Overview of the Chamber's most important activities in the third quarter of 2026

In the third quarter of 2026, the Chamber submitted written opinions on 49 draft legislative acts or other policy-making documents. Since the beginning of the year, we have submitted opinions on 202 occasions in total, 35 more than during the same period last year.

In the third quarter, we focused on reducing companies' administrative burden, the reasonable transposition of European Union requirements, and issues related to labour, energy and the environment. It is positive that the Riigikogu approved 11 of the Chamber's proposals to simplify occupational health and safety requirements. Taking account of an earlier proposal by the Chamber, the minimum investment threshold required to receive support for large-scale investments was also lowered. In addition, we launched a joint analysis in cooperation with companies and the state to calculate which combination of electricity generation, storage and interconnections would meet Estonia's growing electricity consumption at the lowest system cost, while taking account of the conditions arising from energy security, security of supply and environmental requirements.

In the third quarter, we organised 19 events. These included Estonian–Latvian and Estonian–Icelandic business forums, as well as training sessions and meetings for entrepreneurs. We also organised foreign visits to Belgium, the Netherlands and Moldova.

On 5 September, we opened the business season with our members at Ämari Air Base. Oliver Väärtnõu, Chairman of the Chamber's Board, gave a speech in which he stressed that reducing bureaucracy requires a lasting change in the state's administrative culture. He also highlighted the importance of developing employees' skills and vocational education, and the need to ask political parties for concrete solutions to stimulate economic growth and create a competitive tax environment ahead of the Riigikogu elections. Read Oliver Väärtnõu's speech in full

The most important topics in the third quarter of 2026

Policy win: occupational health and safety requirements are being simplified
On 30 September, the Riigikogu adopted amendments to the Occupational Health and Safety Act incorporating 11 proposals from the Chamber. For example, at our proposal, requirements will be eased for private limited companies in which the sole shareholder, sole management board member and sole employee are the same person. As a rule, employers will have six months rather than the previous four to arrange an initial medical examination, and the separate obligation to conduct internal monitoring of the working environment will be abolished.

Companies with fewer than ten employees will no longer have to upload their risk assessment to the Labour Inspectorate's database, although the obligation to prepare one will generally remain. In addition, companies with fewer than ten employees will no longer have to arrange an analysis of their occupational health situation.

Once the Act enters into force, the amendments are expected to save companies an estimated €22.6 million annually. The amendments are expected to enter into force in the coming weeks.Read more

Policy win: the minimum investment threshold for large-scale investment support was reduced to €70 million
Amendments that entered into force on 8 August reduced the minimum investment requirement for large-scale investment support from €100 million to €70 million. When the support measure was being developed, the Chamber had already pointed out that the initial threshold was too high given Estonia's economic environment and geopolitical situation. The minimum investment threshold is now €35 million for projects involving priority technologies and €20 million for defence industry projects. The job creation requirement was also eased: investments must now create at least 20 new jobs instead of the previous 30.

Policy win: employment opportunities for young people have expanded
Amendments easing restrictions on the employment of minors entered into force on 13 July. Among other things, an amendment proposed by the Chamber came into force allowing young people aged at least 16 to perform work related to the production, offering for sale and sale of alcoholic beverages.

Young people subject to compulsory education may now work for up to two months during the summer holidays, provided they have at least four consecutive weeks of holiday. Young people aged 7–17 may also perform light work in a family business without restrictions on the field of activity. The Labour Inspectorate's processing time for permits required to employ children aged 7–12 was reduced from ten working days to five.

The energy audit obligation could be extended to hundreds of companies
In connection with the planned amendments to the Energy Sector Organisation Act, we pointed out that the number of companies subject to the energy audit obligation could increase significantly. Under the proposed amendment, the obligation to conduct an audit would no longer depend on the size of the company but on its energy consumption: a company consuming more than 10 terajoules per year would have to conduct an energy audit, while a company consuming more than 85 terajoules would have to implement an energy management system.

As a result of the amendment, the number of companies subject to the energy audit obligation could rise from approximately 150 at present to around 800. We stressed that companies must be given sufficient time to comply with the requirements, the rules for calculating energy consumption must be clear, and it must be ensured that there are enough energy auditors in Estonia before the obligation is extended. Situations in which a company has to submit the same information or carry out the same activities under several different requirements must also be avoided.

