How to file your own annual report and change your accountant and contact person
The heaviest type of reported complaint is a report paid for but never filed: the deadline passes, the registry fine is written to the customer’s company, and the provider stops answering. This guide explains what to do at that point: you can file the report yourself, and you can change accountant and contact person without the provider’s consent. The company is yours; the provider only sells a service.
Who is responsible: the company, not the accountant
Under the Estonian Accounting Act the management board is responsible for keeping the accounts and filing the annual report; the accountant is a service provider. Registry fines are imposed on the company and the board member, not on the accountant. This looks like bad news but is your real strength: you need nobody’s permission to file the report. You log in to the company portal with your own e-Residency card, Smart-ID or Mobile-ID, fill in the report and sign it.
The same act places the seven-year retention duty on the company. The provider cannot say the statements, invoices and records it holds “stay with us”; they are your documents. In the reported cases documents remaining with the provider and being asked for again and again leave the customer unable to move.
Filing the annual report yourself: step by step
- Log in: ariregister.rik.ee → “Login” at the top right → e-Residency card, Smart-ID or Mobile-ID. After login, “My dashboard” lists the companies where you are a board member.
- Create the report: on the company page, “Submission of a report” → new report → choose the financial year. Small companies can pick the micro-enterprise (mikroettevõtja) format: a balance sheet and income statement of a few pages, minimal notes. The portal asks whether the micro-enterprise conditions (revenue and balance-sheet thresholds, single shareholder-director) are met.
- Enter the data: balance sheet and income statement lines are entered by hand, or an XBRL file from accounting software is uploaded. For a single-owner company with few transactions the number of lines is small: bank balance, receivables, payables, capital, revenue, expenses.
- Attachments: a short management report, a profit allocation proposal, a shareholders’ resolution if needed.
- Sign and submit: the report is signed digitally; shareholders sign the approval in the portal; “Submit” sends it to the register. The next day the Annual reports box shows the “Submitted” date.
Audit and review thresholds are far above what a small company reaches; a one-person e-Residency company almost never needs an audit. The portal warns you if it does.
Time: with the documents at hand, a micro report takes an afternoon. With accounting software (the common Estonian cloud packages produce the XBRL directly) it is shorter. If unsure, preparing the report yourself and having an independent accountant check it at an hourly rate before submission is cheaper than tying a whole year to one provider (opinion).
If the deadline has passed
- The report can still be filed after 30 June; late is always better than never. Even if a fine has been decided, filing closes the proceedings.
- Letters from the registrar (warnings, fine decisions) are served on the contact person. If the contact person is the provider itself and the relationship has broken down, you cannot know whether the letters were passed on. In the company portal, the “Proceeding information” tab shows the registrar’s actions concerning your company; check it regularly.
- The period for objecting to a fine decision is short; check the decision date in the portal.
- If the provider makes delivery of the report conditional on a further payment, know that you can also file it yourself; enter the negotiation with that knowledge (opinion). In the reported cases the gap between payment and delivery grows at exactly this moment.
Changing accountant: five steps
- Find the new provider first, then give notice to the old one. Run the new provider through the 12 checks.
- Written notice: follow the notice period in the contract; if there is none, give a reasonable period (one month). Send the notice by e-mail, dated, with read receipt.
- Request the documents: general ledger (pearaamat), balance sheet and income statement, fixed-asset register, receivables and payables listing, VAT returns filed, past annual reports, an export from the accounting software. These are the company’s property; handing them over cannot be charged for (opinion; if the contract says otherwise, the contract applies).
- Revoke access: log in to e-MTA (emta.ee) as a board member and remove the old accountant’s and their company’s access under “Settings → Access permissions → Access permissions of representatives”; close any view-only access given to the accountant at the bank; delete the user in the accounting software.
- Grant access to the new provider: in the same places, only in the scope needed (filing returns, viewing).
A change of accountant is not notified to the register; there is no such thing as an accountant entry in the register. Only the contact person and the legal address are in the register; they are covered below.
Changing the contact person and legal address in the register
The contact-person entry is changed in the company portal: ariregister.rik.ee → log in → “My dashboard” → “Change the data” next to the company → in the left menu “Persons → Other roles → Contact person” → enter the new contact person’s name/registry code and the term of appointment (a term is mandatory; when it expires the entry lapses automatically, an extension is reported to the register); the new contact person’s digitally signed consent is attached; a board member signs with “Sign” and the state fee is paid. The old contact person’s consent is not required. The registrar usually processes it within a few working days; the new entry appears in the “Address of the contact person” line of the registry card.
The legal address is changed in the same change view under the “Contacts” tab on the left; the consent of the new address holder (the new provider) is attached.
The old contact person can also remove themselves by notifying the registrar, or the entry lapses when the term ends; for a company with its registered address abroad the registrar then grants 1–3 months, and if no new contact person is appointed, deletion of the company and compulsory dissolution may follow. So when the relationship breaks down, you change it first; waiting for the provider to remove itself leaves the company exposed. In the reported cases this is the practical result of the “no exit plan” type.
If you want to close the company altogether: how to close an Estonian company.
Frequently asked questions
If I file the report myself, is an accountant’s signature needed?
No. The annual report is signed by the management board; an accountant’s signature or approval is not a legal requirement. Large companies subject to audit attach the auditor’s report; small companies do not need it.
What if the old accountant does not hand over the documents?
Ask in writing, dated, with a list of items. If they refuse, you can obtain bank statements from the bank, filed VAT returns from e-MTA and past annual reports from ariregister yourself; if the general ledger is missing, the new accountant can rebuild it from these. There is also a legal route against withheld documents (formal notice, if necessary a claim); first gather the sources above so you are not left without records.
What if the provider says “there are suspicious transactions, we will report to the FIU”?
Obliged entities are required by law to report on suspicion, and they are already prohibited from telling the customer about it (the tipping-off ban); mentioning a report during a fee negotiation is therefore not a legal step but a means of pressure (opinion). If your records are in order there is nothing to do; keep the correspondence. In the reported cases this is the “pressure through dependence” type.
How much is the fee for changing the contact person?
A state fee is paid for a data-change application; the amount is shown in the portal during the application and may change over time. A new provider usually includes this application in its service package.
What if I want to close the company?
Voluntary liquidation is started in the portal, a liquidator is appointed, creditors are called, a closing report is filed; the process takes months. Alternatively the company can be transferred. In both cases nothing moves while an annual report is outstanding; file the report first.