PI Licence in Estonia — Payment Institution and Securities Dealer

Payment Institution and Securities Dealer in Estonia

Estonia is one of Europe’s leading fintech jurisdictions, offering advanced digital infrastructure and transparent financial regulation. Payment Institution (PI) and Investment Firm licences allow companies to provide payment and investment services across the EEA through the passporting mechanism.

Since 2016, COREDO has been assisting clients with obtaining financial licences in Estonia, providing full support — from project preparation to communication with the regulator and licence approval.

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Cost of the service
from 25 000 EUR

Regulatory Framework

Licensing of payment institutions in Estonia is carried out in accordance with:

PSD2

(Directive (EU) 2015/2366 on payment services) — establishes uniform rules for payment institutions across the EU;

Payment Institutions and E-Money Institutions Act

(Makseasutuste ja e-raha asutuste seadus, PIEIA) — the national implementation of PSD2 in Estonia;

MiFID II

(Directive 2014/65/EU) — regulates the activities of investment firms and securities dealers;

Securities Market Act

(Väärtpaberituru seadus) — the national implementation of MiFID II in Estonia.

The PI licence enables a company to enter the payment services market across the entire EEA through a single point of entry — Estonia. Once the licence is obtained, the company may notify the regulator of its intention to operate in other EEA countries (passporting procedure under PSD2, Art. 28), eliminating the need to obtain separate licences in each country.

The Securities Dealer (Investment Firm) licence enables the company to work with financial instruments: equities, bonds, derivatives and to manage investment portfolios. MiFID II provides an analogous passporting mechanism (Art. 34–35) for investment firms within the EEA.

What the PI/Securities Dealer Licence Permits

Payment Institution (PI)

The holder of a PI licence is authorised to provide the following payment services:

  • Money transfers (including international money remittance);
  • Execution of payment transactions, including direct debits, payment card operations and credit transfers;
  • Payment initiation services (PIS) — within the framework of open banking;
  • Account information services (AIS);
  • Issuance and acquiring of payment instruments;
  • Issuance of payment cards, management of payment systems.

A PI is not authorised to accept deposits — a banking licence is required for that purpose.

Securities Dealer (Investment Firm)

The holder of a Securities Dealer licence is authorised to:

  • Buy and sell securities on behalf of and at the expense of the client;
  • Manage securities portfolios (portfolio management);
  • Execute client orders on financial markets;
  • Underwrite securities issuances;
  • Hold and manage securities (custody);
  • Provide investment advisory services;
  • Operate investment funds and trading platforms.

Requirements for Obtaining the Licence

Capital Requirements

The minimum capital varies depending on the licence type and range of services:

Payment Institution (PI) — minimum regulatory capital (PSD2, Art. 7):

Type of PI services Min. capital
Money remittance only EUR 20,000
Payment initiation services (PIS) only EUR 50,000
Full range of payment services EUR 125,000

Securities Dealer — minimum regulatory capital:

Type of activity Min. capital
Securities transactions, including on behalf of the client EUR 50,000
Issuance and portfolio management of securities EUR 125,000
Underwriting, custody, management, proprietary trading EUR 730,000

Please note: the amounts listed above are the minimum EU/Estonian regulatory requirements for the company’s own funds. The cost of COREDO’s services for obtaining the licence is a separate expense item (see the “Cost of COREDO’s Services” section below).

Corporate Structure Requirements

  • Legal entity: the company must be registered in Estonia as a public limited company (aktsiaselts, AS) or a private limited liability company (osaühing, OÜ);
  • Physical office: the company must maintain a permanent registered office in Estonia;
  • Directors: management must meet fit & proper requirements — relevant experience in the financial sector, impeccable business reputation, no criminal record;
  • For Securities Dealers: the director is generally required to be an Estonian resident or to have a close connection to the jurisdiction.

AML/KYC and Compliance

  • Development and implementation of an anti-money laundering (AML) policy;
  • Appointment of a Money Laundering Reporting Officer (MLRO);
  • Establishment of internal KYC procedures, transaction monitoring and suspicious activity detection;
  • Software and IT systems ensuring compliance with PSD2 (for PI) or MiFID II (for investment firms);
  • Preparation of a business plan with financial projections for 3 years.

IT Infrastructure

  • Description of software and technical architecture;
  • Information security and operational resilience systems;
  • Compliance with Strong Customer Authentication (SCA) requirements — mandatory for PI under PSD2;
  • For investment firms — trading systems and securities accounting systems.

