EUROPAM

European Public Accountability Mechanisms

Estonia

Country score (EU Average*)
  • 54(72) Political Financing
  • 75(57) Financial Disclosure
  • 42(49) Conflict of Interest
  • 80(59) Freedom of Information
  • 59(63) Public Procurement
  • 53(66) Anti Money Laundering
  • 73(71) Asset Recovery

Country Facts

IncomeHigh
GNI per capita (2011 PPP $)26978.00
Population, total1316481.00
Urban population (% of total)67.47
Internet users (per 100 people)87.24
Life expectancy at birth (years)77.13
Mean years of schooling (years)12.5
Global Competitiveness Index4.8
Sources: World Bank, UNDP, WEF.

Political Financing

The Political Parties Act 1994 and the Riikikogu Election Act 2002 were both amended in 2012 and again in 2014 and 2015. Both laws govern the financing of political parties in Estonia.

For regulations on income there were no bans on donations from foreign entities in 2012 but the most recent amendments resulted in donations from foreign entities being banned. There are also comprehensive bans on donations from corporations, trade unions and anonymous donors amongst others. There are also limits on the amount donors may donate.

There are provisions for the public funding of political parties. Donations are allocated based on the share of votes attained in the previous election and based on the representation in the elected body. There appear to be no subsidies for the use of media in the elections but there are tax incentives.  

Vote buying is banned but there are no limits on spending.

Parties are required to submit annual reports on finances to the Political Party Funding Supervision Committee. The reports must reveal expenses in relation to election campaigns, must be made public and must reveal the identity of donors. There are sanctions in the form of fines for parties breaching the provisions.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Bans and limits on private income0000094
Public funding626262626238
Regulations on spending25252525250
Reporting, oversight and sanctions757575757583

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Bans and limits on private income

Is there a ban on donations from foreign interests to political parties? Yes. (1) For the purposes of this Act ‘donation’ means a financially assessable benefit, including a service, but not voluntary work, voluntarily given by a natural person who is a citizen of the Republic of Estonia or has the Political Parties Act Page 7 / 14 permanent right of residence or the status of a long-term resident in Estonia out of their assets to a political party or a member thereof for the purpose of supporting the activities of the political party. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section is prohibited. Above all, the following is prohibited: 8) donations by aliens, except for donations by persons holding the permanent right of residence or the status of a long-term resident in Estonia. (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from foreign interests to candidates? Yes. (1) For the purposes of this Act ‘donation’ means a financially assessable benefit, including a service, but not voluntary work, voluntarily given by a natural person who is a citizen of the Republic of Estonia or has the Political Parties Act Page 7 / 14 permanent right of residence or the status of a long-term resident in Estonia out of their assets to a political party or a member thereof for the purpose of supporting the activities of the political party. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section is prohibited. Above all, the following is prohibited: 8) donations by aliens, except for donations by persons holding the permanent right of residence or the status of a long-term resident in Estonia. (Political Parties Act (1994, amended 2015), §12.3, section (2)(2))
Is there a ban on corporate donations to political parties? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on corporate donations to candidates? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from corporations with government contracts to political parties? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from corporations of partial government ownership to political parties? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from corporations with government contracts to candidates? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from corporations of partial government ownership to candidates? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from Trade Unions to political parties? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on donations from Trade Unions to candidates? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section isvprohibited. Above all, the following is prohibited: 2) donations by legal persons; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(8))
Is there a ban on anonymous donations to political parties? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section is prohibited. Above all, the following is prohibited: 1) anonymous donations; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(1))
Is there a ban on anonymous donations to candidates? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section is prohibited. Above all, the following is prohibited: 1) anonymous donations; (Political Parties Act (1994, amended 2015), §12.3, section (1) & (2)(1))
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)? Yes. (3) A political party is prohibited to use public funds for conducting or organising the election campaign of the political party or a person running in the list of the political party, except for the allocations from the state budget based on this Act. (see below) (Political Parties Act (1994, amended 2015), §12.1, section (3))
Is there a ban on any other form of donation? Yes. (2) A donation that does not comply with the terms and conditions laid down in subsection (1) of this section is prohibited. Above all, the following is prohibited: 3) the transfer or the granting of use of goods, services or proprietary rights to a political party on conditions not available to other persons; 4) release from ordinary binding duties or obligations; 5) waiver of claims against a political party; 6) payment of the expenses of a political party by third parties for the political party or making concessions to the political party, unless the payment of such expenses or the making of such concessions is also available to other persons in ordinary economic activities; 7) donation made via a natural person and at the expense of the assets of a third party. (Political Parties Act (1994, amended 2015), §12.3, section (2)(2))
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)? Yes. (3) A political party is allowed to accept cash donations from a natural person to the extent of up to 1200 euros per financial year. Cash donations are immediately registered by a political party as revenue. (Political Parties Act (1994, amended 2015), §12.3, section (3))
Is there a limit on the amount a donor can contribute to a political party in relation to an election? No. Absent from legal framework.
Is there a limit on the amount a donor can contribute to a candidate? Yes. (3) A political party is allowed to accept cash donations from a natural person to the extent of up to 1200 euros per financial year. Cash donations are immediately registered by a political party as revenue. [RT I, 05.02.2014, 1 – entry into force 01.04.2014] (Political Parties Act (1994, amended 2015), §12.3, section (3))

Public funding 

Eligibility criteria for direct public funding to political parties Yes. (1) A political party represented in the Riigikoguhas the right to receive an allocation from the state budget by the fifth date of each calendar month. The size of the monthly allocation is one twelfth of the annual amount. The size of the allocation is proportionate to the number of seats obtained in the elections of the Riigikogu. (2) A political party that participated in the elections of the Riigikogu, but did not exceed the election threshold and received at least: 1) 2% but less than 3% of the votes, will receive an annual allocation of 30 000 euros from the state budget; Political Parties Act Page 9 / 14 2) 3% but less than 4% of the votes, will receive an annual allocation of 60 000 euros from the state budget; 3) 4% but less than 5% of the votes, will receive an annual allocation of 100 000 euros from the state budget. [RT I, 05.02.2014, 1 – will enter into force on the day of commencement of the term of office of the XIII composition of the Riigikogu (Political Parties Act (1994, amended 2015), §12.7, section (2))
Eligibility criteria for direct public funding to political parties: Share of votes in previous election Yes. (2) A political party that participated in the elections of the Riigikogu, but did not exceed the election threshold and received at least: 1) 2% but less than 3% of the votes, will receive an annual allocation of 30 000 euros from the state budget; Political Parties Act Page 9 / 14 2) 3% but less than 4% of the votes, will receive an annual allocation of 60 000 euros from the state budget; 3) 4% but less than 5% of the votes, will receive an annual allocation of 100 000 euros from the state budget. [RT I, 05.02.2014, 1 – will enter into force on the day of commencement of the term of office of the XIII composition of the Riigikogu (Political Parties Act (1994, amended 2015), §12.7, section (2))
Eligibility criteria for direct public funding to political parties: Representation in elected body Yes. (1) A political party represented in the Riigikoguhas the right to receive an allocation from the state budget by the fifth date of each calendar month. The size of the monthly allocation is one twelfth of the annual amount. The size of the allocation is proportionate to the number of seats obtained in the elections of the Riigikogu. (Political Parties Act (1994, amended 2015), §12.7, section (1))
Eligibility criteria for direct public funding to political parties: Participation in election Yes. Participation is a prerequisite, as funding is determined by the results obtained in the "elections of the Riigikogu."
Eligibility criteria for direct public funding to political parties: Number of candidates No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Share of seats in previous election Yes. For parties represented in Parliament, the size of the allocation is "proportionate to the number of seats obtained."
Eligibility criteria for direct public funding to political parties: Share of votes in next election No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Registration as a political party Yes. The text specifically grants these rights to a "political party," which under Estonian law must be a registered non-profit association.
Eligibility criteria for direct public funding to political parties: Share of seats in next election No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Number of members No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Other No. Absent from legal framework.
Allocation calculations for direct public funding to political parties Yes. (1) The size of the allocation is proportionate to the number of seats obtained in the elections of the Riigikogu. (2) A political party that participated in the elections of the Riigikogu, but did not exceed the election threshold and received at least: 1) 2% but less than 3% of the votes, will receive an annual allocation of 30 000 euros from the state budget; Political Parties Act Page 9 / 14 2) 3% but less than 4% of the votes, will receive an annual allocation of 60 000 euros from the state budget; 3) 4% but less than 5% of the votes, will receive an annual allocation of 100 000 euros from the state budget. [RT I, 05.02.2014, 1 – will enter into force on the day of commencement of the term of office of the XIII composition of the Riigikogu (Political Parties Act (1994, amended 2015), §12.7, sections (1) and (2))
Allocation calculations for direct public funding to political parties: Proportional to votes received Yes. (2) A political party that participated in the elections of the Riigikogu, but did not exceed the election threshold and received at least: 1) 2% but less than 3% of the votes, will receive an annual allocation of 30 000 euros from the state budget; Political Parties Act Page 9 / 14 2) 3% but less than 4% of the votes, will receive an annual allocation of 60 000 euros from the state budget; 3) 4% but less than 5% of the votes, will receive an annual allocation of 100 000 euros from the state budget. [RT I, 05.02.2014, 1 – will enter into force on the day of commencement of the term of office of the XIII composition of the Riigikogu (Political Parties Act (1994, amended 2015), §12.7, section (2))
Allocation calculations for direct public funding to political parties: Equal Yes. The size of the allocation is proportionate to the number of seats obtained in the elections of the Riigikogu. (Political Parties Act (1994, amended 2015), §12.7, section (1))
Allocation calculations for direct public funding to political parties: Proportional to seats received Yes. The size of the allocation is proportionate to the number of seats obtained in the elections of the Riigikogu. (Political Parties Act (1994, amended 2015), §12.7, section (1))
Allocation calculations for direct public funding to political parties: Flat rate by votes received No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Number of members No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Other No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Campaign spending No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Ongoing party activities No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Intra-party institution No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Other No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Equal No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Number of candidates No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Share of seats No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Other No. Absent from legal framework.
Are there provisions for free or subsidized access to media for candidates? No. Absent from legal framework.
Are there provisions for any other form of indirect public funding? Yes. Notices and advertisements relating to election campaigns of political parties, election coalitions and independent candidates are exempt from advertisement tax (Local Taxes Act (1994, amended in 2013), Article 10 (3))
Provisions for any other form of indirect public funding: Premises for campaign meetings No. Absent from legal framework.
Provisions for any other form of indirect public funding: Space for campaign materials No. Absent from legal framework.
Provisions for any other form of indirect public funding: Tax relief Yes. Notices and advertisements relating to election campaigns of political parties, election coalitions and independent candidates are exempt from advertisement tax (Local Taxes Act (1994, amended in 2013), Article 10 (3))
Provisions for any other form of indirect public funding: Free or subsidised transport No. Absent from legal framework.
Provisions for any other form of indirect public funding: Free or subsidised postage cost No. Absent from legal framework.
Provisions for any other form of indirect public funding: Other No. Absent from legal framework.
Is the provision of direct public funding to political parties related to gender equality among candidates? No. Absent from legal framework.
Are there provisions for other financial advantages to encourage gender equality in political parties? No. Absent from legal framework.

