AMLR LEI Rules in Estonia: What Companies Need to Know

AMLR LEI rules in Estonia will require banks and other obliged entities to obtain a legal entity customer’s Legal Entity Identifier (LEI) where available from 10 July 2027. They will not require a company without an LEI to obtain one. Estonia’s current identification list differs from the forthcoming EU list, while AMLA’s supporting customer due diligence standards remain in draft.

What this means in Estonia

Estonian obliged entities currently identify a legal person under § 22(1) of the Money Laundering and Terrorist Financing Prevention Act (RahaPTS). The provision lists the business name or name; registry code or registration number and registration date; the names of management board members, or their equivalents, and their powers of representation; and contact details. An LEI is not on that list. The current requirements are set out in RahaPTS, published by Riigi Teataja.

RahaPTS § 22(2) also addresses how certain documents are obtained. If an obliged entity has online access to the commercial register, the non-profit or foundations register, or relevant foreign registers, it need not ask the customer to submit the documents listed in § 22(3). That rule concerns document submission; it does not add an LEI to the current identification list. Estonian companies are registered in the e-Business Register (e-äriregister), kept by RIK.

Supervision depends on the obliged entity. Under RahaPTS § 64, Rahapesu Andmebüroo supervises obliged entities unless otherwise provided; Finantsinspektsioon supervises the credit and financial institutions it supervises under the Financial Supervision Authority Act.

From 10 July 2027, the identification list in Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR), Article 22, will apply directly in Estonia. It includes the tax identification number and LEI where available. An OÜ opening an account with an Estonian bank can therefore expect its existing LEI to be relevant to customer identification, but the AMLR does not require the OÜ to obtain one.

AMLR LEI rules: key points

• The AMLR was published in the Official Journal on 19 June 2024. It is binding in its entirety and directly applicable in EU Member States; its identification rules do not need national transposition.
• For most obliged entities, the AMLR will apply from 10 July 2027. Article 22 refers to a legal entity customer’s LEI where available.
• AMLA’s report on draft customer due diligence standards is dated 30 September 2026. AMLA announced their submission to the Commission on 1 October 2026; the standards are not yet binding.
• A company with an LEI can prepare by locating its code and checking whether its identifier details need updating before a customer-information request.

Which customers and obliged entities are covered?

AMLR Article 2(1), point (27), defines a Legal Entity Identifier as a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity. Article 22(1), point (b), sets out the information an obliged entity obtains to identify a legal entity customer. This includes its legal form and name, registered or official office address, any different principal place of business, country of creation and the names of its legal representatives.

The same provision includes the registration number, tax identification number and LEI where available. It also addresses the names of nominee shareholders and directors and their nominee status. The distinction is between obtaining an identifier that exists and requiring a customer to acquire one: Article 22 says the former, not the latter.

Other categories can also involve an LEI. Article 22(1), point (c), refers to the tax identification number and LEI where available for trustees of express trusts or equivalent persons in similar arrangements. Point (d) includes an LEI where applicable for other organisations with legal capacity under national law. An entity uncertain about its category should check with its regulator or adviser.

Article 3 covers more than banks. Its obliged entities include credit institutions, financial institutions, auditors, external accountants, tax advisers, trust or company service providers and estate agents. Notaries, lawyers and other independent legal professionals are covered for certain transactions. An LEI request may consequently arise during a company’s periodic KYC update as well as when it opens an account.

What remains in AMLA’s draft standards?

The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) final report on draft regulatory technical standards under AMLR Article 28(1) is dated 30 September 2026. AMLA’s 1 October 2026 press release says the final draft was submitted to the European Commission. It remains subject to review and possible amendment, so its provisions should not be treated as binding requirements.

Draft Article 18 describes minimum information for low-risk situations. For a legal entity, the list includes its legal form and legal name, a different trade name where applicable, its registered or official office address and, where available, a registration number or tax identification number, or the LEI. Draft Annex I also maps the LEI, where available, to attributes for electronic identification means and qualified trust services.

Draft Article 28 proposes a risk-sensitive approach to bringing documents, data and information for existing business relationships into line with the standards. It refers to the periods in AMLR Article 26(2): no more than one year between customer-information updates for higher-risk customers and five years for all other customers. AMLA proposes that the standards apply six months after entering into force, once adopted and published in the Official Journal. That proposed interval does not mean they have been adopted.

How payment-message LEI rules differ

A separate rule is already applicable to information accompanying transfers of funds. Regulation (EU) 2023/1113, Article 4(1)(d) and 4(2)(c), applies from 30 December 2024. Under its stated conditions, the payer’s payment service provider must ensure a transfer carries the current LEI of the payer and payee, or an available equivalent official identifier if there is no LEI.

That requirement depends on the relevant field existing in the payment message format and on the payer providing the identifier to its payment service provider. It concerns transfer information, not the AMLR’s customer-identification list.

What to do before 10 July 2027

1. Find any existing LEI. An Estonian company that already has one can keep its code accessible for bank onboarding or a periodic KYC update.
2. Check whether its details need updating. If they do, consider renewing the LEI before providing it during a customer check.
3. Distinguish a request from a duty to obtain an LEI. The AMLR calls for collection where available. A company without one can consider applying for an LEI, but Article 22 does not require it to do so.
4. Resolve uncertain cases. Ask your regulator or adviser about the treatment of a particular entity, arrangement or transaction.

Timeline and legal status

Date	Event	Status on 17 October 2026
30 December 2024	Regulation (EU) 2023/1113 begins to apply to transfer information.	Applicable
30 September 2026	AMLA dates its final report on the draft customer due diligence standards.	Final draft, not binding
1 October 2026	AMLA announces submission of the final draft to the Commission.	Subject to review and possible amendment
10 July 2027	The AMLR begins to apply for most obliged entities, including Article 22’s LEI provision.	Future application date
10 July 2029	The AMLR begins to apply to football agents and professional football clubs.	Future application date

LEIs also feature in two related EU rules: a payer’s bank can offer Verification of Payee checks using an LEI as an alternative to checking the payee’s name, while under DORA banks and insurers identify ICT suppliers in their register of information using a valid LEI or EUID, as explained in our guide to DORA LEI requirements for ICT suppliers.

For subsequent developments, see the LEI regulation updates for Estonia. For now, check whether your entity has an LEI and keep its code available if it does.