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Guide

Credit intermediary licence in Estonia

A business that, for a fee, arranges consumer credit in Estonia or concludes credit agreements on a lender's behalf needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority.

LexorCorp Global OÜ · published 11 November 2026

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Eesti

In short

A business that, for a fee, arranges consumer credit in Estonia or concludes credit agreements on a lender's behalf needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority. This page explains what counts as credit intermediation, who is exempt, what the applicant must have in place, which documents go with the application, and the fee and time limit that the law sets. It covers the credit intermediary only; the creditor licence is a separate licence with its own page.

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A business that, for a fee, arranges consumer credit in Estonia or concludes credit agreements on a lender's behalf needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority. This page explains what counts as credit intermediation, who is exempt, what the applicant must have in place, which documents go with the application, and the fee and time limit that the law sets. It covers the credit intermediary only; the creditor licence is a separate licence with its own page.

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 the Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, "KAVS"), credit intermediation means: arranging credit to a consumer for a fee or pointing the consumer to the possibility of concluding a credit agreement; assisting the consumer in the steps before the credit agreement or at its conclusion; and, independently and on a continuing basis, arranging or concluding agreements for a creditor, in its interest and in its name1. A credit intermediary is a natural or legal person that does not act as a creditor and whose business or profession is intermediating credit to consumers2.

The Act applies to intermediaries that arrange credit to consumers in Estonia in the course of their business or profession3. It also covers a person who arranges credit granted by someone who is not lending in the course of business4. An intermediary of credit secured by residential property is a mortgage credit intermediary2. The advisory service on residential property credit is a separate service that only a creditor or intermediary licensed for it may provide, and no licence is granted for advice alone5. One licence cannot cover both lending and intermediation6. Only a credit intermediary may use the words "krediidivahendaja" or "krediidimaakler", their derivatives or foreign-language equivalents in its business name7.

The legal act and the authority

The activity is governed by the Creditors and Credit Intermediaries Act, in the wording in force from 30 June 20268. To act as a credit intermediary, a legal or natural person must hold an activity licence9. The licence is granted and revoked by Finantsinspektsioon9. It has no expiry date, is not valid for subsidiaries and cannot be transferred10. Licensed intermediaries are entered in the list of creditors and credit intermediaries on Finantsinspektsioon's website ("Licensed credit intermediaries in Estonia")11.

Who must apply, and the main exemptions

Every person whose business is intermediating credit to consumers in Estonia must apply39. The Act itself names these main exemptions:

  • Tied credit agent. An intermediary tied to one creditor, acting only in its name and under its full and unconditional responsibility, needs no licence of its own; the creditor must hold the licence and enters the agent in the list of credit agents12.
  • Credit institutions need no licence to intermediate credit13.
  • Sellers of goods and services that, as an ancillary activity, defer payment for a fee and assign the claim to a factor, or arrange credit, are outside the Act if the factor or creditor is licensed (or a credit institution) and is responsible for compliance14.
  • Subsidiaries of EEA credit institutions under consolidated supervision are subject to only part of the Act and notify Finantsinspektsioon instead of applying, unless they deal with residential property credit or advice15.
  • Payment and e-money institutions fall outside the Act unless the Payment Institutions and E-money Institutions Act provides otherwise16.
  • Public lenders and social-purpose lenders: providers of state guarantees or state business support, and persons lending to a restricted circle for a social purpose on better-than-market terms17.

Requirements for the applicant

Capital. A credit intermediary that is a company must have its share capital fully paid in18. The minimum of 50,000 euros in the Act is set for creditors18.

Client money and insurance. An intermediary that pays out credit or receives consumers' repayments must keep the creditor's and the consumer's money on separate accounts; that money cannot be used in its own business and is not part of its bankruptcy estate19. A mortgage credit intermediary must hold professional liability insurance (or an equivalent guarantee) with at least the cover set in Commission Delegated Regulation (EU) No 1125/2014, and file proof of it with the application20.

Management. A manager may only be a person with the knowledge, skills, experience, education, professional suitability and impeccable business reputation needed to manage the intermediary; the Act lists situations in which the reputation is not impeccable, such as an unspent conviction for an economic or property offence21.

Staff. Managers and staff must have knowledge of the credit agreements offered, of creditworthiness assessment and of the terms of intermediation; the required level is set in the internal rules22. Remuneration principles must avoid conflicts of interest23.

Seat. The registered office and head office must be in Estonia, and the articles of association must say so24.

Internal rules and control. The intermediary must adopt internal rules approved by its management board, including the description of the intermediation process, complaints handling, conflicts of interest, outsourcing, and procedures for international sanctions and anti-money-laundering rules25. It must apply internal control measures and appoint an independent internal auditor26. Activities may be outsourced only on the conditions of the Act, and Finantsinspektsioon must be notified of outsourcing27.

