Debt collection business in Estonia: when a licence is needed

Servicing defaulted credit agreements of banks and lenders in Estonia needs an operating licence from the Financial Supervision Authority (Finantsinspektsioon). Whether collecting other claims, such as unpaid invoices between businesses, needs a licence is specified for the client's situation; the Law of Obligations Act limits the collection costs a debtor can be asked to pay.

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

Debt collection means recovering overdue money claims for a creditor (the original seller or lender, or a buyer of the claims) or for oneself: reminders, payment plans, receiving payments, complaints.

Estonian law separates two kinds of collection:

• Credit servicing. The Credit Servicers and Credit Purchasers Act (Krediidiinkassode ja -ostjate seadus, KIOS) covers one or more of these activities in connection with a defaulted credit agreement of a credit institution (bank) or of a creditor (a licensed non-bank lender): collecting the money owed from the borrower; negotiating claims or terms with the borrower; handling the borrower's complaints; informing the borrower of changes in interest, fees or payments¹. A company whose main and permanent business is credit servicing is a credit servicer (krediidiinkasso)². A credit purchaser is a person who buys such a defaulted credit agreement, or a claim under it, in the course of business³.
• Other collection. Claims not arising from such credit agreements, for example unpaid invoices, rent or utility bills. Finantsinspektsioon gives collectors of only fines or maintenance (alimony) arrears as examples of businesses that do not need the licence⁴.

The act also does not apply to the servicing or acquisition of a credit agreement concluded by a lender that is not a credit institution where the borrower is not a consumer⁵.

The legal act and the authority

• KIOS, in the wording in force from 30 June 2026. It transposes Directive (EU) 2021/2167 on credit servicers and credit purchasers⁶.
• Authority: Finantsinspektsioon grants and revokes the operating licence by its decision⁷.
• Where the licence shows: a licensed credit servicer is entered in the list of credit servicers on Finantsinspektsioon's website⁸.
• Collection costs: the Law of Obligations Act (võlaõigusseadus, VÕS) § 113¹ (any creditor) and § 113² (a business creditor claiming from a consumer)⁹¹⁰.
• Anti-money laundering (AML): the Money Laundering and Terrorist Financing Prevention Act (rahapesu ja terrorismi rahastamise tõkestamise seadus, RahaPTS). Debt collectors are not named among the persons it applies to¹¹. It does apply to "other financial institutions" under the Credit Institutions Act (krediidiasutuste seadus, KAS), and these include companies whose main and permanent activity is lending, including factoring¹²¹³. Such a financial institution needs an activity licence under RahaPTS, unless it holds, or must apply for, a Finantsinspektsioon licence¹⁴. Whether a given claim-purchase model counts as factoring is assessed for the client's case.

Who must apply

An operating licence is required to act as a credit servicer¹⁵. Licence-holders must be companies: a credit servicer may operate only as a public limited company (AS) or a private limited company (OÜ)¹⁶. Credit servicing carried out by a credit institution, creditor or credit intermediary itself is subject to KIOS, but a bank or lender established in the European Economic Area (EEA) is not treated as a credit servicer¹⁷.

KIOS sets different duties for a credit purchaser. If it buys a defaulted consumer credit agreement, it must appoint a credit servicer, credit institution or creditor to service it¹⁸. It must also notify Finantsinspektsioon of the servicer's business name and address no later than the date servicing starts¹⁹. A credit servicer that buys defaulted credit itself also has the duties of a credit purchaser²⁰.

Exemptions named by the act:

• credit agreements concluded with a credit institution or lender from a non-EEA country, unless the agreement or claim is assigned to an EEA credit institution or lender²¹;
• acquisition by an EEA credit institution²¹;
• credit from a non-bank lender to a borrower who is not a consumer⁵;
• notaries, bailiffs, bankruptcy trustees and attorneys²¹;
• a person who only passes on payment-default data and does no credit servicing²².

No other person, authority or association may use the word "krediidiinkasso" in its name, in Estonian or another language²³.

Requirements for the applicant

• Capital: share capital of at least EUR 25,000, fully paid in²⁴.
• Seat: the registered seat and the place of permanent and continuous business must be in Estonia, and the articles must state that the registered seat and head office are in Estonia²⁵.
• Management body: at least two management board members. A supervisory board, if there is one, has at least three members, and Finantsinspektsioon may require one²⁶. Each manager must have an impeccable reputation; the act lists cases where reputation is not impeccable²⁷. Managers as a whole must have enough knowledge and experience, and each must have enough time for the role²⁸.
• Internal rules and control: the board adopts internal rules. These cover, among other things, personal data under the General Data Protection Regulation (GDPR), conflicts of interest, outsourcing, IT security, risk management, complaints and fair treatment of borrowers²⁹. The company needs an internal control system and an internal auditor³⁰.
• Conduct towards borrowers: act in good faith, fairly and professionally; give clear, true and current information; protect personal data and privacy; no harassment, coercion or undue influence³¹.
• Client money: money paid by borrowers is kept on a separate payment account at an EEA credit institution and may not be used in the company's own business³².
• Audit: the annual report must be audited³³.
• AML: KIOS lets Finantsinspektsioon revoke the licence where the servicer or its manager breaches the rules against money laundering and terrorist financing³⁴. Whether RahaPTS duties (internal rules, compliance officer, risk assessment) apply in full depends on the business model (see above).

Other collection (not KIOS): Finantsinspektsioon names collectors of only fines or maintenance arrears as not needing its licence⁴; whether another licence is needed is specified for the client's situation. The VÕS limits still apply. From a business debtor, a creditor entitled to default interest may claim EUR 40 of collection costs⁹. From a consumer, the act sets caps by claim size after the contract ends: up to EUR 30 (claim up to EUR 500), EUR 40 (EUR 500–1,000) and EUR 50 (over EUR 1,000), with at most three paid reminder letters, the first sent no earlier than seven days after the contract ends¹⁰. Agreements deviating from these rules to the consumer's detriment are void¹⁰.

