Selling electricity and natural gas in Estonia

A company that sells electricity or natural gas in Estonia files a notice of economic activities¹⁰¹¹ before it starts³⁶. Other activities in the same sectors — generating electricity above 1 MW, running a network, importing gas, storing gas — need an activity licence⁴¹⁵⁵, decided by the Competition Authority (Konkurentsiamet)⁸.

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 Electricity Market Act, "sale" means handing over electricity to another person, for a fee or free of charge¹. A seller (müüja) is an electricity undertaking that sells electricity². Under the Natural Gas Act, sale of gas is handing over gas to a person for a fee³.

The acts treat the following as separate activities with their own regime:

• electricity: generation, distribution network service, transmission network service, transmission through a cross-border direct current line, transmission through a direct line⁴;
• gas: transmission service, distribution service, import, operating a liquefied natural gas (LNG) terminal, storage service⁵.

Gas import, in the sense of the Natural Gas Act, is release of gas for free circulation under the Union Customs Code⁶.

The legal act and the authority

• Electricity Market Act (Elektrituruseadus, ELTS), redaction in force from 1 October 2026⁷.
• Natural Gas Act (Maagaasiseadus, MGS), redaction in force from 1 October 2026⁷.
• General Part of the Economic Activities Code Act (Majandustegevuse seadustiku üldosa seadus, MSÜS) for the general procedure of notices and licences⁷.

The Competition Authority (Konkurentsiamet) decides on activity licences under both acts⁸ and supervises compliance with both acts⁹. An electricity seller files its notice with the Register of Economic Activities (majandustegevuse register, MTR) under the MSÜS procedure¹⁰; the Natural Gas Act says the gas seller's notice is filed with the Competition Authority¹¹. The register is kept by the Consumer Protection and Technical Regulatory Authority (TTJA)¹².

Who must file a notice and who needs a licence

Sale of electricity — notice. To act as an electricity seller, a company must file a notice of economic activities¹⁰. The act names exemptions, among them: sale by the producer of the electricity it has produced; sale on an electricity exchange; sale within one's own building or property outside the main business, or by a non-profit association to its members' homes; and sale to a consumer over a direct line from generating units with a total net capacity below 1 MW¹³. An activity licence for sale issued under the old rules became invalid once the notice was filed¹⁴.

Electricity — licence. An activity licence is required for generation, distribution and transmission network services, and transmission through a cross-border direct current line or a direct line⁴. No licence is needed, among other cases, for generation with a unit of up to 1 MW net capacity, or for a direct line connected to such a unit¹⁵.

Sale of gas — notice. To act as a gas seller, a company must file a notice of economic activities with the Competition Authority¹¹.

Gas — licence. An activity licence is required for gas transmission service, gas distribution service, gas import, operating an LNG terminal and gas storage service⁵. No licence is needed by a person who sells gas only to its members, lessees or tenants, if this is not its main activity and takes place within one property or building¹⁶.

Requirements for the applicant

Form and capital (electricity). A legal-person electricity undertaking must be registered in the European Economic Area¹⁷. The share capital of a producer and of a seller must be at least EUR 31,950¹⁸; that of a network operator and of a line holder using a cross-border direct current line at least EUR 127,800¹⁹. The EEA-registration and EUR 31,950 rules do not apply, among others, to a producer and seller of electricity from its own units of up to 1 MW in total²⁰.

Separate accounts (electricity). An electricity undertaking that also carries on other activities keeps separate accounts for its electricity activities, as if they were run by different undertakings²¹.

Licence conditions (gas). A gas activity licence is granted if the company has the technical means and skilled staff for the activity, and the economic and organisational conditions for it²². The minimum share capital is EUR 31,950 for a distribution network operator and EUR 128,000 for transmission, LNG terminal and storage service providers²².

Balance responsibility and open supply (electricity). Every market participant must ensure that, in each trading period, the electricity it feeds in or buys equals the electricity it takes or sells²³. To meet this, it concludes a contract with one seller — the open supplier — which ensures open supply; the open supplier names in that contract the balance responsible party who keeps the participant's balance, unless the open supplier is itself a balance responsible party²⁴. A balance responsible party concludes a balance agreement with the system operator²⁴ and gives the system operator bank guarantees — a fixed and a variable guarantee²⁵.

Balance responsibility (gas). To supply gas through the transmission network, a market participant concludes a balance agreement with the system operator, unless it has delegated balance responsibility to another balance responsible party²⁶. Each market participant has one open supplier²⁶. On concluding the balance agreement, the balance responsible party gives the system operator bank guarantees from a bank of Estonia or another European Union or EEA state with an international investment-grade credit rating²⁷.

Anti-money laundering (AML/CFT). Whether anti-money laundering requirements apply to the company is specified for the client's case.

