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LexorCorp Global Order

Guide

Safeguarding customer funds in Estonian payment and e-money institutions

A payment institution or e-money institution in Estonia that receives money from its customers must keep that money protected, so that customers get it back even if the institution fails.

LexorCorp Global OÜ · published 11 November 2026

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Eesti

In short

A payment institution or e-money institution in Estonia that receives money from its customers must keep that money protected, so that customers get it back even if the institution fails. Estonian law allows two methods: keeping the funds separate (on a separate account or in low-risk assets), or covering them with an insurance policy or a comparable guarantee. Its description is part of the payment or e-money licence application on which Finantsinspektsioon decides.

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A payment institution or e-money institution in Estonia that receives money from its customers must keep that money protected, so that customers get it back even if the institution fails. Estonian law allows two methods: keeping the funds separate (on a separate account or in low-risk assets), or covering them with an insurance policy or a comparable guarantee. Its description is part of the payment or e-money licence application on which Finantsinspektsioon decides.

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 safeguarding is

Safeguarding is the set of rules that keeps customers' money apart from the institution's own money. A payment institution that executes transfers, issues payment instruments or acquires payment transactions, or an e-money institution that issues e-money against payment, holds money that belongs to its customers. The law requires that this money is kept apart from the institution's own assets and that it does not fall into the institution's bankruptcy estate.123 In the bankruptcy of an e-money institution, or of a payment institution that uses the insurance or guarantee method, customers' claims are satisfied immediately after claims secured by a pledge and before other creditors' claims.45

Covered: funds received for the payment services in points 1–6 of § 3(1) of the act (cash placed on or withdrawn from a payment account, execution of payment transactions, issuing payment instruments and acquiring payment transactions, money remittance) and funds received for issuing e-money.45 Not covered: a payment institution that provides only payment initiation and/or account information services; the act states that a payment initiation service provider does not hold the payer's funds at any time.67

The legal act and the authority

The Estonian act is the Payment Institutions and E-money Institutions Act (Makseasutuste ja e-raha asutuste seadus, MERAS), chapter 9 "Holding of assets" (§§ 78–80); the version in force since 1 October 2026 applies.8 It implements Article 10 of Directive (EU) 2015/2366 (the second Payment Services Directive, PSD2) for payment institutions and Article 7 of Directive 2009/110/EC (the second E-money Directive, EMD2) for e-money institutions.910

The competent authority is Finantsinspektsioon (FI, the Estonian Financial Supervision and Resolution Authority), which grants the payment services licence and the e-money licence.11 FI keeps the public list of licensed Estonian payment and e-money institutions.12 Breach of the safeguarding requirements of §§ 78–80 is a misdemeanour; for a legal person the fine is up to EUR 5,000,000, up to twice the gain obtained or loss avoided, or up to 10 per cent of the consolidated turnover of the legal person or its group.13

Which institutions must safeguard

  • A payment institution that provides one or more of the payment services in § 3(1) points 1–6 MERAS.4
  • An e-money institution, for the funds received for e-money issued.5
  • An e-money institution that also provides payment services not linked to e-money applies the payment-institution rules of § 79 to that activity.14

Exemptions named in the act: § 79 does not apply to a payment institution that provides only payment initiation and/or account information services.6 A payment institution that provides only account information services can be exempted by FI from chapter 9 as a whole.15 The small payment institution and small e-money institution exemptions of § 11(1)–(2) and § 12(1) do not exempt from chapter 9, and such applicants still file the description of safeguarding with their application.1617

Requirements for the applicant

Internal rules. The institution must set in its internal rules the principles for protecting and holding customers' assets, and its internal procedures must cover the security of the systems used to hold customers' assets and their regular checking.118

Method 1 – segregation. A payment institution must keep customers' assets separate from its own assets and hold customers' money on a separate account with a credit institution or on an account with Eesti Pank (the central bank) under the rules of Eesti Pank, or invest it in secure, liquid, low-risk instruments.2 An e-money institution has the same duty for funds equal to its outstanding e-money liabilities.5 For an e-money institution, the act lists the eligible instruments: debt instruments under Article 336 of Regulation (EU) No 575/2013 with a specific-risk capital requirement of no more than 1.6 per cent, and units or shares of UCITS funds (eurofondid) that invest only in such instruments; FI may decide that a particular instrument does not qualify.1920

Method 2 – insurance or guarantee. Instead of segregation, the funds may be covered by an insurance policy or a comparable guarantee from an insurer or credit institution that does not belong to the same group as the institution, for an amount equal to what would have been segregated, payable if the institution cannot meet its financial obligations to customers.2122

Deadline. A payment institution must safeguard the money if it has not passed it on to the payee or another payment service provider by the end of the business day following the day the funds were received.2 An e-money institution must apply the safeguarding requirements no later than the fifth business day after the date of issuing the e-money.23 For future payment transactions, the same rules apply to the known amount or the amount forecast from past data; FI may ask the payment institution to justify the forecast.24

Liquidity and accuracy. Assets must be placed in liquid instruments so that customers' payment orders and other legitimate claims can be met at any time, and the institution must be able at any moment to calculate its own funds and investment limits with sufficient accuracy.2526

