overdue claims reach a partner that follows the consumer protection rules; the terms of that cooperation are agreed directly between the creditor and the partner.

These are ordered together with the creditor licence (from €26,000). A company that lends only to businesses does not need a creditor licence — for that we form a lending company without a licence.

Common mistakes

Treating the credit scoring set-up as software. It is the documented method — the data sources and decision rules behind creditworthiness assessment — not a scoring engine; the creditor's own systems or third-party software sit on top of it.
Skipping the compliance pack for a "simple" product. Advertising rules, the APR calculation, withdrawal and early repayment, complaints and arrears handling apply regardless of how small or short the credit is.
Confusing credit intermediation with introducing customers informally. Sending customers to a lender's website for a commission is often credit intermediation in its own right, which needs its own licence from the Financial Supervision Authority, even without granting any credit directly.
Assuming a debt collection partner is part of our licensed service. We only introduce a partner; we do not supervise or guarantee the collection itself.
Not keeping a credit file per consumer. KAVS requires the information and documents used to assess each consumer's creditworthiness to be kept in a file for that consumer, available for the Financial Supervision Authority to review.

What you receive — and what is not included

lending documents that implement the Law of Obligations Act and KAVS for your product;
documents consistent with the licence application and ready for supervision.

Not included: credit scoring or screening software itself, the credit file system used to store consumer data, and the debt collection partner's own fees — the introduction to a partner is only an introduction. Upcoming change: Directive (EU) 2023/2225 on credit agreements for consumers replaces the earlier EU consumer credit directive and applies in Estonia from 20 November 2026, which may change parts of the pre-contractual information and scope described above; see the creditor licence guide for the implementation date.

The amounts are our fees for the standard scope; no VAT is added. All communication takes place by email.

Ready to start? Choose the creditor licence and tick the lending documents you need. Order.

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 (opens in a new tab); the legally binding text is the Estonian one.

Creditors and Credit Intermediaries Act (opens in a new tab) — Riigi Teataja (opens in a new tab), English translation
Law of Obligations Act (opens in a new tab) — Riigi Teataja (opens in a new tab), English translation
Directive (EU) 2023/2225 (opens in a new tab) — EUR-Lex

To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

What must a consumer credit agreement in Estonia include?

The information the Law of Obligations Act §§ 402–416¹ requires, preceded by the standard European consumer credit information (SECCI): the total amount, the annual percentage rate of charge, the costs, the 14-day right of withdrawal and early repayment.

What is responsible lending in Estonia?

Assessing the consumer's creditworthiness from sufficient information — income, obligations, credit history — before every agreement and before a material increase, and not lending when the consumer is unlikely to repay. The creditor documents the rules and the Financial Supervision Authority checks them.

Consumer credit compliance documents in Estonia