Obtaining an EMI Licence in Estonia. Service offer

In order to obtain an EMI (E-money institution) licence in Estonia, it is necessary to start by registering an Estonian company – building substance in the country (renting an office, hiring employees, relocating the client employees and getting them a work permit, applying for a residence permit). Only then does one proceed with a licence, seek tax and legal advice, and deal with ongoing administration of the company.

To apply for an operating licence, a written application must be submitted to the Financial Supervision Authority together with the additional information required under the Payment Institutions and E-money Institutions Act (MERAS).

To be licensed to provide payment services, the founders of a business or the management of a registered company must submit the following documents and data* to the Financial Supervision Authority:

• A copy of the Articles of Association and, in the case of an operating company, the Resolution by the general meeting to amend the Articles, and the amended Articles;
• A notarized copy of the Memorandum of Association or the Resolution to found a company;
• Documentary proof of payment of share capital or the existence of initial capital;
• An action plan describing in particular the proposed payment services or e-money services;
• A business plan that meets the requirements of MERAS;
• The initial balance of the applicant and an overview of income and expenses or, in the case of an operating company, the balance sheet and income statement at the end of the month prior to submission of the application, and annual reports for the past 3 years (if any);
• A description of how the general requirements of MERAS for safekeeping and protection of client assets will be applied;
• The internal rules in accordance with MERAS, and the accounting policies and procedures, or drafts thereof;
• The information on the IT and other technological equipment and security systems, and control mechanisms and systems required for provision of the proposed services;
• A description of internal controls and measures to ensure compliance with anti-money laundering and terrorist financing obligations and obligations for information about the payer upon transfer of funds;
• A description of the organizational structure of the applicant, covering where necessary the use of agents or branches or the procedures for transferring services, and its participation in domestic and international payment systems;
• A list of the shareholders of the applicant showing the name of each shareholder and their registry code or ID code, or, if none, their date of birth, as well as details of shares or holding of each shareholder;
• The details required by MERAS of the shareholders with substantial holdings in the applicant;
• The details of the managers of the applicant, including their full name, ID code or, if no ID code, date of birth, place of residence, educational background, full employment history with positions held, and, in the case of members of the management board, a description of their areas of responsibility, together with any documentation that the applicant considers necessary to demonstrate that they are trustworthy and meet the requirements;
• The information on any business in which the applicant or its management holds more than 20%, also indicating the amount of share capital, a list of its areas of activity, and the size of the holding of the applicant and each manager;
• The details of the auditor and internal auditor of the applicant, including their name, place of residence or place of business, as well as personal ID code or, if no ID code, date of birth or registry code;
• Documentary proof of the amount of own funds together with the auditor’s report – in the case of an operating company;
• Approval by the Bank of Estonia (Eesti Pank) of the technical, economic and legal principles of the operation of the payment system and the draft rules governing the operation of this system – where the applicant wishes to engages in the operation of a payment system.

An e-money institution should have an adequate organizational structure for the provision of e-money services.

This includes:

• a clear organizational structure with precisely defined, transparent and consistent areas of responsibility,
• effective procedures for identifying, managing, monitoring and reporting the risks to which it is exposed or may be exposed;
• adequate internal controls, including sound administration and accounting procedures.

Processing time starts at 6 months (including preparation of documents and assessment of the application by the Financial Supervision Authority).

*The list is NOT exhaustive. The final list is compiled after the project is carefully reviewed, and the company structure and scope of services are agreed.

**The fees are valid as of September 2025.