Estonia

Country score (European Average*)

54(66) Political Financing
75(53) Financial Disclosure
42(37) Conflict of Interest
80(59) Freedom of Information
59(62) Public Procurement

Country Facts

Income	High
GNI per capita (2011 PPP $)	26978.00
Population, total	1316481.00
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 Index	4.8

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
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020
Bans and limits on private income	58	94	94	94	94
Public funding	38	38	38	38	38
Regulations on spending	25	0	0	0	0
Reporting, oversight and sanctions	83	83	83	83	83

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

Qualitative Data

Bans and limits on private income
Bans on donations from foreign interests
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))
Bans on corporate donations
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))
Bans on donations from trade unions
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))
Bans on anonymous donations
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))
Other bans on donations
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))
Donation limits
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
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	No. Absent from legal framework.
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	No. Absent from legal framework.
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	No. Absent from legal framework.
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
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
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
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?
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?	No. Absent from legal framework.
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
Reporting standards
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))
Political finance oversight
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
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	Trend
Disclosure items	81	75	75	76	76
Filing frequency	75	75	75	75	75
Sanctions	100	100	100	100	100
Monitoring and Oversight	100	69	69	100	100
Public access to declarations	50	25	25	25	25
Alternative Metric	2012	2015	2016	2017	2020	Trend
Head of State	81	70	70	76	76
Ministers	81	70	70	75	75
Members of Parliament	81	70	70	75	75
Civil servants	81	65	65	75	75

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

Qualitative Data

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.
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.
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 2020))
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 (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. (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.
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.
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 2020))
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.
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 2020))
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.
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.
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 2020))
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
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	Trend
Restrictions	43	55	57	55	43
Sanctions	33	0	0	0	33
Monitoring and Oversight	50	0	0	0	50
Alternative Metric	2012	2015	2016	2017	2020	Trend
Head of State	38	13	13	13	38
Ministers	41	17	17	17	41
Members of Parliament	41	17	17	17	41
Civil servants	48	27	30	27	48

