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Guide

Estonian creditor and credit intermediary licence (KAVS)

A company that lends money to consumers in Estonia, or arranges consumer credit for a lender, needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority (FSA). The licence is granted under the Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS). Below: who needs it, the requirements, the application and the fee.

LexorCorp Global OÜ · published 11 November 2026

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Eesti

In short

A company that lends money to consumers in Estonia, or arranges consumer credit for a lender, needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority (FSA). The licence is granted under the Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS). Below: who needs it, the requirements, the application and the fee.

Order the application documents: Order

A company that lends money to consumers in Estonia, or arranges consumer credit for a lender, needs an activity licence from Finantsinspektsioon, the Estonian Financial Supervision Authority (FSA). The licence is granted under the Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS). Below: who needs it, the requirements, the application and the fee.

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

KAVS applies to creditors and credit intermediaries established and operating in Estonia, and to foreign creditors and intermediaries and their Estonian branches, that grant or arrange credit to consumers in Estonia in the course of their economic or professional activity1. A consumer is the person defined in § 1(5) of the Law of Obligations Act (võlaõigusseadus, VÕS)2.

Granting credit covers a credit agreement in the sense of VÕS § 401(1)–(2), deferred payment for a fee, leasing and other financing, including concluding credit agreements in one's own name and for one's own account3.

Credit intermediation means arranging credit for a consumer for a fee or pointing a consumer to the possibility of a credit agreement, assisting the consumer in the steps before or at the conclusion of the agreement, or independently and permanently arranging or concluding agreements on behalf of a creditor4.

A creditor may operate as a public limited company (AS), a private limited company (OÜ) or, under the Savings and Loan Associations Act, a cooperative5. Lending under residential-property consumer credit agreements (mortgage credit) needs a licence covering that activity6.

The legal act and the authority

The licence requirement is in KAVS: a creditor must hold an activity licence7, and so must a credit intermediary, whether a legal or a natural person7. The FSA grants and revokes the licence by its decision; the licence has no end date, does not extend to subsidiaries and cannot be transferred8. One licence cannot cover both granting and intermediating credit9.

The FSA announces a grant on its website by the working day after the decision enters into force10; licensed creditors and intermediaries appear in the list of creditors and credit intermediaries on the FSA website11.

Who must apply, and who is exempt

Every business granting or arranging consumer credit in Estonia must apply unless an exemption applies7. The main exemptions:

  • Credit institutions and Estonian branches of foreign credit institutions12.
  • Payment and e-money institutions granting credit under § 5(4) of the Payment Institutions and E-money Institutions Act13.
  • A credit agent tied to one creditor; that creditor must hold the licence14.
  • State guarantee and state business support providers, and social-purpose lenders to a limited circle at below-market terms15.
  • Sellers offering paid deferred payment as a side activity and assigning the claim to a factor, or arranging credit, where the factor or creditor is a bank or licensed creditor answerable for the KAVS and VÕS duties16.
  • Subsidiaries of EEA credit institutions under consolidated supervision: only listed provisions apply, and the FSA is notified five days before starting17.

Requirements for the applicant

Capital. The share capital of a creditor, and of an intermediary that is a company, must be fully paid in18. A creditor's share capital must be at least EUR 50,00018.

Seat and head office. The registered office and the head office must be in Estonia, and the articles of association must say so19. The FSA may refuse a licence if the applicant intends to operate mainly in another EEA state20.

Management body. Management and supervisory board members need the knowledge, skills, experience, education, professional suitability and impeccable business reputation to manage a creditor; an unspent conviction for an economic or property offence, an international sanction or usury rules this out21. The FSA must be notified at least ten days before a manager is elected or appointed22.

Staff and internal organisation. Managers and staff must know the products, credit agreements and creditworthiness assessment23. The management board approves internal rules that cover among other things the creditworthiness methodology, pre-contractual information, cost of credit, complaints, internal control, conflicts of interest, outsourcing, sanctions and AML procedures and a whistleblowing channel24. Internal control and an independent internal auditor are required25. The pay of the person responsible for creditworthiness assessments may not depend on the number or share of approved applications26.

Responsible lending. VÕS § 403⁴ requires a creditworthiness assessment before the agreement27. KAVS requires a credit file for each consumer28, a methodology covering at least assets, regular income, other obligations and payment history29, and verification of the information30. A consumer credit agreement is void if its annual percentage rate of charge exceeds three times the average rate published by Eesti Pank31. Breaches can be fined up to EUR 1,000,000 for a legal person32.

Qualifying holders. A qualifying holding is a direct or indirect holding of at least 20% of the capital or votes, or one giving significant influence33; data on these persons are part of the application34.

AML/CFT. A creditor or credit intermediary is a financial institution under the Money Laundering and Terrorist Financing Prevention Act (RahaPTS)35. It needs a risk assessment, procedural and internal control rules, a responsible board member (if the board has several members) and a contact person of the Financial Intelligence Unit36.

Outsourcing and IT. Outsourcing follows KAVS § 46: credit granting only to a licensed creditor, full responsibility stays, the FSA is notified37. The application describes the IT systems used for the services34.

