E-money institution authorisation in Estonia

An e-money institution (EMI) issues electronic money in its own name and may also provide payment services, without being a bank. In Estonia it needs an operating licence from Finantsinspektsioon, the Estonian financial supervision authority, under the Payment Institutions and E-money Institutions Act. This page sets out what the act requires and how the procedure runs.

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

Electronic money (e-money) is monetary value stored on an electronic device that represents a claim on its issuer and meets all of three conditions: it is issued at nominal value against funds received, it is used as a means of payment for payment transactions, and it is accepted as a means of payment by at least one person other than the issuer¹.

An e-money institution is a public limited company (AS) or a private limited company (OÜ) whose permanent activity is issuing e-money in its own name². Besides issuing e-money it may provide payment services, grant payment-related loans under the act's conditions, provide closely related services, operate payment systems and carry on other business unless the law provides otherwise³. It must be a public limited company if it provides payment services or payment-related loans, and may be a private limited company only where it does not provide the payment services listed in § 3(1) points 1–5 of the act².

What e-money is not:

• It is not a deposit or other repayable funds within the meaning of the Credit Institutions Act⁴.
• No interest, other remuneration or other benefit may be paid or charged for the period during which e-money is held⁵.
• An EMI may not grant loans from or secured by the funds received in exchange for e-money⁶.
• The e-money rules do not apply to limited-use instruments (for example usable only within a limited network of merchants) or to certain payments charged to a phone bill, where the conditions of § 4 of the act are met⁷.

The legal act and the authority

The activity is governed by the Payment Institutions and E-money Institutions Act (makseasutuste ja e-raha asutuste seadus, MERAS), which transposes Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions, and Directive (EU) 2015/2366 on payment services⁸. To operate as an e-money institution a company must hold an operating licence⁹. For a company founded in Estonia, the licence is granted and revoked by Finantsinspektsioon¹⁰. The licence is open-ended and cannot be transferred to another person¹¹.

Finantsinspektsioon keeps a list of licensed Estonian e-money institutions, their qualifying holders, distributors and managers¹², and announces the grant of a licence on its website no later than the working day after the decision takes effect¹³. Licensed Estonian e-money institutions are shown on the authority's page "E-money institutions"¹⁴.

Who must apply and the exemptions

Any company that wants to issue e-money as its business in Estonia must apply for the licence⁹. Credit institutions, the European Central Bank and the central banks of EEA states, and EEA states and their regional and local authorities need no licence to issue e-money¹⁵.

For small issuers, by decision of Finantsinspektsioon, chapters 3, 4, 6 and 8 of the act do not apply to an e-money institution whose e-money meets the definition of a low-value payment instrument in § 733¹² (1) of the Law of Obligations Act, if its average outstanding e-money does not exceed EUR 500,000¹⁶. A low-value payment instrument is one where single transactions do not exceed EUR 30, or the spending limit is up to EUR 150, or the stored amount never exceeds EUR 150¹⁷. The exemption is requested in the licence application and decided in the licence decision¹⁸. An exempted institution may not open branches, provide cross-border services or distribute e-money through a distributor in another EEA state¹⁹.

Requirements for the applicant

Initial capital and own funds. The share capital or initial capital of an e-money institution must be at least EUR 350,000²⁰. When the institution is founded as a new company, only amounts actually paid in count as share capital²¹. Own funds must at all times be at least the initial capital and at least the own-funds requirement; for e-money issuance that requirement is 2 % of the average outstanding e-money²². A new institution, or one operating for less than six months, calculates the requirement from the e-money volume in its business plan²³.

Safeguarding. Funds received for issued e-money must be kept separate from the institution's own assets and held in a separate account at a credit institution or Eesti Pank, or invested in liquid low-risk assets as the act defines; instead, they may be covered by an insurance policy or comparable guarantee from an insurer or credit institution outside the group²⁴. The safeguarding requirements must be applied no later than the fifth working day after the e-money is issued²⁵.

