Business lending company in Estonia: licence rules

The creditor licence of the Financial Supervision Authority is for granting credit to consumers. Under the Money Laundering and Terrorist Financing Prevention Act, though, a company whose main and permanent activity is lending is a financial institution. It needs an activity licence from the Financial Intelligence Unit before it starts. This page sets out the line between the two and the licence requirements.

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

Business lending means granting loans or other credit, as a regular business, to legal persons and to entrepreneurs acting for their business.

Under Estonian law, granting credit means granting credit as described in the Law of Obligations Act, together with deferred payment for a fee, leasing and other financial accommodation¹. The Credit Institutions Act lists among financial services "loan transactions, including consumer credit, mortgage loans, factoring and other commercial financing transactions" and also leasing transactions².

The boundary with consumer credit depends on who the borrower is. A consumer is a natural person who enters into a transaction that is not connected with an independent economic or professional activity³.

A lending company may not fund itself with deposits: only credit institutions may accept deposits or other repayable funds from the public⁴.

The legal acts and the authorities

• Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS). It applies to creditors and credit intermediaries that grant or arrange credit to consumers in Estonia in the course of their business⁵. In KAVS, a creditor is an undertaking whose business is granting credit to consumers⁶. A creditor must hold an activity licence, which the Financial Supervision Authority (Finantsinspektsioon, FSA) grants⁷. Only a creditor may use the word krediidiandja ("creditor"), its derivatives or foreign-language equivalents in its business name⁸.
• Credit Institutions Act (krediidiasutuste seadus, KAS). A financial institution is a company that is not a credit institution but whose main and permanent activity is acquiring holdings or carrying out one or more of the transactions listed in § 6(1) points 2–12, which include lending and leasing⁹.
• Money Laundering and Terrorist Financing Prevention Act (rahapesu ja terrorismi rahastamise tõkestamise seadus, RahaPTS). The act applies to financial institutions¹⁰. Its definition of a financial institution includes "other financial institutions within the meaning of the Credit Institutions Act"¹¹. An undertaking must hold an activity licence to operate as a financial institution¹².
• Authority: the Financial Intelligence Unit (Rahapesu Andmebüroo, FIU) grants or refuses the licence¹³. It is a government agency in the area of government of the Ministry of Finance¹⁴. It also supervises compliance with RahaPTS, unless the act provides otherwise¹⁵.
• Register: valid FIU authorisations can be searched in the Register of Economic Activities (majandustegevuse register, MTR)¹⁶.

Who must apply

A company whose main and permanent activity is lending to businesses must hold the FIU licence for operating as a financial institution⁹¹².

RahaPTS § 70(2) names four cases in which no RahaPTS licence is needed¹⁷:

1. the person holds an FSA activity licence;
2. another act obliges the person to apply for an FSA activity licence;
3. the person holds a licence from a financial supervisory authority of another European Economic Area (EEA) country that entitles it to operate in Estonia through a branch or across borders, and the FSA has been notified of this activity;
4. the person provides the services only within its group.

A company that also lends to consumers needs the FSA creditor licence⁷ and is then covered by the first two exemptions¹⁷.

Requirements for the applicant

Persons and reputation. The FIU grants the licence if the applicant, its management board members, procurators, beneficial owners and owners have no current conviction for an offence against the state, a money laundering offence or another intentional criminal offence, and if they have a proper business reputation¹⁸. Reputation is not proper, among other cases, where the person caused a bankruptcy or a licence revocation by a supervisory authority, is under a court-imposed business ban, or gave the FIU false information¹⁹.

Capital. Whether a capital requirement applies is specified for the client's situation.

Contact person (compliance officer). The management board must appoint a person to be the FIU contact person. The contact person reports directly to the board and has the competence, means and access to information the role requires²⁰. The contact person must work permanently in Estonia and have the necessary education, professional suitability, experience and an impeccable reputation. The appointment is coordinated with the FIU²¹. The licence requires that the contact person meets these conditions¹⁸. If the company has more than one management board member, it designates one of them as responsible for implementing the act²².

AML/CFT system. The company prepares a risk assessment covering at least customer, geographic, product and delivery-channel risk²³. It adopts procedural rules and internal control rules. At a minimum they cover customer due diligence (simplified and enhanced), a customer risk model, handling and reporting of suspicions, data retention, politically exposed person and sanctions screening, and new-technology risks²⁴. Employees who establish business relationships or carry out transactions must be trained²⁵.

Seat. An applicant not registered in the Estonian commercial register also submits data on its owners and management²⁶. The contact person must work permanently in Estonia²¹.

Documents filed with the application

On top of the general data required by the General Part of the Economic Activities Code Act (majandustegevuse seadustiku üldosa seadus, MSÜS)²⁷, RahaPTS § 70(3) requires the following²⁸.

Place of business and people

• the address of each place where the service is provided, including the website, and the name and contact details of the person responsible at each place;
• for an applicant not registered in the Estonian commercial register: data on its owner, beneficial owner, management body members and procurators;
• the name, personal code, citizenship, address, position and contact details of the FIU contact person, and of the person responsible for implementing international financial sanctions.