Documents filed with the application

The management board members on the commercial register file a written application with³⁵:

• Company: the articles of association; amount of share capital and proof of payment; address of the head office or registered seat; description of the organisational structure.
• Business: a business plan for at least three years, covering the business model, strategy, financial forecasts and protection of borrowers³⁶; a description of IT systems; whether the applicant will receive and hold borrowers' money (if yes, details of the separate payment account).
• People: data on managers, on Finantsinspektsioon's form; criminal record extracts no older than three months for managers and qualifying holders; data on qualifying holders; data on the audit firm and the internal auditor.
• Rules: internal rules, including accounting rules and the internal control procedure; complaint-handling procedures; any outsourcing agreement.
• Fee: proof of payment of the processing fee.

Finantsinspektsioon's page for this licence refers applicants to its application portal and says the application must be in Estonian³⁷.

State fee and processing time

• Processing fee: EUR 3,000³⁸.
• Time limit: Finantsinspektsioon first checks within 45 days whether the application is complete³⁹. It decides within three months of receiving all required documents and data, and no later than six months after receiving the application⁴⁰.
• Finantsinspektsioon may ask for more data and documents and set a deadline for them, and may leave an incomplete application unexamined⁴¹. These time limits are the law's, not a promise of a date or of the outcome.

What LexorCorp Global OÜ does and how to order

The site's service "Debt collection company — corporate structure only, no FSA authorisation" (€3,500, one-time fixed price; the service row says state fees are included) covers:

• setting up a company for a debt collection business, with articles of association and internal rules for business claims;
• the documents we prepare: articles, a collection procedure and a standard collection mandate agreement with creditors;
• result: a registered company ready for business-to-business (B2B) debt collection. The stated timeline is 1–2 weeks.

You provide passports and proof of address of founders and board members, a description of the claims to be collected (B2B, types of creditors, countries) and beneficial ownership information.

This service does not include an application to Finantsinspektsioon. Servicing defaulted credit of banks or lenders needs the separate credit servicer authorisation, listed as its own service on the site. We do not give legal or tax advice and do not audit. We cannot promise any licence, decision or date; whether your activity needs an authorisation is assessed separately.

Order: on the licensed companies page, order form, choose "Debt collection company".

Sources

1. KIOS § 3(2) — text in force from 30.06.2026
2. KIOS § 3(1) — text in force from 30.06.2026
3. KIOS § 3(5) — text in force from 30.06.2026
4. Finantsinspektsioon, Krediidiinkasso tegevusluba — text in force from page last modified 18.03.2026
5. KIOS § 2(4) p 3 — text in force from 30.06.2026
6. KIOS footnote 1; RT header — text in force from 30.06.2026
7. KIOS § 6(4) — text in force from 30.06.2026
8. KIOS § 15(1) — text in force from 30.06.2026
9. VÕS § 113¹(1),(4) — text in force from 01.09.2026
10. VÕS § 113²(2),(3),(6) — text in force from 01.09.2026
11. RahaPTS § 2(1) — text in force from 21.07.2026
12. RahaPTS § 6(2) p 11 — text in force from 21.07.2026
13. KAS § 5(1), § 6(1) p 2 — text in force from 01.10.2026
14. RahaPTS § 70(1) p 1, (2) p 1–2 — text in force from 21.07.2026
15. KIOS § 6(1) — text in force from 30.06.2026
16. KIOS § 3(3) — text in force from 30.06.2026
17. KIOS § 2(2) — text in force from 30.06.2026
18. KIOS § 3(7) — text in force from 30.06.2026
19. KIOS § 63(1) — text in force from 30.06.2026
20. KIOS § 3(6) — text in force from 30.06.2026
21. KIOS § 2(4) p 1, 2, 4 — text in force from 30.06.2026
22. KIOS § 3(4) — text in force from 30.06.2026
23. KIOS § 3(13) — text in force from 30.06.2026
24. KIOS § 46(1)-(2) — text in force from 30.06.2026
25. KIOS § 35 — text in force from 30.06.2026
26. KIOS § 36 — text in force from 30.06.2026
27. KIOS § 37(1),(3) — text in force from 30.06.2026
28. KIOS § 37(5)-(6) — text in force from 30.06.2026
29. KIOS § 41(1),(4) — text in force from 30.06.2026
30. KIOS § 42(1),(3) — text in force from 30.06.2026
31. KIOS § 58 — text in force from 30.06.2026
32. KIOS § 47(1)-(2) — text in force from 30.06.2026
33. KIOS § 51(1) — text in force from 30.06.2026
34. KIOS § 13(1) p 8 — text in force from 30.06.2026
35. KIOS § 7(1)-(2); § 39(5) form — text in force from 30.06.2026
36. KIOS § 8(1)-(2) — text in force from 30.06.2026
37. Finantsinspektsioon, Krediidiinkasso tegevusluba — text in force from page last modified 18.03.2026
38. FIS § 45³(2); FI page — text in force from 01.10.2026
39. KIOS § 9(1) — text in force from 30.06.2026
40. KIOS § 10(1) — text in force from 30.06.2026
41. KIOS § 9(3),(4),(7) — 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.

• Law of Obligations Act — Riigi Teataja, English translation
• Credit Servicers and Credit Purchasers Act — Riigi Teataja, English translation
• Directive (EU) 2021/2167 — EUR-Lex
• Money Laundering and Terrorist Financing Prevention 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.