Regulations on spending 

Is there a ban on vote buying? Yes . (1) Preventing of a person from electing or being elected at an election or from voting at a referendum, and promising or providing of assets or other benefits with the intention of persuading the person not to exercise his or her election or voting rights or to exercise such rights in a certain way, and influencing of a person for the same purpose by use of an official position, violence, deception or dependent relationship of the person with the offender, is punishable by a pecuniary punishment or up to three years’ imprisonment. (2) The same act, if committed by a legal person, is punishable by a pecuniary punishment. (§ 162(1-2), Penal Code, 2001 (amended 2020))
Are there bans on state resources being used in favour or against a political party or candidate? No. Absent from legal framework.
Are there limits on the amount a political party can spend? No. Absent from legal framework.
Are there limits on the amount a candidate can spend? No. Absent from legal framework.

Reporting, oversight and sanctions 

Do political parties have to report regularly on their finances? Yes. A political party will submit an annual report along with the opinion of a certified auditor, provided that auditing is mandatory, by June 30 to the registration department who will publish the report in the online query system of non-profit associations and foundations (Political Parties Act (1994, amended 2015), §12.9, section (1) & (2))
Do political parties have to report on their finances in relation to election campaigns? Yes. (1) Political parties, election coalitions and single candidates submit to the political party funding supervision committee a report on the expenses of the Riigikogu, European Parliament or local authority council election campaign (Political Parties Act (1994, amended 2015), §12.8, section (1))
Do candidates have to report on their campaign finances? Yes. (1) Political parties, election coalitions and single candidates submit to the political party funding supervision committee a report on the expenses of the Riigikogu, European Parliament or local authority council election campaign (Political Parties Act (1994, amended 2015), §12.8, section (1))
Is information in reports from political parties and/​or candidates to be made public? Yes. The election campaign report is published on the website of the political party funding supervision committee. (Political Parties Act (1994, amended 2015), §12.7, section (1))
Must reports from political parties and/​or candidates reveal the identity of donors? Yes. (7) An election coalition specifies in the report the type of the source of revenue specified in subsection 121 (2) of this Act, which has been used for the election campaign, as well as the loans received, the name and personal identification code or registry code of the person who provided the funds, the value of the funds, and the date of accrual of the funds. (Political Parties Act (1994, amended 2015), §12.8, section (7))
Institutions receiving financial reports from political parties and/​or candidates
Institutions receiving financial reports from political parties and/​or candidates: Electoral Management Board No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Auditing agency No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Ministry No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Special institution No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Court No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Other Yes. The report is submitted to the political party funding supervision committee in the required form within one month from the election day. (Political Parties Act (1994, amended 2015), §12.8, section (1))
Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Ministry No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Auditing agency No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Other Yes. (1) The political party funding supervision committee verifies whether political parties, election coalitions and single candidates adhere to the requirements provided for in this Act (Political Parties Act (1994, amended 2015), §12.10, section (1))
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Ministry No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Auditing agency No. Absent from legal framework.
Institutions with a formal role in political finance oversight: EMB No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Institution for this purpose No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Other No. Absent from legal framework.
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines Yes. Numerous fines are set out in Chapter 2 of the Act. For example: § 12.14 (1) The penalty for failure to inform the political party funding supervision committee of a current account of a political party is a fine of up to 300 fine units. (Political Parties Act (1994, amended 2015), Chapter 2.2, §12.14 to §12.19)
Sanctions for political finance infractions: Loss of public funding No. Absent from legal framework.
Sanctions for political finance infractions: Penal/Criminal No. Absent from legal framework.
Sanctions for political finance infractions: Forfeiture No. Absent from legal framework.
Sanctions for political finance infractions: Deregistration of party No. Absent from legal framework.
Sanctions for political finance infractions: Loss of elected office No. Absent from legal framework.
Sanctions for political finance infractions: Suspension of political party No. Absent from legal framework.
Sanctions for political finance infractions: Loss of nomination of candidate No. Absent from legal framework.
Sanctions for political finance infractions: Loss of political rights No. Absent from legal framework.
Sanctions for political finance infractions: Other No. Absent from legal framework.

Legislation

Political Parties Act (1994, amended 2015) (Estonian)pdf
Local Taxes Act (1994, amended in 2013) (English)pdf

*Last update: 2017

Financial Disclosure

Estonia’s Anti-Corruption Act (1999, last amended in 2016) sets down the same financial disclosure laws for all public officials, including Head of State, Ministers, Members of Parliament, and Civil Servants. Public officials declare real estate, movable assets, cash, debts, and income from outside employment. They must also include any securities or shares in private or public companies. Furthermore, partnership or management positions in companies must be disclosed given that they are connected to an income. In the case of having to make decisions that affect private interests, public officials must inform a superior person or body to alleviate the situation. Spouses and children are to be included in all asset statements.

All officials make their declarations upon taking and leaving office, while updates are to be submitted annually. While late filling or non-filling leads to a fine of up to 200 fine units, knowingly making false disclosure may trigger a fine of up to 300 fine units. A common register functions as depository body for all officials. A selected committee is then responsible for verifying submissions and enforcing legislation on financial disclosure. All the while, the Estonian Parliament exercises supervision over the disclosure process and publishes an annual report on the accuracy of disclosure statements.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Disclosure items0000476
Filing frequency00001275
Sanctions00008100
Monitoring and Oversight00006100
Public access to declarations00001225

Alternative Metric

201220152016201720202024Trend
Head of State0000076
Ministers0000075
Members of Parliament00003575
Civil servants0000075

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Disclosure items

Spouses and children included in disclosure Yes. The President must declare economic interests jointly shared with their spouses and children. (Articles 3 and 7 of the Anti-Corruption Act (adopted 2012, amended 2020))
Income and Assets
Real estate Yes. Immovable property ownership and limited rights are included in the declaration. (Article 13.1 and 14.1 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Movable assets Yes. Vehicles entered in the state register are included in the deslaration (Article 13.1 and 14.1 (2) of the Anti Corruption Act (adopted 2012, amended 2020))
Cash No. Absent from legal framework. The legal framework does not explicitly require declaration of cash holdings as a separate category, although certain liquid financial assets are covered. (Article 14 Anti-Corruption Act (consolidated 2024) )
Loans and Debts Yes. The declaration includes proprietary obligations to other persons (names of creditors and the basis of the obligation) once it exceeds four times the Estonian minimun wage. (Article 14.1 (5) of the Anti Corruption Act (adopted 2012, amended 2020))
Income from outside employment/assets Yes. The president must declare income received the previous year in Estonia and abroad. (Article 14.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Incompatibilities
Gifts received as a public official No. Absent from legal framework. Gifts are regulated under conflict-of-interest provisions, but there is no explicit obligation to declare gifts in asset declarations. (Articles 4, 10, 11 Anti-Corruption Act)
Private firm ownership and/or stock holdings Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Ownership of state-owned enterprises (SOEs) Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Holding government contracts Yes. An official is prohibited from carrying out an activity or making a decision, if it concerns a person connected to them; and if they have economic interest in it; and if the official is aware of a risk of corruption (Article 11 of the Anti Corruption Act (adopted 2012, amended 2020))
Board member, advisor, or company officer of private firm Yes. Public officials must disclose activities concerning general partnership or limited partnership or a member of the management outside their official duties if it involves receipt of income. (Article 14 .7 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. An official is prohibited from carrying out an activity or making a decision, if it concerns a person connected to them; and if they have economic interest in it; and if the official is aware of a risk of corruption (Article 11 of the Anti Corruption Act (adopted 2012, amended 2020))
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Declaration within four months from assuming an office. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required upon leaving office Yes. Declaration in the calendar year following the year when he or she leaves office. (Articel 12.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required annually Yes. Declaration each year, but the official shall not submit more than one declaration during a calendar year. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework.

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. Illness of the official is a reason to excuse the delay of submission (Article 12.4 and Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. (Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Knowingly submitting false information to an administrative authority is punishable by a fine up to 300 units or by imprisonment. (Article 280.1 Criminal Code (adopted 2001, amended 2015))

Monitoring and Oversight

Depository body explicitly identified Yes. The government establishes a register for declarations, to which they are submitted. Such registered is controlled by the ministry of justice Central electronic register under the Ministry of Justice, with administrative functions supported by designated authorities. (Article 13.2 and 13.4 of the Anti Corruption Act (adopted 2012, amended 2020))
Enforcement body explicitly identified Yes. The Riigikogu (Parliament of Estonia) exercises supervision over compliance with the restrictions and publishes once a year a report of the supervision activities and the results. (Article 9 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying submission Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying accuracy Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))

Public access to declarations

Public availability Yes. The declarations of the officials are disclosed in the register controlled by the Ministry of Justice. In order to access the information of the declarations, persons shall identify themselves by digital identity cards. A declarant has the right to obtain information from the register about who accessed his or her declaration. Central electronic register under the Ministry of Justice, with administrative functions supported by designated authorities. (Article 16.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Timing of information release specified No. Absent from legal framework.
Location(s) of access specified No. Absent from legal framework.
Cost of access specified No. Absent from legal framework.

Ministers

Disclosure items

Spouses and children included in disclosure Yes. The ministers must declare economic interests jointly shared with their spouses and children. (Articles 3 and 7 of the Anti-Corruption Act (adopted 2012, amended 2020))
Income and Assets
Real estate Yes. Immovable property ownership and limited rights are included in the declaration. (Article 13.1 and 14.1 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Movable assets Yes. Vehicles entered in the state register are included in the deslaration (Article 13.1 and 14.1 (2) of the Anti Corruption Act (adopted 2012, amended 2020))
Cash No. Absent from legal framework. the legal framework does not explicitly require declaration of cash holdings as a separate category, although certain liquid financial assets are covered. (Article 14 .7 (1) of the Anti Corruption Act)
Loans and Debts Yes. The declaration includes proprietary obligations to other persons (names of creditors and the basis of the obligation) once it exceeds four times the Estonian minimun wage. (Article 14.1 (5) of the Anti Corruption Act (adopted 2012, amended 2020))
Income from outside employment/assets Yes. The ministers must declare income received the previous year in Estonia and abroad. (Article 14.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Incompatibilities
Gifts received as a public official No. Absent from legal framework. Gifts are regulated under conflict-of-interest provisions, but there is no explicit obligation to declare gifts in asset declarations. (Articles 4, 10, 11 Anti-Corruption Act)
Private firm ownership and/or stock holdings Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Ownership of state-owned enterprises (SOEs) Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm Yes. Public officials must disclose activities concerning general partnership or limited partnership or a member of the management outside their official duties if it involves receipt of income. (Article 14 .7 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. Prohibition of making a decision in private interest and forced disclosure to inform superior person or body with the right of appoint the official. (Articel 11 (2) of the Anti Corruption Act, 2012, amended 2020)
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Declaration within four months from assuming an office. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required upon leaving office Yes. Declaration in the calendar year following the year when he or she leaves office. (Articel 12.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required annually Yes. Declaration each year, but the official shall not submit more than one declaration during a calendar year. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework.

