Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

Estonia

(Adopted by the Global Forum in June 2026)

Estonia joined the Global Forum in 2009. Estonia underwent its Second Round of EOIR Peer Review in 2018 (Estonia’s 2018 Report),1 which assessed its legal and regulatory framework in force as at 5 January 2018 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 October 2013 to 30 September 2016. Estonia received an overall rating of Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	C
Ratings	LC	C	C	C	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

Estonia received seven in-box recommendations in relation to Elements A.1, A.3, B.1, B.2 and C.5.

This monitoring report assesses the actions taken by Estonia to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that five recommendations are “in the process of being addressed” and two recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”, and it advises on actions required.

Element A.1: Availability of ownership and identity information

1. Implementation of new provisions on beneficial ownership

 

Recommendation (A.1, practice)	Estonia is recommended to monitor the implementation of new provisions relating to beneficial ownership.
Underlying factor	Prior to the amendment of the Money Laundering Prevention Act, beneficial ownership information on partnerships was not ensured to be available. Although new rules related to the identification of beneficial owners came into force, Estonia has not taken adequate implementation measures. New provisions on beneficial ownership are not yet complemented by any detailed guidelines. Further, relevant authorities have not yet developed a plan of supervision. (see paragraphs 96, 103-105, 111, 119, 143 and 148 of the Estonia’s 2018 Report for more information)
Summary of actions reported	Estonia has revised the beneficial ownership definition in the AML Law several times since the peer review and introduced the beneficial ownership guideline in 2018, with revisions having been made in 2020 and further ones being currently under way. The guideline addressed the back-stop option of identifying a senior managing official if no other person fulfils the beneficial ownership criteria, as well as the concept of “control by other means”. From 1 September 2018, all legal persons (including companies and partnerships) in Estonia must report information on their beneficial owners to the beneficial ownership register set up within the Commercial Register. As of 10 May 2021, the obligation to report beneficial owners applies also to trusts operating in Estonia. Beneficial ownership information must be submitted at the time of the legal person’s registration or within 30 days of the creation of a trust and validated annually at the time of annual report filing. Some beneficial ownership information can be accessed publicly. The Registrar can issue sanctions in cases of late or failed submission or submission of incorrect information to the register. A discrepancy reporting mechanism is in place. No sanctions have been applied so far, as the supervisory framework of the register is still under development.
Conclusion	Estonia has made progress to address the recommendation through the establishment of the beneficial ownership register and the issuance of a beneficial ownership guideline. While the beneficial ownership information submission rate is good, no quality checks, monitoring and enforcement measures have yet been carried out, apart from the discrepancy reporting mechanism. The 2020 guideline on beneficial ownership partially addressed gaps identified in the 2018 Report but the new legal definition of beneficial ownership and the 2020 guideline contain uncertainties, and revision of the guideline is ongoing. Estonia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Estonia should – Provide the amended guideline on identification of beneficial owners and explain how it clarifies requirements for identification of beneficial owners of legal persons, including partnerships, the application of the back-stop option and the concepts of joint control and “control through other means”. Provide information on supervisory, monitoring and enforcement measures and outcomes with respect to the beneficial ownership register, to ensure that the information on the register is adequate, accurate and up to date.

2. Beneficial ownership information of foundations

 

Recommendation (A.1, practice)	Estonia is recommended to monitor that all beneficial owners of foundations are identified in practice.
Underlying factor	The definition of beneficial owner of foundations in the Money Laundering Prevention Act 2017 is not clear and there is no guidance issued yet. The application of the new rules that relate to beneficial owners of foundations remains to be tested in practice. (see paragraphs 172 and 174 of the Estonia’s 2018 Report for more information)
Summary of actions reported	The AML Law designates the members of the management board and supervisory board as beneficial owners of foundations. Complementing the AML Law, the 2020 beneficial ownership guideline indicates that persons noted as beneficial owners of foundations are the persons who “can make payouts from the assets of the foundation”, if they have been specified by name in the articles of association. If the latter is not the case, the members of the management board and supervisory board are noted as beneficial owners. Since 2018, foundations have to submit beneficial ownership information to the central register, and the quality of such information is monitored by the Registrar.
Conclusion	Estonia has made progress to address the recommendation through the establishment of the beneficial ownership register, which includes beneficial ownership information of foundations. The beneficial ownership definition in the AML Law and the 2020 guideline do not fully address the doubts identified in the 2018 Report and may not result in the identification of all beneficial owners of foundations in line with the standard. Furthermore, statistical information on the supervisory and enforcement actions of the Registrar and the compliance of foundations with beneficial ownership identification and reporting obligations is yet to be reported. Estonia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Estonia should – Report on guidance to enable the identification of beneficial owners of foundations in line with the standard. Provide statistical information on the compliance levels with the requirements for foundations to identify and report beneficial ownership information to the beneficial ownership register as well as on the monitoring, supervisory and enforcement measures implemented in this respect, including on the application of any exemptions.