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

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	Yes. General (Article 26 of the Anti-Corruption Act (1999))
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. There is Noexplicit provision restricting the Head of State from participating in government contracts as a private individual. However, According to Article 24 of the Anti-Corruption Act (1999), the Head of State may not engage in self-dealing or transactions involving conflict of interest which includes any transaction in an official capacity that would significantly influence the economic interests of the official. (Article 24 of the Anti-Corruption Act (1999))
Board member, advisor, or company officer of private firm	No. Absent from legal framework. (General)
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	Yes. General (Article 84 of the Constitution (1992))
Participating in official decision-making processes that affect private interests	Yes. The Head of State must disclose any conflct of interest before making decisions. (Article 25 of the Anti-Corruption Act (1999))
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. The Head of State is subject to a fine in amount of up to 300 fine units for violation of conflict of interest restrictions. A fine in the amount equal to 50-100 days of wages is imposed for violation of restrictions on employment and activities. (Article 26/3 of the Anti-Corruption Act (1999) Article 158/1 of the Code of Administrative Offences (1992))
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	Yes. The enforcement body is the depository of declarations. The depository for the Head of State is a special committee appointed by the Riigikogu (Parliament). (Article 12/3 of the Anti-Corruption Act (1999))
Ministers
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	Yes. General (Article 26 of the Anti-Corruption Act (1999))
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	Yes. General (Article 99 of the Constitution (1992) Article 4(3) of the Government of the Republic Act (1995))
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	Yes. Ministers may not hold a policy-making position and a policy-executing position simultaneously. However, According to Article 4(1) of the Government of the Republic Act (1995), the President may appoint one minister to head two ministries at the same time. (Article 99 of the Constitution (1992) Articles 4(1), 4(2) and 4(3) of the Government of the Republic Act (1995))
Participating in official decision-making processes that affect private interests	Yes. Ministers must disclose any conflct of interest before making decisions. The Minister is then required to recuse him/herself from making the decision. For these purposes, decisions do not mean legislation of general application. (Article 25 of the Anti-Corruption Act (1999))
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Ministers are subject to a fine in amount of up to 300 fine units for violation of conflict of interest restrictions. (Article 26/3 of the Anti-Corruption Act (1999))
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	Yes. The enforcement body is the depository of declarations. The depository for the Head of State is a special committee appointed by the Riigikogu (Parliament). (Article 12/3 of the Anti-Corruption Act (1999))
Members of Parliament
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	Yes. General (Article 26 of the Anti-Corruption Act (1999))
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	Yes. MPs may not serve on boards of private firms. Moreover, an MP may not be a member of the board of the Central Bank of Estonia or a member of the board of a partially or wholly state-owned company. (Article 26(1) and 26(3) of the Status of Member of Riigikogu Act (2007))
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	Yes. General (Articles 63 & 64 of the Constitution (1992) Articles 22 & 24 of the Status of Member of Riigikogu Act (2007))
Participating in official decision-making processes that affect private interests	Yes. MPs must disclose any conflct of interest before making decisions. The MP is then required to recuse him/herself from making the decision. For these purposes, decisions do not mean legislation of general application. (Article 25 of the Anti-Corruption Act (1999))
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. MPs are subject to a fine in amount of up to 300 fine units for violation of conflict of interest restrictions. (Article 26/3 of the Anti-Corruption Act (1999))
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	Yes. The enforcement body is the depository of declarations. The depository for the Head of State is a special committee appointed by the Riigikogu (Parliament). (Article 12/3 of the Anti-Corruption Act (1999))
Civil servants
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	Yes. General (Article 26 of the Anti-Corruption Act (1999))
Private firm ownership and/or stock holdings	Yes. Civil servants may own private firms and/or stock holdings with permission of their supervisors and under condition that such activity does not interfere with their duties and damage the reputation of the agency. Moreover, Article 72(2) of the Public Service Act (1995) prohibits a civil servant from exercising supervision over his/her own enterprise in performing his/her functions. (Article 26 of the Anti Corruption Act (1999) Articles 72(1) & 72(2) of the Public Service Act (1995))
Ownership of state-owned enterprises (SOEs)	No. Civil servants may own private firms and/or stock holdings with permission of their supervisors and under condition that such activity does not interfere with their duties and damage the reputation of the agency. (Article 26 of the Anti Corruption Act (1999) Articles 72(1) & 72(2) of the Public Service Act (1995))
Holding government contracts	Yes. Civil servants may not conclude transactions with the state through his/her agency. (Article 24 of the Anti Corruption Act (1999) Articles 76(1) of the Public Service Act (1995))
Board member, advisor, or company officer of private firm	Yes. A civil servant may not be a member of a supervisory or management board of a company, unless it is in the capacity of state representative. (Article 19(2)(2) of the Anti Corruption Act (1999) Articles 69(1) and 69(2) of the Public Service Act (1995))
Post-employment	Yes. For a period of three years, a former civil servant may not be employed by the employer, or join the commercial association, over which he/she exercised control in his/her former capacity. (Articles 74 of the Public Service Act (1995))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	Yes. Civil servants must disclose any conflct of interest before making decisions. The civil servant is then required to recuse him/herself from making the decision. For these purposes, decisions do not mean legislation of general application. (Article 25 of the Anti-Corruption Act (1999))
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Civil servants are subject to a fine in amount of up to 300 fine units for violation of conflict of interest restrictions. (Article 26/3 of the Anti-Corruption Act (1999))
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	Yes. The enforcement body is the depository of declarations. The depository for the Head of State is a special committee appointed by the Riigikogu (Parliament). (Article 12/3 of the Anti-Corruption Act (1999))

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
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020
Scope and Coverage	100	100	100	100	100
Information access and release	100	100	100	100	100
Exceptions and Overrides	83	83	83	83	83
Sanctions for non-compliance	33	33	33	33	33
Monitoring and Oversight	83	83	83	83	83

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

Qualitative Data

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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019 )
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 2019 )
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 2019 )
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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 2019)
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, 2007, amended 2020)
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 2019)
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 2019 )
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 2019)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	No. Absent from legal framework. (General)
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 2019)
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	No. Absent from legal framework. (General)
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 2019)
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework. (General)
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 2019)
Public body that is responsible for applying sanctions	Yes. Data Protection Inspectorate (Articles 53 and 54 of the Public Information Act, 2000, amended 2019)
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 2019)
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
Qualitative Data
Laws

Quantitative Data

Primary Metric	2015	2016	2017	2020
Scope	87	86	89	88
Information availability	21	21	21	46
Evaluation	81	81	81	75
Open competition	81	81	81	56
Institutional arrangements	36	36	36	29

