New Hiring Rules for Foreign Workers in Estonia

If you hire (or plan to hire) non-EU talent in Estonia, a quiet but important shift is coming on 1 January 2026. Under amendments to the Aliens Act, employers and temporary work agencies will need to prove real, continuous economic activity for at least six months before sponsoring a foreign worker’s residence permit. In short: paper companies and “hire first, start later” setups won’t fly anymore. 

What exactly is changing?

• For employers: When applying for a temporary residence permit for employment, you must show that your company has had actual economic activity in Estonia for the six consecutive months immediately preceding the application. Think operations, not just incorporation.

• For temporary work agencies: The six-month activity rule also applies, but can be fulfilled in Estonia or another EEA/Schengen country—useful if your agency operates across borders. This replaces the old cash-deposit requirement and shifts the focus to substance.

What counts as “actual economic activity”?

The law doesn’t lock you into one proof. Expect a bundle of evidence that shows real operations, such as:

• client or supplier contracts and invoices,

• bank statements showing business transactions,

• tax filings (VAT/TSD where applicable),

• annual report and management accounts,

• payroll records (if you already employ staff),

• proof of office/warehouse or service delivery.

Immigration counsel and official guidance suggest a pragmatic, document-based approach: the goal is to demonstrate that your business is active, not dormant.

Who is affected?

• Estonian companies hiring third-country nationals on temporary residence permits for work.

• Staffing/lease-of-labour agencies bringing in foreign workers to client sites.

• New ventures planning to hire early: you will need to sequence operations → activity → sponsorship, rather than the other way around.

Why this matters (beyond compliance)

• Timing risk: If you plan to onboard a non-EU specialist in Q1–Q2 2026, the six-month clock pushes the start of your activity back into mid-2025.

• Cash-flow planning: Building six months of bona fide activity (and evidence) costs time and money—budget for it.

• Client commitments: Promises to customers that hinge on imported talent should include immigration contingencies.

A simple readiness checklist (save this)

By month −6 (before the permit application)

• Open and actively use your Estonian (or EEA) business account for transactions.

• Sign your first customer/supplier contracts and start invoicing.

• Register for VAT if required by your activity/thresholds; file on time.

By month −4

• Keep management accounts monthly; reconcile bank and invoices.

• If you’re a staffing agency, document placements and service delivery in Estonia/EEA.

By month −2

• Assemble the evidence pack (contracts, invoices, statements, tax filings, payroll if any, office lease).

• Check annual report status in the Business Register—no overdue filings.

At application

• Submit the six-month activity proof with the residence-permit dossier; be ready to explain your business model and the candidate’s role.

Frequent traps (and how to avoid them)

• “We have a registry entry; that’s activity.” No. Activity is operations, not just a registration. Show trade flow, not just a logo.

• Late filings = red flag. Overdue annual reports or missing VAT/TSD submissions undermine the “we’re active” claim. Clean your slate first.

• All in PDF. Immigration and auditors prefer verifiable documents—bank statements, tax confirmations, structured data where applicable. Keep your records exportable and consistent.

  
  

Official source: 

• Estonian Chamber of Commerce and Industry

• Riigi Teataja