Rules

• the procedural rules and internal control rules under RahaPTS §§ 14–15, and the sanctions procedures required by the International Sanctions Act.

Reliability evidence

• for foreign nationals and undertakings: a home-country criminal record certificate no older than three months, legalised or apostilled, and for foreign citizens copies of identity documents for every country of citizenship;
• where the certificate does not cover what is required, a sworn statement of the person concerned²⁹;
• for each board member and procurator: education, full list of positions held, the board member's area of responsibility, and any evidence of reliability and business reputation.

Accounts and service

• a list of the payment accounts held in the applicant's name, with each account's unique identifier and the account provider's name;
• information on which financial service will be provided³⁰.

A company that is still being founded may submit its founding document instead of a registry code³¹. The application is filed only through the state portal eesti.ee or through a notary³².

State fee and processing time

The state fee for reviewing an application for a licence to operate as a financial institution is EUR 3,300³³.

The FIU decides within 60 days of the application. The period starts once all required documents and data have been submitted. The FIU may extend it to up to 120 days. If no decision is made in time, the licence is not deemed granted³⁴. If the documents are incomplete, incorrect, misleading or not properly formalised, the FIU leaves the application unexamined³⁵. The authority may also ask for additional data and set a reasonable deadline for it³⁶. These are the law's time limits, not a promise about any application.

What LexorCorp Global OÜ does and how to order

On its licensed and regulated companies page, LexorCorp Global sells "Lending company formation — corporate structure only, no creditor licence" for a fixed one-time fee of €3,500. The site states that this fee includes the state and notary fees. The service sets up the company for a lending business, either for business-to-business (B2B) lending or as preparation for a creditor licence. It includes the articles of association, a credit policy outline and a business loan agreement template. The stated timeline is 1–2 weeks. The client provides passports and proofs of address of the founders and management board, a description of the lending product (business borrowers, amounts, terms, security) and the source of the lending capital.

The FIU licence application is not part of this row. The same page sells, as separate rows, AML/CFT internal rules, risk assessment and procedures, and recruitment of an Estonia-based FIU contact person; the FSA creditor licence is a separate service on the credit licensing page.

LexorCorp prepares documents and manages the process. It does not give legal advice, audit or tax advice. The licence is granted or refused by the authority, and LexorCorp cannot promise a licence, a date or a decision. To order, use the form at order form.

Sources

1. KAVS § 3 — text in force from 30.06.2026
2. KAS § 6(1) p 2–3 — text in force from 01.10.2026
3. VÕS § 1(5) — text in force from 01.09.2026
4. KAS § 4(1) — text in force from 01.10.2026
5. KAVS § 2(1) — text in force from 30.06.2026
6. KAVS § 5(1) — text in force from 30.06.2026
7. KAVS § 10(1), (6) — text in force from 30.06.2026
8. KAVS § 8(1) — text in force from 30.06.2026
9. KAS § 5(1) — text in force from 01.10.2026
10. RahaPTS § 2(1) p 2 — text in force from 21.07.2026
11. RahaPTS § 6(2) p 11 — text in force from 21.07.2026
12. RahaPTS § 70(1) p 1 — text in force from 21.07.2026
13. RahaPTS § 71(1) — text in force from 21.07.2026
14. RahaPTS § 53(1) — text in force from 21.07.2026
15. RahaPTS § 64(1) — text in force from 21.07.2026
16. FIU, Authorisation for economic activity — text in force from n/a (web page)
17. RahaPTS § 70(2) — text in force from 21.07.2026
18. RahaPTS § 72(1) — text in force from 21.07.2026
19. RahaPTS § 72(2) p 1, 3, 5 — text in force from 21.07.2026
20. RahaPTS § 17(2) — text in force from 21.07.2026
21. RahaPTS § 17(5) — text in force from 21.07.2026
22. RahaPTS § 17(1) — text in force from 21.07.2026
23. RahaPTS § 13(1) — text in force from 21.07.2026
24. RahaPTS § 14(1) — text in force from 21.07.2026
25. RahaPTS § 14(6) — text in force from 21.07.2026
26. RahaPTS § 70(3) p 3–4 — text in force from 21.07.2026
27. MSÜS § 19(2) — text in force from 01.09.2025
28. RahaPTS § 70(3) p 1–11 — text in force from 21.07.2026
29. RahaPTS § 70(3¹) — text in force from 21.07.2026
30. RahaPTS § 70(4) — text in force from 21.07.2026
31. MSÜS § 19(4) — text in force from 01.09.2025
32. RahaPTS § 70(6) — text in force from 21.07.2026
33. RLS § 269(1) p 2 — text in force from 01.11.2026
34. RahaPTS § 71(1) — text in force from 21.07.2026
35. RahaPTS § 71(2) — text in force from 21.07.2026
36. MSÜS § 19(6) — text in force from 01.09.2025

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.

• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• Law of Obligations Act — Riigi Teataja, English translation
• Creditors and Credit Intermediaries 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.