Insurance agent in Estonia (kindlustusagent)

An insurance agent sells insurance for one or more insurers under an agency agreement. In Estonia an agent does not apply to the Financial Supervision Authority for a licence: the insurer it represents enters the agent in the list of insurance intermediaries and is liable for the agent's distribution.

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

The Insurance Activities Act (kindlustustegevuse seadus, KindlTS) defines insurance distribution as advising on insurance contracts and proposing, preparing and concluding them, and assisting in their administration and performance. It also covers comparison and information services through a website, app or similar platform if the customer can conclude a contract through that process.¹

An insurance agent is a person who, for remuneration and under an agency agreement, distributes insurance for and in the interest of one or more insurers, or concludes insurance contracts in their name and on their account.² An insurance broker is different: it acts under a brokerage contract for the client and recommends a contract on the basis of an independent analysis.³ Brokers and insurers have their own pages.

Not insurance distribution, under the act: occasional information given in another profession without helping to conclude a contract; claims handling or loss assessment for an insurer as part of another profession; and merely passing client data to a distributor or giving clients information about products or distributors, without otherwise assisting in concluding the contract.⁴

The legal act and the authority

Act: Kindlustustegevuse seadus (Insurance Activities Act), chapter on the activity of insurance brokers and insurance agents, mainly §§ 174–198. The redaction in force from 21 July 2026 was used.⁵
Authority: Finantsinspektsioon (Financial Supervision Authority, FI) supervises in Estonia every person engaged in insurance activity and insurance distribution.⁶
Register: brokers and agents (together, "intermediaries") must be entered in the list of intermediaries (vahendajate nimekiri). An Estonian intermediary must have its registered seat or residence in Estonia.⁷ FI publishes its market participants register, including insurance intermediaries, on its website.⁸

An insurer that uses intermediaries may conclude insurance contracts only through intermediaries entered in the list.⁹ Breaching this restriction is a misdemeanour under § 262 of the act.¹⁰

Who must be entered in the list, and the exemptions

Every person who carries on the activity of an insurance agent in Estonia must be in the list of intermediaries.⁷ The agent is entered by the insurer it represents or, in cases provided by law, by FI.¹¹ The insurer enters the agent without delay after the agency agreement is concluded.¹²

An insurer may enter only an agent that is not already listed as the agent of another insurer for distributing contracts of the same class or sub-class of insurance, and that meets the requirements of the act.¹³ An agent may act for several insurers at the same time only if the contracts it distributes do not compete; contracts in different classes or sub-classes are presumed not to compete.¹⁴

Ancillary insurance agents. A lighter regime applies, and only the provisions listed in § 175(1) bind the agent, if all of these conditions are met¹⁵:

insurance distribution is not the agent's principal professional activity;
the agent is not a credit institution or an investment firm;
the insurance covers risks linked to goods the agent supplies or a service it provides: breakdown, damage or loss of the goods, or, for a travel service, damage to or loss of baggage and other travel risks;
no life or liability cover, unless it complements the main cover;
the premium does not exceed EUR 600 per year on a pro rata basis, or, for travel services with a contract of up to three months, EUR 200 per person.

Even an ancillary agent must tell the client in good time before the contract what kind of remuneration it receives.¹⁶ Natural persons who distribute for such an agent must have the insurance knowledge required by § 178, and the insurer whose contracts they sell is responsible for making it possible for them to acquire it.¹⁷

Requirements for the agent

Capital. Whether a minimum share capital or own funds requirement applies to an agent is specified for the client's situation.

Business name. A company acting as an insurance agent (insurance agency) must include the word "kindlustus" (insurance), in Estonian or another language, in its business name. This does not apply to an agency for which distribution is an ancillary activity.¹⁸

Fit and proper. A natural-person agent, every management board member of an insurance agency, and every natural person directly engaged in distribution must have an impeccable business reputation and the insurance knowledge set out in § 178.¹⁹ If distribution is the agency's main activity, the board member responsible for distribution must also have work experience in insurance or other financial services.²⁰ Reputation is not impeccable, for example, where the person has been sentenced for a first-degree crime and the record has not been deleted.²¹ The agency itself must check the reputation of its board members and distribution staff.²² If distribution is an ancillary activity of the agency, these conditions apply to the board member responsible for distribution.²³ These persons may not at the same time be a broker, a broker's board member or a broker's employee.²⁴

Knowledge and training. Required knowledge covers, among other things, the insurance market, the classes distributed, the client's demands and needs, conflicts of interest, contract terms, claims and complaints handling, and the applicable law.²⁵ The insurer must ensure 15 hours of insurance training per year for natural-person agents and for those who directly distribute for an agency whose main activity is distribution.²⁶

Liability. Unlike a broker, an insurance agent does not have to conclude compulsory professional liability insurance. The insurer whose contract the agent distributed is liable to the injured person for damage caused by the agent's breach of its distribution duties.²⁷

Conduct with clients. Before each contract, the agent must, among other things, state that it acts as the insurer's representative, refer to its entry in the list, disclose its remuneration for each contract, name the insurer responsible for its activity, and give the complaints procedure.²⁸ An agency whose main activity is distribution must adopt internal rules ensuring these duties are met, including measures to identify and avoid conflicts of interest.²⁹

Outsourcing and IT. An agent may outsource related activities only under the conditions of § 182, but insurance distribution itself may not be outsourced. The insurer is responsible for the outsourcing agent's compliance.³⁰ Intermediaries must follow the digital operational resilience regulation (EU) 2022/2554 (DORA), but this does not apply to micro, small and medium-sized intermediaries.³¹

AML/CFT. The Money Laundering and Terrorist Financing Prevention Act (rahapesu ja terrorismi rahastamise tõkestamise seadus) names the insurance broker as a financial institution to the extent of life-insurance distribution and other investment-related services.³² Whether any AML/CFT duties apply to a particular agent is specified for the client's case.