Cost of COREDO's Services

The cost of COREDO’s services for obtaining a Payment Institution (PI) or Securities Dealer licence in Estonia:

Service Cost Source
PI licence / Securities Dealer in Estonia from EUR 25,000 + VAT COREDO website

The price includes: preparation of corporate documentation, development of the business plan and financial projections, drafting AML policies and internal procedures, compilation of the document package for EFSA, legal support at all stages, and assistance throughout the regulatory process.

The final cost is determined individually and depends on the scope of services required, the specifics of the client’s structure and the chosen licence type. The price may vary depending on the circumstances of the particular case.

COREDO has been operating since 2016 and specialises in financial licensing across the EU. During this time, the team has completed hundreds of licensing projects across dozens of jurisdictions.

Payment Terms

Payment for COREDO’s services is made in stages:

40%

advance payment upon signing the contract;

40%

upon completion of the full document package and submission of the application to EFSA;

20%

upon obtaining the licence.

This payment structure ensures transparency and protects the client’s interests at every stage of the process.

Comparison of Licences in Estonia

Three main types of financial licences are available in Estonia, and COREDO assists in obtaining all of them:

Licence type Regulatory min. capital Processing time COREDO price Page
EMI (Electronic Money Institution) EUR 350,000 6–12 months from EUR 40,000 + VAT EMI in Estonia
PI / Securities Dealer EUR 20,000–EUR 730,000 (depends on services) 3–6 months from EUR 25,000 + VAT Current page
Investment / Forex broker EUR 50,000–EUR 730,000 3–6 months from EUR 25,000 + VAT Financial Licences in Estonia

If you need the ability to work with electronic money and hold client funds, consider the EMI licence. If the goal is payment transactions or securities management without issuing electronic money, PI or Securities Dealer is the optimal choice.

List of Documents

To submit an application for a PI/Securities Dealer licence to EFSA, the following document package is required:

  • Incorporation documents — articles of association, memorandum of association, certificate of registration;
  • Proof of paid-up capital — bank statement or other confirmation of own funds;
  • Operational plan — description of planned payment/investment services and target market;
  • Business plan — financial projections for 3 years, revenue sources, expense model;
  • IT infrastructure description — software, technical systems, data protection;
  • AML/KYC policy — internal procedures for anti-money laundering;
  • Documents on directors — CVs, proof of professional experience, criminal record certificates for directors;
  • Documents on beneficial owners — information on the ownership structure, disclosure of ultimate beneficial owners (UBO);
  • Fit & proper questionnaires — for each board member and key officers;
  • Risk management policy — operational, regulatory and financial risks;
  • Compliance procedures — internal controls, transaction monitoring, reporting;
  • Office lease or confirmation of registered office — evidence of a registered office in Estonia;
  • Opening balance sheet and income and expenditure report;
  • Description of outsourced functions (if applicable) — service provider agreements.

The full list of documents may vary depending on the type of licence requested and the specific circumstances.

Procedure for Obtaining the Licence

Initial Consultation and Structure Selection (1–2 weeks)

Determining the licence type (PI or Securities Dealer), agreeing on the corporate structure, specifying the planned range of services. Analysis of EFSA requirements as applied to the specific project.

01

Company Registration in Estonia (2–4 weeks)

Incorporation of a legal entity in Estonia (AS or OÜ), opening a corporate bank account, payment of share capital. COREDO supports the registration process and ensures the corporate structure meets the regulator’s requirements.

02

Preparation of the Document Package (4–8 weeks)

Development of the business plan, AML policy, IT description and internal procedures. Completion of fit & proper questionnaires for directors and beneficial owners. COREDO ensures all documents meet EFSA standards.

03

Submission of the Application to EFSA (1 week)

Since 18 March 2026, applications for a payment institution licence in Estonia are submitted through the official Finantsinspektsioon portal. COREDO supports the client during the submission stage and responds to regulator inquiries.

04

Application Review and Licence Issuance (3–6 months)

EFSA reviews the application within three months of receiving the complete document package, but no longer than six months from the date of submission. During the review process, the regulator may request additional information. COREDO ensures prompt responses to EFSA inquiries.

Once the licence is obtained, the company is entitled to commence operations immediately. The licence is issued for an unlimited period.

