Pawnbroking and buying-in or wholesale of precious metals

Running a pawnshop, or buying in or selling wholesale precious metals, precious metal articles or precious stones, needs an activity licence from the Estonian Financial Intelligence Unit. The licence checks the people, the anti-money-laundering rules and the contact person. Makers and importers of precious metal articles also have marking duties under a separate act.

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 Money Laundering and Terrorist Financing Prevention Act (Rahapesu ja terrorismi rahastamise tõkestamise seadus, RahaPTS) requires a licence for two separate activities that this page covers together:

Pawnbroking ("pandimajateenuse osutamine")¹. A pawnshop lends money against a movable item that the borrower hands over as security. Under the Law of Property Act (Asjaõigusseadus, AÕS), a movable can be pledged by handing it over into the possession of the pledgee (possessory pledge)².
Buying-in or wholesale of precious metals, precious metal articles or precious stones, except precious metals and precious metal articles used for production, scientific or medical purposes¹.

The act's definitions decide what is covered. Precious metal means pure gold, silver, platinum and palladium and their alloys³⁴. Precious stones are natural and synthetic precious and semi-precious stones, their powder and dust, and natural and cultured pearls³.

Not covered: precious metals and precious metal articles used for production, science or medicine are excluded¹. A pawn loan to a consumer whose liability is limited to the value of the pledged item held by the lender is outside the consumer-credit rules of the Law of Obligations Act (Võlaõigusseadus, VÕS)⁵ and, for that reason, outside the credit-giving rules of the Creditors and Credit Intermediaries Act (KAVS)⁶. If the consumer is liable beyond the item, those rules may apply; this is specified for the client's case.

The legal act and the authority

Licence requirement: RahaPTS § 70 (1) points 3 and 6¹.
Authority: the Financial Intelligence Unit (Rahapesu Andmebüroo, FIU) grants or refuses the licence⁷ and supervises compliance with RahaPTS⁸.
General procedure: the General Part of the Economic Activities Code Act (Majandustegevuse seadustiku üldosa seadus, MsÜS) applies alongside RahaPTS⁹.
Register: the licence is shown in the Register of Economic Activities (majandustegevuse register, MTR); the FIU directs readers there to search valid authorisations¹⁰.
Product rules: the Precious Metal Articles Act (Väärismetalltoodete seadus, VMTS) sets marking and sales-document rules; where RahaPTS regulates the handling of precious metal articles, VMTS applies with the exceptions arising from RahaPTS¹¹. Name marks are registered with the Consumer Protection and Technical Regulatory Authority (TTJA)¹².

Who must apply

Every undertaking that operates in either field needs the licence¹. Pawnbrokers and persons buying in or selling wholesale precious metals, precious metal articles or precious stones are also "obliged persons" under RahaPTS and must apply its anti-money-laundering duties¹³.

The act names these exemptions from the licence requirement¹⁴:

a person who holds an activity licence of the Financial Supervision Authority (Finantsinspektsioon);
a person who is required by another act to apply for a Finantsinspektsioon licence;
a person licensed by the financial supervisor of another European Economic Area (EEA) state with the right to operate in Estonia through a branch or cross-border, where Finantsinspektsioon has been notified;
a person providing the services within its own group.

Requirements for the applicant

Capital. The former capital and own-funds sections (§§ 72¹–72²) applied to virtual currency service providers and are repealed¹⁵. Whether capital requirements apply is specified for the client's situation.

Owners and management (fit and proper). The licence is granted if the undertaking, its management board members, procurator, beneficial owner and owner have no current conviction for an offence against the state, a money-laundering offence or another intentional crime, and have a proper business reputation¹⁶. Reputation is not proper, among other cases, after false information to the FIU, a business ban or an unspent conviction for an economic, official, property or public-trust offence¹⁷.

Contact person (compliance officer). The management board must appoint a FIU contact person who reports directly to the board¹⁸. Only a person who works permanently in Estonia and has the necessary education, professional suitability, abilities, personal qualities, experience and impeccable reputation may be appointed, and the appointment is coordinated with the FIU¹⁹. The contact person must meet the act's requirements for the licence to be granted¹⁶. Where the board has more than one member, one member is named responsible for applying the act²⁰.

AML/CFT system. The applicant must:

prepare a risk assessment covering at least client, geographic, product/service/transaction and delivery-channel risks²¹;
adopt procedural rules and internal control rules, including customer due diligence, the risk model, the procedure for suspicions and reporting to the FIU, data retention, and checks for politically exposed persons and international sanctions²²;
name in the application the person responsible for international financial sanctions²³;
train employees who establish business relationships or make transactions, when they start and regularly afterwards²⁴.

Seat and place of business. RahaPTS asks extra data from an applicant not registered in the Estonian commercial register, and every place of service, including the website, is stated with its responsible person²³.

