Credit servicer authorisation in Estonia (KIOS)

A company whose main business is collecting, renegotiating or administering defaulted loans granted by banks or licensed creditors needs an activity licence from the Estonian Financial Supervision Authority (Finantsinspektsioon). The rules are in the Credit Servicers and Credit Purchasers Act, which transposes the EU directive on credit servicers and credit purchasers.

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 credit servicing is

Under the Act, a credit servicer (krediidiinkasso) is a company whose main and continuous business includes credit servicing activities: it manages a non-performing credit agreement of a credit institution or creditor, either for itself or on behalf of a credit purchaser¹. Credit servicing activity means one or more of the following in relation to such an agreement: collecting payments due from the debtor; negotiating with the debtor about the claims or the terms of the agreement, including on the credit purchaser's instructions; handling claims and complaints related to the agreement; and informing the debtor of changes in the claims, interest rates, fees or payments².

A credit servicer may operate only as a public limited company (aktsiaselts, AS) or a private limited company (osaühing, OÜ). It may outsource parts of its servicing activities to a third party, called a credit servicing service provider³. A credit purchaser is a person who, in the course of business, acquires a non-performing credit agreement, or a claim under it, from a credit institution or creditor⁴.

Not covered: a person who only passes on payment default data and does no other servicing activity is not a credit servicer⁵; the Act also does not apply to notaries, bailiffs, trustees in bankruptcy and attorneys, or where the credit was granted by a person other than a credit institution and the debtor is not a consumer⁶.

The legal act and the authority

Act: Credit Servicers and Credit Purchasers Act (krediidiinkassode ja -ostjate seadus, KIOS), in the wording in force from 30 June 2026⁷. It implements Directive (EU) 2021/2167 of the European Parliament and of the Council of 24 November 2021 on credit servicers and credit purchasers and amending Directives 2008/48/EC and 2014/17/EU⁸.
Authority: the Financial Supervision Authority (FSA) grants and revokes the licence by its decision⁹. The licence is issued for an unlimited term, does not extend to subsidiaries and cannot be transferred¹⁰.
Register: an authorised credit servicer is entered in the list of credit servicers on the FSA's website, and is deleted from it when the licence ends or is revoked¹¹.

Who must apply

To operate as a credit servicer, an activity licence is required¹². The main exemptions named in the Act:

A credit institution, creditor or credit intermediary established in a state of the European Economic Area (EEA) that services credit is not treated as a credit servicer¹³.
The Act does not apply to credit servicing of a credit agreement concluded with a credit institution or creditor established in a third country, unless the agreement or claim is transferred to one established in the EEA; to acquisition by an EEA credit institution; or to non-consumer credit granted by a non-bank, as noted above⁶.
A credit servicer authorised in another EEA state may service credit in Estonia through a branch or cross-border on the basis of its home-state licence, after notifying the FSA through its home-state supervisor. It may start from the earlier of receiving its home supervisor's notice that the FSA has acknowledged the information, or, if the FSA has not sent that acknowledgement, two months after the information was submitted to the FSA¹⁴.
A person established in a third country may not carry on credit servicing in Estonia, either cross-border or through a branch¹⁵.

An Estonian credit servicer that wants to service credit in another EEA state, by a branch or cross-border, notifies the FSA with the information the Act lists. Where it services non-performing agreements of credit institutions, the FSA forwards the information to the host state supervisors within 45 days¹⁶. Activity in a third country requires a separate FSA permit¹⁷.

Requirements for the applicant

Capital. The share capital must be at least 25,000 euros and fully paid in¹⁸.

Seat and place of business. The registered office and the place of permanent and continuous business must be in Estonia, and the articles of association must state that the registered office and head office are in Estonia¹⁹. The FSA may refuse the licence if the planned place of permanent business is not in Estonia²⁰.

Management body. The management board must have at least two members; a supervisory board, where there is one, at least three, and the FSA may require one²¹. A manager must have an impeccable reputation; the managers together must have sufficient knowledge and experience, and each must have enough time for the role²². Each manager files written consent with the information and documents the Act lists, including a criminal record extract not older than three months²³.

Qualifying holders. A qualifying holding is a direct or indirect holding of at least 20 per cent of the share capital or voting rights, or one that allows significant influence over management²⁴. Information on such holders is filed with the application²⁵.