05

Passporting Across the EEA (after obtaining the licence)

Notification to EFSA of the intention to operate in other EEA countries (passporting procedure). Following notification, the licence extends to the selected jurisdictions without the need to obtain additional licences. For PI — under PSD2, Art. 28; for Investment Firms — under MiFID II, Art. 34–35.

06

Estimated total timeline: 3–6 months from the submission of the complete document package.

Advantages of the Jurisdiction

Estonia is one of the most attractive EU jurisdictions for financial licensing for a number of reasons:

Advanced digital infrastructure.

Over 99% of financial transactions in the country are conducted online. The state e-Governance system allows most corporate and regulatory formalities to be handled electronically, minimising interaction with government authorities.

Zero tax on reinvested profits.

If a company does not distribute dividends and reinvests profits into its development, it pays no corporate income tax. This creates a significant competitive advantage for fintech startups.

EEA passporting.

A PI or Securities Dealer licence obtained in Estonia provides access to the market of the entire European Economic Area (30+ countries). The company may provide services to citizens and businesses across the EU without additional licensing.

E-Residency programme.

Company founders are not required to be citizens or residents of Estonia. The e-Residency programme enables entrepreneurs from anywhere in the world to manage an Estonian company remotely.

Transparency of the regulatory environment.

EFSA is a predictable and professional regulator that follows EU standards. A clear legal framework and transparent procedures reduce regulatory risks.

Fast registration timelines.

A company can be registered online within a few days. The licensing process takes 3 to 6 months.

Our Experts

The COREDO financial licensing team in Estonia includes experienced specialists who have been supporting clients through the licensing process since 2016.

Pavel Kos
Pavel Kos
Head of Legal. Pavel has led the COREDO legal team since July 2020. He has been with the company since June 2017. He specialises in financial licensing across the EU, including the Estonian jurisdiction. He has overseen dozens of PI, EMI and investment licence projects.
Basang Ungunov
Basang Ungunov
Lawyer. Basang has been part of the COREDO team since June 2022. He specialises in the legal support of licensing projects, preparation of documentation for regulators and legal expertise in financial law.

Frequently Asked Questions

What is a Payment Institution (PI) licence in Estonia?

A PI licence is issued by Finantsinspektsioon (EFSA) and authorises the company to provide payment services: money transfers, transaction processing, payment initiation, account information and other services provided for by PSD2. Unlike an EMI, a PI is not authorised to issue electronic money.

How does a Securities Dealer licence differ from a PI?

A Securities Dealer (Investment Firm) licence is issued under the Securities Market Act and is regulated by MiFID II. It authorises the company to work with financial instruments: buying and selling equities, portfolio management, underwriting. A PI licence covers payment services (transfers, cards) and not investment activities.

What is the minimum capital required for a PI licence in Estonia?

The minimum regulatory capital for a PI is determined by PSD2 and amounts to: EUR 20,000 for companies providing money remittance services only; EUR 50,000 for companies providing payment initiation services; EUR 125,000 for the full range of payment services. These are regulatory requirements, not the cost of COREDO’s services.

How long does it take to obtain the licence?

From the submission of the complete document package, EFSA reviews the application within three months, but no longer than six months. Including document preparation, the estimated timeline is 3–6 months.

Is it possible to operate in other EU countries with an Estonian licence?

Yes. An Estonian PI licence allows passporting to EEA states under PSD2 (Art. 28). To do so, EFSA must be notified, which in turn notifies the regulator of the host country. An analogous mechanism is available for investment firms under MiFID II (Art. 34–35).

Is it mandatory to register a company specifically in Estonia?

Yes. To obtain an Estonian financial licence, the company must be registered and have a physical office in Estonia. COREDO provides full support throughout the company registration process.

Does the company director need to be a resident of Estonia?

For a Securities Dealer licence, the director is generally required to have a connection to the Estonian jurisdiction. Requirements for directors vary depending on the licence type. COREDO assists in structuring the company’s governance in accordance with EFSA requirements.

What is the cost of COREDO's services?

The cost of COREDO’s services for obtaining a PI licence or Securities Dealer licence in Estonia starts from EUR 25,000 + VAT. The price is determined individually based on a consultation. To receive a personalised offer, contact our team through the form on the website.

Get Started with the Licensing Process

COREDO supports clients at every stage of obtaining a PI / Securities Dealer licence in Estonia: from the initial consultation and company registration to interaction with EFSA and post-licensing support.

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    COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.