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

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS)	EUR 30000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 1)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	EUR 60000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 2)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	EUR 30000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 1)
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	EUR 30000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 1)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	EUR 60000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, §§ 14 (1) 2, 15, 16, 131, 132 and 133)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	EUR 60000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 2, 134 and 168)
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	EUR 30000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 1)
What are the minimum application thresholds for the procurement type? (Product type WORKS)	EUR 60000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 2)
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	EUR 30000. Applicable thresholds for the simple procurement procedure: EUR 30,000 for the supply of goods and services; EUR 60,000 for public works, concession contracts, and for the supply of goods and services in the field of defence and security; EUR 300,000 for public works in the field of defence and security. Thresholds for public procurement procedure (not simple) are set in accordance with EU Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU: EUR 60,000 for the supply of goods and services and EUR 150,000 for public works. International thresholds are established periodically by the European Commission. (Public Procurement Act of 2017, as amended in 2020, § 14 (1) 1)
Information availability
Publishing and record keeping
Is there a requirement that tender documents must be published in full?	Yes. The contracting authority or entity draws up procurement documents in accordance with the requirements provided for in the Procurement Act in a form reproducible in writing and makes them electronically available to economic operators free of charge and without restrictions from the start of the procurement procedure. However, the contracting authority or entity may establish in the contract notice requirements or measures and restrict access to confidential information by economic operators who do not comply with the requirements or measures. In such an event the contracting authority or entity does not have to make the procurement documents electronically available. (Public Procurement Act of 2017, as amended in 2020, § 77 (1) (3) (4))
Are any of these documents published online at a central place?	Yes. The register is a database established for processing public procurement data and beneficiary purchase data and the purpose of which is to: 1) ensure the publication of public procurement notices and beneficiary purchase notices, and the communication of public procurement notices to the Publications Office of the European Union; 2) indicate the results of review proceedings; 3) enable the electronic processing of public procurements and beneficiary purchases; 4) ensure the gathering of public procurement statistics; 5) publish other relevant public procurement information. The following data are entered in the register and publicly available, unless access has been legally retricted: 1) details on public procurement notices and beneficiary purchase notices; 2) details on the results of review proceedings; 3) details on public procurement procedures and beneficiary purchase procedures; 4) electronic documents on the details specified in clauses 1 and 2 of this subsection; 5) other data and electronic documents provided for in the Public Procurement Act and in legislation governing beneficiary purchases. Available at: https://riigihanked.riik.ee/rhr-web/#/ (Public Procurement Act of 2017, as amended in 2020, § 181 (1) (2) (4))
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. Public procurement data, beneficiary purchase data and review procedure results data and digital public procurement documents that do not contain data on natural persons related to an economic operator participating in a public procurement and in a beneficiary purchase procedure, including data on the education, professional qualifications, experience, convictions for an offence, tax arrears and other similar are retained in the register for an unspecified period. (Public Procurement Act of 2017, as amended in 2020, § 181 (5˛))
Are contracts awarded within a framework agreement published (ie mini contracts)?	Yes. They are, but only anually and/or after termination of the mini-contract. The contracting authority submits to the register details on the time of awarding and value of public contracts awarded on the basis of the framework agreement over a period of 12 months within 30 days after the passing of each 12-month period from the awarding of the framework agreement. Within 30 days after the termination of a public contract, the contracting authority submits to the register the following information: 1) the actual value of the public contract; 2) amendments made to the public contract regarding which no public contract modification notice was given; 3) breaches of the public contract by the economic operator, as a result of which a legal remedy specified in clause 8 of subsection 4 of § 95 of the Procurement Act has been applied, and information on whether the contracting authority’s claim has been contested. The contracting authority submits this information within 30 days after the termination of the framework agreement or termination of the last public contract awarded on the basis of the framework agreement, provided that the public contract terminates later than the framework agreement. The contracting authority may also submit to each bidder party to the framework agreement a notice regarding the decision on the mini contract, indicating the name(s) of the