Credit Servicer Authorisation Documents (KIOS)

A company that services consumer credit agreements on behalf of a credit purchaser — collects payments, renegotiates terms, handles complaints — needs an authorisation as a credit servicer from the Financial Supervision Authority under the Credit Servicers and Credit Purchasers Act (krediidiinkassoteenuse osutajate ja krediidiostjate seadus, KIOS), which implements Directive (EU) 2021/2167. The application must contain a fixed set of documents. This guide lists them and explains which of our add-ons are mandatory with the application.

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

Who needs a credit servicer authorisation

A company needs this authorisation if its main and permanent business is credit servicing activity on a defaulted credit agreement of a credit institution or a licensed creditor — collecting or recovering payments, negotiating with the borrower, handling complaints, or informing the borrower of changes in interest, charges or payments due — whether it does this for itself or on behalf of a credit purchaser that bought the claim. See the Estonian credit servicer licence for the full definition and the distinction from ordinary debt collection of non-credit debts, which falls outside KIOS.

How the application is prepared — step by step

We confirm that the activity is credit servicing within KIOS at all — who the creditors are, whether the agreements are in default, and whether the servicer will receive and hold borrowers' money.
We draft the business plan and the internal rules and internal control system together, so that the organisation described in one matches the governance described in the other.
We draft the complaints procedure, the fit and proper file for the managers, the qualifying holding information and the description of the IT systems.
Where the servicer will hold borrowers' funds, we add the payment account requirements.
We file the application and manage the Financial Supervision Authority's questions until it decides.

The documents the application must contain

Business plan (KIOS § 8) — the services, the types of credit agreements serviced, the credit purchasers you will work for, the organisation, and financial projections. Our business plan: from €2,800.
Internal rules and internal control system (KIOS §§ 41–42) — governance, risk management, compliance, conflicts of interest, outsourcing, record keeping and the treatment of borrowers. Internal rules: from €3,600.
Complaints handling procedure (KIOS § 60) — how borrowers' complaints are received, answered within the set time and recorded. Complaints procedure: from €1,700.
Fit and proper assessment of the managers — the management board and, where there is one, the supervisory board: reputation, knowledge, experience, criminal records. Fit and proper file: from €2,400.
Qualifying holdings (KIOS § 29) — the persons with a qualifying holding, their suitability and the source of the funds. Qualifying holding information: from €1,600.
IT systems — the systems used for servicing, data protection and security. Description of IT systems: from €1,800.

These six are added automatically when you choose the credit servicer authorisation (from €24,000) in our order form — an application without them is incomplete.

The optional document

If the credit servicer receives and holds borrowers' payments before passing them to the credit purchaser, KIOS § 47 requires a separate payment account and rules for it. The payment account requirements (from €1,400) are needed only in that model.

After authorisation

A credit servicer reports to the Financial Supervision Authority periodically. Our supervisory reporting service (from €2,400 / year) prepares the reports for twelve months. See also the credit servicer licence and supervisory reporting after authorisation.

Common mistakes

Assuming outsourcing removes the need for a licence. A credit servicer may outsource parts of its servicing activity to a credit servicing service provider, but the outsourcing agreement itself becomes part of the application, and the servicer stays responsible for complying with KIOS.
Confusing credit servicing with debt collection generally. KIOS covers defaulted credit agreements of credit institutions and licensed creditors specifically; a company that collects unpaid utility, telecom or other non-credit invoices is not a credit servicer within KIOS, though other rules still apply to it.
Leaving the payment account question until late. Whether the servicer will receive and hold borrowers' money changes the document list (KIOS § 47) and the bank discussion; it is worth deciding the servicing model before the application is drafted.
Treating the complaints procedure as a formality. KIOS § 60 requires complaints to be resolved quickly through an effective and transparent process, and it is one of the first documents the authority reads.
Assuming the licence travels with the group. The authorisation is issued to one company, is not valid for its subsidiaries and cannot be transferred.

What you receive — and what is not included

a complete application with all documents KIOS requires, written for your business;
filing and answers to the authority's questions until the decision.

Not included: the state fee and the annual supervision fee, the share capital the company must hold, the payment account itself (opened by a bank or payment institution at its own discretion), and, where used, the fees of an outsourced credit servicing service provider or of the auditor and internal auditor named in the application.

The amounts are our fees for the standard scope; no VAT is added. They do not include the state fee for the application, which the applicant pays. All communication takes place by email.

Ready to start? Choose the credit servicer authorisation: the documents the application needs arrive ticked. 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.

Credit Servicers and Credit Purchasers Act (opens in a new tab) — Riigi Teataja (opens in a new tab), English translation
Directive (EU) 2021/2167 (opens in a new tab) — EUR-Lex

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

Frequently asked questions

Which documents are mandatory in a credit servicer application?

The business plan (KIOS § 8), internal rules and internal control (§§ 41–42), the complaints procedure (§ 60), the fit and proper file of the managers, qualifying holding information (§ 29) and the description of the IT systems. They arrive ticked in our order form; you can untick any of them.

When does a credit servicer need a payment account?

When it receives and holds borrowers' payments before passing them to the credit purchaser. KIOS § 47 then requires a separate payment account and rules for it; otherwise the document is not needed.

Credit servicer authorisation: the application documents