ESTONIA Law and Practice Contributed by: Yuliya Barabash, Ivan Nevzorov, Daria Lysenko and Nikita Prokopenko, SBSB FinTech Lawyers
1. Fintech Market 1.1 Evolution of the Fintech Market
are no less important, even though this business has undergone regulatory tightening. It is also worth not - ing the active development of fintech infrastructure, in particular digital identification, compliance and AML monitoring. 2.2 Regulatory Regime In Estonia, the regulation of fintech companies depends on the applicable business model and the type of services provided. The main regulator is Finant- sinspektsioon (Estonian Financial Supervision and Resolution Authority – FSA). It should be noted sepa - rately that the issue of prevention of money laundering in Estonia falls within the competence of investigative bodies, the Prosecutor General’s Office and courts, the Rahapesu Andmebüroo (Financial Intelligence Unit – FIU) and other bodies for certain aspects. At the same time, the FIU is the main body that monitors, collects information and prevents money laundering. Finantsinspektsioon is an independent financial super - vision and resolution authority. It carries out state financial supervision over the following: • banks; • insurance companies; • insurance intermediaries;
As of early 2026, Estonia remains a mature fintech hub with a strong start-up culture and experience in regu - lating innovative businesses. It should be noted that previous periods, including the last 12 months, have been periods of growth, with new businesses show - ing significant revenue growth (mainly due to fintech companies). It should be noted that fintech in Estonia is not only about start-ups, but also about businesses that have become a strong system with stable rev - enues, international activity and a stable condition. The next 12 months can be considered a phase of implementation of initiatives. In particular, the FSA is preparing to reduce administrative pressure in the financial sector and reduce the number of require - ments, which is the subject of active discussion. There are also plans to launch digital solutions for licensing procedures. Equally important is that the use of artificial intelli - gence-based solutions is already being implemented, especially for fintech companies in the pilot and early stages (according to a survey conducted by the FSA). At the same time, it should be noted that there are no recommendations from regulatory authorities on the use of AI in fintech, which complicates the process in a certain way and leaves it to the discretion of busi - nesses.
• investment firms; • fund managers; • investment and pension funds;
• payment institutions; • e-money institutions;
• creditors and credit intermediaries; • crowdfunding service providers; • debt collection agencies; and • the crypto-asset and securities markets. 2.3 Compensation Models
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
In Estonia, the fintech environment is characterised by several key verticals, including both start-ups and mature companies. The most developed sector remains payment infrastructure and payment tech - nologies, such as card issuance or BaaS solutions. These models are popular among local fintech com - panies as well as international businesses operating in a broader market. Another significant area is crowdfunding platforms and digital lending. Crypto and blockchain services
Compensation models depend directly on the appli - cable business model under national and EU law. Fin - tech companies can use models of transaction fees, subscription fees, spreads between asset purchase and sale prices, fees for executing transactions or storing assets, or fees from third parties. For crypto businesses, trading fees, custody fees, and deposit or withdrawal fees are most commonly applicable.
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