selected bidder(s) and, in the notice given to a bidder who was not selected, also the details characterising the selected tender and its advantages over the tender of the recipient of the notice. A caveat: at the request of the European Commission, the contracting authority draws up and submits in writing via the Ministry of Finance a report on each procurement procedure and dynamic purchasing system whose estimated value equals or exceeds the international threshold. This report is not, however, drawn up regarding public contracts awarded on the basis of the framework agreement or where the information requested in the report is contained in the public contract award notice. (Public Procurement Act of 2017, as amended in 2020, §§ 30 (11), 83 (3) (7) (8) and 84)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	No. There is no general duty to publish information on subcontractors in all contracts covered by the Public Procurement Act of 2017. Unless otherwise provided for by the Act or where the relevant information has not been published in the contract notice, the procurement documents must contain the information specified in § 122 of the Act on subcontractors. (Public Procurement Act of 2017, as amended in 2020, §§ 77 (4) 6, 84 (1) 6 and 122)
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.	0�%.
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. Technical specifications do not refer to a specific source, process, trade mark, patent, type, origin or type of production with the effect of favouring or eliminating certain undertakings or certain products. Such reference is permitted, on an exceptional basis, where a sufficiently precise and intelligible description of the subject-matter of the public contract in accordance with subsections 1 and 2 of this section is not possible. Such reference is accompanied by the words ‘or equivalent.’ Technical specifications must ensure that the conditions for the submission of a tender are equal for all tenderers and must not have the effect of creating unjustified obstacles to the opening up of public procurement to competition. (Public Procurement Act of 2017, as amended in 2020, §§ 87 and 88 (6) (7))
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No.
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	No. Upon carrying out public procurement, the contracting authority or the contracting entity must treat all persons whose place of residence or seat is in Estonia, in another Member State of the EU, in another contracting state of the EEA or in a country that has joined the Government Procurement Agreement of the World Trade Organization equally and the contracting authority or the contracting entity makes certain that all restrictions and criteria imposed on the persons are proportional, relevant and reasoned in relation to the purpose of the public procurement. (Public Procurement Act of 2017, as amended in 2020, § 3 (2))
Is there a specific set of rules for green/sustainable procurement?	Yes. Social considerations, implementation of innovation and environmentally friendly solutions are taken into account upon planning and carrying out public procurement. Where the subject-matter of the public contract is a road vehicle, the procurement documents must contain terms and conditions that take into account the energy and environmental impact over the entire service life of the vehicle. Where ecofriendliness criteria have been set to the furniture, cleaning products and services, office equipment or copy and drawing paper which constitutes the subject matter of the public contract, the procurement documents must contain terms and conditions that take into account the energy and environmental impact throughout the service life. Moreover, upon identifying the most economically advantageous tender, the contracting authority takes into account the best price-quality ratio that includes qualitative, environmental or social criteria, the tender price or cost, including costs that are likely to be incurred upon performance of the public contract and the costs of the life cycle. The contracting authority may determine the price or cost of the public contract in the procurement documents and assess tenders solely based on qualitative, environmental or social criteria. Importantly, the method used for the assessment of costs imputed to environmental externalities must be publicly available and be based on verifiable and non-discriminatory criteria that do not restrict competition. The data and documents required for determining the costs can be provided with reasonable effort by normally diligent tenderer. Environmental protection requirements may also be included in technical specifications and a breach of environmental duties constitutes grounds for bidder exclusion. What is more, the contracting authority may request in a contract notice the submission of the list of environmental management measures applied. In that case, the contracting authority will refer to the EU Eco Management and Audit Scheme (EMAS) or to the EU legislation based on the relevant European or international standards regulating certification or to the environmental management standards based on the relevant European or international standards certified by the relevant authorities. (Public Procurement Act of 2017, as amended in 2020, §§ 3 (2), 77 (4) 4. 6. 6ą. 7ą., 85 (3) (7) (8), 86, 87 (2) 1. (4) 1., 95 (1) 4. (4) 2., 101 (1) 7. (6) (7), 115 (9), 117 (4), 139 (2) and 140 (1))
