Email survey – Competent Authorities supervising or overseeing ADR bodies in the financial sector ADR bodies
Thank you for contributing to this study. This questionnaire aims to gather information on the supervision, operation and performance of alternative dispute resolution (ADR) bodies in the financial sector in your Member State. Unless otherwise indicated, please provide information covering all ADR bodies in the financial sector that fall within your authority’s remit, aggregated at national level. Please tick the relevant boxes for multiple-choice questions and provide brief explanations where requested. Where available, please include references to relevant legislation, public reports or websites. If data are unavailable, please indicate this clearly. 
1. General information and ADR Coverage
1) Member State: Estonia
2) Name of competent authority: Ministry of Economic Affairs and Communications
3) Number of ADR bodies in the financial sector currently supervised or overseen by your authority: 3
4) Which financial sectors are covered by these ADR bodies? (Tick all that apply.) 
☒Banking/deposits 
☒Insurance 
☒Investment /securities
☒Payment services /e-money
☒Consumer credit 
☒Mortgages 
☒Pensions
☐Other (please specify): __________________________________________________________ 

5) To ensure that we interpret the information provided consistently across Member States, please provide the definitions you use for the following terms:
a) ADR body: An entity established on a permanent basis that offers out-of-court dispute resolution procedures between consumers and traders and meets the requirements set out in Directive 2013/11/EU
b) Complaint received: A complaint submitted by a consumer to an ADR body
c) Admissible case: A dispute that has been accepted for consideration by an ADR body after verifying that it falls within the scope of its competence
d) Closed case: A case for which the ADR procedure has been completed. This includes cases resolved through an agreement between the parties, as well as cases closed by an ADR body for other reasons (e.g. withdrawal, inadmissibility or a decision issued).
e) Cross-border dispute: A dispute where the consumer resides in a Member State other than the Member State of establishment of the trader.
f) Decision/outcome: The result of an ADR procedure.

6) Are there any gaps in ADR coverage in the financial sector in your Member State (for example, particular sectors, products, types of dispute, or geographic areas not covered)?
x

If yes, please describe: _______________________________________________________

2. Supervisory framework 
7) Which of the following activities are part of your authority’s role in relation to ADR bodies? (Tick all that apply.) 
☒Authorisation, approval or designation of ADR bodies
☒ Ongoing monitoring, supervision or oversight
☐ Audits, inspections or file reviews
☐ Assessment of performance indicators (KPIs) 
☒Handling complaints about ADR bodies
☒Enforcement or corrective measures
☐Other (please specify): __________________________________________________________ 

8) Does your authority require ADR bodies to submit regular reports or data?
x



If yes, please indicate what is reported, how often, and in what format: annually on their website

9) Are ADR bodies required to publish information on their activities and performance (for example, through annual reports, websites or statistics)?
x


If yes, please provide details or links, where available: The Consumer Dispute Committee: Komisjoni otsused | Tarbijakaitse ja Tehnilise Järelevalve Amet
The motor insurance conciliation body and The insurance conciliation body : Statistika | Eesti Liikluskindlustuse Fond ja Eesti Kindlustusseltside Liit

10) Does your authority require ADR bodies to report on any of the following indicators? (Tick all that apply.)
☒Resolution rate
☒Number of complaints/cases handled
☒Number of admissible cases
☒Number of closed cases
☒Compliance with decisions or outcomes
☒Time taken to resolve cases
☒User satisfaction
☐Number or share of cross-border cases
☐Other (please specify): __________________________________________________________ 

11) Does your authority have powers to take corrective or enforcement action where an ADR body fails to meet applicable legal or supervisory requirements?
x


If yes, please describe the available measures and the circumstances in which they may be used. If possible, please provide an anonymised practical example: 
If it appears that an alternative dispute resolution entity does not conform to the requirements provided by this Act, the competent authority shall notify the entity of the requirements to which the entity does not conform and set a term for bringing the entity into conformity with the requirements. The term shall not be longer than three months. If the entity fails to ensure conformity to the requirements within three months after receipt of the notice on failure to conform to the requirements from the competent authority, the minister in charge of the policy sector shall declare the decision to recognise the alternative dispute resolution entity invalid by a directive.

