Credit institution (bank) licence in Estonia

Only a licensed credit institution may take deposits or other repayable funds from the public in Estonia. The application is filed with Finantsinspektsioon (the Estonian Financial Supervision and Resolution Authority, FI), but the authorisation itself is granted by the European Central Bank (ECB) on FI's proposal. Below: the law, requirements, documents, fees, statutory time limits and what LexorCorp Global OÜ does.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

Under Estonian law, only credit institutions may take deposits from the public or otherwise raise repayable funds from the public¹. "The public" means a circle of persons not determined in advance². In EU law, a credit institution is, among other things, an undertaking that takes deposits or other repayable funds from the public and grants credits for its own account³.

A credit institution may also provide the other financial services the Act lists, such as lending, leasing, payment services, issuing means of payment and e-money, guarantees and securities transactions⁴.

What is not covered: funds received for providing payment services or e-money services are not deposits when e-money is issued for them without delay⁵. A company that is not a credit institution but whose main and permanent activity is services such as lending, leasing or guarantees is a financial institution under the Act⁶.

The legal act and the authority

• Krediidiasutuste seadus (Credit Institutions Act, KAS), version in force from 1 October 2026⁷.
• Council Regulation (EU) No 1024/2013 (the Single Supervisory Mechanism (SSM) Regulation): the ECB is exclusively competent to authorise credit institutions in the participating Member States⁸.
• Regulation (EU) No 575/2013 (the Capital Requirements Regulation, CRR) and Directive 2013/36/EU (the Capital Requirements Directive, CRD).

The Act states that FI issues the licence to a company entered in the Estonian commercial register⁹. Under the SSM Regulation, if the applicant meets all the conditions of national law, the national competent authority adopts a draft decision proposing that the ECB grant the authorisation¹⁰. FI states that the decision to grant the authorisation is made by the ECB on the basis of FI's proposal¹¹.

The licence is valid without a time limit and cannot be transferred¹². FI publishes a granted licence on its website by the next working day¹³. Licensed credit institutions are listed on FI's "Supervised entities" page¹⁴.

Who must apply

Any company that takes deposits or other repayable funds from the public needs the licence¹⁵. A credit institution may operate as a public limited company (aktsiaselts) or a commercial association (tulundusühistu)¹⁶. A bank set up as a public limited company must use the word "pank" (bank) in its business name, and only a credit institution may use that word¹⁷.

The Act exempts an EEA Contracting State, its regional or local governments, international public bodies of which a Contracting State is a member, and legal persons entitled by law to raise funds from the public under supervision protecting depositors and investors¹⁸.

Requirements for the applicant

Capital. A new bank needs paid-in share capital of at least five million euros, counting only amounts actually paid in¹⁹. The CRD also requires refusal where initial capital is below EUR 5 million²⁰. A cooperative bank (ühistupank) that provides no investment services and no cross-border services may have smaller share capital, but at least one million euros²¹. Founding shares are paid only in money, into an account at Eesti Pank or an Estonian credit institution, and not by public subscription²². The CRR own funds ratios are: Common Equity Tier 1 (CET1) 4.5%, Tier 1 6% and total capital 8%²³.

Seat and head office. The registered office and the head office must be in Estonia, and the articles of association must say so²⁴. FI refuses the licence if the applicant intends to operate mainly in another Contracting State²⁵.

Management body. At least two persons must effectively direct the business²⁶. Board and supervisory board members need the knowledge, skills, experience, education, suitability and impeccable reputation to manage a credit institution²⁷. The management board has three members and the supervisory board five, unless the articles provide for more²⁸. Each board member needs higher education and three years of relevant experience; the chair, five years of managerial financial work²⁹.

