Financial service provider license (cryptocurrency) in Estonia

Legal Basis

Applicant Requirements

To obtain a license, the business must meet the following requirements:

• The company, its board member, prosecutor, beneficial owner, and shareholder must not have a valid conviction for criminal offenses against public authority, money laundering, or any other intentional crime.
• The company, its board member, trustee, beneficial owner, and shareholder must have an impeccable business reputation. The assessment of reputation is conducted by the licensing authority, considering past activities and related circumstances. An impeccable reputation is presumed unless there are undermining factors.
• The compliance officer appointed under § 17 of the MLTFP Act must meet legal requirements, including education, professional qualifications, skills, personal qualities, and an impeccable reputation.
• If the company has a subsidiary engaged in licensable activities, the subsidiary must also meet the above requirements.
• For virtual currency service providers, the company’s registered office, board location, and place of business must be in Estonia, or it must operate through a branch registered in the Business Register with its legal address and management in Estonia. The board must consist of Estonian residents or citizens. A physical office must be maintained for MLTFP Act compliance.
• Virtual currency service providers must hold a payment account with a credit institution, e-money institution, or payment institution established in Estonia or an EEA member state offering cross-border services in Estonia.
• The share capital of a virtual currency service provider must be at least €12,000, fully paid in cash.

The board’s location is determined by the residence or citizenship of its members (must be Estonian residents or citizens). The place of business must include a physical office used for MLTFP Act compliance.

Licensing rules for these activities are not harmonized in the EU. A license obtained in another EEA state does not authorize operations in Estonia, and vice versa. For cross-border activities, consult the respective state’s single contact point.

To apply for a license, submit the following:

• Internal rules and procedures per §§ 14–15 of the MLTFP Act (or § 23 of the International Sanctions Act for special obligations).
• For foreign board members, trustees, beneficial owners, or shareholders: a criminal record certificate (or equivalent) no older than 3 months, notarized and apostilled (unless exempted by international agreement). If documents do not fully prove the absence of penalties, a sworn affidavit with an official Estonian translation is required.
• For foreign individuals: copies of passports and documents proving no convictions.
• Documents on board members/trustees (education, work history, responsibilities) and evidence of their good repute.
• List of payment accounts (for virtual currency providers), including account identifiers and owners.
• Details of the specific financial/virtual currency service (for non-bank financial institutions and virtual currency providers).
• For companies in registration: memorandum/articles of association or a notarized copy. Licenses take effect only after registration.

Note: The state fee must be paid before application submission.

Applications can be submitted:

• via the Business Register (login with ID-card, Mobiil-ID, or Smart-ID);
• Through a notary.

The state fee is:

• €3,300 for non-bank financial institutions and virtual currency service providers;
• €345 for pawnbrokers, trust services, trade associations, or wholesale trading of precious metals/stones.

Payment accounts (reference: 2900083015):

• Swedbank: EE932200221023778606;
• SEB: EE891010220034796011;
• Luminor: EE701700017001577198;
• LHV: EE777700771003813400.

Description: “[Company Name] – FIU license application.”

Applications are processed within 60 days (extendable to 120 days). The FIU will send an initial response within 3 business days. Licenses are issued electronically and are valid indefinitely (unless a fixed term is requested).

Notify the FIU at least 30 days before planned changes to licensed conditions. Unforeseen changes must be reported within 5 business days. For changes involving foreign individuals, submit a criminal record certificate.

Submit changes:

• via the Business Register;
• Through a notary.

A license is invalid if:

• False information affecting the license decision is provided;
• The business is discontinued;
• A Financial Supervision Authority license is obtained;
• Supervisory requirements are knowingly violated;
• Licensed activities are not commenced within 6 months.

Failure to report changes may result in revocation. Licenses may also be revoked if conditions are no longer met.

The FIU oversees MLTFP compliance. The Consumer Protection and Technical Regulatory Authority handles consumer protection supervision.

For assistance with obtaining a crypto license, see here.

For details on obtaining a financial service provider (cryptocurrency) license in Estonia, contact us. We answer questions and assist with the licensing process.

Call us on Messenger: +372 552 00 78
Email: info@sowana.ee
Follow our Telegram channel: @EstoniaSowana for updates.

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