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. Illness of the official is a reason to excuse the delay of submission (Article 12.4 and Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. (Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Knowingly submitting false information to an administrative authority is punishable by a fine up to 300 units or by imprisonment. (Article 280.1 Criminal Code (adopted 2001, amended 2015))

Monitoring and Oversight

Depository body explicitly identified Yes. The government establishes a register for declarations, to which they are submitted. Such regitser is controlled by the ministry of Justice. (Article 13.2 and 13.4 of the Anti Corruption Act (adopted 2012, amended 2020))
Enforcement body explicitly identified Yes. The Riigikogu (Parliament of Estonia) exercises supervision over compliance with the restrictions and publishes once a year a report of the supervision activities and the results. (Article 9 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying submission Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying accuracy Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))

Public access to declarations

Public availability Yes. The declarations of the officials are disclosed in a register. To access a person needs to identify him/herself and the respective official has a right to information who had access to his/her declaration. (Article 16.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Timing of information release specified No. Absent from legal framework.
Location(s) of access specified No. Absent from legal framework.
Cost of access specified No. Absent from legal framework.

Members of Parliament

Disclosure items

Spouses and children included in disclosure Yes. The Members of Parliament must declare economic interests jointly shared with their spouses and children. (Articles 3 and 7 of the Anti-Corruption Act (adopted 2012, amended 2020))
Income and Assets
Real estate Yes. Immovable property ownership and limited rights are included in the declaration. (Article 13.1 and 14.1 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Movable assets Yes. Vehicles entered in the state register are included in the deslaration (Article 13.1 and 14.1 (2) of the Anti Corruption Act (adopted 2012, amended 2020))
Cash No. Absent from legal framework. Cash is not a separate declarable category, although financial assets are partially covered.
Loans and Debts Yes. The declaration includes proprietary obligations to other persons (names of creditors and the basis of the obligation) once it exceeds four times the Estonian minimun wage. (Article 14.1 (5) of the Anti Corruption Act (adopted 2012, amended 2020))
Income from outside employment/assets Yes. The Members of Parliament must declare income received the previous year in Estonia and abroad. (Article 14.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Incompatibilities
Gifts received as a public official No. Absent from legal framework.
Private firm ownership and/or stock holdings Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Ownership of state-owned enterprises (SOEs) Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm Yes. Public officials must disclose activities concerning general partnership or limited partnership or a member of the management outside their official duties if it involves receipt of income. (Article 14 .7 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. Prohibition of making a decision in private interest and forced disclosure to inform superior person or body with the right of appoint the official. (Articel 11 (2) of the Anti Corruption Act, 2012, amended 2020)
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Declaration within four months from assuming an office. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required upon leaving office Yes. Declaration in the calendar year following the year when he or she leaves office. (Articel 12.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required annually Yes. Declaration each year, but the official shall not submit more than one declaration during a calendar year. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework.

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. Illness of the official is a reason to excuse the delay of submission (Article 12.4 and Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. (Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Knowingly submitting false information to an administrative authority is punishable by a fine up to 300 units or by imprisonment. (Article 280.1 Criminal Code (adopted 2001, amended 2015))

Monitoring and Oversight

Depository body explicitly identified Yes. The government establishes a register for declarations, to which they are submitted. Such registered is managed by the Ministry of Justice (Article 13.2 and 13.4 of the Anti Corruption Act (adopted 2012, amended 2020))
Enforcement body explicitly identified Yes. The Riigikogu (Parliament of Estonia) exercises supervision over compliance with the restrictions and publishes once a year a report of the supervision activities and the results. (Article 9 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying submission Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying accuracy Yes. A selected committee has exclusive right to verify the declarations submitted by the official. (Article 15.1 of the Anti Corruption Act (adopted 2012, amended 2020))

Public access to declarations

Public availability Yes. The declarations of the officials are disclosed in a register. To access a person needs to identify him/herself and the respective official has a right to information who had access to his/her declaration. (Article 16.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Timing of information release specified No. Absent from legal framework.
Location(s) of access specified No. Absent from legal framework.
Cost of access specified No. Absent from legal framework.

Civil servants

Disclosure items

Spouses and children included in disclosure Yes. The civil servants must declare economic interests jointly shared with their spouses and children. (Articles 3 and 7 of the Anti-Corruption Act (adopted 2012, amended 2020))
Income and Assets
Real estate Yes. Immovable property ownership and limited rights are included in the declaration. (Article 13.1 and 14.1 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Movable assets Yes. Vehicles entered in the state register are included in the deslaration (Article 13.1 and 14.1 (2) of the Anti Corruption Act (adopted 2012, amended 2020))
Cash No. Absent from legal framework. The legal framework does not explicitly require declaration of cash holdings as a separate category, although certain liquid financial assets are covered. (Article 14 Anti-Corruption Act (consolidated 2024) )
Loans and Debts Yes. The declaration includes proprietary obligations to other persons (names of creditors and the basis of the obligation) once it exceeds four times the Estonian minimun wage. (Article 14.1 (5) of the Anti Corruption Act (adopted 2012, amended 2020))
Income from outside employment/assets Yes. The civil servants must declare income received the previous year in Estonia and abroad. (Article 14.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Incompatibilities
Gifts received as a public official No. Absent from legal framework. Gifts are regulated under conflict-of-interest provisions, but there is no explicit obligation to declare gifts in asset declarations. (Articles 4, 10, 11 Anti-Corruption Act)
Private firm ownership and/or stock holdings Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Ownership of state-owned enterprises (SOEs) Yes. Securities (share certificates in investment funds, bonds, convertible bonds, privatisation vouchers, certificates proving the right or obligation of purchase or sale (option), etc.), and shares must be disclosed. Rights and obligations in joint ownerships shall also be declared. (Article 14.1 (3) and 14.8 of the Anti Corruption Act (adopted 2012, amended 2020))
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm Yes. Public officials must disclose activities concerning general partnership or limited partnership or a member of the management outside their official duties if it involves receipt of income. (Article 14 .7 (1) of the Anti Corruption Act (adopted 2012, amended 2020))
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. Prohibition of making a decision in private interest and forced disclosure to inform superior person or body with the right of appoint the official. (Articel 11 (2) of the Anti Corruption Act, 2012, amended 2020)
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Declaration within four months from assuming an office. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required upon leaving office Yes. Declaration in the calendar year following the year when he or she leaves office. (Articel 12.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Filing required annually Yes. Declaration each year, but the official shall not submit more than one declaration during a calendar year. (Articel 12.2 of the Anti Corruption Act (adopted 2012, amended 2020))
Ad hoc filing required upon change in assets or conflicts of interest No. Absent from legal framework.

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. Illness of the official is a reason to excuse the delay of submission (Article 12.4 and Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Fines in the amount of up to 200 fine units. (Article 18 of the Anti Corruption Act (adopted 2012, amended 2020))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Knowingly submitting false information to an administrative authority is punishable by a fine up to 300 units or by imprisonment. (Article 280.1 Criminal Code (adopted 2001, amended 2015))

Monitoring and Oversight

Depository body explicitly identified Yes. The government establishes a register for declarations, to which they are submitted (Article 13.2 and 13.4 of the Anti Corruption Act (adopted 2012, amended 2020))
Enforcement body explicitly identified Yes. The Riigikogu (Parliament of Estonia) exercises supervision over compliance with the restrictions and publishes once a year a report of the supervision activities and the results. (Article 9 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying submission Yes. A selected committee has exclusive right to verify the declarations submitted by the official. The person establishing the obligation civil servants to submit declarations or an official authorised by them shall also have the right to verify declarations. (Article 15.1 and 15.3 of the Anti Corruption Act (adopted 2012, amended 2020))
Some agency assigned responsibility for verifying accuracy Yes. A selected committee has exclusive right to verify the declarations submitted by the official. The person establishing the obligation civil servants to submit declarations or an official authorised by them shall also have the right to verify declarations. (Article 15.1 and 15.3 of the Anti Corruption Act (adopted 2012, amended 2020))

Public access to declarations

Public availability Yes. The declarations of the officials are disclosed in a register. To access a person needs to identify him/herself and the respective official has a right to information who had access to his/her declaration. (Article 16.1 of the Anti Corruption Act (adopted 2012, amended 2020))
Timing of information release specified No. Absent from legal framework.
Location(s) of access specified No. Absent from legal framework.
Cost of access specified No. Absent from legal framework.

Legislation

Anti-Corruption Act of 2012_EST (Estonian)pdf
Penal Code of 2001_EST (Estonian)pdf

*Last update: 2017

Conflict of Interest

The Estonian Anti-Corruption Act (2012, amended 2016) makes a general restriction for all public officials to partake in an act or decision which affects private or personal economic interests. It also states that Head of State, Ministers, MPs and Civil Servants may not accept gifts or participate in decisions which constitute a conflict of interests. In addition, the Constitution (1992, amended 2015) prevents Ministers and Members of Parliament from holding advisory or managerial positions in private companies. More additional restrictions are specified for Civil Servants. These include engaging in a private or public enterprise, acquiring assets, or holding government contracts. Additionally, a cooling-off period of three years is imposed on Civil Servants who wish to work for an employer they supervised during their tenure.

All the while, no sanctions are specified for any public official who violates regulations on conflicts of interests. There are also no monitoring or enforcement bodies in place, which would be able to track conflicts of interest law or provide public officials with guidance.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Restrictions55551043
Sanctions0000033
Monitoring and Oversight121212122550

Alternative Metric

201220152016201720202024Trend
Head of State0000041
Ministers0000044
Members of Parliament0000041
Civil servants232323234741

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Restrictions

General restriction on conflict of interest Yes. An official (here included the President) is prohibited from performing an act or making a decision, if at least one of the following circumstances exists: 1) the decision is made or the act is performed with respect to the official or a person connected to him or her; 2) the official is aware of an economic or other interest of that official or a person connected to him or her and which may have an impact on the act or decision; 3) the official is aware of a risk of corruption. (Anti-Corruption Act of 2012, as amended in 2024, §§ 2 (1) and 11 (1))
Accepting gifts Yes. Income derived from corrupt practices is the proprietary or other benefits offered to the official or any third person due to his or her official duties or demanded by the official, and benefits received by violation of the obligations of the official. Benefits, which cannot be associated with official duties or which are unambiguously understood as common courtesy, shall not be deemed to be corruptive. An official shall immediately give notification to his or her agency or the person or body who has the right to appoint him or her of accepting benefits which can be associated with official duties. An official shall refuse to accept a benefit defined as income derived from corrupt practices or, if this is impossible, deliver the benefit immediately to his or her agency or the person or body who has the right to appoint him or her. If delivery of the benefit is impossible, the official shall pay the market value of the benefit instead of this. The delivered benefit or the value thereof in money shall be transferred into state ownership or returned, if so provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 4)
Private firm ownership and/or stock holdings No. There are no restrictions on ownership. However, the President must declare securities for the purposes of the Securities Market Act, with the exception of funded pension units, holdings in companies and such holdings in companies in which at least 1/10 of the holding belongs to a company connected to the official. The name of each issuer, the type and number of the securities shall be set out in the declaration concerning securities, and the name of the company and nominal value of the holding concerning holdings in companies. (Anti-Corruption Act of 2012, as amended in 2024, §§ 13 (1) 1. and 14)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. Absent from legal framework.
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position Yes. Upon assuming office, the mandate and duties of the President of the Republic in all elected and appointed offices shall terminate, and he or she shall suspend his or her membership in a political party for the duration of his or her term of office. (Constitution of the Republic of Estonia of 1992 (as of 2020), § 84)
Participating in official decision-making processes that affect private interests Yes. If a decision is made or an act is performed with respect to the public official him/herself or a person connected to him/her, the official is prohibited from assigning the task of performing the act, or of decision-making to his/her subordinates. An official shall immediately inform his or her immediate superior or the person or body who has the right to appoint the official and the latter shall perform the act or make the decision or assign this task to another official. (Anti-Corruption Act of 2012, as amended in 2024, § 11 (2))
Assisting family or friends in obtaining employment in public sector No. The Anti-corruption Act prohibits corrupt use of office or influence, but it does not clearly establish a specific 2020 rule against helping family or friends obtain public-sector employment as such. (Anti-corruption Act, § 3(1).)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Corrupt use of official position, public resources, influence or inside information by an official for the purpose of personal gain is punishable by a fine of up to 300 fine units. Knowing violation by an official of a procedural restriction, which includes restrictions on conflict of interest, or the terms and conditions of a procedural restriction is punishable by a fine of up to 200 fine units. (Anti-Corruption Act of 2012, as amended in 2024, §§ 17 and 19)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The select anti-corruption committee of Riigikogu shall exercise parliamentary supervision over the implementation of anti-corruption measures, discuss at its own the initiative potential incidents of corruption involving officials specified in subsection 13 (1) of the Act and assess these, exercise supervision over compliance with the restrictions on activities of the members of the Riigikogu, verify within the limits of its competence the declarations of interests, inform the Riigikogu and the public of the results of anti-corrupt activities in its competence and perform other duties provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (1))
Enforcement body specified (sanctions, hearings) No. If elements of an offence become evident, the select committee shall forward the materials to an investigative body or body conducting extra-judicial misdemeanour proceedings. However, such a body is not specified in the Anti-Corruption Act of 2012. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (3))

