ESTONIA Trends and Developments Contributed by: Yuliya Barabash, Ivan Nevzorov, Daria Lysenko and Nikita Prokopenko, SBSB FinTech Lawyers
For offers to the public or admission to trading of EMTs : • the issuer does not need EFSA authorisation; but • must already be authorised as a credit institution or e-money institution (EMI); and • must notify EFSA and publish a white paper under Article 51 of MiCA. Fees The processing fee payable when applying for authori - sation of a crypto-asset service provider, an issuer of an asset-referenced token or an e-money institution is EUR3,000. CASPs, issuers of ARTs and EMIs must also pay ongo - ing supervision fees (0.005–2% of the total value of transactions initiated and received by the crypto-asset service provider). Recent updates from Estonia In the crypto world, Estonia has long been considered one of the early pioneers. Benefiting from very liberal regulation in the early years, the country experienced a rapid influx of crypto businesses. At its peak, by the end of 2019, there were around 2,000 crypto com - panies registered in Estonia, although many of them were inactive or dormant. This rapid growth attracted increasing attention from regulators due to the potential risks related to money laundering and terrorist financing. As a result, Estonia began tightening its regulatory framework and revising its licensing requirements. The first major turning point came in 2019, when leg - islative amendments significantly strengthened the regulatory regime. The reform was driven by concerns that Estonia had effectively become an “offshore juris - diction” in the context of the global crypto industry. Experts also highlighted the inherent anonymity of cryptocurrencies and the associated risks that funds of illicit origin could circulate through the Estonian crypto ecosystem.
Further regulatory tightening followed, and the current version of the Money Laundering and Terrorist Financ - ing Prevention Act entered into force in March 2022. As a result of these stricter requirements, the number of licensed entities dropped significantly. Today, there are around 50 crypto companies operating in Estonia as Virtual Currency Service Providers (VASP/VCSP) registered with the Estonian Financial Intelligence Unit (FIU). With the introduction of the Markets in Crypto-Assets Regulation (MiCA) at the EU level, Estonia adopted the Crypto Market Act (MCAA), which became appli - cable from 30 December 2024 for entities falling within the scope of MiCA. However, as of March 2026, the Estonian Financial Supervision Authority (EFSA) has not yet granted any authorisations under the Crypto Market Act for Estonian Crypto-Asset Service Provid - ers (CASPs). At the same time, 67 CASPs from other EU member states currently provide services in Estonia on a cross- border basis, using the MiCA passporting regime. This situation does not necessarily indicate a low suc - cess rate for licensing applications. Rather, it reflects the ongoing transition period, during which previous - ly licensed providers must align with the new MiCA framework and apply for CASP authorisation by 1 July 2026. Conclusion Estonia has evolved from one of the most liberal crypto jurisdictions in Europe into a highly regulat - ed and MiCA-aligned market. While the number of locally licensed crypto companies has significantly decreased, the country continues to remain part of the European crypto ecosystem, particularly through cross-border services provided by CASPs authorised in other EU member states. The final shape of the Estonian crypto market will likely become clearer after the end of the transition period in July 2026, when all market participants must operate under the MiCA regime.
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