Payment institution authorisation in Estonia

A payment institution is a company that provides payment services, such as executing transfers, acquiring card payments or money remittance, without being a bank. In Estonia it needs an authorisation (operating licence) from Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority. This page explains what the activity is, which law applies, what the applicant must have and file, and what LexorCorp Global OÜ does in the process.

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 Payment Institutions and E-money Institutions Act (makseasutuste ja e-raha asutuste seadus, MERAS) lists eight payment services: services enabling cash to be placed on a payment account; services enabling cash to be withdrawn from a payment account; execution of payment transactions, including transfers to a payment account; execution of payment transactions covered by a credit line; issuing payment instruments and acquiring payment transactions; money remittance; payment initiation services; and account information services¹. A payment institution is a company whose permanent activity is the provision of payment services².

Not covered, among others: cash paid directly from payer to payee; payments through a commercial agent acting for only the payer or only the payee; cash-in-transit; technical support services; and instruments usable only in a limited network or for a very limited range of goods or services³.

Client funds held for payments are not deposits or e-money⁴, and a payment institution may not accept deposits or other repayable funds⁵. Issuing electronic money requires a separate e-money institution licence under the same act⁶.

The legal act and the authority

• Act: Makseasutuste ja e-raha asutuste seadus (Payment Institutions and E-money Institutions Act), version in force since 1 October 2026⁷. It implements Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market (the second Payment Services Directive, PSD2)⁸.
• Authority: for a company founded in Estonia, Finantsinspektsioon grants and revokes the licence by its decision⁹.
• Register: Finantsinspektsioon keeps a list of Estonian payment institutions holding a valid licence, including exemptions applied¹⁰; it is published on fi.ee under "Payment institutions" in the supervised entities section¹¹.
• Related acts: the Money Laundering and Terrorist Financing Prevention Act (RahaPTS)¹²; the Financial Supervision Authority Act (FIS)¹⁹; Regulation (EU) 2022/2554 on digital operational resilience (DORA)¹³.

Who must apply

A company must hold a licence to operate as a payment institution¹⁴. Credit institutions, e-money institutions, certain postal service providers, central banks and the state acting outside their public functions may provide payment services without this licence¹⁵. The licence has no expiry date and cannot be transferred to another person¹⁶.

A payment institution providing any of the services in points 1–5 (account-based services, transfers, credit-line transactions, issuing and acquiring) may operate only as a public limited company (aktsiaselts, AS)².

Exemptions for small providers. The act names three exemptions, decided by Finantsinspektsioon in the licence decision; the company still applies for a licence and requests the exemption in the application¹⁷:

• money remittance only, if the average monthly total of payment transactions over the preceding 12 months does not exceed EUR 1 million;
• services in points 1–5, if less than half of annual revenue comes from payment transactions, the average monthly total does not exceed EUR 3 million and no money remittance, payment initiation or account information service is provided;
• account information service only.

Under the first two, the chapters on cross-border activity, qualifying holdings, restructuring and prudential requirements (including initial capital) do not apply, and the institution may not passport its services to other EEA countries¹⁷.

Requirements for the applicant

Initial capital (share capital or initial capital) must be at least¹⁸:

When the institution is founded as a new company, only amounts actually paid in count¹⁸. After authorisation the institution must also meet minimum own funds requirements calculated under the act²⁰.

Management. A manager must have the education, experience and professional suitability needed and an impeccable business reputation²¹. The management board has at least two members²¹. The act bars, among others, a person whose earlier activity led to bankruptcy, compulsory liquidation or licence revocation, and a person with an unexpunged conviction for an economic, official, property or public-trust offence or terrorist financing²¹. Holders of a qualifying holding are assessed as well²².

Seat and place of management. The registered office and head office must be in Estonia, and the articles of association must say so²³. Finantsinspektsioon may refuse a licence if the applicant intends to operate mainly in another EEA country²⁴.

Internal rules and control. Internal rules must cover, among others, segregation of duties, ICT and client-asset security, internal control, sanctions and AML/CFT, security incidents, access to sensitive payment data, business continuity and fraud statistics²⁵. The supervisory board appoints an internal auditor²⁶.

AML/CFT. A payment service provider (other than a provider of payment initiation or account information services only) is a financial institution under RahaPTS¹². It must prepare a money-laundering and terrorist-financing risk assessment covering at least client, geographic, product/service and channel risks²⁷, adopt procedural rules and internal control rules²⁸, name the management board member responsible for RahaPTS, and appoint a contact person of the Financial Intelligence Unit (Rahapesu Andmebüroo) who works permanently in Estonia, whose appointment is agreed with the Financial Intelligence Unit²⁹.

Safeguarding. An institution providing services in points 1–6 must keep client funds separate from its own assets and, if they have not been passed on by the end of the working day after receipt, hold them in a separate account with a credit institution or Eesti Pank or invest them in secure, liquid, low-risk instruments; instead, the funds may be covered by an insurance or comparable guarantee contract with an insurer or credit institution outside the group³⁰. Safeguarded client assets do not form part of the institution's bankruptcy estate³⁰. Providers of payment initiation and account information services only are outside this rule³⁰, but must hold professional indemnity insurance or a comparable guarantee³¹.