Ministers

Restrictions

General restriction on conflict of interest Yes. An official (here included Ministers) is prohibited from performing an act or making a decision, if at least one of the following circumstances exists: 1) the decision is made or the act is performed with respect to the official or a person connected to him or her; 2) the official is aware of an economic or other interest of that official or a person connected to him or her and which may have an impact on the act or decision; 3) the official is aware of a risk of corruption. (Anti-Corruption Act of 2012, as amended in 2024, §§ 2 (1) and 11 (1))
Accepting gifts Yes. Income derived from corrupt practices is the proprietary or other benefits offered to the official or any third person due to his or her official duties or demanded by the official, and benefits received by violation of the obligations of the official. Benefits, which cannot be associated with official duties or which are unambiguously understood as common courtesy, shall not be deemed to be corruptive. An official shall immediately give notification to his or her agency or the person or body who has the right to appoint him or her of accepting benefits which can be associated with official duties. An official shall refuse to accept a benefit defined as income derived from corrupt practices or, if this is impossible, deliver the benefit immediately to his or her agency or the person or body who has the right to appoint him or her. If delivery of the benefit is impossible, the official shall pay the market value of the benefit instead of this. The delivered benefit or the value thereof in money shall be transferred into state ownership or returned, if so provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 4)
Private firm ownership and/or stock holdings No. There are no restrictions on ownership. However, members of the Government of the Republic (Ministers) must declare securities for the purposes of the Securities Market Act, with the exception of funded pension units, holdings in companies and such holdings in companies in which at least 1/10 of the holding belongs to a company connected to the official. The name of each issuer, the type and number of the securities shall be set out in the declaration concerning securities, and the name of the company and nominal value of the holding concerning holdings in companies. (Anti-Corruption Act of 2012, as amended in 2024, §§ 13 (1) 1. and 14)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm Yes. Members of the Government of the Republic shall not hold any other public office, nor belong to the management board or supervisory board of a for-profit enterprise. Additionally, a member of the Government of the Republic shall not be in any elected or appointed office outside his or her official duties or act based on a contract of employment or contract for provision of services, except research or teaching. A member of the Government of the Republic shall immediately inform the Government of the Republic in writing if he or she acts or intends to act outside his or her official duties as an undertaking or a general partner in a general partnership or limited partnership or as a member of a management or controlling body of a legal person. (Constitution of the Republic of Estonia of 1992 (as of 2020), § 99 Government of the Republic Act of 1995, as amended in 2024, § 4 (3))
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position Yes. Members of the Government of the Republic shall not hold any other public office. The President of the Republic may, on the proposal of the Prime Minister, appoint a minister to direct two ministries. Additionally, a member of the Government of the Republic shall not be in any elected or appointed office outside his or her official duties or act based on a contract of employment or contract for provision of services, except research or teaching. (Constitution of the Republic of Estonia of 1992 (as of 2020), § 99 Government of the Republic Act of 1995, as amended in 2024, § 4 (1) (3))
Participating in official decision-making processes that affect private interests Yes. If a decision is made or an act is performed with respect to the public official him/herself or a person connected to him/her, the official is prohibited from assigning the task of performing the act, or of decision-making to his/her subordinates. An official shall immediately inform his or her immediate superior or the person or body who has the right to appoint the official and the latter shall perform the act or make the decision or assign this task to another official. (Anti-Corruption Act of 2012, as amended in 2024, § 11 (2))
Assisting family or friends in obtaining employment in public sector No. The Anti-corruption Act prohibits corrupt use of office or influence, but it does not clearly establish a specific 2020 rule against helping family or friends obtain public-sector employment as such. (Anti-corruption Act, § 3(1).)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Corrupt use of official position, public resources, influence or inside information by an official for the purpose of personal gain is punishable by a fine of up to 300 fine units. Knowing violation by an official of a procedural restriction, which includes restrictions on conflict of interest, or the terms and conditions of a procedural restriction is punishable by a fine of up to 200 fine units. (Anti-Corruption Act of 2012, as amended in 2024, §§ 17 and 19)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The select anti-corruption committee of Riigikogu shall exercise parliamentary supervision over the implementation of anti-corruption measures, discuss at its own the initiative potential incidents of corruption involving officials specified in subsection 13 (1) of the Act and assess these, exercise supervision over compliance with the restrictions on activities of the members of the Riigikogu, verify within the limits of its competence the declarations of interests, inform the Riigikogu and the public of the results of anti-corrupt activities in its competence and perform other duties provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (1))
Enforcement body specified (sanctions, hearings) No. If elements of an offence become evident, the select committee shall forward the materials to an investigative body or body conducting extra-judicial misdemeanour proceedings. However, such a body is not specified in the Anti-Corruption Act of 2012. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (3))

Members of Parliament

Restrictions

General restriction on conflict of interest Yes. An official (here included Members of Parliament) is prohibited from performing an act or making a decision, if at least one of the following circumstances exists: 1) the decision is made or the act is performed with respect to the official or a person connected to him or her; 2) the official is aware of an economic or other interest of that official or a person connected to him or her and which may have an impact on the act or decision; 3) the official is aware of a risk of corruption. (Anti-Corruption Act of 2012, as amended in 2024, §§ 2 (1) and 11 (1))
Accepting gifts Yes. Members of the Riigikogu shall not accept gifts or services related to their work and beyond the limits of common courtesy and not based on the universally accepted customs of diplomacy or international relations, and not permitted as donations under the law. Income derived from corrupt practices is the proprietary or other benefits offered to the official or any third person due to his or her official duties or demanded by the official, and benefits received by violation of the obligations of the official. Benefits, which cannot be associated with official duties or which are unambiguously understood as common courtesy, shall not be deemed to be corruptive. (Good Practice of Members of the Riigikogu of 2014 Anti-Corruption Act of 2012, as amended in 2024, § 4)
Private firm ownership and/or stock holdings No. There are no restrictions on ownership. However, members of the Riigikogu must declare securities for the purposes of the Securities Market Act, with the exception of funded pension units, holdings in companies and such holdings in companies in which at least 1/10 of the holding belongs to a company connected to the official. The name of each issuer, the type and number of the securities shall be set out in the declaration concerning securities, and the name of the company and nominal value of the holding concerning holdings in companies. (Anti-Corruption Act of 2012, as amended in 2024, §§ 13 (1) 1. and 14)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. There are no restrictions related to private firms. However, there are prohibitions concerning: 1. membership of a supervisory board of a legal person in public law if this requires appointment by the Government of the Republic, a Minister or the head of other authority of the executive branch of government; 2. being chair or member of the management board of a legal person in public law; and 3. being chair or member of the management board of a partially government-owned company or of a foundation whose founders include the government. (Status of Members of the Riigikogu Act of 2007 (as of 2020), §§ 26 (1) (3) and 28)
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position Yes. A member of the Riigikogu shall not hold any other public office. During his or her mandate, a member of the Riigikogu may not: 1. hold a position or perform functions which are in conflict with the principle of separation of powers or which may otherwise lead to a conflict of interests in the activities of the member of the Riigikog; 2. be a civil servant at an executive body of the government or of a local authority; 3. be the head of a government institution administered by an executive agency of the government; 4. hold the office of the chair of the executive board of a municipality or city, a member of the executive board of a municipality or city, or of an official of either type of the local authority; and 5. be in the service of other states, of institutions or bodies of the European Union, or of international organisations. (Constitution of the Republic of Estonia of 1992 (as of 2020), § 63 Status of Members of the Riigikogu Act of 2007 (as of 2020), §§ 22 (2) and 23)
Participating in official decision-making processes that affect private interests Yes. If a decision is made or an act is performed with respect to the public official him/herself or a person connected to him/her, the official is prohibited from assigning the task of performing the act, or of decision-making to his/her subordinates. An official shall immediately inform his or her immediate superior or the person or body who has the right to appoint the official and the latter shall perform the act or make the decision or assign this task to another official. (Anti-Corruption Act of 2012, as amended in 2024, § 11 (2))
Assisting family or friends in obtaining employment in public sector No. The Anti-corruption Act prohibits corrupt use of office or influence, but it does not clearly establish a specific 2020 rule against helping family or friends obtain public-sector employment as such. (Anti-Corruption Act of 2012, as amended in 2024, § 3 (1))

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Corrupt use of official position, public resources, influence or inside information by an official for the purpose of personal gain is punishable by a fine of up to 300 fine units. Knowing violation by an official of a procedural restriction, which includes restrictions on conflict of interest, or the terms and conditions of a procedural restriction is punishable by a fine of up to 200 fine units. (Anti-Corruption Act of 2012, as amended in 2024, §§ 17 and 19)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The select anti-corruption committee of Riigikogu shall exercise parliamentary supervision over the implementation of anti-corruption measures, discuss at its own the initiative potential incidents of corruption involving officials specified in subsection 13 (1) of the Act and assess these, exercise supervision over compliance with the restrictions on activities of the members of the Riigikogu, verify within the limits of its competence the declarations of interests, inform the Riigikogu and the public of the results of anti-corrupt activities in its competence and perform other duties provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (1))
Enforcement body specified (sanctions, hearings) No. If elements of an offence become evident, the select committee shall forward the materials to an investigative body or body conducting extra-judicial misdemeanour proceedings. However, such a body is not specified in the Anti-Corruption Act of 2012. (Anti-Corruption Act of 2012, as amended in 2024, § 9 (3))

