Savings and loan associations in Estonia (hoiu-laenuühistu)

A savings and loan association is a member-owned commercial association that takes deposits from its members and lends to them. Estonia reformed the regime on 1 March 2026: no new association can be formed, existing associations must stop or convert by 1 January 2029, and the Savings and Loan Associations Act itself expires on 1 March 2029. This page sets out the rules in force today and the transition paths the act names.

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

Under the Savings and Loan Associations Act (hoiu-laenuühistu seadus, HLÜS), a savings and loan association is a financial institution operating in the form of a commercial association (tulundusühistu) whose activity consists only of the services and transactions listed in § 6 of the act¹. Its main and permanent activity is providing financial services to its own members: taking deposits and other repayable funds; loans, including consumer credit, mortgage loans, factoring and other business financing; guarantees; and leasing². It may also offer currency exchange and payment services to members and other persons, but it may not provide its services abroad, either cross-border or through a branch³.

Membership is based on a common occupation or field of activity or a shared economic interest; members may be natural persons, sole traders, companies, non-profit associations and foundations linked to that common field. Companies may make up no more than 25 percent of the members, and the state and local authorities cannot be members⁴. The seat and the place of business must be in Estonia⁵.

What is not covered: an association whose activity goes beyond § 6(1) or breaks § 6(5) is treated as taking deposits from the public within the meaning of the Credit Institutions Act (krediidiasutuste seadus, KAS) § 4⁶; under KAS § 4(1) only credit institutions may take deposits or other repayable funds from the public⁷.

The legal act and the authority

The core act is HLÜS, redaction in force from 1 March 2026⁸. Unless HLÜS provides otherwise, the rules on commercial associations apply⁹. An association is entered in the Estonian commercial register (äriregister)¹⁰.

Two other acts bring an association under supervision:

• Money Laundering and Terrorist Financing Prevention Act (rahapesu ja terrorismi rahastamise tõkestamise seadus, RahaPTS): a savings and loan association is a financial institution under § 6(2)(9), and acting as a financial institution requires an activity licence under § 70(1)(1)¹¹. The licence is issued by the Financial Intelligence Unit (Rahapesu Andmebüroo, FIU), which must take HLÜS § 36 into account when assessing the managers¹².
• Creditors and Credit Intermediaries Act (krediidiandjate ja -vahendajate seadus, KAVS): an association that grants consumer credit is a creditor, unless no credit agreement exceeds the six-month average annual percentage rate of consumer loans by credit institutions to private persons last published by Eesti Pank and the association has fewer than 3,000 members¹³. Creditor licences are issued by the Financial Supervision Authority (Finantsinspektsioon, FSA)¹⁴.

The association also reports statistical data to Eesti Pank¹⁵. The EU Digital Operational Resilience Act, Regulation (EU) 2022/2554, does not apply to it¹⁶.

Who must apply — and what has changed since 1 March 2026

No new associations. After 1 March 2026 a savings and loan association can no longer be formed or entered in the commercial register in that form¹⁷. Since the same date an association cannot apply for an FIU licence under RahaPTS¹⁸.

Restrictions on existing associations. From 1 July 2026 an association may not conclude new deposit contracts or grant loans to natural-person members for purposes outside their business, and may not extend existing deposit contracts or loan contracts concluded with natural persons¹⁹. Associations founded before 1 March 2026 had to bring their activity and documents into line with the listed provisions of the new redaction by 1 October 2026²⁰.

Transition paths (HLÜS § 47³).

• From 1 January 2029 an association may continue taking deposits only as a credit institution, including a cooperative bank (ühistupank). Otherwise it may continue as a commercial association, including under a payment institution or creditor licence, only after it has stopped taking deposits²¹.
• An association that wishes to continue as a credit institution, payment institution or creditor must file the licence application with the FSA by 1 January 2027²².
• An association that does not apply but continues as a commercial association must notify the FSA in writing by 31 December 2028²³; if its activity is that of a financial institution, it needs an FIU licence²⁴.
• An existing FIU licence expires when the FSA grants one of those licences, or at the latest on 31 December 2028²⁴.
• An association that neither applied in time (or was refused) nor notified the FSA by 31 December 2028 faces an FSA claim for compulsory dissolution, filed by 1 March 2029²⁵.

Associations may also merge to found a cooperative bank under the Credit Institutions Act²⁶. HLÜS remains in force until 1 March 2029²⁷.

Requirements for an existing association

Capital. Share capital of at least EUR 125,000; net assets must at all times be at least equal to the share capital²⁸. A reserve of at least half the share capital, with at least 20 percent of net profit transferred to it each year²⁹. Each member pays an entry fee of at least EUR 40 and a share contribution of at least EUR 50, in money; these minimums do not apply to members who joined before 1 March 2026³⁰.