Internal rules and internal control. The management board adopts internal rules that cover, among other things, conflicts of interest, fit-and-proper assessment of managers, outsourcing, IT and fund-holding security, risk management, accounting, complaints and fair treatment of debtors²⁶. An adequate internal control system is required, and an internal auditor (or a person performing that function) is appointed²⁷.

AML/CFT. The FSA may revoke the licence if the servicer or its manager breaches international sanctions or anti-money laundering and counter-terrorist financing (AML/CFT) rules²⁸. Which AML/CFT duties apply to the business model is specified for the client's case.

Outsourcing. Outsourced servicing requires a written agreement, the servicer remains fully responsible, and the FSA is notified before outsourcing²⁹.

Debtors' funds and complaints. If the servicer receives debtors' payments, it must keep them on a separate payment account, not use them in its own business, and open that account only with a credit institution established in Estonia or another EEA state³⁰. Complaints must be answered within 15 days for consumers and 30 days for legal persons, and no fee may be charged for handling them³¹.

Documents filed with the application

The application is filed by the management board members of an existing company, with a written request and the documents listed in KIOS § 7³²:

Company: articles of association; amount of share capital and proof of payment; address of head office or registered office.
Business: a business plan meeting § 8, covering at least three years³³; description of the organisational structure; description of the IT systems and other technical means; where relevant, the outsourcing agreement.
People: data on management and supervisory board members; criminal record extracts for managers and qualifying holders, not older than three months; § 29 information on qualifying holders; data on the audit firm and internal auditor.
Rules: internal rules meeting §§ 41 and 42, including accounting rules and the internal control procedure; complaint-handling procedures meeting § 60.
Funds: whether the applicant wishes to receive and hold debtors' funds, and if so, the details of a payment account meeting § 47.
Proof of payment of the procedural fee.

State fee and processing time

The procedural fee for a credit servicer licence application is 3,000 euros³⁴. After authorisation, a credit servicer pays a supervision fee to the FSA³⁵.

Within 45 days of receiving the application, the FSA assesses whether it contains all required information and documents³⁶. It may request additional information and documents, and may leave an incomplete application unreviewed³⁷. It decides within three months of receiving all necessary information and documents, but not later than six months after receiving the application³⁸. These are the time limits of the law, not a promise about any individual application; a material change during the proceedings may restart the term³⁹.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application for authorisation as a credit servicer under KIOS and the documents it requires, and manages the procedure with the FSA until its decision. The service includes the business plan (KIOS § 8), the internal rules and internal control system (§§ 41–42), the complaints procedure (§ 60), the fit-and-proper file of the managers, the qualifying holding information (§ 29) and the description of the IT systems; the business plan and internal rules can also be ordered as separate documents. The client provides the information, capital and people the law requires, signs the application and answers the authority's questions.

Not included: state fees, IT systems, legal advice, audit and tax advice. LexorCorp's own FIU licence (FIU000117) covers its trust and company services and does not authorise the client. The licence is granted or refused by the FSA; no one can promise the licence, its date or the authority's decision.

Order: credit licensing page.

Sources

Credit Servicers and Credit Purchasers Act (KIOS) § 3(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 3(2) points 1–4 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 3(3) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 3(5) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 3(4) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 2(4) points 1–4 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) Riigi Teataja header; official English title — text in force from 30.06.2026
KIOS footnote 1; EUR-Lex title — text in force from n/a (OJ L 438, 8.12.2021)
Credit Servicers and Credit Purchasers Act (KIOS) § 6(4) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 6(2)–(3) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 15(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 6(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 2(2) second sentence — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 24(1), (3) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 25 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 18(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 19(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 46(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 35(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 11(1) point 6 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 36(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 37(1), (5), (6) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 39(1) incl. point 5 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 26(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 7(1) point 7 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 41(1), (4) points 4, 5, 6, 8, 9, 11, 14, 15 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 42(1), (3) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 13(1) point 8 — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 43(1), (3) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 47(1)–(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 60(2), (5) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 7(1) points 1–15, § 7(2) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 8(2) — text in force from 30.06.2026
Financial Supervision Authority Act § 45³(2) — text in force from 01.10.2026
Financial Supervision Authority Act § 38(2) — text in force from 01.10.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 9(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 9(2), (3), (7) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 10(1) — text in force from 30.06.2026
Credit Servicers and Credit Purchasers Act (KIOS) § 9(5) — text in force from 30.06.2026

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.

Credit Servicers and Credit Purchasers Act — Riigi Teataja, English translation
Directive (EU) 2021/2167 — EUR-Lex
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.