Riigikogu passed 994 SE on 28.10.2026: from 01.01.2027 the TSD is e-filed whatever the headcount. The first data-based TSD is due 10.11.2026. Steps for an OÜ.
▸ TaxationOn 28 October 2026 the Riigikogu passed amendments to Estonia's Income Tax Act (bill 994 SE): from 1 January 2027 the TSD return is filed electronically whatever the number of payees. The current exception that let an employer with five or fewer payees file the TSD on paper is repealed. Paper filing stays available only on a reasoned application where electronic filing is objectively impossible. From 1 December 2026 the declaration forms in the tax acts are replaced by data sets (andmekoosseis) set by ministerial regulation. The law locks in the switch the Estonian Tax and Customs Board (EMTA) launched in October: salary data now goes straight from accounting software, and the first deadline under the new route, for October payments, falls on 10 November 2026.
Does your Estonian OÜ pay salaries or board member fees? An INNOVA partner reviews how your company files the TSD, moves reporting to software that sends data to EMTA, and takes over payroll. Send an enquiry →
The Act amending the Income Tax Act and related acts passed by 60 votes to 4 and was sent to the President for promulgation on 28 October. It amends the Income Tax Act, the Social Tax Act, the Unemployment Insurance Act and the Funded Pensions Act.
| Date | What changes | Basis |
|---|---|---|
| 01.10.2026 | EMTA launches the data-based TSD: payments flow from accounting software | EMTA news, 11.03.2026 |
| 28.10.2026 | Riigikogu passes 994 SE | Riigikogu press release, 28.10.2026 |
| 10.11.2026 | October TSD due, the first month on the new route | EMTA news, 05.10.2026 |
| 01.12.2026 | Declaration forms replaced by data sets | 994 SE, § 5(1) |
| 01.01.2027 | TSD electronic only, whatever the number of payees; social tax return too | 994 SE, § 1(3), § 3(2), § 5(2) |
| Q2 2027 | VAT return (KMD) and employment register (TÖR) move to data-based reporting | EMTA TSD handbook |
| 31.12.2027 | Last day for TSD uploads in CSV format | EMTA TSD handbook |
For resident individuals, electronic filing becomes mandatory from 2027 where the annual return declares income under § 15, 16 or 18 of the Income Tax Act (gains on disposal of property, rental income and royalties, dividends and other income from holdings) more than five times under the relevant section, or more than five payments into and out of an investment account (§ 17²). The rule sits in § 44(6²).
The TSD is due by the 10th of each month. Until now, Annex 1 and Annex 2 data were typed into e-MTA or uploaded as a file. Since October 2026, accounting software sends payments to EMTA through a machine-to-machine interface; EMTA builds the declaration and calculates the taxes, and the company reviews and confirms the result. EMTA estimates the business sector will save up to 5 million working hours a year.
What changed technically:
An OÜ is an Estonian resident, so the new rule applies to it directly. From 2027 an employer with one or two staff, or a director on a fee, can file a paper TSD only with EMTA's permission. According to the explanatory memorandum, an average of 800 paper TSDs a month were filed in 2025, out of 103,000 to 107,000 TSD filers each month.
A company whose books already run in software with data exchange changes almost nothing: the software provider updates the transfer format. The most work falls on those who type payments into e-MTA by hand or upload the old XML. An owner who runs an Estonian company from abroad is best served by handing payroll services in Estonia to an accountant whose software is connected to EMTA. Payroll tax rates and deadlines are covered in our Estonia payroll guide 2026.
For companies without accounting software, the state offers digitalisation grants through Enterprise Estonia. Choosing software and migrating data usually takes a few weeks, depending on the volume of records.
Only with EMTA's permission, on a reasoned application. From 1 January 2027 an Estonian resident files the TSD electronically whatever the number of payees (Income Tax Act § 40(5) as amended by 994 SE). The explanatory memorandum gives examples of valid reasons: exceptional health circumstances or a technical authentication failure.
10 November 2026, for October payments. The September TSD was filed the old way by 12 October, because 10 October fell on a Saturday.
The law does not require it. Data can be entered in e-MTA by hand or sent through the SEB or LHV payroll module. Software with data exchange saves the most time: EMTA's tax calculation appears in it before the filing deadline.
INNOVA runs the OÜ, bookkeeping, payroll and TSD through one Estonia-practice partner. A partner replies within 24 hours, and the price is fixed once the scope is clear.
Send an enquiry → · Payroll services in Estonia · Estonia payroll guide 2026 · Book the $99 strategy session, credited to the project
Sources: Riigikogu press release, 28.10.2026; Bill 994 SE: third reading text and explanatory memorandum; EMTA news, 05.10.2026; EMTA news, 11.03.2026; EMTA handbook: data-based TSD filing.
Information only, primary sources as of 07.11.2026. Effective dates follow the text of the Act as passed by the Riigikogu.
This material is for general information only and does not constitute legal or tax advice. Accurate as of the publication date.