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. The contracting authority or entity does not award a public contract to a tenderer or a candidate and excludes from the procurement procedure a tenderer or a candidate: 1) who or whose member of an administrative, management or supervisory board or another legal or contractual representative involved in the public procurement has been convicted by final judgment for participating a criminal group, violating the duty of integrity, corrupt practice, fraud, terrorist act, other criminal offence linked to terrorist activities or inciting or aiding or abetting or attempting to commit an offence, money laundering offence, or terrorist financing; 2) who or whose member of an administrative, management or supervisory board or another legal or contractual representative involved in the public procurement has been convicted by final judgment for enabling an illegal alien to work or for enabling a breach of the criteria applicable to the work performed by an alien in Estonia, including for payment of a salary below the statutory rate; 3) who or whose member of an administrative, management or supervisory board or another legal or contractual representative involved in the public procurement has been convicted by final judgment for illegal use of child labour or another form of trafficking in human beings; 4) who has tax arrears within the meaning of the Taxation Act regarding state taxes, contributions or environmental charges or tax arrears or overdue social security contributions under the legislation of the country where the tenderer or candidate is established; 5) who or whose member of an administrative, management or supervisory board is a subject of an international sanction within the meaning of the International Sanctions Act. Where overriding requirements in the general interest make a public contract award indispensable and no public contract would be awarded upon exclusion of the tenderer or candidate, the contracting authority may not apply these grounds for tenderer exclusion. Furthermore, the contracting authority may exclude from the procurement procedure a tenderer or candidate: 1) who has arrears of a tax of the location of the contracting authority within the meaning of the Taxation Act; 2) who has breached environmental, social or labour law duties arising from law or from a collective agreement; 3) who is bankrupt or in liquidation, against whom bankruptcy or liquidation proceedings have been initiated, whose business activities have been suspended or who is in another similar situation under the legislation of the country where the tenderer or candidate is established; 4) who has engaged in grave professional misconduct which renders its integrity questionable; 5) due to an agreement distorting competition, a decision of an association of economic operators or concerted action; 6) where a conflict of interests cannot be avoided by any other means; 7) whose tender or request to participate has been drawn up with the involvement of a person who has participated in preparing the same public procurement or who is otherwise related to the contracting authority and information known to the person gives them an advantage over other participants and the distortion of competition arising therefrom cannot be avoided by other means; 8) who has been in a fundamental or constant breach of a prior public contract or public contracts in such a manner that the breach has resulted in withdrawal from or termination of the contract, a reduction of the price, compensation for damage or payment of a contractual penalty; 9) who has given false information on meeting the applicable selection criteria or failed to submit the information or the additional documents requested by the contracting authority; 10) who intentionally influences the contracting authority or negligently submits misleading information that may unduly influence its decisions in the public procurement or acts with the aim of obtaining confidential information that may give them an advantage over other participants; 11) who or whose member of an administrative, management or supervisory board or another legal representative has been convicted by final judgment for tax offences; 12) who does not have the right to submit a tender or request to participate based on the Procurement Act. (Public Procurement Act of 2017, as amended in 2020, § 95)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	Yes. Where the contracting authority finds that the value of a tender is, given the subject-matter of the public contract, unreasonably low, it must ask the bidder, in writing, for relevant clarifications. The tenderer must submit a written explanation within five working days of receipt of the respective request. Where the contracting authority still finds that the value of the tender is abnormally low or where the tenderer submits no required clarifications to the contracting authority or entity, the contracting authority or entity rejects the tender on the basis of a reasoned written decision. Grounds for rejection of tender: 1. the abnormally low value is caused by disregarding provisions governing the fields of environmental, social and labour law in the place of performance of the public contract; 2. the value of a tender is abnormally low because the tenderer has obtained state aid, and has failed to prove within a reasonable time limit that the state aid was legally granted. The contracting authority may also make a reasoned written decision to reject all tenders where: 1) the values of all of the tenders or tenders which have been declared suitable exceed the estimated value of the public contract, or 2) the contracting authority has provided for the possibility of rejection of all tenders on objective and non-discriminatory grounds in the procurement documents and such grounds exist. (Public Procurement Act of 2017, as amended in 2020, §§ 115 and 116)
Is scoring criteria published?	Yes. Unless otherwise provided for in Public Procurement Act or where the relevant information has not been published in the contract notice, the procurement documents must contain the award criteria in accordance with §§ 85–86 of the Act. (Public Procurement Act of 2017, as amended in 2020, §§ 77 (4) 2 and 85 (9))