Documents filed with the application

The members of the management board file a written application with the documents listed in MERAS § 15³². Grouped:

• Corporate: articles of association; for a new company, notarised memorandum or founding resolution; proof of payment of share capital or of initial capital; list of shareholders; address of head office or registered office.
• Business: programme of operations; business plan for at least three years, including financial forecasts, risk management strategy and investment policy³³; opening balance sheet or, for an operating company, financial statements and audited own-funds evidence.
• Governance and controls: internal rules and accounting rules or drafts; internal control and AML/CFT measures; organisational structure, including agents, branches, outsourcing and payment-system participation.
• Safeguarding, ICT and security: description of how client assets are protected; information on ICT and other systems in line with DORA; security policy with a risk assessment and mitigation measures.
• People: data on qualifying holders; data on managers (education, full list of positions, area of responsibility) and documents on their reliability; companies in which the applicant or a manager holds over 20%; the auditor and internal auditor.
• Other: proof of the procedural fee; for payment initiation or account information services, proof of professional indemnity insurance³¹.

An applicant requesting an exemption files a reduced set¹⁷.

Procedural fee and processing time

The fee is a procedural fee (menetlustasu) under the Financial Supervision Authority Act: EUR 3,000 for a payment institution licence application, or EUR 500 where an exemption is requested; it is paid before the application is filed¹⁹. After authorisation the institution pays an annual supervision fee³⁴.

Finantsinspektsioon decides within three months of receiving all required documents and data in due form, but not later than six months after receiving the application³⁵. It may require additional information, carry out on-site inspections, leave an incomplete application unexamined, and restart the time limit after a material change³⁶. These are the law's time limits, not a promise of a date or outcome; Finantsinspektsioon may grant or refuse the licence³⁷.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application for authorisation as a payment institution under MERAS and manages the procedure until Finantsinspektsioon's decision: programme of operations and business plan, governance, internal control and AML/CFT documents, the application file, and answers to the authority's questions. The client provides information, capital and people that meet the legal requirements, signs the application and answers the authority's questions.

Not included: state and procedural fees, the regulatory capital, IT systems, audits and third-party costs. We do not give legal or tax advice and do not audit. The FIU licence FIU000117 is LexorCorp's own licence for its trust and company services and does not authorise the client. The authorisation is granted or refused by Finantsinspektsioon; no service provider can promise it or a date.

The service "Estonian payment institution authorisation — application preparation and management" is ordered and paid at order form. The price is our fee for the standard scope; further work only with the client's written agreement.

Sources

1. MERAS § 3(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
2. MERAS § 5(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
3. MERAS § 4(1) p 1–3, 9, 10; § 4(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
4. MERAS § 5(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
5. MERAS § 5(6) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
6. MERAS § 14(1), § 7 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
7. Riigi Teataja header — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
8. EUR-Lex CELEX 32015L2366 — text in force from consolidated version 17/01/2025
9. MERAS § 14(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
10. MERAS § 105(1) p 1, 9 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
11. fi.ee Payment institutions — text in force from page as viewed 2026-11-11
12. RahaPTS § 6(2) p 2 — text in force from 21.07.2026
13. MERAS § 15(1) p 9 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
14. MERAS § 14(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
15. MERAS § 14(5) with § 3(6) p 2–6 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
16. MERAS § 14(4) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
17. MERAS § 11(1)–(4), (6); § 14(3¹); § 15(1³)–(1⁴); chapter headings 3, 4, 6, 8 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
18. MERAS § 64(1), (3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
19. FIS § 45³(2), (5); § 45¹⁰(1) — text in force from 01.10.2026
20. MERAS § 72(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
21. MERAS § 47(1), (2), (4) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
22. MERAS § 38; § 15(1) p 13 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
23. MERAS § 46(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
24. MERAS § 19(1) p 7 — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
25. MERAS § 50(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
26. MERAS § 51(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
27. RahaPTS § 13(1) — text in force from 21.07.2026
28. RahaPTS § 14(1) — text in force from 21.07.2026
29. RahaPTS § 17(1), (2), (5) — text in force from 21.07.2026
30. MERAS § 79(1)–(3), (8) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
31. MERAS § 15(1²), § 63⁷ — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
32. MERAS § 15(1) p 1–21, (3) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
33. MERAS § 16(1)–(2) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
34. FIS § 38(2) — text in force from 01.10.2026
35. MERAS § 18(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
36. MERAS § 17(1), (1¹), (2), (3), (5) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)
37. MERAS § 18(1); § 19(1) — text in force from 01.10.2026 (RT I, 11.07.2026, 53)

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.

• Payment Institutions and E-money Institutions Act — Riigi Teataja, English translation
• Directive (EU) 2015/2366 — EUR-Lex
• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• Financial Supervision Authority Act — Riigi Teataja, English translation
• Regulation (EU) 2022/2554 — EUR-Lex

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