Entrepreneurs must be informed as early as possible of potential exceedances of new air quality standards
We drew the Ministry of Climate's attention to the fact that stricter ambient air quality limit values from 2030 could affect a significant number of companies. According to the explanatory memorandum to the draft act, approximately 250 installations could be at risk of exceeding the new standards.

We proposed assessing the impact of the new requirements on different economic sectors before their implementation and informing, as early as possible, companies whose activities could be affected by the new limit values. Companies must have sufficient time to plan investments and make the necessary changes, and it must also be clear how exceeding the new air quality standards will affect the granting of environmental permits and the operation of existing installations.

Equal requirements must apply to accommodation service providers
In connection with the planned amendments to the regulation of accommodation services, we considered that equal requirements must apply to natural and legal persons providing accommodation services as a professional or economic activity. The way the service is provided or the form of business must not give one market participant an unjustified competitive advantage over others.

The Ministry is considering introducing a nationwide registration obligation for providers of short-term rental services. The Chamber supports the establishment of a register if it would provide real practical benefits, particularly for carrying out supervision and thereby ensuring fair competition. We recommended that the Ministry analyse in greater detail the costs and benefits associated with establishing the register.

Changes to enforcement proceedings would only partially reduce the burden on employers
We supported the intention to exempt employers from complying with wage attachment orders if wages are transferred to the debtor's account opened in Estonia. However, the employer's existing obligation would remain if the employee wishes to have their wages transferred to a third party's account or an account abroad. We proposed extending the simplification to these situations as well, for example by making the calculation of the amount to be attached the responsibility of the bailiff.

Vocational education objectives need corresponding funding
Together with the Estonian Association for the Promotion of Vocational Education, we addressed political parties because the objectives set for vocational education and the funding of the sector are not aligned.

The state's objective is to increase the proportion of basic school graduates entering vocational education from approximately 20% at present to at least 40% by 2035, but funding for vocational education has not kept pace with rising prices in recent years. Between 2022 and 2025, current expenditure per vocational student increased by 14.2%, while the price level rose by 34.9%.

We proposed increasing funding for vocational education by at least 30% and stressed that, if the number of students doubles, total funding for the sector must more than double as well.

Companies and state representatives will jointly calculate which electricity generation portfolio is most affordable for Estonian consumers
An analysis carried out in cooperation between the Chamber, companies and state representatives will be completed in the first quarter of 2027 to determine which combination of electricity generation, storage and interconnections would meet Estonia's growing electricity consumption at the lowest system cost.

The analysis will be based on the total cost borne by consumers, not merely the electricity exchange price. The analysis should provide the state with a better basis for shaping energy policy and support measures, and companies with a better basis for making investment decisions.

The work will be completed by the end of February 2027, and its terms of reference, methodology, inputs and results will be made public.Read more

Packaging register requirements must not hinder exports by companies with low sales volumes
The European Commission is planning to harmonise packaging producer registers and reporting. We pointed out that even the sale of individual products to another Member State entails an obligation to appoint an authorised representative and other obligations related to extended producer responsibility, the costs of complying with which may be disproportionate to the volume of sales.

We proposed establishing a uniform minimum threshold across the EU below which such a burden would not arise for entrepreneurs handling small quantities of packaging. We also recommended moving towards a solution in which entrepreneurs submit data once in their country of establishment and the data are automatically transferred to the registers of other Member States.

The emissions trading system must take account of the industry's actual capabilities
The Chamber pointed out to the European Commission that the planned changes to the emissions trading system must take account of companies' competitiveness and capacity to invest. We do not support making the receipt of free allowances conditional on an obligation to invest an amount equal to the value of the allowances in emissions reductions. A company should not lose protection against carbon leakage solely because suitable technology or the financial means to invest are lacking.

We welcome the proposed slower pace of emissions reductions but stressed the need to ensure greater predictability of CO₂ prices. Nor should premature restrictions on domestic production increase dependence on imports from third countries.

