Insurance broker in Estonia: entry in the list of insurance intermediaries

An insurance broker in Estonia arranges insurance for clients on the basis of an independent analysis of the market. Before starting, the broker must be entered in the list of insurance intermediaries kept by Finantsinspektsioon (the Estonian Financial Supervision Authority), which checks the company, its management, its internal rules and its professional indemnity insurance. Insurance agents are entered in the same list by the insurer they represent.

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, proposing, preparing and concluding insurance contracts and assisting in their administration and performance; it also covers comparison websites and apps through which a client can conclude a contract directly or indirectly¹. The act names two kinds of intermediary:

• an insurance broker (kindlustusmaakler) distributes insurance for a fee under a brokerage contract, in order to recommend and arrange for the client, on the basis of an independent analysis, the contract that best meets the client's insurance interest and needs²;
• an insurance agent (kindlustusagent) distributes insurance for a fee under an agency contract for and in the interest of one or more insurers, or concludes contracts in their name and on their account³.

Not distribution: occasional information given in another profession, claims handling or loss assessment for an insurer as another business, and merely passing client data or product information on without helping to conclude a contract⁴.

The legal act and the authority

• Act: Kindlustustegevuse seadus (Insurance Activities Act), chapter 10 "Kindlustusmaakleri ja kindlustusagendi tegevus" (§§ 174–215¹), in the wording in force from 21 July 2026⁵. The act transposes Directive (EU) 2016/97 on insurance distribution (IDD)⁶.
• Authority: Finantsinspektsioon (FI). A broker files its application with FI, and FI enters it in the list of intermediaries⁷.
• Register: the list of intermediaries (vahendajate nimekiri). Brokers and agents must be entered in it, and an Estonian intermediary must have its registered seat or residence in Estonia⁸. For a company it shows the name, registry code, address, contacts and the board member responsible for distribution⁹. The list is published under "Supervised entities" on fi.ee¹⁰.

Who must apply

Every broker and every agent must be in the list⁸, and an insurer that uses intermediaries may conclude contracts only through intermediaries entered in it¹¹.

• Brokers apply to FI themselves⁷.
• Agents do not apply to FI: the insurer they represent enters them in the list immediately after the agency contract is signed (or FI does so in cases named in the law)¹².
• Ancillary agents: a lighter regime applies to a business (not a bank or investment firm) whose main activity is not insurance and which sells cover for its own goods or travel services, if the premium is at most EUR 600 a year, or EUR 200 per person for travel cover of up to three months¹³.
• Foreign intermediaries: an intermediary from another state of the European Economic Area (EEA) may work in Estonia through a branch or cross-border, notified to FI by its home supervisor¹⁴.

Requirements for the applicant

Business name and main activity. The broker's business name must contain the word "kindlustusmaakler" in Estonian or a foreign language¹⁵. Brokerage must be its main activity, meaning that it earns most of its income from it; other activities are allowed only on the conditions of § 185, and acting as an insurance agent is not one of them¹⁶.

Own funds and client money. Whether a minimum capital applies is specified for the client's situation. Premiums paid by clients and belonging to the insurer must be kept on a separate account; they cannot be used in the broker's business, are not part of its bankruptcy estate and cannot be seized for its debts¹⁷.

Professional indemnity insurance. The broker must hold a compulsory liability insurance contract with a sum insured of at least EUR 1,564,610 per claim and EUR 2,315,610 per year for all claims, valid at least in the EEA and governed by Estonian law¹⁸. An equivalent guarantee from an insurer, credit institution or financial institution may be used instead¹⁹. An insurance agent does not need this insurance; the insurer it represents is liable for its acts²⁰.

Management and staff (fit and proper). Board members and every person directly engaged in distribution must have an impeccable business reputation and the insurance knowledge set out in § 178²¹. Reputation is not impeccable, for example, after an unspent conviction for an economic or property offence, under a business ban, or after giving FI false information²². The board member responsible for distribution must also have work experience in insurance or other financial services²³. The knowledge covers the insurance market, the products sold, the client's needs, conflicts of interest, claims, complaints and the law²⁴. Distribution staff must receive at least 15 hours of insurance training a year²⁵. A broker's board member or distribution staff member may not at the same time be an insurance agent or work for one²⁶.

Internal rules. The broker must adopt internal rules covering, among other things, brokerage contracts, the client's needs, presenting offers, conflicts of interest, remuneration, segregation of client money, outsourcing, information and communication technology (ICT), international sanctions and reporting to FI²⁷. A whistleblowing channel for staff is also required²⁸.

Outsourcing and ICT. A broker may outsource activities only on the conditions of § 182, but insurance distribution itself may not be outsourced²⁹. Regulation (EU) 2022/2554 (DORA) applies, except to micro, small and medium-sized intermediaries³⁰.

AML/CFT. To the extent that a broker distributes life insurance or provides other investment-related services, it is a financial institution under the Money Laundering and Terrorist Financing Prevention Act (Rahapesu ja terrorismi rahastamise tõkestamise seadus, RahaPTS)³¹. It must then prepare a money-laundering risk assessment, adopt procedural rules and internal control rules, name the responsible board member if it has more than one, and appoint a contact person of the Financial Intelligence Unit³². FI supervises compliance by the financial institutions it supervises³³.