Members. At least 25 members; if the number falls below 25 and does not rise within two months, the association is dissolved³¹.

Management. A management board of two members unless the articles provide more; a supervisory board of three members unless the articles provide more, who must be members of the association; and an audit committee (revisjonikomisjon) of three members unless the articles provide more, each with economic or legal education or three years' relevant experience³². A loan committee is mandatory once the association has 50 members³³. Board and supervisory board members must have an impeccable business reputation and the education, knowledge and professional suitability needed; the act lists what excludes a person³⁴.

Prudential rules. At least ten percent of members' deposits held as demand deposits with a credit institution or in other liquid assets, a liquidity buffer covering at least 60 days, and limits on lending to one member and to related persons³⁵.

Internal rules and AML/CFT. Internal rules must cover, among other things, conflicts of interest, segregation of duties, credit assessment, and procedures for international sanctions and the prevention of money laundering and terrorist financing³⁶.

Audit. The annual accounts must be audited, and each year an auditor must carry out a special assurance engagement on capital, prudential, liquidity and lending-limit compliance³⁷.

Documents

As no new association can be formed or registered¹⁷, the documents for the transition depend on the licence chosen:

• Creditor licence (KAVS § 12). The general KAVS application list applies with two differences for an association: no data on persons with qualifying holdings or control are filed, but the application must include data and documents on the origin of funds used to pay any share contribution of EUR 5,000 or more³⁸.
• Credit institution or payment institution licence. The documents follow the Credit Institutions Act or the Payment Institutions and E-money Institutions Act; the list is specified for the client's case.
• The decision to apply for a licence is taken by the general meeting³⁹.

State fee and processing time

For a creditor licence, the FSA decides within four months of receiving all required, correct information and documents and the requirements being met, but no later than six months after receiving the application; the applicant may give irrevocable written consent to an extension⁴⁰. These are the law's time limits, not a promise of a date. The fees for the creditor, payment institution and credit institution licences are described on the pages of those licences and are specified for the client's case.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ (registry code 12233761) offers the row "Activity licence application documentation": the requirements of the act for the activity, from its official text; the application and the documents it needs; the submission and the written follow-up of the authority's questions. The price is from €3,500, one-time, no VAT is added. The state fee is separate and paid by the company.

The service is application preparation, not legal advice, and does not include audit or tax advice. Meeting the act's capital, staff or premises requirements is not included. The authority decides; a licence, a date or a decision cannot be promised. Licences with their own page on this site — credit institutions, payment institutions and creditor licences — are priced there.

Order: order form

Sources

1. HLÜS § 3(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
2. HLÜS § 6(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
3. HLÜS § 6(3), (5) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
4. HLÜS § 17(2)-(4) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
5. HLÜS § 5(3) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
6. HLÜS § 2(4) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
7. KAS § 4(1) — text in force from 01.10.2026
8. HLÜS header — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
9. HLÜS § 2(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
10. HLÜS § 14 — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
11. RahaPTS § 6(2)(9), § 70(1)(1) — text in force from 21.07.2026
12. RahaPTS § 72(2¹) — text in force from 21.07.2026
13. KAVS § 2(6) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
14. KAVS § 10(1), (6) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
15. HLÜS § 41³ — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
16. HLÜS § 2¹ — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
17. HLÜS § 47¹(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
18. RahaPTS § 118⁶(1) — text in force from 21.07.2026
19. HLÜS § 47¹(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
20. HLÜS § 47²(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
21. HLÜS § 47³(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
22. HLÜS § 47³(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
23. HLÜS § 47³(3) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
24. RahaPTS § 118⁶(2) — text in force from 21.07.2026
25. HLÜS § 47³(5) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
26. HLÜS § 44(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
27. HLÜS § 48(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
28. HLÜS § 22(3) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
29. HLÜS § 24(1), (3) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
30. HLÜS § 16(1), § 23(1)-(2), § 47²(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
31. HLÜS § 18(1), § 45(1)(3) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
32. HLÜS § 34(1), § 32⁵(2)-(3), § 37(1)-(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
33. HLÜS § 29(1) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
34. HLÜS § 36(1)-(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
35. HLÜS § 27(1)(1), § 27¹(4)-(5), § 28(7¹), (9) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
36. HLÜS § 31(2) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
37. HLÜS § 41(1), (4) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
38. KAVS § 12(3) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)
39. HLÜS § 32(1)(5¹) — text in force from 01.03.2026 (RT I, 13.02.2026, 2)
40. KAVS § 15(2) — text in force from 30.06.2026 (RT I, 20.06.2026, 24)

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
• Creditors and Credit Intermediaries Act — Riigi Teataja, English translation
• Regulation (EU) 2022/2554 — EUR-Lex
• Payment Institutions and E-money Institutions 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.