Estonia

Key Requirements

• Establish Estonia-based legal entity with place of business in Estonia subject to Estonian law and FSA supervision.
• Maintain minimum capital per MiCA Annex IV: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3) depending on service scope.
• Implement organizational structure with independent board-level governance, compliance function, and internal controls per FSA requirements.
• Adopt comprehensive customer asset safeguarding procedures including segregated custody arrangements and written custody agreements per MiCA Article 72.
• Develop detailed AML/CFT compliance program exceeding 5th EU Money Laundering Directive requirements with transaction monitoring.
• Establish cybersecurity procedures aligned with DORA requirements including operational resilience testing and incident response protocols.
• Implement fair pricing and order execution procedures ensuring transparent pricing and non-discriminatory order treatment.
• Establish professional indemnity insurance covering minimum 25% of quarterly fixed overheads per MiCA requirements.

Application Process

1. 1.Establish Estonia-based company with submitted articles of association, management documentation, and beneficial ownership structure.
2. 2.Prepare comprehensive business plan including organizational structure, service offerings, AML/CFT procedures, and market strategy.
3. 3.Document capital adequacy with bank account evidence, shareholder investment commitments, or capital contribution documentation.
4. 4.Prepare detailed operational procedures covering customer onboarding, AML/CFT compliance, and asset safeguarding arrangements.
5. 5.Submit CASP authorization application to Estonian FSA including business plan, governance documents, and compliance framework.
6. 6.Provide evidence of professional indemnity insurance and custody/safeguarding arrangement documentation.
7. 7.Engage with FSA during assessment period (4-8 months) responding to information requests and on-site inspection.
8. 8.Receive FSA authorization decision and register in national register receiving EU-wide passporting notification.

Ongoing Obligations

• Maintain minimum capital requirement with quarterly capital calculations reported to FSA demonstrating ongoing compliance.
• Submit annual audited financial statements and governance reports to FSA within statutory deadlines.
• Report significant incidents or regulatory violations to FSA within 24 hours of discovery.
• Conduct annual internal governance review with board approval and submit summary to FSA with annual report.
• Update AML/CFT compliance procedures annually addressing identified risks and regulatory guidance changes.
• Maintain professional indemnity insurance continuously with coverage of minimum 25% quarterly fixed overheads.
• Notify FSA of material changes including shareholder composition, management, or service offerings within 30 days.