Estonia should not impose packaging requirements stricter than EU rules
The Chamber proposed removing unjustified additional national requirements from the draft Packaging Act and clearly distinguishing obligations arising from European Union law from Estonia's own choices in the explanatory memorandum. We do not support a ban on providing takeaway packaging free of charge or an obligation to show the price of packaging as a separate item on a receipt, because their environmental benefits have not been sufficiently demonstrated, while they would impose additional costs on entrepreneurs. As a positive change, we supported raising the threshold for the audit of packaging records to 100 tonnes per year and applying it already to reporting for 2026.

The combined impact of regulations must also be assessed in the legislative process
We proposed that the Ministry of Justice and Digital Affairs include in the new impact assessment methodology an obligation to analyse the cumulative impact of regulations on entrepreneurs. An individual requirement may appear justified and have little impact on its own, but obligations arising from several legal acts can together impose a significant additional burden on a company.

We conveyed entrepreneurs' concerns about stricter transposition of EU requirements to the European Commission
We compiled feedback from entrepreneurs on situations where implementing European Union law in Estonia results in stricter requirements or an additional administrative burden and forwarded it to the European Commission. This practice, known as gold-plating, can put Estonian companies at a disadvantage compared with their competitors in other Member States.

We provided examples of additional requirements in the packaging sector, duplicate submission of medical device data and restrictions applied in forestry. We stressed that additional national obligations must be clearly justified and proportionate, and their economic impact must be thoroughly assessed before they are introduced.

Environmental permit procedures need clearer and shorter deadlines
The Chamber submitted proposals to the Ministry of Climate to speed up environmental permit procedures and make them more predictable. We considered that a clear limit must be placed on extensions of the deadline for processing environmental permits: the deadline should be extendable once if significant circumstances arise, and a decision should be made no later than 180 days after the application is submitted.

We also proposed shortening the deadlines for assessing whether an application complies with the requirements and for reviewing a corrected application. Entrepreneurs must know how long obtaining a permit will actually take, which is why we recommended that the Environmental Board begin publishing the total duration of procedures.

Changes to the professions of bankruptcy trustee and bailiff need more thorough analysis
The Ministry of Justice and Digital Affairs is considering transferring the duties of bankruptcy trustees to the state, along with other changes to the professions of bankruptcy trustee and bailiff. For the Chamber, it is important that proceedings be efficient, creditors' claims be satisfied to the greatest possible extent and debtors acting in bad faith be held accountable. Before moving to a state-run model, it must be compared with the current system in terms of costs, funding and effectiveness. Without more thorough analysis, we support maintaining the current arrangement.

We also warned in our appeal that stricter educational requirements for bankruptcy trustees could exacerbate the shortage of trustees. We supported making trustees' working arrangements more flexible, provided that the necessary oversight and protection of creditors are maintained.

Reducing food and textile waste must not introduce unjustified additional obligations
The Chamber supports the objective of the amendments to the Waste Act to reduce food and textile waste, but does not consider obligations going beyond the directive to be justified. For example, we proposed keeping food waste records for the company as a whole rather than separately for each place of business. Nor should entrepreneurs be obliged to publish the proportion of donated food on their websites.

When calculating the producer responsibility service fee for textile products, taking the product's service life into account should not be mandatory, as there is no uniform, reliable methodology for assessing it. We also asked for the total cost of the new requirements to be assessed and clear guidelines on classifying food waste to be prepared for entrepreneurs.

Employers must retain a substantive role in the qualifications system
Together with five business organisations, we approached the Riigikogu with a proposal to amend the draft Professional Qualifications and Skills Act. In our view, the role of employers in developing occupational standards and assessing skills must not become merely advisory. Occupational standards and competence profiles must be established with the approval of the relevant sectoral expert council. In addition, the participation of representatives of the world of work in the independent assessment of skills must be retained when initial professional qualifications are awarded, so that the same qualification represents a comparable level across different educational institutions.

Repairing goods should not extend the seller's liability to nearly five years
The Chamber does not support the solution proposed in the draft amendments to the Law of Obligations Act and the Consumer Protection Act, which would extend the seller's liability period beyond what the European Union directive requires. Under the directive, when defective goods are repaired, the seller's liability period is extended once by 12 months. Under the Estonian draft act, however, a new two-year period would begin upon repair, with another year added to it. The seller's total liability could therefore extend to nearly five years. We proposed extending only the existing liability period by 12 months, rather than starting a new two-year period.