Are decisions always made by a committee?	No. The Public Procurement Act stipulates such a procedure only for design contests. In case of a design contest, there is a jury appointed by the contracting authority which evaluates the submitted conceptual designs. This jury is composed of natural persons independent of the participants. Where a particular professional qualification is required of participants in a contest, at least a third of the jury members must have at least an equivalent qualification. (Public Procurement Act of 2017, as amended in 2020, § 130)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. The contracting authority must avoid a conflict of interests distorting the competition. According to the Procurement Act, ‘conflict of interest’ means a situation where the contracting authority’s employee, official, management board member or another competent representative involved in the preparation or carrying out of public procurement or who may otherwise influence the outcome of the public procurement has, directly or indirectly, a financial, economic or other personal interest which might be perceived to compromise their impartiality and independence. The contracting authority that does not have the obligation to establish procurement rules establishes measures for the prevention, identification and remedying of a conflict of interest in an internal document on work organisation or, where the contracting authority does establish procurement rules, in the procurement rules. (Public Procurement Act of 2017, as amended in 2020, §§ 3 (4), 4 (8) and 9 (4) 6. (5))
Is some part of evaluation committee mandatorily independent of contracting authority?	No.
Are scoring results publicly available?	No. The only results made publicly available are those of design contests. Within 30 days after announcing the winner of the design contest, the contracting authority or entity submits the results to the register. Where the release of information on the outcome of the contest would impede law enforcement, would be contrary to general interests or would prejudice the legitimate commercial interests of a particular economic operator or might prejudice fair competition between service providers, such information may be withheld from publication. (Public Procurement Act of 2017, as amended in 2020, §§ 45 (3) 6 and 129 (7))
Does the law specify under which conditions the tender can be cancelled?	Yes. The procurement procedure terminates upon: 1) rejection of all tenders for the reason that no tender was found to be in conformity with the procurement documents or that the value of all of the tenders was abnormally low; 2) rejection of all tenders on the grounds provided for in § 116 of the Procurement Act; 3) exclusion of all tenderers or candidates from the procurement procedure or upon not qualifying any of the tenderers or candidates; 4) failure to submit tenders or requests to participate within the time limit established; 5) upon declaring the procurement procedure invalid by a decision of the contracting authority or entity on the basis of a precept made in supervisory proceedings carried out by the Ministry of Finance or, where there is a justifiable need, on its own initiative; 6) expiry of the period of validity of all tenders, unless any tenderer agrees to extend the period of validity of the tender. (Public Procurement Act of 2017, as amended in 2020, § 73 (3))
Open competition
CFT publication
Does the law specify the location for publicizing open 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 in 2020, §§ 45 (3), 73 (1), 181 and 183)
Does the law specify the location for publicizing restricted 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 in 2020, §§ 45 (3), 73 (1), 181 and 183)
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 in 2020, §§ 45 (3), 73 (1), 181 and 183)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	5. (Public Procurement Act of 2017, as amended in 2020, § 54 (3))
What is the minimum number of bidders for negotiated procedures?	3. (Public Procurement Act of 2017, as amended in 2020, § 68 (3))
What is the minimum number of bidders for competitive dialogue procedures?	3. (Public Procurement Act of 2017, as amended in 2020, § 64 (3))
Bidding period length
What are the minimum number of days for open procedures?	General. In an open procedure, the time limit for the submission of tenders must not be shorter than: 1) 15 days from the submission of the contract notice to the register, except in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold and the entire communication and the entire exchange of information in the procurement procedure takes place via electronic means; 2) 20 days from the submission of the contract notice to the register, except in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold and the entire communication and the entire exchange of information in the procurement procedure does not take place via electronic means; 3) 25 days from the submission of the contract notice to the register in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold; 4) 30 days from the submission of the contract notice to the register, except in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information in the procurement procedure takes place via electronic means; 5) 35 days from the submission of the contract notice to the register, except in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information in the procurement procedure does not take place via electronic means; 6) 45 days from the submission of the contract notice to the register in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold. (Public Procurement Act of 2017, as amended in 2020, § 93 (1))
What are the minimum number of days for restricted procedures?	General. In a restricted procedure, competitive procedure with negotiation, innovation partnership and competitive dialogue, the time limit for submission of tenders must not be shorter than: 1) 15 days from the submission of the contract notice to the register, except in the case of a public works contract, where the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold; 2) 25 days from the submission of the contract notice to the register in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold; 3) 25 days from the submission of the invitation to tender where the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information takes place via electronic means; 4) 30 days from the submission of the invitation to tender where the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information does not take place via electronic means. (Public Procurement Act of 2017, as amended in 2020, § 94 (3))