Key functions. Internal control consists of internal audit, risk control and compliance, each organisationally independent of risk-taking³⁰. Key persons include the chief financial officer and the heads of compliance, risk control and internal audit³¹. The bank needs internal capital and liquidity adequacy assessment processes (ICAAP and ILAAP)³². It must also comply with Regulation (EU) 2022/2554 on digital operational resilience (DORA)³³. FI refuses the licence if the applicant lacks sufficient resources and experience to operate continuously as a credit institution. FI weighs, among other things, the organisational and technical set-up and the business plan³⁴.

Qualifying holdings. A person holding or acquiring a qualifying holding must have an impeccable business reputation and a sufficiently sound financial position, with no reasonable suspicion of a link to money laundering or terrorist financing³⁵. The ECB decides on acquisitions of qualifying holdings on a proposal of the national authority³⁶.

Anti-money laundering and counter-terrorist financing (AML/CFT). Credit institutions are obliged persons under the Money Laundering and Terrorist Financing Prevention Act³⁷. They must prepare a risk assessment and adopt procedural rules and internal control rules³⁸. One board member is made responsible for AML/CFT where there are several³⁹. The board also appoints a contact person of the Financial Intelligence Unit (FIU) who works permanently in Estonia and whose appointment is coordinated with the FIU³⁹.

Documents filed with the application

The board members file a written application with the documents listed in KAS § 13¹(1), in groups⁴⁰:

• Corporate: the articles of association; for a new company, a notarised copy of the memorandum of association and proof that the share capital can be paid in; the group structure⁴⁰.
• Business and finance: a business plan covering at least three years. It covers the business, organisation, internal control, management, financial forecasts, credit and investment policy and risk strategy⁴¹. Also an opening balance sheet with an income and expense overview, and a description of the IT, security and control systems⁴⁰.
• Rules: internal rules (where investment services are planned), the accounting rules and the internal audit charter, or drafts of them⁴⁰.
• People and owners: data on board and supervisory board members and the head of internal audit, with documents on their reliability; data on the auditor; the list of shareholders; for natural-person shareholders above 2%, documents on their financial standing for three years; for legal-person shareholders above 5%, the articles and three years of audited annual reports; data on persons with qualifying holdings⁴⁰.
• Deposit guarantee: a document committing the applicant to pay the one-off contribution to the Guarantee Fund's deposit guarantee sectoral fund⁴⁰.

Commission Delegated Regulation (EU) 2022/2580 details the information required⁴². FI asks for the application in Estonian, or in Estonian and English in parallel⁴³. After the licence, the one-off deposit guarantee contribution is 3,200 euros, payable within one month of the licence decision⁴⁴. Eligible deposits are covered up to 100,000 euros per depositor per credit institution⁴⁵.

State fee and processing time

The fee for an application for a credit institution licence is a procedural fee of 5,000 euros under the Financial Supervision Authority Act⁴⁶.

FI decides within six months of receiving all the required documents and information, but no later than 12 months after receiving the application⁴⁷. FI's draft decision is deemed adopted by the ECB unless the ECB objects within at most ten working days, a period that can be extended once by the same length in duly justified cases⁴⁸. FI may ask for more information, check on site, and leave an incomplete application unexamined⁴⁹. The licence may come with mandatory conditions⁵⁰. These time limits are the law's, not a promise of a decision or a date.

After the licence decision, the board must apply for entry in the commercial register within six months⁵¹.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ offers Package C: regulatory documentation and project coordination for a new credit institution:

• incorporation documents, the licence application and a three-year business plan with financial projections;
• shareholder, beneficial owner, capital and own funds documents, and suitability files for board members and key function holders;
• governance, ICAAP/ILAAP, liquidity, credit, counterparty and operational risk documents;
• AML/CFT, know-your-customer (KYC), sanctions, compliance and internal audit frameworks;
• information security and DORA documents, business continuity, outsourcing, remuneration, conflicts of interest and reporting policies;
• compiling the dossier and coordinating with local legal and regulatory specialists.

The client provides the capital, people, premises, IT and source information, and signs. The site shows a starting ("from") price; the final professional fee is agreed before the service agreement and excludes the capital, state and supervisory fees, independent legal and audit services, staff, premises and banking IT. We do not give legal, tax or audit advice. The authorities decide on the authorisation and its timing; no one can promise the licence or a date.