Documents and data

There is no application to FI for an agent. Instead, before the agency agreement is concluded, the agent must give the insurer the following data³³:

Owners: name, registry or personal code (or date of birth) of each shareholder holding at least 10%, with each one's contribution, shares and votes;
Links: the name of any insurer in which the agent holds a qualifying holding and the size of that holding; persons with whom the agent has close links; and information that these holdings or close links do not prevent effective supervision;
Identity data for the list: for a natural person, name, personal code (or date of birth) and contact details including e-mail³⁴; for an insurance agency, business name, registry code, address, contact details including e-mail, website if any, and the name of the board member responsible for distribution³⁵.

The insurer is responsible for the correctness of the entries and must correct or delete incorrect data without delay.³⁶ The insurer removes the agent when the agency agreement ends, or when the agent dies or the agency is dissolved.³⁷ If FI deletes an agent from the list, the agency agreement ends from the deletion of the entry.³⁸

State fee and processing time

Whether a state fee applies to entering an insurance agent in the list of intermediaries is specified for the client's situation.

An agent is entered in the list by the insurer it represents or, in the cases provided by law, by FI¹¹. The insurer must enter the agent without delay after the agency agreement is concluded.¹² An agent listed in Estonia may also distribute in other countries through a branch or cross-border, under the separate procedure in KindlTS §§ 199–208.⁴⁰

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ offers the general row Activity licence application documentation, from €3,500 (one-time). LexorCorp Global OÜ is not registered for VAT, so no VAT is added. We prepare the documents and manage the process; the work covers the act's requirements for the activity, taken from its official text. The timeline is by agreement.

This is a professional fee for corporate and regulatory documentation work. It is not the price of an entry in the list and does not include third-party costs, which the client pays. We do not give legal, tax or audit advice. The agent is entered in the list by the insurer it represents, and we cannot promise any insurer's agreement, any entry or any date.

Order: order form

Sources

KindlTS § 5(1) — text in force from 21.07.2026
KindlTS § 174(2) — text in force from 21.07.2026
KindlTS § 174(1) — text in force from 21.07.2026
KindlTS § 5(4) p 1–4 — text in force from 21.07.2026
KindlTS header and chapter 'Kindlustusmaakleri ja kindlustusagendi tegevus' — text in force from 21.07.2026
KindlTS § 223(1) — text in force from 21.07.2026
KindlTS § 174(3) — text in force from 12.12.2022 (§ 174(3) wording); act redaction 21.07.2026
Finantsinspektsioon web page 'Kindlustusvahendajad' (Turuosaliste register) — text in force from n/a (web page)
KindlTS § 176(1) — text in force from 21.07.2026
KindlTS § 262(1) — text in force from 21.07.2026
KindlTS § 195(1) — text in force from 21.07.2026
KindlTS § 195(3) — text in force from 21.07.2026
KindlTS § 195(2) — text in force from 21.07.2026
KindlTS § 198(1) — text in force from 21.07.2026
KindlTS § 175(1) p 1–3, 5, 6 — text in force from 21.07.2026
KindlTS § 175(1¹) — text in force from 21.07.2026
KindlTS § 175(3) — text in force from 21.07.2026
KindlTS § 194(1)–(2) — text in force from 21.07.2026
KindlTS § 197(1) — text in force from 21.07.2026
KindlTS § 197(2) — text in force from 21.07.2026
KindlTS § 197(3) — text in force from 21.07.2026
KindlTS § 197(4) — text in force from 21.07.2026
KindlTS § 197(6) — text in force from 21.07.2026
KindlTS § 197(5) — text in force from 21.07.2026
KindlTS § 178(2) — text in force from 21.07.2026
KindlTS § 103¹(2) — text in force from 21.07.2026
KindlTS § 179(4) — text in force from 21.07.2026
KindlTS § 198(2) p 1, 2, 10, 11, 12 — text in force from 21.07.2026
KindlTS § 198(3), (3¹) — text in force from 21.07.2026
KindlTS § 182(1), (6), (7) — text in force from 21.07.2026
KindlTS § 181¹(1), (3) — text in force from 17.01.2025 (§ 181¹); act redaction 21.07.2026
RahaPTS § 6(2) p 4–5 — text in force from 21.07.2026
KindlTS § 195(4) p 1–6 — text in force from 21.07.2026
KindlTS § 195(5) — text in force from 21.07.2026
KindlTS § 195(6) — text in force from 21.07.2026
KindlTS § 196(1) — text in force from 21.07.2026
KindlTS § 196(2) — text in force from 21.07.2026
KindlTS § 196(3)–(4) — text in force from 21.07.2026
KindlTS § 199(1); chapter 10 division 4 (§§ 199–208) — text in force from 21.07.2026

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.

Regulation (EU) 2022/2554 — 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.