Documents filed with the application

A member of the management board submits a written application with the documents listed in KAVS § 12(1)34. Grouped:

  • Company: articles of association; shareholder list with holdings and votes; data on qualifying holders and controlling persons; data on companies in which the applicant or a manager holds more than 20% or control; proof of paid-in share capital; opening balance sheet and any latest financial statements and last three annual reports34.
  • Business: a business plan meeting § 13; an operating plan describing the planned services; the organisational structure, including any use of intermediaries or outsourcing; the address of the head office or registered office34. The business plan covers at least three years and confirms that the applicant has no tax debt and that no bankruptcy proceedings have been initiated against it38.
  • People: data on each management and supervisory board member and evidence of the knowledge, skills and experience of managers and staff; data on the auditor and the internal auditor34. Each person signs their own data39.
  • Rules and systems: the internal rules under § 44 and the accounting rules (or their drafts); a description of the IT systems; a description of the AML/CFT measures34.
  • Fee: proof of payment of the procedural fee34.

A credit intermediary does not file the business plan or the financial statements40. From 18 March 2026 applications are submitted through the FSA application portal41.

State fee and processing time

The procedural fee for a creditor or credit intermediary licence application is EUR 3,00042.

The FSA decides within four months of receiving all required documents and data in due form, but no later than six months from receiving the application; the applicant may agree in writing to extend the term43. If the application is incomplete the FSA may require the gaps to be remedied or leave it unreviewed44, and it may ask for additional information and documents44. A material change during the procedure may restart the time limit45. These are the law's limits, not a promise. After a refusal, a new application cannot be filed for three months46.

The rules may change: Directive (EU) 2023/2225 on consumer credit had to be transposed by 20 November 2025 and applies from 20 November 202647.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application for an activity licence as a creditor under KAVS and manages the FSA's questions until the decision48. It prepares the application, the business plan, the internal rules and internal control system, the creditworthiness and responsible lending rules, the complaints procedure, credit agreement templates with the pre-contractual information form (SECCI) and the AML/CFT rules48. The client provides company documents, proof of premises, data on managers and qualifying holders, the product description and funding sources48.

The fee is from €26,000 (no VAT is added). It is a professional fee for the work described, not the price of a licence, and does not include state or supervisory fees, the share capital or third-party costs49. LexorCorp Global does not give legal or tax advice and does not audit. The licence is granted or refused by the FSA; LexorCorp Global cannot promise a licence, its timing or the authority's decision.

Order on the service page: order form.

Sources

  1. KAVS § 2(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  2. KAVS § 2(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  3. KAVS § 3 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  4. KAVS § 4 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  5. KAVS § 5(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  6. KAVS § 5(3), § 11(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  7. KAVS § 10(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  8. KAVS § 10(6)-(8) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  9. KAVS § 11(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  10. KAVS § 19(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  11. KAVS § 20(1); FSA page 'Creditors' (lists 'Licensed creditors in Estonia') — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  12. KAVS § 10(4), § 2(7) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  13. KAVS § 10(5), § 2(10) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  14. KAVS § 10(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  15. KAVS § 2(5) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  16. KAVS § 2(9) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  17. KAVS § 2(8), § 20(1¹) — 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 § 37(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  20. KAVS § 16(1) p 5 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  21. KAVS § 39(1), (2) p 6 — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  22. KAVS § 41(4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  23. KAVS § 40(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  24. KAVS § 44(1), (3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  25. KAVS § 45(1)-(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  26. KAVS § 43(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  27. VÕS § 403⁴(1) — text in force from 01.09.2026
  28. KAVS § 48(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  29. KAVS § 49(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  30. KAVS § 50(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  31. VÕS § 406²(1) — text in force from 01.09.2026
  32. KAVS § 99(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  33. KAVS § 28(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24); § 28(1) wording from 01.03.2026
  34. KAVS § 12(1) — text in force from 30.06.2026 (RT I, 20.06.2026, 24); § 12(1) last amended RT I, 11.11.2025, 1 (from 21.11.2025)
  35. RahaPTS § 6(2) p 8, § 2(1) p 2 — text in force from 21.07.2026
  36. RahaPTS § 13(1), § 14(1), § 17(1)-(2) — text in force from 21.07.2026
  37. KAVS § 46(2), (5), (10) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  38. KAVS § 13(2), (4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  39. KAVS § 12(4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  40. KAVS § 12(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  41. FSA page 'The operating licence for a creditor' — text in force from page checked 2026-11-10
  42. Finantsinspektsiooni seadus § 45³(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 12); § 45³(2) RT I, 04.07.2024, 2 (from 14.07.2024)
  43. KAVS § 15(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  44. KAVS § 14(1), (2), (4) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  45. KAVS § 14(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  46. KAVS § 12(5) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
  47. Directive (EU) 2023/2225 Art. 48(1) — text in force from OJ L 2023/2225
  48. LexorCorp Global price list and service description (price list)
  49. 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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