Management body. The management board must have at least two members²⁶. A manager must have the education, experience, professional suitability and impeccable business reputation needed to manage the institution²⁷. The act excludes, among others, persons whose earlier activity led to a bankruptcy or licence revocation, persons under a business ban, and persons with an unexpunged conviction for an economic, official, property or public-trust offence or terrorist financing²⁸.

Qualifying holders. The application includes the information listed in § 40 of the act on persons with a qualifying holding in the applicant²⁹.

Seat and head office. The registered office and the head office must be in Estonia, and the articles of association must state this³⁰.

Internal rules and internal control. The institution must adopt internal rules covering, among others, service provision and business continuity, segregation of duties, ICT and client-asset security, internal control, sanctions and AML, security incidents, access to sensitive payment data, and fraud statistics³¹. The supervisory board appoints an internal auditor³².

AML/CFT. An e-money institution is a financial institution under the Money Laundering and Terrorist Financing Prevention Act (RahaPTS)³³. It must prepare a risk assessment covering at least customer, geographic, product and channel risks³⁴, adopt procedural rules and internal control rules³⁵, designate a management board member responsible for AML/CFT where the board has more than one member, and appoint a contact person of the Financial Intelligence Unit (Rahapesu Andmebüroo) who works permanently in Estonia³⁶.

ICT. The application must describe the ICT systems and their use in line with Regulation (EU) 2022/2554 on digital operational resilience (DORA), and include a security policy³⁷.

Documents filed with the application

The management board members file a written application with Finantsinspektsioon³⁸; since 18 March 2026 applications go through the authority's application portal³⁹. Section 15(1) of the act lists, grouped here³⁸:

• Corporate: articles of association (for a new company, a notarised copy of the memorandum), proof of paid-in capital, the head office address and the list of shareholders.
• Business: a programme of operations describing the planned services, a business plan for at least three years meeting § 16⁴⁰, an opening balance sheet or the latest financial statements, and, for an operating company, documents proving own funds with an auditor's report.
• Controls: the safeguarding description, internal and accounting rules (or drafts), ICT and systems data, the AML/CFT internal control system, the organisational structure (agents, branches, outsourcing, payment systems) and a security policy with a risk assessment.
• People: data on qualifying holders, data on managers (education, full career, area of responsibility, evidence of reliability), data on companies in which the applicant or a manager holds more than 20 %, and data on the auditor and internal auditor.
• Fee: proof of payment of the procedural fee.

An applicant requesting the small-institution exemption files a shorter list⁴¹.

State fee and processing time

The fee for an e-money institution licence application is a procedural fee of EUR 3,000 under the Financial Supervision Authority Act⁴². Where the application asks for the exemption under § 12(1) of MERAS, the fee is EUR 500; the provision names a payment institution as the applicant and refers expressly to § 12(1) of MERAS⁴³.

Finantsinspektsioon decides within three months of receiving all necessary documents and data in due form, and no later than six months after receiving the application⁴⁴. The authority may require additional data and documents⁴⁵, may leave an incomplete application unexamined⁴⁶, and may set a new time limit when the applicant makes a material change to the filed documents⁴⁷. These are the law's time limits, not a promise.

What LexorCorp Global does and how to order

LexorCorp Global OÜ prepares the full application file for authorisation as an e-money institution under MERAS and manages Finantsinspektsioon's questions until the decision; the deliverables are the filed application, the internal rules and the answers to the authority. The client provides the corporate documents, proof of premises and place of management, and the documents on board members and qualifying holders.

The price is a professional fee for this work. It is not the price of a licence and does not include supervisory fees, the regulatory capital or third-party costs. LexorCorp Global does not give legal, audit or tax advice and does not promise a licence, a date or any decision: the authorisation is granted by Finantsinspektsioon.

To order, use the request form: order form (service "Estonian e-money institution (EMI) authorisation — application preparation and management").