3. Supervision of notaries, accountants and service providers in respect of their AML obligations

 

Recommendation (A.1, practice)	Estonia is recommended to supervise legal requirements pertaining to ownership information and to exercise its enforcement powers where necessary.
Underlying factor	Notaries and accountants do not appear to consistently verify information received from entities in the course of their duties. Moreover, the FIU’s [Financial Intelligence Unit’s] supervision of accountants and service providers is very low. (see paragraphs 115, 124-125, 129 and 131-132 of the Estonia’s 2018 Report for more information)
Summary of actions reported	The Financial Intelligence Unit is responsible for AML supervision of corporate service providers and auditors/accountants. According to the 2025 national AML risk assessment, auditors/accountants are exposed to lower AML risk and corporate service providers to higher AML risk. The Financial Intelligence Unit has intensified its supervisory actions in the corporate service providers’ sector and observed an increased number of refusals to grant licences and revocations of existing licences. During the monitoring period, 11 on-site inspections were carried out on corporate service providers. Enforcement actions have been applied, with one order to remove deficiencies issued in 2023 and six in 2024, requiring the respective service providers to carry out corrective actions and report on them. The Financial Intelligence Unit controls the implementation of these corrective actions. It also carries out annual off-site inspections of corporate service providers and provides training and other support on AML matters. Auditors and accountants have also been provided with training sessions, but they have not been subject to off- or on-site supervision due to their low-risk character. The Chamber of Notaries has strengthened its supervisory capacity by creating a post for AML-related issues. An extraordinary inspection was carried out in 2020 and resulted in the issuance of recommendations to notaries to improve their customer due diligence practices. During the monitoring period, nine inspections were carried out, one of which led to the notary having to undergo additional training and having to develop and adopt a risk assessment and risk management plan. The chamber has also contributed to the national risk assessment, conducted trainings and awareness raising sessions, and issued a guidance for notaries on how to fulfil their customer due diligence obligations. Based on the national risk assessment, it is working on a 2026 action plan, which will include extending the enforcement powers of the chamber’s supervisory committee.
Conclusion	Estonia has made progress to address the recommendation. AML-obliged persons remain a relevant source of beneficial ownership information while the beneficial ownership register is not being adequately supervised. Supervision of non-financial AML-obliged persons has been strengthened, with a focus on corporate service providers and notaries, and enforcement measures have been applied. Improvements to the supervisory framework are still ongoing. No supervision of accountants and auditors has been carried out thus far. Estonia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Estonia should – Report on steps taken to ensure availability of adequate, accurate and up-to-date beneficial ownership information for all relevant legal persons and arrangements.

Element A.3: Availability of banking information

4. Identification of beneficial owners of foundations by banks

 

Recommendation (A.3, practice)	Estonia is recommended to monitor that all beneficial owners of foundations are identified in practice.
Underlying factor	The definition of beneficial owner of foundations in the Money Laundering Prevention Act 2017 is not clear and there is no guidance issued yet. The application of the new rules that relate to beneficial owners of foundations remains to be tested in practice. (see paragraph 225 of the Estonia’s 2018 Report for more information)
Summary of actions reported	See actions reported under Recommendation 2. Banks are subject to annual off-site monitoring of their beneficial ownership identification duties, and to risk-based on-site inspections. Three failures to identify beneficial owners were detected during the on-site inspections carried out between 2018 and 2025, including one case involving a foundation. Enforcement measures, including corrective action orders and pecuniary penalties, were taken in response to broader AML supervision, and the banks had to rectify the deficiencies.
Conclusion	Estonia has made progress to address the recommendation through the issuance of a beneficial ownership guideline and amendments to the AML Law. However, the amended beneficial ownership definition in the AML Law and the 2020 guideline do not fully address the doubts identified in the 2018 Report. Estonia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Estonia should – Ensure guidance is available to enable consistent identification of beneficial owners of foundations in line with the standard and provide the revised guideline. Continue providing detailed information on supervisory and enforcement measures, including statistics, to assess whether banks keep adequate, accurate and up-to-date information on beneficial owners of foundations.