Documents filed with the application

Notice of economic activities (electricity or gas sale) contains the general data set by the MSÜS: the company's name and registry code, contact details, the statutory name of the activity and its classification code, the start date if different from the filing date, and the name and contact details of the signatory and the basis of the right of representation²⁹.

Activity licence application contains the same general data, except the start date³⁰ and, under the Electricity Market Act, in addition³¹:

• for distribution network service — the definition and a schematic plan of the service area;
• for a cross-border direct current line or a direct line — the maximum permitted operating voltage, length, location plan and geographical coordinates of the line;
• for a direct line — a document proving the condition of § 61(1) of the act.

Under the Natural Gas Act the application adds the requested area of activity (except for sale and import) and, except for import, a location plan and description of the networks in the area of activity³².

State fee and processing time

State fee. Under the State Fees Act (Riigilõivuseadus), the fee for an activity licence is, among others: EUR 160 for each year of validity for electricity generation; EUR 1,280 for each year of validity for a direct line³³; and EUR 640 for each year of validity for gas import³⁴. The State Fees Act still lists a fee for an activity licence for sale (electricity EUR 640, gas EUR 260 per year of validity)³³³⁴; the two acts require a notice of economic activities for sale¹⁰¹¹. A notice of economic activities filed otherwise than through the single point of contact (the state portal or a notary) costs EUR 10³⁵. The fee for amending licence conditions is 50% of the rate³³³⁴.

Processing time. A notice is filed before the activity starts³⁶. The Competition Authority decides an electricity licence application within 60 days (ten months for transmission network service)⁸. Under the general rule of the MSÜS, an activity licence application is decided within 30 days, counted from the submission of all required data; the authority may suspend the period for up to 30 days to remedy a shortcoming and may extend it once by up to 30 days in a complex case³⁷. The authority may ask for additional information during the procedure³⁸. These are the time limits of the law, not a promise of a decision date.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application documents for an activity licence or a registration (notice) in the Register of Economic Activities: it checks the requirements of the act against the client's business, drafts the documents, assembles the application, submits it through the Register of Economic Activities and follows up the authority's questions in writing. The client describes the activity and provides what the act requires of the company.

This is application preparation, not legal advice, audit or tax advice. The state fee is separate and paid by the company, and so is meeting the act's capital, staff and premises requirements. The Competition Authority decides on the licence; LexorCorp does not promise a licence, a date or an authority's decision.

The price is given on request: each activity above has a "Request a price" button in the guide Licensed activities in Estonia, and we reply by email.

Sources

1. ELTS § 3 p 18 — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
2. ELTS § 10 — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
3. MGS § 7(4) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
4. ELTS § 22(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
5. MGS § 27(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
6. MGS § 7(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
7. Riigi Teataja headers 'Sõnastuse jõustumise kp' — text in force from see quote
8. ELTS § 23(1); MGS § 28(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16); 01.10.2026 (RT I, 30.06.2026, 95)
9. ELTS § 93(1); MGS § 37(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16); 01.10.2026 (RT I, 30.06.2026, 95)
10. ELTS § 22^1(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
11. MGS § 26^10 — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
12. MSÜS § 8(4) — text in force from 01.09.2025 (RT I, 02.01.2025, 26)
13. ELTS § 22^1(2) p 1–3, 6; § 15(6) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
14. ELTS § 111^3(6) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
15. ELTS § 22(2) p 1, 7 — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
16. MGS § 27(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
17. ELTS § 15(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
18. ELTS § 15(3) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
19. ELTS § 15(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
20. ELTS § 15(5), (5^1), (6) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
21. ELTS § 16(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
22. MGS § 29 — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
23. ELTS § 43(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
24. ELTS § 44(1)–(3), (5) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
25. ELTS § 20(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
26. MGS § 12(1), (3) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
27. MGS § 12^2(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
29. MSÜS § 15(1) — text in force from 01.09.2025 (RT I, 02.01.2025, 26)
30. MSÜS § 19(2) p 1 — text in force from 01.09.2025 (RT I, 02.01.2025, 26)
31. ELTS § 23(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 16)
32. MGS § 28(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 95)
33. RLS § 136^3(1) p 2, 11, 12; (3) — text in force from 01.11.2026 (RT I, 21.10.2026, 10)
34. RLS § 136^4(1) p 1, 2; (2) — text in force from 01.11.2026 (RT I, 21.10.2026, 10)
35. RLS § 345; MSÜS § 9(6), § 58(1) p 1 — text in force from 01.11.2026 (RT I, 21.10.2026, 10)
36. MSÜS § 14(1) — text in force from 01.09.2025 (RT I, 02.01.2025, 26)
37. MSÜS § 20(1)–(3) — text in force from 01.09.2025 (RT I, 02.01.2025, 26)
38. MSÜS § 19(6) — text in force from 01.09.2025 (RT I, 02.01.2025, 26)

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.

• State Fees 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.