What are the minimum number of days for competitive negotiated procedures?	General. In a restricted procedure, competitive procedure with negotiation, innovation partnership and competitive dialogue, the time limit for submission of tenders must not be shorter than: 1) 15 days from the submission of the contract notice to the register, except in the case of a public works contract, where the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold; 2) 25 days from the submission of the contract notice to the register in the case of a public works contract whereby the estimated value of the public procurement equals or exceeds the public procurement threshold, but is below the international threshold; 3) 25 days from the submission of the invitation to tender where the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information takes place via electronic means; 4) 30 days from the submission of the invitation to tender where the estimated value of the public procurement equals or exceeds the international threshold and the entire communication and exchange of information does not take place via electronic means. (Public Procurement Act of 2017, as amended in 2020, § 94 (3))
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. The contracting authority or entity is not required to apply the rules provided for in this Act where: 1) the main purpose of awarding a public contract or organising a design contest is to provide or exploit public communications networks or to provide to the public an electronic communications service; 2) a public contract is awarded or a design contest organised in accordance with the rules provided for in an international agreement between Estonia and one or more third countries and the signatories use the subject-matter of the public contract jointly or for their joint project; 3) a public contract is awarded or a design contest is organised in accordance with an obligatory special procedure of an international organisation; 4) a public contract is awarded on the basis of an international agreement relating to the stationing of troops; 5) a public contract is awarded or a design contest is organised in accordance with an obligatory special procedure of an international organisation and the contract is fully financed by that organisation; 6) a public contract or a design contest is co-financed for the most part by an international organisation or international financing institution and the parties have agreed on applicable procurement procedures; 7) a public contract is awarded for the acquisition or use, regardless of the contract type, of an immovable, existing buildings or related rights; 8) the contracting authority or entity is a media service provider who awards a public service contract or a concession contract for the acquisition, development, production or co-production of programme materials or a part thereof; 9) a public contract related to buying broadcasting time or a programme is awarded to a media service provider; 10) arbitration or conciliation services are bought; 11) legal services are to be provided; 12) a financial service in connection with the issue, purchase, sale or transfer of securities or other financial instruments or services provided by Eesti Pank are bought or operations are conducted with the European Financial Stability Facility and the ESM; 13) a loan contract is concluded; 14) an employment contract is concluded; 15) a public contract is awarded to a non-profit organisation or a non-profit association for the purpose of buying civil defence, civil protection and danger prevention services as per EU Directives; 16) a public contract for public passenger transport services by rail or metro is awarded; 17) a public contract is awarded by a political party in the context of an election campaign for buying political campaign services covered by certain CPV codes; 18) a service is bought from a contracting authority or an association of contracting authorities whom the exclusive right to provide the service in the respective territory has been granted based on a legal act that is in accordance with the requirements of the TFEU; 19) certain research and development servicesare bought, unless the benefits accrue exclusively to the contracting authority or entity for its use in the conduct of its own affairs and the service provided is wholly remunerated by the contracting authority; 20) a public contract is connected with a state secret or classified information of a foreign state for the purposes of the State Secrets and Classified Information of Foreign States Act; 21) the contracting authority or entity makes an agreement with a central purchasing body for the provision of centralised or ancillary purchasing activities or an agreement specified in subsection 1 of § 43 of the Procurement Act. Moreover, the contracting authority is not required to apply the rules provided for in the Procurement Act to in-house transactions. The contracting authority is not required to follow the rules provided for in this Act where the contracting authority awards a public contract to another contracting authority or to other contracting authorities and all of the following conditions are fulfilled: 1) the public contract establishes the bases of cooperation between the participating contracting authorities or the terms of implementation thereof with the aim of ensuring that public services they have to perform are provided with a view to achieving objectives they have in common; 2) the implementation of that cooperation is governed solely by considerations relating to public interests; 3) the participating contracting authorities perform on the open market less than 20 per cent of the activities concerned by the public contract. (Public Procurement Act of 2017, as amended in 2020, §§ 11 and 12 (1) (7))