Order with a price request: order form.

Sources

1. KAS § 4(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
2. KAS § 4(2)–(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
3. Regulation (EU) No 575/2013 Art. 4(1)(1)(a) — text in force from consolidated version 26.06.2026 (current per EUR-Lex)
4. KAS § 6(1) points 2–7 and § 6(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
5. KAS § 4(1¹) (refers to MEAS § 3(1) and § 6(3) services) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
6. KAS § 5(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
7. KAS header of the consolidated text — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
8. Regulation (EU) No 1024/2013 Art. 4(1)(a) — text in force from original text, OJ L 287, 29.10.2013
9. KAS § 13(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
10. Regulation (EU) No 1024/2013 Art. 14(1)–(2) — text in force from original text, OJ L 287, 29.10.2013
11. Finantsinspektsioon, Operating licence of a credit institution — text in force from page as read 11.11.2026
12. KAS § 13(3)–(4) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
13. KAS § 18(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
14. Finantsinspektsioon, Supervised entities — text in force from page as read 11.11.2026
15. KAS § 13(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
16. KAS § 3(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); § 3(1) wording in force from 01.03.2026
17. KAS § 12(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
18. KAS § 4(4) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
19. KAS § 35(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
20. Directive 2013/36/EU Art. 12(1) — text in force from consolidated version 11.07.2026
21. KAS § 44(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); § 44 wording in force from 01.03.2026
22. KAS §§ 23, 24(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
23. Regulation (EU) No 575/2013 Art. 92(1)(a)–(c) — text in force from consolidated version 26.06.2026 (current per EUR-Lex)
24. KAS § 13(2), § 13¹(1¹) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
25. KAS § 15(1) point 6 — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
26. Directive 2013/36/EU Art. 13(1) — text in force from consolidated version 11.07.2026
27. KAS § 48(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); § 48(2) wording in force from 21.07.2026
28. KAS § 56(1), § 53(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
29. KAS § 56(2), § 57 — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
30. KAS § 59(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); § 59 wording in force from 21.07.2026
31. KAS § 48(5⁵) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); in force from 21.07.2026
32. KAS § 63¹(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
33. KAS § 82⁴(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 16); in force from 21.07.2026
34. KAS § 15(1) point 3 and § 15(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
35. KAS § 29¹ points 1, 3 and 5 — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
36. Regulation (EU) No 1024/2013 Art. 15(2)–(3) — text in force from original text, OJ L 287, 29.10.2013
37. RahaPTS § 2(1) point 1 — text in force from 21.07.2026
38. RahaPTS §§ 13(1), 14(1) — text in force from 21.07.2026
39. RahaPTS § 17(1), (2), (5) — text in force from 21.07.2026
40. KAS § 13¹(1) points 1–19 — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
41. KAS § 13²(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
42. Commission Delegated Regulation (EU) 2022/2580 — text in force from original text
43. Finantsinspektsioon, Operating licence of a credit institution — text in force from page as read 11.11.2026
44. Tagatisfondi seadus § 33(1)–(2) — text in force from 21.07.2026
45. Tagatisfondi seadus § 25(2) — text in force from 21.07.2026
46. Finantsinspektsiooni seadus § 45³(1) — text in force from 01.10.2026; § 45³(1) wording in force from 01.07.2024 (RT I, 21.06.2024, 3)
47. KAS § 14(1); Directive 2013/36/EU Art. 15 — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
48. Regulation (EU) No 1024/2013 Art. 14(3) — text in force from original text, OJ L 287, 29.10.2013
49. KAS § 13³(1)–(3), (5) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
50. KAS § 14(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)
51. KAS § 14(4) — text in force from 01.10.2026 (RT I, 11.07.2026, 16)

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
• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• Financial Supervision Authority Act — Riigi Teataja, English translation

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.