Sources

1. MERAS § 6(1) — text in force from 01.10.2026
2. MERAS § 7(1) — text in force from 21.11.2025 (§ 7(1)); redaction 01.10.2026
3. MERAS § 7(2) — text in force from 01.10.2026
4. MERAS § 6(6) — text in force from 01.10.2026
5. MERAS § 6(2) — text in force from 01.10.2026
6. MERAS § 7(3) — text in force from 01.10.2026
7. MERAS § 6(3), § 4(1) p 10–11, § 4(3)–(4) — text in force from 01.10.2026
8. MERAS footnote 1; EUR-Lex title of Directive 2009/110/EC — text in force from 01.10.2026
9. MERAS § 14(1) — text in force from 01.10.2026
10. MERAS § 14(3) — text in force from 01.10.2026
11. MERAS § 14(4) — text in force from 01.10.2026
12. MERAS § 105(1) — text in force from 01.10.2026
13. MERAS § 23(1) — text in force from 21.11.2025 (§ 23); redaction 01.10.2026
14. Finantsinspektsioon, E-money institutions — text in force from n/a (web page, checked 2026-11-11)
15. MERAS § 6(7) p 3–5, § 14(6) — text in force from 01.10.2026
16. MERAS § 12(1) — text in force from 01.10.2026
17. Võlaõigusseadus § 733¹²(1) — text in force from 01.09.2026 (redaction of VÕS)
18. MERAS § 12(1) last sentence, § 14(3¹) — text in force from 01.10.2026
19. MERAS § 12(3) — text in force from 01.10.2026
20. MERAS § 64(2) — text in force from 01.10.2026
21. MERAS § 64(3) — text in force from 01.10.2026
22. MERAS § 71(1)–(2) — text in force from 01.10.2026
23. MERAS § 71(4) — text in force from 01.10.2026
24. MERAS § 80(1), (3), (4) — text in force from 18.07.2025 (§ 80(1)); redaction 01.10.2026
25. MERAS § 80(7) — text in force from 01.10.2026
26. MERAS § 47(2) — text in force from 01.10.2026
27. MERAS § 47(1) — text in force from 01.10.2026
28. MERAS § 47(4) — text in force from 01.10.2026
29. MERAS § 15(1) p 13 — text in force from 01.10.2026
30. MERAS § 46(1)–(2) — text in force from 01.10.2026
31. MERAS § 50(3) — text in force from 01.10.2026
32. MERAS § 51(2) — text in force from 01.10.2026
33. RahaPTS § 6(2) p 3 — text in force from 21.07.2026
34. RahaPTS § 13(1) — text in force from 21.07.2026
35. RahaPTS § 14(1) — text in force from 21.07.2026
36. RahaPTS § 17(1), (2), (5) — text in force from 21.07.2026
37. MERAS § 15(1) p 9 and p 19, § 15(1¹) — text in force from 01.10.2026
38. MERAS § 15(1) p 1–21 — text in force from 21.11.2025 (p 20–21); redaction 01.10.2026
39. Finantsinspektsioon, Operating licences for payment institutions and e-money institutions — text in force from n/a (web page, checked 2026-11-11)
40. MERAS § 16(1)–(2) — text in force from 01.10.2026
41. MERAS § 15(1³) — text in force from 01.10.2026
42. Finantsinspektsiooni seadus § 45³(2) — text in force from 14.07.2024 (§ 45³(2)); FIS redaction 01.10.2026
43. Finantsinspektsiooni seadus § 45³(5) (wording names 'makseasutus' but covers MERAS § 12(1), the EMI exemption) — text in force from 13.01.2018 (this subsection); FIS redaction 01.10.2026
44. MERAS § 18(1) — text in force from 01.10.2026
45. MERAS § 17(2) — text in force from 01.10.2026
46. MERAS § 17(1), (5) — text in force from 18.07.2025 (§ 17(1)); redaction 01.10.2026
47. MERAS § 17(1¹) — text in force from 18.07.2025 (§ 17(1¹)); redaction 01.10.2026

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.

• Payment Institutions and E-money Institutions Act — Riigi Teataja, English translation
• Directive (EU) 2015/2366 — EUR-Lex
• Law of Obligations Act — Riigi Teataja, English translation
• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• Regulation (EU) 2022/2554 — EUR-Lex
• Financial Supervision Authority Act — Riigi Teataja, English translation

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