Civil servants

Restrictions

General restriction on conflict of interest Yes. An official shall refuse to execute an order if the order would lead to the breach of a procedural restriction for the purposes of the Anti-Corruption Act. The latter stipulates that an official is prohibited from performing an act or making a decision, if at least one of the following circumstances exists: 1) the decision is made or the act is performed with respect to the official or a person connected to him or her; 2) the official is aware of an economic or other interest of that official or a person connected to him or her and which may have an impact on the act or decision; 3) the official is aware of a risk of corruption. (Civil Service Act of 2012, as amended in 2019, § 54 (1) 2. Anti-Corruption Act of 2012, as amended in 2024, §§ 2 (1) and 11 (1) )
Accepting gifts Yes. Income derived from corrupt practices is the proprietary or other benefits offered to the official or any third person due to his or her official duties or demanded by the official, and benefits received by violation of the obligations of the official. Benefits, which cannot be associated with official duties or which are unambiguously understood as common courtesy, shall not be deemed to be corruptive. An official shall immediately give notification to his or her agency or the person or body who has the right to appoint him or her of accepting benefits which can be associated with official duties. An official shall refuse to accept a benefit defined as income derived from corrupt practices or, if this is impossible, deliver the benefit immediately to his or her agency or the person or body who has the right to appoint him or her. If delivery of the benefit is impossible, the official shall pay the market value of the benefit instead of this. The delivered benefit or the value thereof in money shall be transferred into state ownership or returned, if so provided by law. (Anti-Corruption Act of 2012, as amended in 2024, § 4)
Private firm ownership and/or stock holdings No. There are no restrictions on ownership. However, public officials must declare securities for the purposes of the Securities Market Act, with the exception of funded pension units, holdings in companies and such holdings in companies in which at least 1/10 of the holding belongs to a company connected to the official. The name of each issuer, the type and number of the securities shall be set out in the declaration concerning securities, and the name of the company and nominal value of the holding concerning holdings in companies. (Anti-Corruption Act of 2012, as amended in 2024, §§ 13 (1) 1. and 14)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. Absent from legal framework.
Board member, advisor, or company officer of private firm No. On the contrary. Unless prohibited by law, an official may also take up an ancillary activity: 1) on the basis of the employment or service contract; 2) in the elected or appointed post; 3) as an undertaking or general partner in a general or limited partnership; 4) as a member of the management or controlling body of a legal person. An official shall immediately notify the appointing authority in writing if he or she is engaged or intends to be engaged in an ancillary activity. (Civil Service Act of 2012, as amended in 2019, § 60 (1) (3))
Post-employment Yes. An official who is released from office may not become, within one year from the day of release, a connected person for the purposes of § 7 (1) 2) and 3) of the Anti-Corruption Act with such legal person in private law over which he or she has exercised direct or constant supervision during the last year. The appointing authority may grant an exceptional permission for the activity, taking account of the size of the local government, the specific character of posts or the scarcity of persons corresponding to the established requirements. The exceptional permission shall be granted in the procedure provided for in the Administrative Procedure Act. (Civil Service Act of 2012, as amended in 2019, § 60 (5) (6))
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. If a decision is made or an act is performed with respect to the public official him/herself or a person connected to him/her, the official is prohibited from assigning the task of performing the act, or of decision-making to his/her subordinates. An official shall immediately inform his or her immediate superior or the person or body who has the right to appoint the official and the latter shall perform the act or make the decision or assign this task to another official. (Anti-Corruption Act of 2012, as amended in 2024, § 11 (2))
Assisting family or friends in obtaining employment in public sector No. The Anti-corruption Act prohibits corrupt use of office or influence, but it does not clearly establish a specific 2020 rule against helping family or friends obtain public-sector employment as such. (Anti-Corruption Act of 2012, as amended in 2024, § 3 (1))

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. The types of a disciplinary penalty are: 1) a reprimand; 2) the reduction of the basic salary by up to 30 percent for up to six months; 3) the release from service. (Civil Service Act of 2012, as amended in 2019, §§ 69 and 70)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. Agencies performing public duties had to ensure awareness and supervision, and anti-corruption activities were coordinated centrally by the Ministry of Justice. (Anti-corruption Act, § 3(3) and § 8.)
Enforcement body specified (sanctions, hearings) No. A disciplinary proceeding may be initiated by a directive or order issued by the appointing authority if sufficient facts are known about the commission of a disciplinary offence. (Civil Service Act of 2012, as amended in 2019, § 72 (1))

Legislation

Constitution of the Republic of Estonia of 1992 (Estonian)pdf
Anti-Corruption Act of 2012 (Estonian)pdf
Status of Members of the Riigikogu Act of 2007 (Estonian)pdf
Government of the Republic Act of 1995 (Estonian)pdf
Civil Service Act of 2012 (Estonian)pdf
Good Practice of Members of the Riigikogu of 2012 (English )pdf

*Last update: 2017

Freedom of Information

Estonia's 1992 Constitution provides for the right to access government information, and the Public Information Act (2000, amended 2016) establishes the procedural mechanisms for such access. This law applies to state and local government agencies, legal persons in public law, undertakings which have a dominant position in the market or special or exclusive rights, organizations funded by state or local budgets, and organizations performing public duties pursuant to law.

Specific exemptions to disclosure are outlined in the aforementioned FOI law, the State Secrets Act (2008), and the Personal Data Protection Act (2008). The head of an agency may grant access to information classified as internal if the interests of the state or a local government are not harmed.

Appeals may be filed with public authorities and with the courts. There is no appeals process through an independent non-judicial mechanism, such as an information commissioner.

The Data Protection Inspectorate is responsible for applying sanctions (fines) and conducting public awareness. The Data Protection Inspectorate, the superior body or agency and the Estonian Information System's Authority have the authority and responsibility for ensuring implementation of statutes.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope and Coverage8993939393100
Information access and release5871717171100
Exceptions and Overrides676767676783
Sanctions for non-compliance0000033
Monitoring and Oversight0000083

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope and Coverage

Scope of disclosure

Existence of legal right to access Yes. (1) Everyone has the right to freely obtain information disseminated for public use (Article 44, Constitution of Estonia, 1992, amended 2015)
"Information" or "Documents" is defined Yes. (1) Public information (hereinafter information) is information which is recorded and documented in any manner and on any medium and which is obtained or created upon performance of public duties provided by law or legislation issued on the basis thereof. (Article 3 of the Public Information Act, 2000, amended 2023)
Proactive disclosure is specified Yes. (1) The holders of information specified in § 31 of this Act shall disclose the information specified in subsection 28 (1) of this Act on a website, or shall add a link to a webpage through which the information can be accessed. (Article 29 of the Public Information Act, 2000, amended 2023)

Coverage of public and private sectors

Executive branch Yes. (1) The following are holders of information: 1) state and local government agencies; 2) legal persons in public law; (Article 5 of the Public Information Act, 2000, amended 2023)
Legislative branch Yes. (1) The following are holders of information: 1) state and local government agencies; 2) legal persons in public law; (Article 5 of the Public Information Act, 2000, amended 2023)
Judicial branch Yes. (1) The following are holders of information: 1) state and local government agencies; 2) legal persons in public law; (Article 5 of the Public Information Act, 2000, amended 2023)
Other public bodies Yes. (3) The following are deemed to be equal to holders of information: 1) undertakings which have a dominant position in the market or special or exclusive rights or which are natural monopolies – with regard to information concerning the conditions and prices of the supply of goods and services and changes thereto; 2) sole proprietors, nonprofit associations, foundations and companies – with regard to information concerning the use of funds allocated from the state or a local government budget for the performance of public duties or as support. (Article 5 of the Public Information Act, 2000, amended 2023)
Private sector Yes. 3) legal persons in private law and natural persons under the conditions provided for in subsection (2) of this section. (2) The obligations of holders of information extend to legal persons in private law and natural persons if the persons perform public duties pursuant to law, administrative legislation or contracts, including the provision of educational, health care, social or other public services, – with regard to information concerning the performance of their duties. (Article 5 of the Public Information Act, 2000, amended 2023)

Access to specific documents (subject to reactive and/or proactive disclosure)

Draft legal instruments Yes. Holder of information is required to disclose draft legal instruments (laws, decrees, regulations, and subsidiary legislation). (Article 28 of the Public Information Act, 2000, amended 2023)
Enacted legal instruments Yes. 2) legislation prepared and signed in the agency, on the date of signature thereof or the working day after such date; (Articles 11, 12 and 28 of the Public Information Act, 2000, amended 2023)
Annual budgets Yes. Disclosure of information on budgets of the state agencies, local governments and local government agencies is required. (Article 28, part 1 of the Public Information Act, 2000, amended 2023 )
Annual chart of accounts (actual expenditures) Yes. Disclosure of information on budgets of the state agencies, local governments and local government agencies is required. (Article 28, part 1 of the Public Information Act, 2000, amended 2023 )
Annual reports of public entities and programs Yes. Disclosure of information on budgets of the state agencies, local governments and local government agencies is required. (Article 28, part 1 of the Public Information Act, 2000, amended 2023 )

Information access and release

Procedural access

Universal access (agencies, citizens and non-citizens) Yes. Each person who submits a request for information to a holder of information pursuant to the procedure provided for in this Act is a person making a request for information. (Article 7 of the Public Information Act, 2000, amended 2023)
Type of request is specified (written, electronic, oral) Yes. (1) A request for information shall set out the following information orally or in writing: 1) the given name and surname of the person making the request for information; 2) the name of the legal person or agency in the case of a request for information made on behalf of an agency or legal person; 3) the contact details of the person making the request for information (postal or electronic mail address, or fax or telephone number), through which the holder of information could release the information or contact the person making the request for information; 4) the content of the information or the type, name and content of the document requested, or the requisite information on the document known to the person making the request for information; 5) the manner of complying with the request for information. (Article 14(1) of the Public Information Act, 2000, amended 2023)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.) Yes. § 15. Obligation of holders of information to assist persons making requests for information (1) Holders of information are required to clearly explain the procedure for and the conditions and methods of access to information to persons making requests for information. (2) Officials or employees of holders of information are required to assist persons making requests for information in every way during the making of requests for information and the identification of the information necessary for the persons making requests for information, the location of the information and the most suitable methods of access thereto. (3) An official or employee of a holder of information who is not competent to comply with a request for information is required promptly to send the person making the request for information to an official or employee who has the corresponding competence, or promptly to communicate the request for information in writing to the specified official or employee. (4) If a request for information does not indicate the method or the information which the person making the request for information is requesting, the holder of information shall promptly contact the person making the request for information in order to specify the request for information. (Articles 9 and 15 of the Public Information Act, 2000, amended 2023)
Cost of access is specified (free, request fees, photocopying costs, other administrative costs) Yes. (4) Access to information shall be granted without charge unless payment for the direct expenses relating to the release of the information is prescribed by law. (4-1) A holder of information must publish the conditions for accessing the information and the amount to be charged for access and, if a person making a request for information so requires, provide explanations concerning the cost orientation of the charges. (Articles 4 and 25-27 of the Public Information Act, 2000, last amended 2023)

