Obtaining a crypto license in Estonia

License Requirements

1. The company must pay up its share capital of €12,000 before applying for the license. Shareholders must deposit this amount prior to the license application. These funds may later be used for business purposes.

   For existing companies with previously registered share capital: Documentation of prior capital contribution must be submitted. If the amount is less than €12,000, additional capital must be deposited.

   According to §136 of the Estonian Commercial Code: “A company’s share capital must be denominated in euros.” Therefore, crypto companies cannot denominate their share capital in cryptocurrency.

   Once the share capital is transferred to your company’s bank account and registered in the Estonian Commercial Register, you may begin using these funds for business operations.

   Share capital payment is made via cash deposit (cash or bank transfer). Board members contribute amounts corresponding to their share percentages. Payments must be made from board members’ personal bank accounts to the company account.

2. The company must maintain a corporate bank account or payment service account within the European Economic Area that functions as a full bank account with personal IBAN, enabling both SEPA and SWIFT transactions.

• Estonian banks typically don’t accept account applications from crypto companies. Most crypto firms use specialized payment service providers instead.

3. The company must have a physical office in Estonia that regulators can verify for business operations. A lease agreement with photographs must be provided.
4. Company management must be physically based in Estonia. While founders may be non-residents, at least one board member must be local (Estonian citizen, tax resident, or residence permit holder).
5. The company must appoint a Compliance Officer responsible for regulator communications and ensuring AML/CTF compliance to minimize money laundering risks.

The Compliance Officer must have relevant education, professional experience, and a clean criminal record. After applying for the crypto license, the officer must pass an interview with the Financial Intelligence Unit (FIU) to verify qualifications.

Note: The interview is conducted in Estonian – professional interpretation may be required.

6. Prior to license approval, the company must submit all AML-related documentation including procedural rules and internal control policies demonstrating money laundering risk mitigation.

Additional Requirements

All associated persons (board members, shareholders, ultimate beneficial owners, and the Compliance Officer) must provide:

• Certificate of no criminal record
• CV demonstrating relevant industry experience

The board member and Compliance Officer must prove their professional qualifications for these positions, including industry experience, clean reputation, and appropriate education.

Each case is reviewed individually by regulators, with decisions made on a case-by-case basis.

License Specifics

• Only Estonian legal entities may obtain the license
• The legal address must be located in Estonia
• Non-resident board members are advised to obtain e-Residency to improve approval chances

License Application Process

Once all documentation is prepared and requirements met, applications are submitted to the Financial Intelligence Unit (FIU), the independent regulatory body overseeing virtual currency service providers.

Since March 10, 2020, only digital submissions are accepted. Scanned documents must be uploaded through the online portal.

The application must be submitted by a company board member either:

• Electronically using e-Residency card
• Through an Estonian notary
• By authorizing Sowana as your representative

Processing Timeline

Applications are typically processed within 60 days, though regulators may extend this to 6 months for additional inquiries. The crypto license has indefinite validity once granted.