AML/CFT (anti-money laundering and countering the financing of terrorism). A credit intermediary is a financial institution under the Money Laundering and Terrorist Financing Prevention Act28. It must prepare a documented risk assessment, adopt procedures and internal control rules, appoint a management board member responsible for that Act if it has more than one board member, and appoint a contact person for Rahapesu Andmebüroo (the Financial Intelligence Unit)29.

After the licence. The intermediary reports to Finantsinspektsioon quarterly, within one month after the quarter30. The licence may be revoked if activity has not started within six months31.

Documents filed with the application

The application is filed by a management board member (or by the natural person applying) and consists of a written application with the documents in KAVS § 12(1)32. Finantsinspektsioon states that since 18 March 2026 applications are submitted through its application portal33. Grouped:

  • Applicant: articles of association (or a natural person's identification data); proof of paid-in share capital; address of the head office or registered office32.
  • Activity and organisation: an operating plan describing the planned services; the internal rules and accounting rules or their drafts; a description of the information systems and other technical means; a description of the organisational structure, including the use of agents or outsourcing32.
  • AML/CFT: a description of the measures ensuring compliance with anti-money-laundering and terrorist-financing obligations32.
  • People and owners: data on management and supervisory board members; data showing the knowledge, skills and experience of managers and staff; the list of shareholders; data on qualifying holders and controlling persons; data on companies in which the applicant or a manager holds over 20 percent; data on the auditor and internal auditor32. The persons concerned confirm their data with their signature34.
  • Fee: proof of payment of the procedural fee32.

A credit intermediary does not file the business plan or the opening balance sheet and annual reports that a creditor files35. A mortgage credit intermediary adds proof of professional liability insurance or an equivalent guarantee20.

State fee and processing time

The procedural fee for a credit intermediary licence application is 3,000 euros36. Finantsinspektsioon decides within four months after receiving all required documents and data in proper form, but not later than six months after receiving the application; the applicant may consent in writing to an extension37. If the application is incomplete, the authority may leave it unreviewed or require the gaps to be remedied, and it may ask for additional information and documents; a material change during the procedure may restart the time limit38. These are the law's time limits, not a promise of a date or of a decision. After a refusal, a new application may not be filed for three months39.

What LexorCorp Global OÜ does and how to order

The site sells this work as the general row "Activity licence application documentation" in the licensed-companies service: from €3,500, one-time; LexorCorp Global OÜ is not registered for VAT, so no VAT is added40. The work covers the requirements of the Act for the activity, taken from its official text, preparation of the application documents, the submission and the written follow-up of the authority's questions40. The price is a professional fee; it is not the price of the licence and does not include the state fee, capital or third-party costs, which the client pays40. LexorCorp Global OÜ does not give legal, audit or tax advice and cannot promise the licence, a date or the authority's decision: the licence is granted by Finantsinspektsioon.

Order: order form

Sources

  1. KAVS § 4 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  2. KAVS § 6(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  3. KAVS § 2(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  4. KAVS § 2(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  5. KAVS § 7(1)-(2), § 11(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  6. KAVS § 11(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  7. KAVS § 8(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  8. Riigi Teataja header of KAVS; English name per Finantsinspektsioon page — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  9. KAVS § 10(2), (6) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  10. KAVS § 10(7)-(8) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  11. KAVS § 20(1); fi.ee Credit intermediaries page — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  12. KAVS § 10(3), § 21(1), § 25(1),(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  13. KAVS § 10(4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  14. KAVS § 2(9) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  15. KAVS § 2(8), § 20(1¹) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  16. KAVS § 2(10) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  17. KAVS § 2(5) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  18. KAVS § 54(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  19. KAVS § 55(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  20. KAVS § 55(4),(6); § 12(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  21. KAVS § 39(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  22. KAVS § 40(2)-(3), § 38(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  23. KAVS § 43(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  24. KAVS § 37(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  25. KAVS § 44(1), (3) p 8, 12, 14, 15, 16 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  26. KAVS § 45(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  27. KAVS § 46(1), (10) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  28. RahaPTS § 6(2) p 8; § 2(1) p 2 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
  29. RahaPTS § 13(1),(4), § 14(1), § 17(1)-(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
  30. KAVS § 57(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  31. KAVS § 18(2) p 1 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  32. KAVS § 12(1) p 1-18 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  33. Finantsinspektsioon, Operating licence of a credit intermediary — text in force from page last edited 18.03.2026
  34. KAVS § 12(4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  35. KAVS § 12(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  36. Finantsinspektsiooni seadus § 45³(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 12)
  37. KAVS § 15(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  38. KAVS § 14(1),(3),(4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  39. KAVS § 12(5) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  40. LexorCorp Global price list and service description (price list)

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.

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.

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We prepare the application documents and manage the process; the authority decides. Not legal advice.

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