Deadlines for release of information

20-day response deadline Yes. Answer to inquiry is provided within 5 days. If request cannot be complied with due to insufficiency of information submitted by the person making the request he/she should be notified within 5 days. If the entity to whom the request has been made does not possess the requested information, within 5 days the request is forwarded to appropriate holder of information and the requesting person is notified. (Article 18 and 21 of the Public Information Act, 2000, amended 2023)
Agency granted right to extend response time Yes. Response time to information request can be extended for up to fifteen days by notifying the person making the request of the extension and reasons for it within five working days. Response time to information request can be extended for up to fifteen days by notifying the person making the request of the extension and reasons for it within five working days. (Article 19 of the Public Information Act, 2000, amended 2023)
Maximum total response time of no more than 40 days Yes. Response time to information request can be extended for up to fifteen days by notifying the person making the request of the extension and reasons for it within five working days. (Article 19 of the Public Information Act, 2000, amended 2023)

Exceptions and Overrides

Exemptions to disclosure

Existence of secrecy/states secrets law Yes. Access to state secrets is restricted to only certain individuals. (Article 26 of the State Secrets Act, 2008, amended 2023)
Existence of personal privacy/data law Yes. Individuals may have access to data pertaining to them, as well as other information about how such information has been used. (Article 19 of the Personal Data Protection Act, 2018, amended 2023)
Specific exemptions to disclosure Yes. The following types of information are exempt from disclosure requirements: preliminary information collected in legal proceedings; information collected in the course of state supervision, administrative supervision and supervisory control proceedings until the entry into force of a decision made thereon; preliminary information collected during state supervision proceedings; information that may damage foreign relations; sensitive military and security information; sensitive information on certain endangered objects, animals, or animals; and draft legislation and accompanying documents. The following types of information are exempt from disclosure requirements: recent public opinion polls; statistical surveys; economic forecasts; environmental notices; information damaging to officials’ reputations; public nonprofits; and information on certain public-to-private transfers of funds. (Article 35, 36, 38 of the Public Information Act, 2000, amended 2023 )
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

Appeals

Appeals allowed within public entities Yes. There is a formal appeals mechanism through supervisory body or administrative court. (Article 46 of the Public Information Act, 2000, amended 2023)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding. No. Absent from legal framework.
Judicial appeals mechanism Yes. There is a formal appeals mechanism through supervisory body or administrative court. (Article 46 of the Public Information Act, 2000, amended 2023)

Sanctions for non-compliance

Administrative sanctions are specified for violations of disclosure requirements No. Absent from legal framework.
Fines are specified for violations of disclosure requirements Yes. Knowing release of incorrect public information or knowing disclosure or release of information intended for internal use or failure to comply with a precept of the Data Protection Inspectorate is punishable by a fine of up to 300 fine units. (Article 54 of the Public Information Act, 2000, amended 2023)
Criminal sanctions are specified for violations of disclosure requirements No. Absent from legal framework.

Monitoring and Oversight

Information officers must be appointed in public agencies Yes. The head of the holder of information is responsible for the organization of access to information, unless it is assigned to another person by legislation. (Article 10 of the Public Information Act, 2000, amended 2023)
Public body that is responsible for applying sanctions Yes. Data Protection Inspectorate (Articles 53 and 54 of the Public Information Act, 2000, amended 2023)
Public body that is responsible for public outreach (raising public awareness) Yes. Data Protection Inspectorate (Statutes and Composition of Data Protection Inspectorate, 2007, last amended 2016)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman. Yes. The Data Protection Inspectorate, the superior body or agency, and the Estonian Information System's Authority. have the authority and responsibility for ensuring implementation of statutes. (Articles 44 and 45 of the Public Information Act, 2000, amended 2023)
Ombudsman involvement in implementation is specified by law No. Data Protection Inspectorate functions as ombudsman. ( )
Reporting of data and/or implementation is required Yes. Pursuant to the Personal Data Protection Act and the Public Information Act the inspectorate shall submit its activity reports to the Constitutional Committee of the Riigikogu [Parliament] and the Chancellor of Justice. (Article 3, Statutes and Composition of Data Protection Inspectorate, 2007, last amended 2016)

Legislation

Constitution of the Republic of Estonia of 1992_EST (Estonian)pdf
Public Information Act of 2000_EST (Estonian)pdf
State Secrets and Classified Information of Foreign States Act of 2007_EST (Estonian)pdf
Personal Data Protection Act of 2018_EST (Estonian)pdf
Statutes and Composition of Data Protection Inspectorate of 2007_EST (Estonian)pdf

*Last update: 2017

Public Procurement

The Estonian public procurement system is regulated by the Public Procurement Act, and supplemented by several additional regulations of the Government. The public procurement body is the Public procurement and state aid department that is part of the Ministry of Finance.

The lowest minimum thresholds for conducting a public procurement tender are:

▪         EUR 40,000 for goods

▪         EUR 250,000 for works

▪         EUR 40,000 for services

The minimum number of bidders is 5 for restricted procedures and 3 for negotiated procedures and competitive dialogue. The minimum submission period is 52 days for open procedures, 40 days for restricted procedures and 37 for negotiated procedures from dispatch date. The final beneficial owners do not have to be disclosed when placing a bid.

There is no preferential treatment, however environmental considerations can alter decisions. Furthermore, there are several options for bid exclusion: criminal considerations, bankruptcy, open procedures compulsory liquidation, outstanding tax or social insurance liabilities, joint bidding for the same lot, false information. Furthermore, extremely low bid prices can be excluded as well.

In the bid evaluation phase, there are conflict of interest restrictions on the composition of the evaluation committee. However, no form of independence of  the contracting authority is mandated for the evaluation committee.

There is a payable fee in case of an arbitration procedure that is set in a separate State Fees Act. Decisions are publicly released.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope7371775988
Information availability66683146
Evaluation6262567575
Open competition5050757556
Institutional arrangements3636363629

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope

Threshold - lowest PP

What is the minimum contract value above which the public procurement law is applied? (Product type GOODS) EUR 30,000. Any supply contract above EUR 30,000 must follow the Act (either simple procurement up to EUR 60,000, then formal procedures above EUR 60,000). Goods contracts above the EU threshold (EUR 143,000 for most authorities, higher for utilities/defense) must follow EU notices and rules. (PPA 2017 (as in force Dec. 2024), §14(1,2), §16)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS) EUR 60,000. Works contracts above EUR 60,000 must comply with the Act, and those exceeding EUR 150,000 are subject to full, open procedures and publication. Major works above EU threshold (EUR 5,538,000 as of Dec. 2024) require TED notice and full EU rules. (PPA 2017 (as in force Dec. 2024), §14(1,2), §16; Commission Notice on thresholds)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES) EUR 30,000. Services (other than social/special regime) above EUR 30,000: simple procurement applies. Above EUR 60,000: formal procedures (open, restricted, negotiated). For certain services (Annex XVII), threshold is EUR 300,000. (PPA 2017 (as in force Dec. 2024), §14(1,2), §16, Annex II, III)

Threshold - by PP type

What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR) EUR 30,000. For all supplies/services contracts, EUR 30,000 for simple, EUR 60,000 for full procedures; for works, EUR 60,000/150,000/5,538,000. Thresholds are set in §14 with detailed procedures listed in §§20–30. (PPA 2017 (as in force Dec. 2024), §14, §§20–31)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES) EUR 60,000. Utilities (water, energy, postal, transport) have higher initial thresholds, with all major contracts following EU sectoral rules above the EU thresholds (EUR 443,000 for goods/services, EUR 5,538,000 for works). (PPA 2017 (as in force Dec. 2024), §14(2), §16, Annex II)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE) EUR 60,000. Defense/secure acquisitions: EUR 60k for supplies/services and EUR 150k for works/services and EUR 300k for larger contracts. Above EU directives’ threshold, tender must be published in TED; special rules for security/dual-use. (PPA 2017 (as in force Dec. 2024), §14(2), §16; Annex III)

Threshold - by product type

What are the minimum application thresholds for the procurement type? (Product type GOODS) EUR 30,000. For goods, EUR 30k is the “simple procurement” entry, all contracts above EUR 60k require full public procedure. The distinction is clearly established in Art. 14. (PPA 2017 (as in force Dec. 2024), §14(1))
What are the minimum application thresholds for the procurement type? (Product type WORKS) EUR 60,000. Works below 60k: simple procurement; above 150k (public authorities) and EU threshold (EUR 5.5 million): formal procedures and international notices apply. (PPA 2017 (as in force Dec. 2024), §14(1,2), §16)
What are the minimum application thresholds for the procurement type? (Product type SERVICES) EUR 30,000. As above: general services EUR 30k/60k; social/special regime EUR 300k. (PPA 2017 (as in force Dec. 2024), §14(1,2), §16; Annexes II–III)

Information availability

Publishing and record keeping

Is there a requirement that tender documents must be published in full? Yes. All main documentation, including evaluation rules, contract drafts, award decisions and scoring sheets, must be published with the procurement notice and remain accessible during and after the procedure, with redactions only for confidential or sensitive business data subject to explicit legal grounds. (PPA 2017 (as in force Dec. 2024), §79, §123)
Are any of these documents published online at a central place? Yes. The Public Procurement Register (https://riigihanked.riik.ee/) serves as the single platform for all above-threshold procurement and for data reporting, mandated for all authorities. (PPA 2017 (as in force Dec. 2024), §32)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system) Yes. Record-keeping includes both hard copy and digital files; contract amendments and litigation are specially flagged for audit; data must be kept minimally for 7 years (§122). (PPA 2017 (as in force Dec. 2024), §120–122)
Are contracts awarded within a framework agreement published (ie mini contracts)? Yes. The law requires that contracts awarded under framework agreements or dynamic purchasing systems be published at least quarterly, with key details (name, value, subject, duration) provided for each mini-contract (“call-off” contract). (PPA 2017 (as in force Dec. 2024), §95)

Sub-contracting

Is it mandatory to publish information on subcontractors (ie names) in some cases? No. The Public Procurement Act does not impose a general requirement for publishing the names of all subcontractors. If the contracting authority relies on the capacity of subcontractors for qualification purposes, the main contractor must identify them in the tender (notices or qualification documentation). For on-site works/services, authorities may demand advance disclosure and may publish these details in the contract register but are not legally obliged to publish for all contracts. (PPA 2017 (as in force Dec. 2024), §39(3), §123)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column. There is no percentage threshold for the publication of subcontractor information; it depends entirely on the nature of the procurement and the requirements stated in the tender documentation. If subcontracting represents a significant part of the contract or is essential for qualification, the authority may require all such details to be included in the procurement register. (PPA 2017 (as in force Dec. 2024), §39(3), §123)

Evaluation

Preferential treatment

Is there a ban on mentioning specific companies or brands in tender specification/call for tender? Yes. Tender documentation or technical specifications must not refer to trade marks, patents, types, or a specific origin/producer unless essential to subject-matter and “or equivalent” is always required if used. (PPA 2017 (as in force Dec. 2024), §88(6))
Is there a preferential treatment for small-to-medium enterprises (SMEs)? No. No explicit legal preference for SMEs. Procuring entities may, but are not obliged to, divide contracts into lots to facilitate SME access; such division should be justified in written records. (PPA 2017 (as in force Dec. 2024), §50(1), §52)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies) No. Contracting authorities must not grant any preference or apply discriminatory conditions based on the seat, nationality, or origin of bidders (subject to EU/EEA and GPA coverage). (PPA 2017 (as in force Dec. 2024), §45)
Is there a specific set of rules for green/sustainable procurement? Yes. Green/social criteria (life-cycle costing, environmental performance, resource efficiency, social inclusion) may be used in selection and award criteria. These requirements must be measurable, relevant, and shown in the contract files and award decisions. (PPA 2017 (as in force Dec. 2024), §116(3), §117, §118)

