Kirjavahetus

From: Erika Adams <[email protected]>
Date: Tuesday, 6 January 2026 at 10:27
To: Cristina Vega | IDVIA <[email protected]>
Cc: Tais Vakrõõm <[email protected]>, Riigi Infosüsteemi Amet <[email protected]>
Subject: RE: Inquiry - eIDAS Qualified Preservation Service

Dear Cristina

Thank you for your inquiry and for your interest in providing qualified trust services in Estonia. Below we provide an initial overview of the process for applying for QTSP status and the related supervisory requirements in Estonia.

Please note that if you wish to provide the same QTSP service in Estonia while remaining registered on the Spanish Trusted List and under the supervision of the Spanish competent authority, it is not necessary to register the service on the Estonian Trusted List or to come under Estonian supervision. The provision of qualified trust services is cross-border in nature. It is sufficient for a qualified trust service to be registered and supervised by the competent authority of one EU Member State and included in that Member State’s Trusted List. The qualified status of the service is valid throughout the European Union.

If you nevertheless wish to obtain an operating authorisation in Estonia and be placed under Estonian supervision, the provision of qualified trust services would require the establishment of a legal entity in Estonia and an application for QTSP status submitted in accordance with Estonian and EU requirements.

Complience with the following legislation is required:

1. REGULATION (EU) No 910/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (eIDAS);  

2.  Electronic Identification and Trust Services for Electronic Transactions Act,  is available here  https://www.riigiteataja.ee/en/eli/ee/527102016001/consolide/current    

3. General Part of the Economic Activities Code Act,  https://www.riigiteataja.ee/en/eli/515042021004/consolide    

4. Commercial Code  is available here https://www.riigiteataja.ee/en/eli/ee/511012021004/consolide/curren     

5. Commission implementing regulation (EU) 2025/1946 (service-based),  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1946

6. Submission of the completed and signed application, together with the required data and documentation to the Information System Authority at [email protected].

Conformity assessment must follow the Estonian regulation „Trust service provider and trust service conformity assessment procedure  available at https://www.riigiteataja.ee/akt/128102016017    (in Estonian) .

Please note that there currently no Conformity Assessment Bodies (CABs) established in Estonia that are competent to issue eIDAS- compliant certificates.  Estonian QTSPs and their services are assessed by CABs from ohter EU Member States abroad. Accepted CABs are listed in the EU list of CABs https://eidas.ec.europa.eu/efda/browse/notification/cab-nab  .

Only compliance of a specific trust service with the applicable ETSI standards and Commission Implementing Regulations are accepted. To provide a qualified trust service, both the service provider and the trust service must have a qualified status in accordance with Article 21 (2) of Regulation (EU) No. 910/2014 of the European Parliament and of the Council, as evidenced by the Estonian Information System Authority.

The information System Authority decides on an application after receipt of all required data and documents:

1. within 80 days in case of an application for an initial trust service licence;

2. within 50 days in case of an application for a repeated trust service licence.

Qualified trust service providers and trust services are entered in the Trusted List for two years.

State fees related to operations in the Estonian Trusted List:

• * review of an application for an initial trust service licence and inclusion in the Trusted List: EUR 1,030 per trust service;

• * review of an application for a renewed trust service licence and inclusion in the Trusted List: EUR 770 per trust service;

• * review of an application for modification of trust service provider or service data: EUR 65;

More detailed information on obtaining a trust service provider operating licence is available at  https://www.eesti.ee/eraisik/en/artikkel/licences-and-notices-of-economic-activity/usaldusteenused/trust-service-providers-operating-licence

If you have any further questions, please do not hesitate to contact us.

Best regards

Erika Adams

Chief Expert of Cyber Security Centre

and Trust Services

[email protected]

Estonian Information System Authority

Pärnu mnt 139a Tallinn 15169