Element B.1: Access to information

5. Access to accounting records of liquidated companies

 

Recommendation (B.1, practice)	Estonia is recommended to ensure that it is able to access accounting information of liquidated companies in all cases.
Underlying factor	Estonian law requires the documents of liquidated companies to be held by the liquidator or other depository. However, in 5 cases the Estonian authorities were unable to reach the designated depository, and the accounting information could not be obtained. (see paragraphs 251-253 of the Estonia’s 2018 Report for more information)
Summary of actions reported	The Commercial Code has been amended in 2018 and now requires that documents of liquidated companies and partnerships must be held in Estonia and contact details of the person with whom documents have been deposited must be entered in the Commercial Register. The legal framework foresees sanctions for cases of non-compliance. Separate statistics on the penalties imposed on depositaries are not available. Estonia has not encountered any instances during the monitoring period where accounting information could not be obtained for liquidated companies.
Conclusion	Estonia has made progress to address the recommendation. The legal framework has been strengthened by requiring that the accounting records of liquidated companies and partnerships be kept in Estonia and the contact information of the depositary be recorded in the Commercial Register. No failures to obtain accounting information for liquidated companies and partnerships occurred during the monitoring period. However, no information has been provided on monitoring and enforcement actions to ensure the implementation of the amended legal framework. Estonia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Estonia should – Provide information and statistics on the monitoring, supervisory and enforcement measures in place to ensure compliance with the amended provisions on record keeping for liquidated companies and partnerships in Estonia. Continue reporting on cases of EOI requests for accounting information on liquidated entities and whether sanctions are applied in case of failure to access information.

Element B.2: Notification and appeals

6. Implementation of the amended notification rules

 

Recommendation (B.2, practice)	Estonia is recommended to monitor that the practical application of the new rules that concern notification is in line with the international standard.
Underlying factor	Estonia introduced new notification rules which became effective from beginning of April 2017. However, Estonia has not yet applied these new requirements in practice. (see paragraphs 268-269 of the Estonia’s 2018 Report for more information)
Summary of actions reported	Estonia has reported that it always complied with requests (around 80 between 2019 and 2024) not to notify the taxpayer.
Conclusion	Estonia has taken actions to address the recommendation. It has successfully applied the 2017 notification rules in practice.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	No immediate action required.

Element C.5: Effective exchange of information

7. Provision of status updates

 

Recommendation (C.5, practice)	Estonia should provide status updates in all cases where requests take longer than 90 days to fulfil.
Underlying factor	The competent authority did not provide status updates in all cases of requests taking longer than 90 days to answer. (see paragraph 322 of the Estonia’s 2018 Report for more information)
Summary of actions reported	The tracking system for providing status updates was improved. During the monitoring period 2023-2024, Estonia has provided status updates in 100% of cases where EOIR requests could not be replied to in 90 days.
Conclusion	Estonia has taken actions to address the recommendation. A new tracking system is in place and status updates were provided in all required cases during the monitoring period.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	In its next self-assessment, Estonia should provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the methodology for enhanced monitoring.

EOIR experience

Over the monitoring period, Estonia received 712 requests and sent 104 requests. Finland, Latvia and Norway were the top three partners in respect of incoming requests. Lithuania, Finland and Latvia were the key partners in respect of outgoing requests. Estonia reported providing full and final responses in 100% of all the received requests and indicated that there were no pending requests.

Ten peers provided peer input on Estonia. Peers reported general satisfaction in respect of their EOIR experience with Estonia.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Estonia or have otherwise come to light.

Next steps

Estonia should continue taking actions towards implementing the standard effectively.

The following next steps are expected from Estonia:

• Submit its next self-assessment in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and Methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

Estonia thanks the Peer Review and Monitoring Group members for valuable input and comments. We highly appreciate the work the Global Forum Secretariat and PRMG has done for transparency and level playing field across jurisdictions. We highly appreciate the Global Forum Secretariat cooperation and support during the enhanced monitoring process as well as for clear and smooth communication during the process. Estonia remains committed to the work of the Global Forum on Transparency and Exchange of Information for Tax Purposes and the effective implementation of the EOI Standard. Estonia agrees with the findings and accepts the recommendations and takes them into consideration to be continuously fully compliant with the EOI Standard. Relevant legislative changes regarding beneficial ownership registration are planned to be in force in mid-2027. We will provide relevant updates and submit the next self-assessment in 2028 under the second round of enhanced monitoring.

Note

← 1.  OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Estonia 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, OECD Publishing, Paris, http://dx.doi.org/10.1787/9789264291034-en.