Fintech 2026

ESTONIA Law and Practice Contributed by: Yuliya Barabash, Ivan Nevzorov, Daria Lysenko and Nikita Prokopenko, SBSB FinTech Lawyers

This classification is crucial for understanding the regulatory requirements and implications for each type of token. Asset-referenced tokens are designed to maintain a stable value by referencing one or sev - eral assets, such as fiat currencies or commodities. E-money tokens, on the other hand, are digital rep - resentations of fiat currency and are intended to be used as a means of payment. Finally, other crypto- assets encompass a wide range of digital assets that do not fall under the previous two categories, includ - ing utility tokens. By establishing these categories, MiCA provides a clear framework for the regulation of crypto-assets, ensuring that each type of token is subject to appropriate oversight and consumer pro - tection measures. 6.3 Impact of the Emergence of Cryptocurrency Exchanges The emergence of cryptocurrency exchanges on the Estonian market has had a significant impact on the regulatory approach. The country was one of the first in Europe to introduce a licensing regime for virtual asset providers. Tighter AML and sanctions controls have gradually led to a reduction in the number of locally licensed companies. The implementation of MiCA in the country requires crypto exchanges to obtain the appropriate CASP licence, which means higher requirements for corpo - rate governance, customer asset protection, trading transparency and sustainability. For the fintech mar - ket, this leads to the gradual institutionalisation of crypto trading, and the regulation of such platforms is approaching the standards of traditional financial markets. 6.4 Listing Standards Listing standards in Estonia depend directly on the type of asset and platform. When it comes to financial instruments, the rules applicable to securities require transparency, disclosure of information about the issuer, verification of the asset, prevention of market abuse, publication of a prospectus, etc. For crypto-assets with appropriate regulation, the asset must have an approved white paper containing key information about the asset, its issuer, risk assess- ment, etc before it can be admitted to trading.

In addition to formal requirements, additional stand - ards also apply, including issuer due diligence, liquid - ity assessment, technology verification and AML compliance. These practices are designed to reduce the risk of fraud, protect users and increase investor confidence. 6.5 Order Handling Rules As described earlier, Estonian regulations on order handling are based on pan-European standards and depend on the type of assets and platform, respec - tively. For securities, investment firms must ensure fair, prompt and consistent execution of orders, which is implemented through clear internal policies that determine the prioritisation of transactions, prevent conflicts of interest, etc. For crypto-assets, companies with CASP licences must ensure a transparent procedure for accepting, transmitting and executing orders. The platform must have clear rules for execution, disclosure of informa - tion about the order processing procedure, and proper accounting of transactions. It should be noted that this brings such platforms closer to the standards of traditional financial markets. 6.6 Rise of Peer-to-Peer Trading Platforms In Estonia, as in other countries, the growth of peer- to-peer (P2P) trading platforms has had a significant impact on market participants (both traditional and fintech). P2P platforms have effectively expanded users’ access to investments and lending without intermediaries, directly between themselves. This has become a challenge for financial institutions, and they have begun to integrate digital platforms and auto - mated services into their own activities, as well as interact with fintech companies in order not to lose market share. An important aspect remains that P2P platforms must comply with regulatory requirements, especially regarding investor protection, risk transparency, AML/ CFT requirements and the obligation to operate within the legal framework.

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