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 in 2020, § 5 (2))
Does the law specify the main procedure types or procurement methods permitted?	Yes. Open procedure, restricted procedure, innovations partnership, competitive dialogue, competitive procedure with negotiation, negotiated procedure without prior publication, or simplified procurement procedures. (Public Procurement Act of 2017, as amended in 2020, §§ 48-72 and 125)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. The Public Procurement Review Committee (Public Procurement Act of 2017, as amended in 2020, §§185 and 187)
Is there a procurement regulatory body dedicated to public procurement?	No. The Ministry of Finance ("the Ministry") exercises state supervision and administrative supervision only in public interests over compliance with the Procurement Act and legislation established on the basis thereof. The Ministry acts pursuant to law and is independent upon exercising supervision. In supervisory proceedings, the lawfulness of the actions of the contracting authority or entity is verified. Supervisory proceedings are not carried out for the purpose of verifying the practicality of the actions of the contracting authority or entity or assessment of the effectiveness of its decisions and steps. However, it is still the Ministry and not a separate regulatory entity. (Public Procurement Act of 2017, as amended in 2020, § 203)
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)?	No. The only relevant provision on this matter is that in case of design contests, at least one-third of the members of the jury shall have the particular professional qualification that is required from participants of the contest or an equivalent qualification. (Public Procurement Act of 2017, as amended in 2020, § 130 (3))
Is disclosure of final, beneficial owners required for placing a bid?	No. While the Public Procurement Act does not require beneficial ownership disclosure from bidders, the Money Laundering and Terrorist Financing Prevention Act of 2017 (RT I, 17.11.2017, 2) defines the concept of beneficial owner, stipulates what are the "obliged entities'" and their corresponding due diligence measures, and imposes a duty on them to keep data on beneficial owners. More importantly, the Money Laundering Act establishes legal entities' obligation to submit, via the commercial register information system, specific data on beneficial owners. Data is publicly available in the commercial register: https://www.rik.ee/en/e-business-register.
Complaints
Is there a fee for arbitration procedure?	Yes. Upon filing a request for review and a request for compensation of damage with the Review Committee, a state fee is paid in accordance with § 258 of the State Fees Act. Accordingly, a state fee in the following amounts shall be paid upon the submission of a public procurement appeal: 1) EUR 640 if the estimated value of a public procurement is below the international threshold; 2) EUR 1280 if the estimated value of a public procurement equals or exceeds the international threshold. Joint tenderers and joint candidates shall pay the state fee at the rate of state fee specified 1). A state fee upon the submission of an application for compensation of loss shall be paid according to the rate provided in subsection 60 (2) of the State Fees Act, i.e. 3% of the amount the payment of which is applied for, but no less than EUR 15 and no more than EUR 750. (Public Procurement Act of 2017, as amended in 2020, §186 State Fees Act of 2014, as amended in 2020, § 60 (2) and 258)
Is there a ban on contract signature until arbitration court decision (first instance court)?	No. However, the Review Committee may make a decision on the suspension of the procurement procedure, design contest or award of a public works concession at any stage of the review proceedings on the basis of a founded request, taking into account the potential consequences arising from the suspension to all interests that might be harmed. The Review Committee makes a decision within 3 working days following the receipt of a request to suspend the procurement procedure that does not have any deficiencies. Where the request has been returned to the requester for the purpose of elimination of deficiencies, the Committee hears a request to suspend public procurement and make a decision within 3 working days as of the receipt of a request for review that does not have any deficiencies. (Public Procurement Act of 2017, as amended in 2020, § 193)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	General. The Review Committee makes a decision on the substantive adjudication of a request for review within 30 days after the receipt of the request that does not have any deficiencies. Where the Review Committee has involved an expert in the hearing of a request for review, asked the Court of Justice for a preliminary ruling or notified the Ministry of Finance (but the Ministry of Finance does not commence supervisory proceedings or terminate them without making a precept to declare the public procurement invalid) and, therefore, it is not possible to make a decision within 30 days, the Committee announces a decision that substantively adjudicates the case within 10 working days following the receipt of the expert opinion, preliminary ruling or notice of the non-commencement or termination of the supervisory proceedings of the Ministry of Finance. (Public Procurement Act of 2017, as amended in 2020, § 200 (1) (2))
Is there a requirement to publicly release arbitration court decisions?	Yes. The Public Procurement Register makes the information about the results of review proceedings available to the public. (Public Procurement Act of 2017, as amended in 2020, § 181 (1) 2, (2) 2)

Legislation

Money Laundering and Terrorist Financing Prevention Act of 2017, RT I, 17.11.2017, 2 (Estonian)	pdf
Public Procurement Act of 2017, RT I, 01.07.2017, 1 (Estonian)	pdf
State Fees Act of 2014, RT I, 30.12.2014, 1 (Estonian)	pdf

*Last update: 2017

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