Fund manager · Estonia

Small fund manager registration without activity licence (Estonia)

The Small fund manager registration without activity licence is issued by Finantsinspektsioon (FI) under Regulation (EU) 2020/1503 on European crowdfunding service providers for business (ECSPR). It is a national licence: it does not give a passport to other EU/EEA states. The official register lists 67 current holders. Ownership changes need the regulator's approval before completion.

Last verified 2026-09-24Regulator FIMarkdown · Data (CC BY 4.0)

At a glance

Official name	Small fund manager registration without activity licence¹
Also known as	Small fund manager registration · Estonian small AIFM registration · Sub-threshold AIFM Estonia · Registered fund manager Estonia
Issued by	Finantsinspektsioon
Jurisdiction	Estonia
Licence family	Fund manager
Legal basis	Regulation (EU) 2020/1503 on European crowdfunding service providers for business (ECSPR)²
Passporting	Domestic only
Public register	official register¹
Current holders	67¹

What it lets you do

Managing alternative investment funds	Performing portfolio management and risk management for funds that are not UCITS, such as hedge, private equity and real estate funds.

Where it is valid

Valid in Estonia.

Buying a company that already holds it

Prior approval required. Acquiring or increasing a qualifying holding reaching or crossing 10%, 20%, 30%, or 50% of share capital or voting rights in an Estonian bank, payment institution, EMI, investment firm, or CASP requires prior notification and approval from Finantsinspektsioon. Filings are submitted electronically through the FI Application Portal (or via the ECB SSM portal for credit institutions). The statutory assessment period is 60 working days from receipt of complete documentation, interruptible once by up to 20 or 30 working days to request additional information, evaluating acquirer reputation, financial solidity, and AML/CFT compliance.³

FM in other countries

Country	Licence	Regulator	Min. capital	Application fee	Statutory time
Abu Dhabi Global Market (ADGM)	Fund manager licenceFinancial Services Permission for Managing a Collective Investment Fund (Category 3C)	FSRA	n/a	n/a	n/a
Bermuda	Fund Administrator LicenceFund Administrator Licence (Part III, Investment Funds Act 2006)	BMA	n/a	n/a	n/a
British Virgin Islands	Fund manager licenceBVI mutual fund recognition (private/professional fund), registration (public fund) or approval (incubator/approved fund) - funds are recognised/registered/approved, not 'licensed'	BVI FSC	n/a	n/a	n/a
Cayman Islands	Regulated Mutual FundRegulated Mutual Fund (registered, master, or administered fund under the Mutual Funds Act)	CIMA	n/a	n/a	n/a
Cayman Islands	Registered Private FundRegistered Private Fund under the Private Funds Act	CIMA	n/a	n/a	n/a
Cyprus	Alternative Investment Fund Manager (AIFM) authorisation	CySEC	n/a	n/a	~3 mo
Cyprus	Sub-threshold Alternative Investment Fund Manager registration	CySEC	n/a	n/a	n/a
Cyprus	UCITS Management Company authorisation	CySEC	n/a	n/a	n/a
Czech Republic	Sub-threshold Alternative Investment Fund Manager registrationSub-threshold Alternative Investment Fund Manager registration pursuant to Section 15 of AMCIF	CNB	n/a	CZK 10,000	~1 mo
Czech Republic	Investment Company / Fund Manager licence	CNB	n/a	CZK 50,000	~6 mo
Dubai International Financial Centre (DIFC)	Fund manager licenceFinancial Services Permission for Managing a Collective Investment Fund (Category 3C)	DFSA	n/a	USD 10,000	n/a
Estonia	Small fund manager registration without activity licence	FI	n/a	n/a	n/a
Estonia	Operating licence as a fund management company	FI	n/a	EUR 600	n/a
France	Portfolio management company authorisation	AMF	n/a	n/a	~3 mo
Germany	Investment management company licence	BaFin	n/a	n/a	n/a
Ireland	Alternative Investment Fund Manager (AIFM) Authorisation/Registration	CBI	n/a	n/a	n/a
Ireland	UCITS Management Company Authorisation	CBI	n/a	n/a	n/a
Luxembourg	Alternative investment fund manager (AIFM) authorisation	CSSF	n/a	EUR 18,000	~3 mo
Luxembourg	Management company authorisedManagement company authorised under Chapter 15 of the Law of 17 December 2010	CSSF	n/a	EUR 18,000	~6 mo
Netherlands	Alternative Investment Fund Manager (AIFM) licenceAlternative Investment Fund Manager (AIFM) licence under Wft Article 2:65 and Directive 2011/61/EU	AFM	n/a	EUR 200	~6 mo
Netherlands	Fund manager licenceUndertakings for Collective Investment in Transferable Securities (UCITS / ICBE) registration under Wft and Directive 2009/65/EC	AFM	n/a	n/a	n/a
Poland	Investment Fund Company licence	KNF	n/a	n/a	n/a
Poland	Alternative Investment Company Manager registration / licence	KNF	n/a	n/a	n/a
Seychelles	Fund Administrator's LicenceFund Administrator's Licence (and Restricted Fund Administrator's Licence) under the Mutual Fund and Hedge Fund Act 2008	FSA	n/a	n/a	n/a
Spain	Fund manager licence (SGIIC)	CNMV	n/a	EUR 10,000	n/a
Switzerland	Fund management company licence	FINMA	n/a	n/a	n/a
Switzerland	Manager of collective assets licence	FINMA	n/a	n/a	n/a
United Kingdom	Fund manager licenceAlternative Investment Fund Manager (AIFM) Authorisation / Registration	FCA	n/a	n/a	n/a

Values come from each licence's page, where every figure has its source.

Laws behind it

European Crowdfunding Service Providers Regulation: Regulation (EU) 2020/1503

Last verified 2026-09-24Author Danil Marmysh, Founder & CEO, ProtegraReviewed by Anastasia Sidorenkova, Head of Licensing, ProtegraReport an errorReference information, not legal advice.

Sources

fi.ee: supervised entities · retrieved 2026-09-24
EUR-Lex: CELEX 32020R1503 · retrieved 2026-09-24
taotlus.fi.ee · retrieved 2026-09-24

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