EMI license in Estonia: e-money institution (EMI) requirements (2026)

Yes. To provide electronic-money or payment services in Estonia you need authorisation as an Electronic Money Institution (EMI), supervised by the Estonian Financial Supervision Authority (Finantsinspektsioon), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

The Estonian Financial Supervision Authority (Finantsinspektsioon).

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

Payment institutions and e-money institutions must obtain an operating licence from Finantsinspektsioon under MERAS. Licences have no expiry date and are non-transferable; Finantsinspektsioon must decide within 3 months of a complete application, and no later than 6 months after receipt. From 18 March 2026, applications must be submitted through the FSA's digital portal.

The MERAS (Payment Institutions and E-money Institutions Act) is the primary national statute, implementing PSD2 requirements including strong customer authentication (SCA), safeguarding of client funds, and passporting rights across the EEA. The consolidated English text is published in Riigi Teataja (State Gazette).

Estonia implemented PSD2 open banking APIs in 2019. Major banks, Swedbank, SEB, LHV, and Coop Pank, expose PSD2-compliant AIS (account information) and PIS (payment initiation) APIs built on the Berlin Group NextGenPSD2 standard, enabling licensed third-party providers to access customer data and initiate payments with consent.

Estonia participates in SEPA Instant Credit Transfer. The EU Instant Payments Regulation (2024/886), adopted 13 March 2024, required eurozone credit institutions to receive SCT Inst by 9 January 2025 and to send SCT Inst by 9 October 2025, with charges no higher than equivalent standard credit transfers. Verification of Payee (VoP) was mandatory for all PSPs by 9 October 2025.

EU Regulation 2023/1114 (MiCA) applies directly in Estonia. Finantsinspektsioon is the competent authority for issuing crypto-asset service provider (CASP) licences and for supervising issuers of asset-referenced tokens and e-money tokens. Estonia previously had a national virtual-asset service provider (VASP) registration regime (repealed on MiCA's entry into force).

Estonia has no standalone BNPL-specific statute as of May 2026. BNPL products are regulated under existing consumer credit (EU Consumer Credit Directive) and PSD2 frameworks where payment services are involved. The EU Consumer Credit Directive 2023/2225, which narrows exemptions that previously excluded many BNPL products, must be transposed by member states by November 2025, bringing more BNPL offerings under full credit-licensing requirements.