Soda Labs

Estonia

The licence cull that reshaped the European market

JurisdictionEuropeConfidential with disclosure

Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.

What Estonia actually says

Estonia mattered to this market out of proportion to its size, because for a few years it issued more crypto authorisations than anywhere else in Europe. The 2022 amendments ended that: capital requirements, real local presence, a compliance officer and fit and proper testing of owners took the register from over fourteen hundred licences to roughly a hundred. Worth being precise about what that was and was not. It was a gate on who may operate, not a rule about what operators may offer. We found no Estonian instrument touching anonymity-enhancing assets or self-hosted wallets, so on confidentiality the European baseline governs here as it does elsewhere.

The instruments that matter

From over 1,400 licences to roughly 100
amendments to the money laundering prevention act in force from March 2022 cut the register by around 93%, with most authorisations either surrendered or revoked
What the amendments required
minimum capital of EUR 250,000, genuine physical presence and operations in Estonia, a dedicated anti-money-laundering officer, and fit and proper testing of managers and beneficial owners
An entity-side gate, not a transaction rule
the cull changed who may hold a licence rather than what licensed firms may do, and we located no Estonian rule on anonymity-enhancing assets or self-hosted wallets

What this means for confidential transactions

Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.