A company that lends money to consumers in Estonia, or arranges consumer loans for others, needs an activity licence from the Financial Supervision Authority (Finantsinspektsioon). The licence is granted under the Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS). This guide explains who needs the licence, the difference between a creditor and a credit intermediary, the capital requirement, what the application contains, the responsible lending rules that the authority will look for in your documents, and the state fee. Our prices are on the credit licensing page.
The rules below are those of KAVS in the wording in force from 30 June 2026 (Riigi Teataja). The guide is general information, not legal advice.
Who needs a creditor licence
KAVS applies to creditors and credit intermediaries established and operating in Estonia, and to foreign creditors and intermediaries and their Estonian branches, that in the course of their economic or professional activity grant or arrange credit to consumers in Estonia (KAVS § 2(1)). Granting credit means granting credit in the sense of the Law of Obligations Act, deferred payment for a fee, leasing or other financial assistance, including concluding credit agreements in one's own name and for one's own account (§ 3).
Two points follow from this. First, the Act is about consumer credit: a company that only lends to businesses is outside its core scope, although other rules — for example on anti-money laundering — still apply. Second, the form of the product does not matter much: instalment plans, leasing and deferred payment for a fee can all be credit.
Creditor or credit intermediary
A creditor grants credit itself. A credit intermediary arranges credit for a fee, points consumers to the possibility of concluding a credit agreement, assists them before or at the conclusion of the agreement, or concludes credit agreements on behalf of a creditor (§ 4). Both need a licence from the Financial Supervision Authority, but the application of an intermediary is lighter: some documents required from a creditor need not be submitted by an intermediary (§ 12(2)).
If your business sends customers to a lender's website for a commission, it is worth checking early whether that activity is credit intermediation — it often is.
Capital
The share capital of a creditor, and of a credit intermediary that is a company, must be fully paid in (KAVS § 54(1)). For a creditor the share capital must be at least 50,000 euros (§ 54(2)). The Act sets no separate minimum amount for a credit intermediary. A credit intermediary that disburses credit or receives consumers' money must also keep that money separately and hold liability insurance (§ 55).
The capital belongs to the company and must stay available. It is not a fee and not part of our price.
What the application contains
The application is submitted by a member of the management board (or by the natural person who wants to act as an intermediary) and consists of a written application and the documents listed in § 12(1). In substance these are:
- the articles of association and the company details;
- a business plan meeting the requirements of § 13 — the nature of the business, the planned services, the persons involved and their responsibilities, and forecasts of income, costs and the development of the business;
- information about the management board and supervisory board members, and proof that the managers and employees have sufficient knowledge, skills and experience;
- information about the shareholders with a qualifying holding;
- the internal rules — among them the methodology for assessing consumers' creditworthiness;
- the address of the head office or registered office; and
- proof of payment of the procedural fee under § 45³(2) of the Financial Supervision Authority Act.
Responsible lending: what the authority will look for
The core of a consumer-credit licence application is the responsible lending framework. A creditor or intermediary must keep a credit file for each consumer containing the information and documents collected to assess creditworthiness (KAVS § 48). It must set out in its internal rules a methodology for assessing creditworthiness and checking the information provided, taking into account at least the consumer's financial situation and regular income, other financial obligations and payment history (§ 49). It obtains the information from the consumer, from relevant internal sources and from databases (§ 50).
These rules are linked to the Law of Obligations Act: the responsible lending principle and the obligation to assess creditworthiness in § 403⁴, and the maximum cost of credit in § 406². Breaches are punishable by fines of up to 1,000,000 euros for a legal person (KAVS § 99). A credit scoring model, a responsible lending policy and credit agreement templates that match the Law of Obligations Act are therefore not optional extras: they are what the authority reads first. We offer them as add-ons on the credit licensing page.
Upcoming change: the new Consumer Credit Directive
Directive (EU) 2023/2225 on credit agreements for consumers replaces the earlier consumer credit directive. Member States had to adopt their implementing laws by 20 November 2025 and must apply them from 20 November 2026 (Article 48, EUR-Lex). The Estonian implementation may change parts of the rules described above — for example the scope of products covered and the information to consumers. We check the wording in force at the time of your application.
State fee
The Financial Supervision Authority charges a procedural fee for a creditor or credit intermediary licence application: 3,000 euros in the wording of the Financial Supervision Authority Act in force on 29 September 2026 (§ 45³(2), Riigi Teataja). After authorisation the company pays supervision fees. Our guide to state fees and capital for EU licences puts this fee next to those for other licences.
Creditor licence or lending company formation
On our licensed companies page, "Lending company formation — corporate structure only, no creditor licence" is exactly that: an Estonian company set up for a lending business, without the licence. It suits business lending or a project that will apply for the licence later. The creditor licence itself is a separate line on the credit licensing page. If borrowers fall behind, a lender often works with a credit servicer — see our guide to the Estonian credit servicer licence.
How we work
We start with your product: who the borrowers are, what the credit looks like, how it is sold and how it is funded. From there we prepare the business plan, the internal rules and the creditworthiness methodology, coordinate the information about managers and shareholders, submit the application with you and manage the authority's questions. Every project starts with a written quote by email. Our fee is our professional fee for the work described. It is not the price of a licence; the Financial Supervision Authority grants or refuses the licence, and we cannot promise the outcome or its timing.
After the licence
A licensed creditor or credit intermediary is supervised by the Financial Supervision Authority for as long as it holds the licence. In practice this means keeping the credit files and the creditworthiness methodology up to date, reporting to the authority in the forms it sets, notifying changes of managers and qualifying shareholders, paying the annual supervision fee and keeping the share capital at the required level. The licence ends, among other cases, when it is revoked or when the company merges into a company that is not a creditor (KAVS § 17). Planning these running costs is part of the business plan the authority reads.
Frequently asked questions
How much share capital does an Estonian creditor need?
At least 50,000 euros, fully paid in, under KAVS § 54(2).
Does a credit intermediary need capital?
Its share capital must be fully paid in, but the Act sets no separate minimum amount. An intermediary that handles consumers' money must keep it separately and hold liability insurance.
Do I need a licence to lend only to companies?
KAVS covers credit to consumers. Business-only lending is outside its core scope, but the details of your model matter; we check them in the quote.
What is the state fee for a creditor licence?
3,000 euros under § 45³(2) of the Financial Supervision Authority Act, in the wording in force on 29 September 2026.
Will the new Consumer Credit Directive change the rules?
Directive (EU) 2023/2225 must be applied from 20 November 2026, and the Estonian implementation may change parts of the rules. We check the law in force when you apply.