12) How is ADR integrated into the broader judicial system in your Member State? (Tick all that apply.)
☒ADR bodies are formally recognised or established in legislation.
☐Courts may refer parties to ADR.
☐Courts encourage parties to consider ADR before initiating litigation.
☐ADR outcomes may be recognised or enforced through judicial procedures.
☒ADR outcomes have no formal link with judicial proceedings.
☐Other (please specify): __________________________________________________________
Please explain briefly where the answer differs depending on the ADR body or procedure:______

13) What are the main challenges your authority faces in supervising or overseeing ADR bodies? (Tick all that apply.)
☐Ensuring the independence of ADR bodies
☐Ensuring consistency across ADR bodies
☐Limited availability of data
☐Fragmentation of the ADR landscape 
☒Limited resources within the competent authority
☐Legal or procedural uncertainty
☒Limited enforcement or corrective powers
☐Other (please specify): ______________________________________________________

3. Coordination and cross-border aspects
14) Does your authority cooperate with authorities in other Member States on ADR-related issues?

x

If yes, please briefly describe the forms of cooperation (for example, information exchange, participation in networks, case-related cooperation, or good-practice sharing): 
The Ministry does not communicate directly with the ministries of other countries. However, the Estonian Consumer Disputes Committee holds annual meetings and regularly exchanges information with its counterparts in Latvia and Lithuania.

15) Are there specific procedures, protocols or cooperation mechanisms in place for handling cross-border financial disputes by means of ADR?


x

If yes, please briefly describe: _______________________________________________________

16) Are there any shared databases, case-tracking systems, common guidelines, or good-practice exchange mechanisms relating to ADR? 
a) within your Member State?

X No

If yes, please briefly describe: _______________________________________________________
b) with authorities or ADR bodies in other Member States?

x

If yes, please briefly describe: _______________________________________________________

4. Recourse to ADR 
5. Please provide aggregated figures for all financial-sector ADR bodies within your authority’s remit for each of the last five full calendar years. If data are unavailable, please indicate “not available”. If your definitions of the categories below differ from the standard meaning, please explain briefly.
Year
Number of total complaints received
Number of admissible cases
Number of closed cases
2021
301
285
166
2022
379
346
171
2023
440
399
200
2024
505
426
226
2025
527
445
210

Unfortunately, we are unable to provide a comprehensive overview, as the Consumer Disputes Committee does not deal exclusively with disputes concerning financial services but with consumer disputes in general. Therefore, the table contains data relating to disputes concerning insurance and motor insurance. These bodies operate as conciliation bodies, meaning that they do not issue binding decisions; rather, their purpose is to facilitate an amicable settlement between the parties. "Number of closed cases" means the number of cases in which an agreement (settlement) was reached. In certain cases, a settlement was reached before the conciliator was involved in the dispute.
17) Overall, how has the use of ADR in the financial sector changed over this period in terms of volume of cases and general recourse by consumers? 
x
 


Please elaborate on your answer:
The statistics of ADR bodies show that the number of cases submitted has increased from year to year.

18) What are the main factors influencing this trend? (Tick all that apply.)
☒Increased consumer awareness 
☐Regulatory or legislative changes
☐Digitalisation of services or ADR procedures
☒Increase in specific types of disputes (e.g. fraud)
☐Changes in firms’ internal complaint-handling procedures
☐Market or economic developments
☐Other (please specify): _______________________________________________________ 
Please elaborate on your answer: The number of complaints has increased because consumers are now more aware of the existence of ADR.