Documents filed with the application

The act's list (KindlTS § 187(1))³⁴, grouped:

• Company: articles of association; on founding, a notarised copy of the founding document and the bank's confirmation of paid-in share capital.
• Owners: list of shareholders with shares and votes; qualifying holdings in insurers; persons with close links, and why holdings of 10% or more and close links do not hinder supervision.
• Management: details of the board member responsible for distribution (identity, education, jobs of the last five years); confirmation that board members meet the requirements and of that member's experience and knowledge.
• Cover and rules: a valid offer of liability insurance or a guarantee meeting § 179; the internal rules or their draft; the data to be entered in the list.

From 18 March 2026 applications for entry in the list of insurance brokers are submitted through FI's application portal³⁵. The applicant must notify FI without delay of any change in these data and documents³⁶.

Fee and processing time

• Procedural fee: EUR 150 for an application to enter an insurance broker in the register of intermediaries, under the Financial Supervision Authority Act (Finantsinspektsiooni seadus)³⁷, paid before the application is filed³⁸.
• Annual supervision fee: a broker pays only the volume part, 0.5–5% of the total commissions it has collected³⁹.
• Time limit: FI decides on entry or refusal within three months after all required data and documents have been submitted⁴⁰. This is the law's time limit, not a promise of a date or a result.
• After a positive decision, FI enters the broker in the list as soon as it receives a copy of a valid liability insurance or guarantee contract⁴¹. FI may refuse entry, for example if a board member does not meet the requirements or the liability cover is insufficient⁴².
• Cross-border activity: a registered intermediary that wants to work cross-border in another EEA state files a request with FI; FI informs the host supervisor within one month, and the intermediary may start after FI tells it that the host supervisor has confirmed receipt⁴³. Cross-border activity in a non-EEA country needs FI's permission, decided within two months of a complete file and at the latest three months after the application⁴⁴.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application documents and manages the process: it prepares the application and handles the written follow-up of the authority's questions. Insurance broker registration is one of the licensable activities; the site has no fixed price for it, and the price is given on request. Requests go through the activity licence application documentation service described in the guide Licensed activities in Estonia, and we reply by email.

The price is our professional fee for the documentation work. It does not include FI's procedural fee, the professional indemnity insurance or other third-party costs. We do not give legal, tax or audit advice, and we do not take out the liability insurance. Finantsinspektsioon alone decides on entry in the list; we cannot promise the entry, a date or the authority's decision.

Sources

1. KindlTS § 5(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
2. KindlTS § 174(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
3. KindlTS § 174(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
4. KindlTS § 5(4) p 1–4 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
5. KindlTS, header; 10. peatükk — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
6. KindlTS footnote 1; EUR-Lex title — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
7. KindlTS § 187(1), § 188(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
8. KindlTS § 174(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
9. KindlTS § 188(5) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
10. Finantsinspektsioon, 'Insurance intermediaries' page — text in force from page read 2026-11-11
11. KindlTS § 176(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
12. KindlTS § 195(1),(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
13. KindlTS § 175(1) p 1–3, 5, 6 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
14. KindlTS § 209(1), § 214(1), § 215¹ — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
15. KindlTS § 183(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
16. KindlTS § 185(1),(2) p 5 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
17. KindlTS § 180(1),(2); chapter 10 read in full — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
18. KindlTS § 179(1) p 2, 3, 5 (p 2 in force since 21.10.2024, RT I, 11.10.2024, 1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
19. KindlTS § 179(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
20. KindlTS § 179(4) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
21. KindlTS § 191(1) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
22. KindlTS § 191(2) p 3, 4, 6 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
23. KindlTS § 191(5) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
24. KindlTS § 178(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
25. KindlTS § 186(2) p 16 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
26. KindlTS § 191(4) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
27. KindlTS § 186(1),(2) p 1–5¹, 7, 9, 10, 13, 14, 15 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
28. KindlTS § 186(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
29. KindlTS § 182(1),(7) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
30. KindlTS § 181¹(1),(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
31. RahaPTS § 6(2) p 5; § 2(1) p 2 — text in force from 21.07.2026
32. RahaPTS § 13(1), § 14(1), § 17(1),(2) — text in force from 21.07.2026
33. RahaPTS § 64(2) — text in force from 21.07.2026
34. KindlTS § 187(1) p 1–11 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
35. Finantsinspektsioon, 'Registration of insurance intermediaries' — text in force from page read 2026-11-11
36. KindlTS § 187(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
37. Finantsinspektsiooni seadus § 45³(4) — text in force from 01.10.2026
38. Finantsinspektsiooni seadus § 45¹⁰(1) — text in force from 01.10.2026
39. Finantsinspektsiooni seadus § 38(3), § 39(2) p 8 — text in force from 01.10.2026
40. KindlTS § 188(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
41. KindlTS § 188(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
42. KindlTS § 189 p 2, 4 — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
43. KindlTS § 206(1)–(3) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)
44. KindlTS § 207(1),(2) — text in force from 21.07.2026 (RT I, 11.07.2026, 140)

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
• Financial Supervision Authority 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.