Bid evaluation

Are there restrictions on allowable grounds for tenderer exclusion? Yes. Exclusion is automatic or discretionary for: criminal convictions (corruption, fraud, money laundering, terrorism, tax evasion), prior serious contractual breaches, unresolved conflicts of interest, bankruptcy, etc. Bidders may be excluded for failing to meet financial, technical, or professional requirements. (PPA 2017 (as in force Dec. 2024), §95–§100)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc. Yes. Bidders must be automatically excluded if convicted for offences listed in §95, or if they are bankrupt/insolvent, have unpaid mandatory taxes/social contributions, or have provided false statements. (PPA 2017 (as in force Dec. 2024), §95)
Is scoring criteria published? Yes. The contracting authority must publish all detailed criteria and scoring rules before submission deadline; all evaluations must follow them. (PPA 2017 (as in force Dec. 2024), §116)
Are decisions always made by a committee? No. Committees are mandatory only for design contests; otherwise, evaluation may be performed by a procurement manager or staff panel as determined by the authority's procurement rules. (PPA 2017 (as in force Dec. 2024), §120; §150 (design contests))
Are there regulations on evaluation committee composition to prevent conflict of interest? Yes. All evaluators involved in bid scoring or decision must sign written declarations of impartiality and absence of conflicts of interest (§120). Where conflict arises, individuals must recuse themselves and are replaced. (PPA 2017 (as in force Dec. 2024), §120(4), §45)
Is some part of evaluation committee mandatorily independent of contracting authority? No. No legal requirement for independent experts outside the contracting authority, except for certain jury-based evaluation in design contests. Independence is left to internal policy. (PPA 2017 (as in force Dec. 2024), §150)
Are scoring results publicly available? No. Only the final decision and winner must be published; scoring summaries must be available on request to all bidders, but are not released publicly unless specifically requested. Bidder feedback letters are mandatory. (PPA 2017 (as in force Dec. 2024), §124, §129)
Does the law specify under which conditions the tender can be cancelled? Yes. The authority may cancel a procurement procedure if all bids are unaffordable, none meet conditions, a material error is discovered, or circumstances have materially changed (force majeure, funding lost, etc.); all reasons must be documented and notified to bidders. (PPA 2017 (as in force Dec. 2024), §121)

Open competition

CFT publication

Does the law specify the location for publicizing open calls for tenders? Yes. Identical requirement: restricted notices must be published via the Register and TED as per value. (PPA 2017 (as in force Dec. 2024), §73)
Does the law specify the location for publicizing restricted calls for tenders? Yes. For negotiated procedures (with/without prior publication), calls are published on the Register and, if above the EU threshold, on TED. Only direct award by law is exempt. (PPA 2017 (as in force Dec. 2024), §75, §77)
Does the law specify the location for publicizing negotiated calls for tenders? Yes. Publications Office of the European Union (TED) and Public Procurement Register, available at: https://riigihanked.riik.ee/rhr-web/#/ (Public Procurement Act of 2017, as amended, §§ 45 (3), 73 (1), 181 and 183)

Minimum # of bidders

What is the minimum number of bidders for restricted procedures? 5. At least 5 candidates must be invited for restricted procedures (if available after selection). (PPA 2017 (as in force Dec. 2024), §91(2))
What is the minimum number of bidders for negotiated procedures? 3. 3 minimum for negotiated and competitive dialogue procedures. (PPA 2017 (as in force Dec. 2024), §93(2), §95(3))
What is the minimum number of bidders for competitive dialogue procedures? 3. As above: 3 minimum for competitive dialogue. (PPA 2017 (as in force Dec. 2024), §95(3))

Bidding period length

What are the minimum number of days for open procedures? 15. Standard minimum: 15 days for submission of bids for open, restricted, or negotiated procedures from dispatch of call to deadline. Higher minimums apply for certain international/EU funded/complex contracts. (PPA 2017 (as in force Dec. 2024), §74)
What are the minimum number of days for restricted procedures? 15. 15 days from invitation in restricted procedures. (PPA 2017 (as in force Dec. 2024), §74)
What are the minimum number of days  for competitive negotiated procedures? 15. 15 days for negotiated and dialogue from invitation. (PPA 2017 (as in force Dec. 2024), §74)

Institutional arrangements

Institutions and regulations

Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations? Yes. Notable exceptions: defense/security, classified, arbitration/legal, media, lease/acquisition real estate, urgent disasters, international organizations, energy/water/transport when separately regulated; full list is in §11 and §13. (PPA 2017 (as in force Dec. 2024), §11, §13)
Does the law specify the main types of institutions that must apply the public procurement law? Yes. Contracting authority means: 1) the state or a state authority; 2) a local authority, a local authority agency or an association of local authorities; 3) another public legal person or an agency of a public legal person; 4) a foundation where the state is one of the founders or where more than half of the founders are contracting authorities specified in clause 2 or 3 of this subsection or where more than half of the members of the supervisory board are appointed by the contracting authorities specified in clauses 1–3; 5) a private legal person established for the purpose of performing, as a principal or ancillary activity, in the public interests a function that does not have an industrial or commercial character and mainly financed by or where more than half of the members of the management body, administrative body or supervisory body are appointed by or where the management is otherwise jointly or severally controlled by the contracting authorities specified in clauses 1–4 of this subsection or by the contracting authorities of another contracting state of the EEA or by other private legal persons that have the characteristics specified in this clause. (Public Procurement Act of 2017, as amended, § 5 (2))
Does the law specify the main procedure types or procurement methods permitted? Yes. Law specifies open, restricted, negotiated (with or without prior publication), competitive dialogue, design contest, innovation partnership, simplified procedure (below threshold), and direct award for exceptional cases. (PPA 2017 (as in force Dec. 2024), §§20–35)
Is there a procurement arbitration court dedicated to public procurement cases? No. There is no automatic “standstill”; however, the Review Committee may order a temporary suspension of contract award/execution if request is deemed justified within 3 working days. (PPA 2017 (as in force Dec. 2024), §191(4))
Is there a procurement regulatory body dedicated to public procurement? No. The Ministry of Finance manages policy, guidance, and Register, but is not a separate independent regulatory body; oversight, review, and enforcement are divided with the National Audit Office and the Review Committee. (PPA 2017 (as in force Dec. 2024), §197)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)? Yes. The Public Procurement Register must publish the outcome and summary of review proceedings, with full decision documents accessible on request for interested parties. (PPA 2017 (as in force Dec. 2024), §200)
Is disclosure of final, beneficial owners required for placing a bid? No. See Q54; enforced only as part of the Commercial Register or by separate anti-money laundering control, not directly in public procurement procedures. (Money Laundering Act 2017, §20)

Complaints

Is there a fee for arbitration procedure? Yes. See Q55; fee for RVK is set by State Fees Act, not differentiated beyond threshold. (State Fees Act 2014, §56, §601)
Is there a ban on contract signature until arbitration court decision (first instance court)? No. No automatic ban exists; only if the Review Committee grants a suspension, contract signing is forbidden until a decision. (PPA 2017 (as in force Dec. 2024), §191(4))
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts? Yes. See Q58: arbitration decisions and summaries published on the Public Procurement Register with access for all stakeholders. (PPA 2017 (as in force Dec. 2024), §200)
Is there a requirement to publicly release arbitration court decisions? Yes. The Register is legally obliged to publish all key evaluation, contract, and review decisions; accessible to the public except for information protected by law (business secrets, national security). (PPA 2017 (as in force Dec. 2024), §200)

Legislation

Money Laundering and Terrorist Financing Prevention Act (English)pdf
Public Procurement Act (English)pdf
State Fees Act (English)pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data

Primary Metric

201220152016201720202024Trend
Risk-based approach67
Sanctions for natural persons100
Sanctions for legal persons25
Pecuniary sanctions for obliged entities100
Beneficial ownership of legal persons and legal arrangements14
Supervision of obliged entities0
Financial Intelligence Units (FIUs)100
Mutual legal assistance (MLA) and International Cooperation100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Risk-based approach

Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it. Yes. The Act expressly requires a national risk assessment and specifies its AML/CFT functions and outputs. (Money Laundering and Terrorist Financing Prevention Act (2017), § 11(1))
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years. No. The Act requires coordination and updating of the national risk assessment, but no explicit rule was found requiring review at least every four years. (Money Laundering and Terrorist Financing Prevention Act (2017), § 12(1)(1))
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks. Yes. The Act establishes the AML/CFT Committee as the government committee that coordinates preparation and updating of the national risk assessment. (Money Laundering and Terrorist Financing Prevention Act (2017), § 12(1)(1))

Sanctions for natural persons

The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action; Yes. Conversion or transfer of criminal property to conceal its illicit origin or assist an offender is included in the statutory definition of money laundering, and money laundering is punishable as a criminal offence. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(1)(1); Penal Code (2001), § 394(1))
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity; Yes. Concealment of the true nature, origin, location, manner of disposal, relocation or ownership rights in criminal property is included in the statutory definition of money laundering, and money laundering is punishable as a criminal offence. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(1)(3); Penal Code (2001), § 394(1))
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity. Yes. Acquisition, possession or use of criminal property, knowing at receipt that it derives from criminal activity, is included in the statutory definition of money laundering, and money laundering is punishable as a criminal offence. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(1)(2); Penal Code (2001), § 394(1))
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence. Yes. The Act expressly covers attempts and aiding or abetting within the definition of money laundering, and accomplice liability is punishable under the Penal Code. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(2); Penal Code (2001), §§ 22, 25)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years. Yes. Money laundering is punishable by up to five years’ imprisonment, which exceeds the four-year threshold. (Penal Code (2001), § 394(1))
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences Yes. Section 4(5) allows money laundering to be established even where the details of the predicate criminal activity have not been identified, which substantively means a prior or simultaneous predicate-offence conviction is not required. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(5))
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator; Yes. Sections 4(4) and 4(5) allow knowledge or intent to be inferred from objective facts and allow money laundering to be established even where the details of the predicate criminal activity have not been identified, which substantively covers conviction without proving all factual elements or the perpetrator’s identity. (Money Laundering and Terrorist Financing Prevention Act (2017), § 4(4)–(5))

Sanctions for legal persons

Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person. No. National law provides legal-person fines for certain breaches of Regulation (EU) 2023/1113, but no explicit national rule was found matching the indicator’s leading-position attribution rule or extending it to Regulation (EU) 2024/1624. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 96(2), 96^2(2))
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority. No. No explicit national rule was found making legal persons liable because a lack of supervision or control enabled money laundering for the legal person’s benefit. (Penal Code (2001), § 14(1))
Legal persons held liable are punishable by criminal or non-criminal fines. Yes. Where a legal person is liable for money laundering, the sanction is a pecuniary punishment. (Penal Code (2001), § 394(3))
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence. No. Estonian law provides pecuniary punishment for legal persons, but no explicit general rule was found imposing the additional sanctions listed in the indicator on legal persons held liable for money laundering. (Penal Code (2001), §§ 44, 55^1; § 46 repealed)