Records and reconciliation. How often customer balances are reconciled with the safeguarded amount is specified for the client's situation. Data required by the act must be kept unchanged and available to FI for five years, unless FI has set a different term or a law sets a longer one.27 The internal auditor checks compliance with the law and the internal rules, and the annual report must be audited.2829

Other licence requirements (assessed together with safeguarding): minimum share capital of EUR 20,000, 50,000 or 125,000 for a payment institution depending on the services, and EUR 350,000 for an e-money institution; a management board of at least two members who meet the fit-and-proper requirements; registered seat and head office in Estonia; anti-money-laundering and counter-terrorist-financing (AML/CFT) internal rules.30313233

What goes into the application

The safeguarding part of the licence application consists of:

  • a description of how the general requirements of chapter 9 on holding and protecting customers' assets will be applied (§ 15(1) point 7);34
  • the internal rules under § 50, including the rules on the security of systems holding customers' assets, or their drafts (§ 15(1) point 8);3518
  • a description of how these documents and their implementation are audited and organised to protect customers' legitimate interests (§ 15(3));36
  • the business plan for at least three years, including the obligations related to the services and the investment policy (§ 16).37

FI's own page lists the same item as "A description of how the general requirements of MERAS for holding client assets and client protection will be applied".38 Which method is chosen, and whether insurance or a bank account is available, is specified for the client's case.

State fee and processing time

The safeguarding description is filed within the licence application.34 The procedure fee for a payment institution or e-money institution licence is EUR 3,000. Where an exemption under § 11(1)–(3) or § 12(1) MERAS is applied for, the fee is EUR 500.3940

FI decides within three months of receiving all necessary documents and data in due form, but no later than six months after receiving the application.41 FI may require additional data and documents, and if a material change is made during the procedure it may count the time limit from receipt of that change.4243 These time limits are the law's limits for the authority; they are not a promise about the date or content of the decision.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ offers "Safeguarding of customers' funds — policy and account documentation" as an add-on to the payment institution and e-money institution licence services.44 It includes a safeguarding policy (segregation or insurance/guarantee method), a daily reconciliation procedure and a documentation pack for the bank that holds the safeguarding account.44 It does not include opening the safeguarding account, which the bank grants at its discretion, or insurance or guarantee premiums.44 The price starts from €2,400 (one-time), and the documents are usually delivered within 7 working days after the necessary information has been received.44

LexorCorp prepares the documents and manages the process; it does not give legal advice, carry out audits or give tax advice, and it cannot promise a licence, a date or a decision of Finantsinspektsioon or a bank.

Order: order form.

Sources

  1. MERAS § 78(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  2. MERAS § 79(1) points 1–2 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53); point 2 wording in force from 18.07.2025
  3. MERAS § 79(2), § 80(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  4. MERAS § 3(1), § 79(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  5. MERAS § 80(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  6. MERAS § 79(8) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  7. MERAS § 3(3¹) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  8. MERAS header and chapter 9 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  9. Directive (EU) 2015/2366 Art. 10(1) — text in force from in force (consolidated EUR-Lex text)
  10. Directive 2009/110/EC Art. 7(1) — text in force from in force (EUR-Lex)
  11. MERAS § 14(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  12. MERAS § 105(1) point 1 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  13. MERAS § 114(1)–(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53); § 114(2) wording from 01.07.2024
  14. MERAS § 80(6) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  15. MERAS § 11(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  16. MERAS § 11(1)–(2), § 12(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  17. MERAS § 15(1³) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  18. MERAS § 50(3) point 6 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53); point 6 from 17.01.2025
  19. MERAS § 80(4) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  20. MERAS § 80(5) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  21. MERAS § 79(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  22. MERAS § 80(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  23. MERAS § 80(7) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  24. MERAS § 79(5) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  25. MERAS § 78(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  26. MERAS § 78(4) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  27. MERAS § 51(6) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  28. MERAS § 51(2)–(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  29. MERAS § 84(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  30. MERAS § 64(1)–(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  31. MERAS § 47(1)–(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  32. MERAS § 46(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  33. MERAS § 50(3) point 8 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  34. MERAS § 15(1) point 7 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  35. MERAS § 15(1) point 8 — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  36. MERAS § 15(3) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  37. MERAS § 16(1) points 2, 9; § 16(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  38. FI: Operating licences for payment institutions and e-money institutions, item 7 — text in force from page as read 2026-11-11
  39. FIS § 45³(2); MERAS § 15(1) point 21 — text in force from 01.10.2026 (FIS consolidated version); § 45³(2) from 14.07.2024
  40. FIS § 45³(5) — text in force from 01.10.2026 (FIS consolidated version)
  41. MERAS § 18(1) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  42. MERAS § 17(2) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53)
  43. MERAS § 17(1¹) — text in force from 01.10.2026 (MERAS version RT I, 11.07.2026, 53); from 18.07.2025
  44. LexorCorp Global price list and service description (price list)
  45. MERAS § 88(5) — text in force from 01.10.2026 (MERAS version 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.

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.

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We prepare the application documents and manage the process; the authority decides. Not legal advice.

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