Short answer
The clearest current Riigikogu dossier is , the proposed Law of Obligations Act and Other Acts Amendment Act (transposition of the new Consumer Credit Directive).
The Government introduced it on 15 June 2026 to transpose . As of 13 September 2026, it remained a bill: the official page recorded acceptance for proceedings on 18 June and a committee sitting scheduled for 17 September. It had not been enacted.
Four legislative materials are especially useful:
- the dossier page, for identity, proposer, stage and proceeding history;
- the , for the exact proposed amendments;
- the , for the Government's reasons and article-by-article explanation; and
- , for a structured review of the transposition choices and remaining drafting questions.
Together they explain proposals to expand consumer-credit coverage, tighten the information used in creditworthiness assessments, add rights when a register or automated processing contributes to refusal, and regulate registers holding payment-default information or credit scores. These are proposed rules, not the law currently in force.
What is 947 SE?
Matter 947 SE is a Government bill in the 15th Riigikogu. Its title expressly identifies its purpose as transposition of the new Consumer Credit Directive.
The Legalcode dossier contains 14 attachments or attachment variants at the initiation stage. They include:
- the original bill in PDF, DOCX and ASiC-E formats;
- the explanatory memorandum in PDF and DOCX;
- an analytical annex;
- a draft implementing act;
- a directive-to-draft correspondence table;
- comments and proposals;
- a cover letter; and
- an EIS notice.
The count should not be read as 14 independent policy papers. Several entries are the same substantive document in different formats. The fetched PDFs provide the searchable text used here; four DOCX or ASiC-E variants are transparently marked by Legalcode as unsupported for body extraction.
What each material can establish
Keeping those roles separate prevents an analyst from presenting explanatory prose or an annex recommendation as enacted statutory wording.
Proposed changes to the creditworthiness assessment
The bill would amend §403⁴ of the Law of Obligations Act (Võlaõigusseadus, VÕS). The proposed text retains the central repayment-capacity inquiry but adds several express limits and procedural protections.
Assessment would remain broader than payment history
The proposed §403⁴(2) would require the lender to consider all known circumstances that may affect the consumer's ability to repay on the agreed terms. The listed factors include:
- financial position;
- regular income;
- other financial obligations;
- prior performance of payment obligations;
- possible increases in obligations under the proposed credit; and
- risks arising to the consumer from the credit.
The memorandum explains that assessment remains proportionate to the contract, the available information, the amount and the consumer's risk. It does not prescribe one universal scoring template.
The bill would expressly add that an assessment cannot be based solely on the consumer's historical performance of payment obligations. The memorandum explains the distinction: previous payment behaviour remains relevant, but payment-default data or its absence cannot by itself satisfy the lender's assessment duty.
This is particularly important for credit bureaus. A payment-history product can contribute evidence, but the bill would not make a bureau's negative or positive file a complete substitute for the lender's own repayment-capacity assessment.
Social media and special-category data would be excluded
The proposed §403⁴(3) would allow the lender to obtain information from the consumer and other relevant sources, including registers, but expressly exclude social media.
It would also prohibit collecting or using the special categories of personal data identified in GDPR Article 9(1) for creditworthiness assessment. The memorandum uses health information, including cancer-related data, as an example and says the consumer could not make such use permissible merely by consenting.
These restrictions are source-specific and purpose-specific. They concern the information used for the creditworthiness assessment; they do not turn every register into an authorised source or supply an independent GDPR legal basis.
The lender would have to verify more than the consumer's answers
The proposed §403⁴(4), read with amendments to the Creditors and Credit Intermediaries Act, would require appropriate verification of both:
- information supplied by the consumer; and
- other information used in the assessment.
Annex 1 stresses that the lender remains responsible. A credit intermediary may transmit information or perform preliminary work, but the lender should not decide creditworthiness merely from a third party's apparently formal assessment without checking it.
Joint applicants would be assessed on joint repayment capacity
A new §403⁴(5¹) would address multiple consumers seeking one agreement. The lender would assess their creditworthiness by reference to their joint repayment capacity.
The memorandum defines this as the consumers' combined ability to repay the credit. That proposal should not be paraphrased as automatically making each applicant's data or liability interchangeable; the operative effect would depend on the final enacted text and the agreement.
Proposed rights when credit is refused
The bill distinguishes refusal based on register information from refusal based on automated processing.
Register-based refusal
If a decision not to enter the consumer-credit agreement is based on information obtained from a register, proposed §403⁴(10) would require the lender to tell the consumer promptly and free of charge:
- the result of the register query;
- which register was used; and
- the type of data taken into account.
This would make the evidential source visible to the consumer and help direct a correction challenge to the right organisation.
Automated refusal
If refusal is based on automated data processing, proposed §403⁴(11) would require prompt notice of:
- the refusal;
- the use of automated processing;
- the right to request a human assessment; and
- the procedure for challenging the decision.
The memorandum says the automation must have a substantive influence on the creditworthiness assessment. Merely moving contact details between internal forms automatically would not trigger the same explanation; automation affecting a substantive stage would.
The draft would also require immediate notice of any refusal and, where appropriate, a recommendation to accessible debt-counselling services.
These provisions should not be treated as already-operative rights under this bill. They describe the Government's proposal and may change during parliamentary proceedings.
Proposed rules for creditworthiness registers
The bill would add §10¹ to the Personal Data Protection Act (Isikuandmete kaitse seadus, IKS). It would apply to a register containing payment-default data under existing IKS §10 or similar information used to assess consumer creditworthiness, including a probability value for future payment behaviour—a credit score.