Precious metal articles (VMTS). The manufacturer or importer must ensure that an article bears the compulsory marks, the name mark and the fineness mark²⁵. A name mark is registered in the TTJA supervision information system on the application of a manufacturer or importer¹², for up to ten years²⁶. A wholesaler must give a delivery document identifying the article, the metal and its fineness²⁷. The former VMTS notification duty (§ 3) was repealed from 1 July 2014²⁸.

Documents filed with the application

Besides the general data required by MsÜS (name and registry code, contact details, field of activity, signatory)²⁹, RahaPTS § 70 (3) lists²³:

Business and places of service

the address of each place of service, including the website, and the name and contact details of the person responsible at each;
a list of the undertaking's payment accounts with their unique identifiers and account providers.

People

for an undertaking not in the Estonian commercial register: owner and beneficial owner data, and management board members' and procurators' data;
for management board members and procurators: documents showing education, a full list of jobs and positions and, for board members, their area of responsibility, plus any documents showing reliability and business reputation;
where the undertaking, a board member, procurator, beneficial owner or owner is a foreign citizen or foreign-established: a criminal record certificate of the home state not older than three months, notarised and legalised or apostilled unless a treaty provides otherwise, and copies of identity documents for all states of citizenship.

AML/CFT

the procedural rules and internal control rules under RahaPTS §§ 14–15 and, where applicable, the sanctions procedures;
the name, personal data, position and contact details of the contact person and of the person responsible for international financial sanctions.

Where foreign certificates do not prove the absence of convictions to the required extent, a sworn statement of the person is added³⁰. The application is filed only through the Estonian state portal or a notary³¹; the FIU names the Eesti.ee portal and the register's website³².

State fee and processing time

State fee: 345 euros for reviewing a RahaPTS licence application for pawnbroking or for buying-in or wholesale of precious metals, precious metal articles or precious stones³³. Registering a name mark with TTJA, changing it or extending it costs 30 euros³⁴.

Time limit: the FIU decides within 60 days; the period runs from the filing of all required documents and data, and the FIU may extend it to 120 days. If the FIU does not decide in time, the licence is not deemed granted⁷. If the documents are incomplete, incorrect, misleading or not properly formalised, the FIU leaves the application unexamined³⁵. The authority may ask for additional information needed to check the requirements³⁶. These are the law's time limits for the authority, not a promise of a decision or a date.

After the licence: it is granted without a time limit unless an act provides otherwise or the undertaking itself asks for a limited term³⁷. The FIU revokes it if, among other grounds, the undertaking has not started the activity within six months of the licence³⁸.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the activity licence application documents for the company: the requirements of the act for the activity, taken from its official text, the submission through the Register of Economic Activities and the written follow-up of the authority's questions; the timeline is agreed with the client. The state fee is paid by the client. We do not give legal or tax advice and do not audit, and we cannot promise the licence, a date or the authority's decision, which belongs to the FIU.

The price is given on request. Both activities are listed in the guide Licensed activities in Estonia, each with its own "Request a price" button; we reply by email.

Sources

RahaPTS § 70 (1) p 3 and 6 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
AÕS § 281 (1) — text in force from 01.10.2026
RahaPTS § 3 p 6–8 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
VMTS § 2 p 1 — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
VÕS § 403 (3) p 4 — text in force from 01.09.2026
KAVS § 2 (11) p 1 — text in force from 30.06.2026
RahaPTS § 71 (1) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 64 (1) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 70 (3); MsÜS § 19 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
FIU, Authorisation for economic activity — text in force from page read 2026-11-11
VMTS § 1 (4) — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
VMTS § 12 (1) — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
RahaPTS § 2 (1) p 6 and 14 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 70 (2) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS §§ 72¹, 72² (repealed) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 72 (1) p 1, 1¹, 2 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 72 (2) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 17 (2) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 17 (5) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 17 (1) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 13 (1) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 14 (1) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 70 (3) p 1–11 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 14 (6) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
VMTS § 7 (1), (3) — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
VMTS § 20¹ (1) — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
VMTS § 34 (1) — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
VMTS § 3 — text in force from 01.07.2025 (RT I, 30.04.2024, 14)
MsÜS § 19 (2) p 1; § 15 (1) p 1–4, 7 — text in force from 01.09.2025
RahaPTS § 70 (3¹) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
RahaPTS § 70 (6) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
FIU, Applying for authorisation — text in force from page read 2026-11-11
RLS § 269 (1) p 1 — text in force from 01.11.2026
RLS § 234 — text in force from 01.11.2026
RahaPTS § 71 (2) — text in force from 21.07.2026 (RT I, 11.07.2026, 93)
MsÜS § 19 (6) — text in force from 01.09.2025
MsÜS § 24 (1) — text in force from 01.09.2025
RahaPTS § 75 (1) p 3 — text in force from 21.07.2026 (RT I, 11.07.2026, 93)

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.

Pawnbroking and buying-in or wholesale of precious metals and stones in Estonia