Pecuniary sanctions for obliged entities

In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach. Yes. Estonian law lays down pecuniary sanctions and supervisory measures for breaches of the national AML/CFT framework and also for breaches of Regulation (EU) 2023/1113. Under the methodology, sanctions for breach of the national AML law implementing EU AML rules are sufficient. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 64–67, 82–94, 96–96^2)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention). Yes. Estonian law allows sanctions to reach both legal persons and responsible natural persons, including management board members, executives and employees, for AML/CFT breaches and certain Regulation (EU) 2023/1113 breaches. That is sufficient in substance. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 82–93, 96(1)–(2), 96^2(1)–(2))
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed. Yes. Estonian law imposes pecuniary sanctions for breaches of internal controls, customer due diligence, reporting and record-keeping duties under the national AML/CFT framework. Under the methodology, that is sufficient even without a verbatim cross-reference to Regulation (EU) 2024/1624. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 82, 84–85, 92, 94)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures. Yes. Supervisors may impose non-compliance levies where an obliged entity fails to comply with an administrative decision or complies improperly, in order to compel performance of the duty. (Money Laundering and Terrorist Financing Prevention Act (2017), § 65(2)–(4))
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments. Yes. The Financial Intelligence Unit and the Financial Supervision and Resolution Authority must publish final sanctioning and administrative decisions, compliance notices and non-compliance levy decisions on their websites after they become final. (Money Laundering and Terrorist Financing Prevention Act (2017), § 67(3)–(5))

Beneficial ownership of legal persons and legal arrangements

Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered. Yes. Estonia has a central beneficial ownership framework for private legal persons and for trusts through trust-service providers resident or registered in Estonia, with filing into the Beneficial Ownership Information Database via the Commercial Register information system. That substantively satisfies the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 2(6), 76(1), 76(1^2), 76^2(2)–(3), 77(3^3)–(3^4))
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation. No. Absent from legal framework
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number No. Where no natural person is identified, national law treats senior managing officials as beneficial owners, but it does not require the register to include a statement that no beneficial owner was identified and it does not require all of the listed data fields. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 9(4^1), 77(1)–(3))
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date. No. The registry department can demand filing of missing data and record a note where substantiated doubts are notified, but no explicit rule was found requiring verification of beneficial ownership information within a reasonable time upon submission and on a regular basis thereafter. (Money Laundering and Terrorist Financing Prevention Act (2017), § 77^2(1)–(4))
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them. No. National law provides for discrepancy notifications by obliged entities, not an explicit duty for competent authorities generally to report discrepancies they find to the register. (Tegelike kasusaajate andmekogu asutamine ja põhimäärus (2023), § 9(1)–(4))
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register. No. Companies, non-profit associations and foundations must file changed beneficial ownership data within 30 days, but the national rule does not clearly cover legal arrangements and nominee arrangements as described in the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 77(5))
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date. No. Absent from legal framework
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration. No. Absent from legal framework
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership. No. The Act penalises certain failures to submit or update beneficial owner data, but no explicit national rule was found empowering the register entity itself, directly or through another authority, to apply the measures described in the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 95(1))
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States. No. Certain authorities and obliged entities receive beneficial owner data free of charge, but national law does not clearly establish the full category of authorities listed in the indicator as having immediate, unfiltered, direct access through the interconnected central registers without alerting the entity concerned. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(3))
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers. Yes. Obliged entities receive beneficial ownership data free of charge. Free access is broader than access subject to a cost-based fee and therefore satisfies the indicator in substance. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(2)–(3))
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest. No. Beneficial ownership data are public in the commercial register information system, but national law does not establish the specific legitimate-interest access regime set out in the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(1); Tegelike kasusaajate andmekogu asutamine ja pőhimäärus (2023), § 10(2))
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Beneficial ownership data are publicly available, but no explicit national rule was found deeming journalism, reporting or other media expression to constitute legitimate interest for access. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(1))
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Beneficial ownership data are publicly available, but no explicit national rule was found deeming civil society organisations or academia to constitute legitimate interest for access. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(1))
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing; No. Beneficial ownership data are publicly available, but no explicit national rule was found deeming prospective transaction counterparties to constitute legitimate interest for access. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(1))
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure; No. Beneficial ownership data are publicly available, but no explicit national rule was found deeming public authorities in public procurement procedures to constitute legitimate interest for access. (Money Laundering and Terrorist Financing Prevention Act (2017), § 78(1))
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing. No. Absent from legal framework
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days. No. Absent from legal framework
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679. Yes. Although Estonia does not use the indicator’s exact wording, the framework contains concrete conditions under which access can be limited, including disproportionate risk to the beneficial owner and cases involving minors or persons of limited active legal capacity. Under the methodology, at least one operative ground for refusal is sufficient. (Money Laundering and Terrorist Financing Prevention Act (2017), § 79^2(1)–(3))
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed. No. Estonia allows case-by-case limitation of public access where disclosure would create disproportionate risks or where the beneficial owner is a minor or a person of limited active legal capacity, but no explicit national rule was found in this framework guaranteeing the administrative review and judicial remedy described in the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 79^2(1)–(3))

Supervision of obliged entities

Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113. No. National law designates several supervisory authorities and enforcement powers under the Act, but no explicit national rule was found requiring supervision of compliance with Regulations (EU) 2024/1624 and 2023/1113 in the terms of the indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 64(1)–(6))

Financial Intelligence Units (FIUs)

Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing. Yes. The Act establishes the Financial Intelligence Unit as a national authority for AML/CFT purposes. (Money Laundering and Terrorist Financing Prevention Act (2017), § 53(1))
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing. Yes. The Financial Intelligence Unit receives, gathers, registers, processes and analyses information referring to money laundering and terrorist financing. (Money Laundering and Terrorist Financing Prevention Act (2017), § 54(1)(1))
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing. Yes. The Financial Intelligence Unit must forward materials to the competent authorities without delay when it identifies elements of a criminal offence. (Money Laundering and Terrorist Financing Prevention Act (2017), § 54(3))
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference. Yes. The Financial Intelligence Unit acts autonomously, performs its statutory tasks independently and makes decisions independently; its separate budget is also expressly provided. (Money Laundering and Terrorist Financing Prevention Act (2017), § 53(1), (3); Rahapesu Andmebüroo pőhimäärus (2023), § 1(1))
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information. Yes. The Financial Intelligence Unit may obtain information from supervisory authorities, other state and local authorities, obliged entities and third parties, including secrecy-protected and covertly collected data. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 58(1)–(3), 59)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction. Yes. The Financial Intelligence Unit may suspend a transaction or restrict disposal of property where there is a suspicion of money laundering or terrorist financing. (Money Laundering and Terrorist Financing Prevention Act (2017), § 57(1))

Mutual legal assistance (MLA) and International Cooperation

Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU. Yes. For requests from another EEA FIU, the Estonian FIU may obtain and forward additional information from obliged entities without delay and may use its ordinary information-gathering powers to respond. That substantively satisfies the requirement to use the full range of available domestic powers. (Money Laundering and Terrorist Financing Prevention Act (2017), §§ 54(1), 58–59, 63(2), 63(5^1))
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange. Yes. The Estonian FIU may exchange information spontaneously or on request, may send and receive any information another FIU may need for AML/CFT efforts and analysis, and may refuse only in exceptional cases. That substantively satisfies the information-sharing indicator. (Money Laundering and Terrorist Financing Prevention Act (2017), § 63(1)–(2), (5)–(7^1))

Legislation

Political Parties Act (1994, amended 2015)missing file:
Local Taxes Act (1994, amended in 2013)missing file:

*Last update: 2017

Asset Recovery

Quantitative Data

Primary Metric

201220152016201720202024Trend
Asset Offices100
Confiscation67
International cooperation75

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

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Country score

Asset Offices

Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters. Yes. Estonia has an Asset Recovery Bureau within the National Criminal Police (Police and Border Guard Board) acting as the national Asset Recovery Office for tracing criminal assets and cooperating with foreign AROs. (National designation of the Asset Recovery Bureau – National Criminal Police – Police and Border Guard Board under Council Decision 2007/845/JHA.)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order. Yes. Confiscated property is transferred to the state and its management, including sale and administration, is regulated by law, with the Ministry of Finance (Penal Code, §83(6) (confiscated property transferred to state); State Assets Act (Riigivara seadus),)

Confiscation

Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures) Yes. Estonian (Code of Criminal Procedure (Kriminaalmenetluse seadustik), §§ 142–143 (seizure of property and provisional measures).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation) Yes. The Penal Code (Penal Code, §83(1) (confiscation of assets acquired by an offence), §83ą(1) (confiscation of instrumentalities and direct object).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value) Yes. Where assets acquired by an offence or instrumentalities cannot be confiscated because they have been transferred, consumed, or otherwise made unavailable, (Penal Code, §84 (Substitution of confiscation).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation) Yes. Where assets acquired by an offence have been transferred to another person, (Penal Code, §83(1¹)–(1²) (assets partially acquired by an offence, including intermingled or exchanged property), applied together with §84.)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation) Yes. Extended confiscation allows the court, upon conviction, to confiscate part or all of the offender’s (Penal Code, §83˛ (Extended confiscation of assets acquired through criminal offence).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation) No. As of 31.12.2024, Estonian law did not yet contain a fully operational non‑conviction based confiscation regime; (Penal Code, §§ 83–84 (confiscation linked to conviction or criminal offences); no enacted NCB confiscation framework by 31.12.2024.)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation) No. Non‑conviction based confiscation was still being considered at legislative level and had not yet been implemented; (Penal Code, §§ 83–84 (no general NCB confiscation), legislative status as described for non‑conviction)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth) Yes. Extended confiscation allows confiscation of assets whose origin cannot be explained by lawful income where the nature of the offence and the discrepancy in wealth indicate that the assets derive from criminal activity, (Penal Code, §83²(1)–(3).)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027) No. No specific legal provision was identified in Estonian law establishing a national asset recovery strategy with a mandatory five‑year update cycle by 31.12.2024. (No explicit asset‑recovery strategy article in Penal Code, Code of Criminal Procedure or related asset‑recovery legislation by 31.12.2024.)

International cooperation

To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters. Yes. The Code of Criminal Procedure contains provisions on international cooperation for seizure and confiscation, (Code of Criminal Procedure, Chapter 19 (International cooperation in criminal proceedings),)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information Yes. Estonia’s Asset Recovery Bureau, as the national ARO, is mandated to exchange information with other EU AROs for tracing and identification of criminal assets under the EU ARO (Designation of the Asset Recovery Bureau – National Criminal Police – Police and Border Guard Board as ARO under Council Decision 2007/845/JHA.)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders. No. Estonian legislation on international cooperation and confiscation does not contain an explicit provision allowing cost‑sharing (No explicit cost‑sharing rule identified in Code of Criminal Procedure, Chapter 19.)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions Yes. Estonia may share confiscated assets with foreign states under applicable international conventions and national rules implementing asset‑sharing (Code of Criminal Procedure, provisions implementing the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (CETS No. 198), including asset‑sharing)

Legislation

Political Parties Act (1994, amended 2015)missing file:
Local Taxes Act (1994, amended in 2013)missing file:

*Last update: 2017