6. Cross-border ADR
19) If available, what percentage of ADR cases in the financial sector involved cross-border disputes during the most recent full calendar year?:_________________________________________% 

20) What are the main difficulties in handling cross-border cases? (Tick all that apply.)
☐Jurisdiction issues 
☐Language barriers 
☐Differences in applicable law
☒Difficulties in enforcing outcomes
☐Lack of participation by financial services providers
☐Lack of consumer awareness or accessibility
☐Other (please specify): ________________________________________________________ 
7. Outcomes of ADR cases 
21) In the financial sector in your Member State, ADR outcomes are generally:


x


Please explain briefly, including the legal effect of ADR outcomes and any consequences of non-compliance: The decisions of the Consumer Disputes Committee are non-binding recommendations. If a trader fails to comply with a decision, the trader may be included on a public list of non-compliant traders. The objective of the other ADR bodies is to facilitate a mutually agreed settlement between the parties.

8. Compliance and effectiveness 
22) Is compliance with decisions or outcomes monitored?
x


If yes, please briefly describe by whom, how, and how frequently: The Consumer Disputes Committee publishes annual statistics on the disputes it handles.

23) If known, what are the main reasons for non-compliance with ADR decisions or outcomes?
Please elaborate on your answer: The decisions are not binding, and some traders are not concerned about being placed on the public list of non-compliant traders.
 
9. Efficiency
24) What is the average time to resolve a case?: 70 days (if we talk about Consumer Dispute Committee)
25) To your knowledge, is the time required to resolve a case a barrier for consumers using ADR?

x

Please elaborate on your answer: Under Directive 2013/11/EU, disputes should be resolved within 90 days. The Consumer Disputes Committee resolves disputes significantly faster, with an average case handling time of 70 days

26) Compared to court proceedings, ADR is generally for consumers: 
x





Please elaborate on your answer: Out-of-court dispute resolution is free of charge for both consumers and traders.

27) Are costs a barrier for consumers using ADR?

x

Please elaborate on your answer: Because it is free of charge
10. Quality and safeguards
28) Are ADR bodies required by law or regulation to have formal safeguards to ensure their independence and impartiality?
x



Please describe the main safeguards and, if possible, cite the legal basis: The Estonian Consumer Protection Act § 33 regulates the Independence and impartiality of alternative dispute resolution entities

29) Based on your supervisory or oversight experience, to what extent do you agree with the following statements regarding ADR bodies operating in the financial sector in your Member State? (Please mark with ‘X’ in the table below.)


Fully
To a large extent
To some extent
To a limited extent
Not at all
Don’t know/not applicable
ADR bodies operate independently from financial service providers and other external influences.
x





ADR bodies handle disputes in an impartial manner.
x





ADR bodies provide consumers and financial service providers with transparent information on their procedures, decisions and timelines.
x






Please provide any comments or examples relevant to your ratings:
We have not received any complaints indicating that ADR bodies have encountered problems with the statements mentioned above.
11. Looking  forward
30) In your view, what are the main areas in which ADR systems in the financial sector could be improved?
The establishment of a dedicated Financial Ombudsman has been discussed for many years. However, these discussions have not yet resulted in the creation of such a body due to various practical and institutional considerations.Which activity, if any, should be strengthened at EU level in relation to the ADR bodies (e.g. guidance, harmonisation, data collection)?
_______________________________________________________________________________________
31) Which aspects of ADR bodies in the financial sector should remain flexible at national level?
At national level, flexibility should be maintained regarding the organisational structure and governance model of ADR bodies, as well as the choice of whether to establish sector-specific ADR bodies or a more general ADR system. Member States should also be able to take into account the specific characteristics of their financial markets, existing dispute resolution mechanisms and national legal frameworksAny additional comments, including data limitations or challenges? 
_________________________________________________________________________________________

32) If available, we would be grateful if you could share a link to the most recent report your authority submitted to the European Commission under Article 20 of Directive 2013/11/EU (ADR Directive).

As the deadline for submitting the report is 1 November, it has not yet been prepared.

If the report is not publicly available, we would be grateful if you could share a copy together with the completed questionnaire by email.
Thank you for your contribution!