Payment and e-money authorisation in Estonia

The first questions are who receives and holds customer funds, who owes the customer, who executes each payment and what contractual and technical roles partners perform. Product labels such as “wallet” or “platform” cannot answer those questions.

Finantsinspektsioon grants payment institution and e-money institution licences in Estonia. A possible exemption or alternative operating basis must be assessed against the actual services. Applications have been submitted through its application portal since 18 March 2026.

We advise on the legal perimeter, service and money flows, governance, safeguarding, AML/CFT, outsourcing and contracts. We coordinate or review the agreed legal and documentary workstream and check consistency between the business plan, policies, financial assumptions and actual arrangements.

The supervisory decision period described by Finantsinspektsioon starts only when the required documentation and data are complete; preparation time and a positive result are not guaranteed.

Prepare a short service map, flow of funds, target customers and countries, owners and managers, main partners, system architecture, existing agreements, forecasts and policies. We can start with a bounded feasibility or document-gap review.