The explanatory memorandum makes clear that including credit scores in the definition would not compel every existing payment-default register to start producing scores. It identifies which registers would fall within the proposed rules if they process the relevant information for consumer-credit assessment.
Access by supervised lenders
Where a GDPR legal basis exists, the register operator would have to limit access for consumer-credit assessment to lenders that comply with data-protection requirements and are supervised either:
- by Finantsinspektsioon in Estonia; or
- by the competent authority in another EU Member State.
The memorandum emphasises that this is not a new independent legal basis for processing personal data. The user must first have a lawful basis under the GDPR. Supervision and compliance are additional access conditions.
Qualifying lenders established elsewhere in the EU would have to receive access on the same basis as Estonian lenders.
Minimum content, accuracy and notification
The proposed register rules would require at least:
- information about arrears under a consumer-credit agreement;
- the type of consumer credit; and
- the lender's name.
The operator would have to establish measures ensuring that the information is current and accurate. The memorandum describes this as complementing the GDPR's existing accuracy principle.
The operator would also have to notify the consumer within 30 days after consumer-credit arrears are entered and inform the consumer of GDPR rights.
An internal dispute route
The operator would have to maintain a procedure allowing the consumer easily to dispute recorded information, including data available to third parties.
The memorandum says access to the Data Protection Inspectorate would not be enough on its own: the register operator would need its own usable challenge process and would need to examine disputes within a reasonable time. It also says disputed information should not remain published where doing so would conflict with accuracy and currentness requirements.
The bill proposes a new offence for violating the register duties, with a maximum fine of €10 million and, for a legal person, up to €10 million or 4% of the previous financial year's worldwide annual turnover, whichever is higher.
Wider consumer-credit coverage
The analytical annex identifies expansion of scope as another major change. The new directive no longer generally excludes every interest-free or fee-free product, and the draft would bring specified “buy now, pay later” arrangements and other previously excluded forms within consumer-credit rules, subject to detailed exceptions.
That broader scope matters to creditworthiness duties. A product newly classified as consumer credit may bring its provider, assessment process, disclosures and database access within rules that did not previously apply in the same way.
The bill also proposes rules on personalised offers based on automated personal-data processing, pre-ticked choices, unsolicited credit, pre-contract information, linked insurance, debt counselling and restructuring. Those changes confirm that 947 SE is an omnibus consumer-credit reform rather than a bill about one credit-register field.
Draft wording must not be confused with current law
As of the review date, the production MCP described 947 SE as INTRODUCED, at the initiation stage, not enacted, and recorded no relationship to an enacted law. The official Riigikogu page likewise showed only initiation-stage proceedings, although it contained later events missing from the MCP snapshot.
Accordingly:
- existing VÕS, IKS and Creditors and Credit Intermediaries Act provisions remain the binding national rules;
- the bill PDF proves what the Government proposed on introduction;
- the memorandum explains the proposal but does not itself amend the law;
- Annex 1 comments may identify weaknesses without changing the introduced bill; and
- only a later enacted and published Riigi Teataja text could establish the final amendment and commencement rules.
The distinction is essential for policy work. A system may prepare for proposed duties, but it should not label them “current Estonian law” before enactment and entry into force.
Source-text and MCP audit findings
Production research used one Discover, two source-language Searches and four exact Fetches. All seven calls used the configured bypass token and charged zero. The dossier, bill, explanatory memorandum and analytical annex were then reviewed through the exact authenticated full-text downloads returned by the MCP.
Two defects were confirmed.
The MCP proceeding history is incomplete
The MCP flow says the latest legislative activity was introduction on 15 June 2026. The live official page also records acceptance for proceedings on 18 June and a committee sitting scheduled for 17 September.
The 18 June event predates Legalcode's stated 4 July source observation, so this is not only ordinary post-ingest drift. requests complete event extraction, a defined policy for future scheduled events, refresh of active dossiers and canonicalisation of the redirected matter URL.
The official source documents contain apparent drafting errors
The explanatory memorandum correctly identifies Directive (EU) 2023/2225 in most passages, but twice refers to 2023/225. Direct extraction from the official PDF confirms that Legalcode did not introduce the missing digit.
The bill's proposed §403⁴(11) also contains krediidiandaja where the surrounding text uses krediidiandja. records both source-text anomalies.
Legalcode should preserve the official wording, prevent the malformed directive number from becoming a canonical EU-law relation, and expose a source-quality warning. Silently “correcting” the source text would destroy provenance; repeating the typo without warning would invite incorrect citations.
The unsupported DOCX and ASiC-E attachment variants were not treated as a separate defect in this review because the corresponding bill and memorandum PDFs were fetched successfully and the unsupported status was explicit.
Conclusion
Riigikogu matter 947 SE provides a well-structured legislative package for studying proposed changes to Estonian consumer-credit and creditworthiness rules. The exact proposal is in the bill; the Government's rationale is in the explanatory memorandum; Annex 1 tests the drafting choices; and the remaining attachments document implementation and consultation.
For creditworthiness assessment, the main proposals would prohibit social-media and special-category-data use, prevent reliance solely on payment history, require broader verification, add notices and human-review rights around register-based or automated refusals, and regulate access, accuracy, notification and disputes for relevant credit registers.
None of those draft provisions should yet be presented as binding law. The bill remained at the initiation stage on 13 September 2026, its MCP chronology is incomplete, and its official source documents contain identifiable drafting errors that must remain separated from the final enacted text.
Sources and audit issues
This article provides general legal information, not advice for a specific matter. Laws, facts and procedural deadlines may change the result. Follow the linked primary sources and obtain local advice before acting.