Estonia should not rush to introduce Nutri-Score
Together with six business associations, the Chamber approached the government with a recommendation not to introduce a new packaging labelling system voluntarily in Estonia before a uniform, science-based solution that takes different food cultures into account has been agreed upon in the European Union.

The business associations believe that the actual benefits of Nutri-Score for public health have not been sufficiently demonstrated and that a simplified assessment may also mislead consumers. We stressed that assessing the impact of the labelling cannot be based solely on consumers' choices in an experimental setting: its actual impact on public health and Estonia's food sector must be analysed.

Land occupied by state border defence structures must be exempt from land tax
We proposed to the Ministry of Finance that land on which ditches, barriers or other defence structures are built to protect the state border be exempted from land tax. In our view, it is not justified to require owners to pay land tax on land that they can no longer use for its previous economic purpose and that serves the security of Estonia as a whole.

The tax exemption would increase landowners' willingness to enter into agreements and help the defence structures to be completed more quickly. As land tax revenue accrues to local authorities, we recommended that the state compensate them for the loss of revenue resulting from the exemption.

The Ministry of Finance does not support the Chamber's proposal.

Rail Baltica requires shared responsibility from the three Baltic states
The chambers of commerce of Estonia, Latvia and Lithuania appealed to the governments of the three countries to ensure that completion of Rail Baltica remains a common strategic priority even when governments and political preferences change.

We stressed that this is not merely a transport project, but a connection that affects the region's security, military mobility and competitiveness. Entrepreneurs and the public must be given a realistic overview of deadlines, total costs and funding, and concrete solutions must be presented if risks arise. We drew particular attention to the importance of completing the main line in Latvia, because Rail Baltica can fulfil its purpose only as a complete transport corridor.

Amendments to the Tobacco Act must not increase the illicit market for nicotine products
In connection with the planned amendments to the Tobacco Act, we pointed out that a nicotine content limit that is too low and an overly narrow list of permitted flavourings could drive consumers towards unregulated tobacco products. We therefore proposed making the restrictions more proportionate. We also proposed allowing products that meet the nicotine content requirements of the destination market to be manufactured in Estonia for export.

At the same time, we supported a ban on ordering tobacco products and related products through distance selling, as well as the principle that nicotine product packaging must not be attractive to young people. We stressed that, alongside restrictions, clear implementation criteria and sufficient supervisory capacity are needed.

At the Opinion Festival, we sought solutions to reduce the illicit e-cigarette market
At a discussion organised by the Chamber at the Opinion Festival, we addressed the illicit e-cigarette market and ways to restrict young people's access to illegal nicotine products. The discussion highlighted that new bans alone are not enough: effective supervision, clear rules and consistent preventive work are needed.

Mait Palts, Director General of the Chamber, stressed that for every restriction it is necessary to assess both its actual impact on market behaviour and the state's ability to ensure compliance with the requirement. Tougher action against illegal sellers and raising awareness among young people and parents were also considered important.

We recognised Estonia's most attractive employers
On 3 September, together with employer branding agency Instar, we recognised the organisations where people most want to work at Attractive Employers' Day in Tallinn. According to Instar's survey, the most attractive employer was Swedbank among experienced employees, Apollo Group among vocational school students and TalTech among higher education students. Nearly 4,000 people participated in the survey.

Oliver Väärtnõu, Chairman of the Chamber's Board, stressed in his opening speech that competition for talented people makes employer attractiveness increasingly important: employees' skills and experience give a company capabilities that its competitors may not have.

A demining robot made by an Estonian company was handed over to the National Guard of Ukraine
On 4 July, the National Defence Promotion Foundation, established by the Chamber and the Ministry of Defence, handed over a demining robot made by the Viljandi-based company Milmech Systems to the National Guard of Ukraine. The robot, delivered to Ukraine with the support of a targeted donation from an Estonian company, helps reduce the danger faced by soldiers in mine-contaminated areas.

At the same time, the manufacturer receives feedback from a real operating environment, which supports the further development of Estonia's defence industry. This was the Foundation's 30th aid shipment to Ukraine. During the visit, representatives also met with the Dnipropetrovsk Regional Chamber of Commerce to discuss the region's needs and opportunities for cooperation between Estonian and Ukrainian entrepreneurs.