Businesses that issue performance bonds, advance payment guarantees and other commercial guarantees often look for a licensed non-bank structure in the EU. In Estonia such a company is a financial institution: it does not need a banking licence, but it needs an authorisation from the Financial Intelligence Unit (FIU) before it starts. This guide explains what the authorisation covers, what it does not cover, what the application contains and what it costs with us.
The guide is general information, not legal advice. We read the Credit Institutions Act, the Money Laundering and Terrorist Financing Prevention Act and the State Fees Act in Riigi Teataja on 4 November 2026.
Which guarantees make a company a financial institution
The Credit Institutions Act lists guarantee and surety transactions, and other transactions that create binding obligations for a person in the future, among the financial services (§ 6 (1) 6). A company that is not a bank and whose business is these services is a financial institution. The Money Laundering and Terrorist Financing Prevention Act applies to it as a financial institution within the meaning of the Credit Institutions Act (§ 6 (2) 11), and it needs the FIU's authorisation before it begins.
Typical instruments are performance bonds, advance payment guarantees, financial guarantees and other permitted commercial guarantee and surety transactions, issued to legal entities.
What an FIU authorisation is not
An Estonian FIU authorisation is not a banking licence and does not automatically grant direct SWIFT access or guarantee acceptance of instruments by other financial institutions. Where an instrument such as a standby letter of credit or a documentary letter of credit must be issued or confirmed by a licensed bank, the bank remains responsible for that issuance or confirmation, and banking agreements, accounts, credit facilities and individual transactions remain subject to the bank's decision. If you want to work with banks in that way, our guide on SBLC and bank partners describes the framework that Package B adds.
What the application contains
- The company: a new Estonian private limited company (OÜ) owned by the client, its articles, appointments and beneficial owners.
- The application to the FIU with the business plan and the description of activities.
- The AML/CTF risk assessment and procedures: customer due diligence (KYC), beneficial owners, politically exposed persons, international sanctions, internal control, suspicious transaction reporting.
- The guarantee business: issuance and approval, risk assessment, exposure limits, collateral, liquidity, claims and payments, and contract templates for performance bonds, advance payment guarantees and financial guarantees.
- The people: an FIU contact person who works permanently in Estonia, and the compliance officers' job descriptions. The client appoints the shareholders, the management board and the responsible professionals.
How long it takes
The first complete version of the documentation is ready within one week after we receive all required source information. The official licensing procedure is separate, and its time is set by the supervisory authority. Under the Money Laundering and Terrorist Financing Prevention Act § 71 (1), the FIU decides within 60 days after receiving all required documents and data, and it may extend this to 120 days. The FIU decides on the authorisation. LexorCorp prepares the documents and coordinates the application, but cannot guarantee that the authority will grant it.
What it costs
Package A — company and complete FIU application documentation — costs €17,500 (VAT is added where the law requires it). When you order, you pay 50% of our professional fee. The other 50% is paid after the first complete version of the documentation is ready, and before the final package is handed over.
The following are separate:
- The FIU state fee for a financial institution's authorisation: 3,300 euros (State Fees Act § 269 (1) 2, checked 4 November 2026).
- Other state fees at the official rates.
- Notarisation, apostille, legalisation, translations and courier, at actual cost.
- Independent lawyers, auditors and regulatory specialists.
- Personnel, capital, collateral and IT, which are the client's own costs.
Optional add-ons on the same order:
- An office outside Tallinn (from €450 / month) or in Tallinn (from €650 / month).
- Recruitment of the FIU contact person: €700.
- A search for a new banking partner: €2,000.
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.
- Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
- State Fees Act — Riigi Teataja, English translation
To see which of our services your company needs, open the Business Navigator.
Frequently asked questions
Does a guarantee company in Estonia need a licence?
Yes. Guarantee and surety transactions are financial services under the Credit Institutions Act (§ 6 (1) 6). A company that provides them without being a bank is a financial institution and needs an authorisation from the Financial Intelligence Unit (FIU) before it starts (Money Laundering and Terrorist Financing Prevention Act § 6 (2) 11).
Is an FIU authorisation a banking licence?
No. An Estonian FIU authorisation is not a banking licence and does not automatically grant direct SWIFT access or guarantee acceptance of instruments by other financial institutions.
How long does the FIU take to decide?
The FIU decides within 60 days after receiving all required documents and data and may extend this to 120 days (Money Laundering and Terrorist Financing Prevention Act § 71 (1)). The first complete version of our documentation is ready within one week after we receive all required source information; the official procedure is separate.
Can you guarantee the FIU authorisation?
No. The FIU decides on the authorisation. We prepare the documents and coordinate the application, but we cannot guarantee that the authority will grant it.
What does the office price include?
The monthly price of the premises starts from the amount shown and depends on the premises chosen; security deposits, utilities and associated costs follow the actual lease terms. A licensed company needs genuine premises in Estonia.
Is the contact person's pay included in the recruitment price?
No. The price covers the search and the coordination of the appointment; the contact person's ongoing remuneration is agreed separately at market rates. The FIU contact person must work permanently in Estonia.