Chamber’s Active Role in Standing for the Interests of the Members

According to the Articles of Association, one of the most important purposes of the Chamber is to represent the interests of its members in the process of forming Estonian economic policy, and to participate in submitting proposals for improving legislation.

In 2021, we worked through approximately 5,500 pages of legislation-related materials and asked for the feedback of nearly 20,000 companies on the planned amendments of legal acts. As a result, we submitted 182 written positions on draft acts, intents to develop, activity plans and other documents to the ministries, Parliament and other authorities. Additionally, we made proposals for amending and updating existing legal acts. The Chamber’s representatives also participated in various working groups.

Overview of the most important activities and topics in 2021

• The Chamber prevented amendments on the Commercial Code that may be detrimental for the entrepreneurs.
• We made a proposal to make the regulation for remote work more flexible.
• We stood against the global corporate income tax reform decreasing Estonia’s competitive advantage.
• We made a proposal to postpone the increase of the excise duty on fuels. The proposal was taken into account.
• We made efforts to have the state alleviate restrictions on foreign labour.
• The Chamber’s work victory: some companies were exempt from the obligation to have their packaging reports audited.
• The Chamber did not support the new requirements related to health checks.
• We made a proposal to increase the tax-free limit for health promotion expenses.
• Concluding short-term employment contracts may become simpler.
• Agreement on variable hours could be allowed to be used for smaller commercial companies and other sectors.
• European Union climate package needs detailed impact analysis.
• We made yet another proposal for decreasing the administrative burden on employers in relation to fulfilling the legal instruments of seizure of salary.
• The state should not collect additional fee from entrepreneurs for performing its core tasks.
• We stood against the law allowing a small group of employees and employers extending the terms and conditions of their collective agreements on the entire sector.
• We made a proposal for establishing a voluntary health fund.
• We were against imposing a pollution charge on plastic packaging waste.
• Labour market services and assistance should be more motivating for going back to work.
• We were against increasing bureaucracy.
• The Chamber was against establishing a target for recycling of sales packaging.
• Several of the Chamber’s proposals were entered into the whistle blower’s protection act.
• There should be no charge for the traders for the settlement of consumer disputes.
• We made proposals regarding the Public Procurements Act.
• Data of the Commercial Register should be made available without a charge.
• The Chamber was against several unreasonable amendments of the Packaging Act.
• Entrepreneurs have now the opportunity to share their tax behaviour assessment with their transaction partners.
• Failure to submit annual reports in due time should be more visible.
• We made several proposals for alleviating the covid-19 crisis.
• We made a proposal according to which occupational health doctors should communicate more with employers upon researching occupational illnesses.
• It should be possible to decrease the interest rate on postponed tax arrears also in 2022.
• Consumer credit rules should not be imposed on payment in instalments without a fee.
• The Chamber did not support establishing a national quality assessment system for refresher training institutions.
• The Chamber’s work victory: it is no longer required to obtain a safety card for each hazardous chemical.
• We made 22 proposals for the amendment of the Public Water Supply and Sewerage Act.
• The general terms and conditions for assistance granted from the recovery facility became more entrepreneur-friendly as a result of the proposals made by the Chamber.
• A person providing a service through a platform should not be considered as an employee.
• Legislative drafting should be made more transparent.

The Chamber prevented amendments on the Commercial Code that may be detrimental for the entrepreneurs
In the summer of 2021, the Ministry of Justice made public the Draft Commercial Register Act, which brings along several significant changes to the commercial law. The draft act establishes the Commercial Register Act as a new act and amends more than 30 acts, including over 100 amendments to the Commercial Code. For example, according to the draft act, the list of shareholders will, as a general rule, be kept by the Commercial Register and as a general rule the data of the shareholders will gain a legal meaning in the Commercial Register. Furthermore, the minimum requirement for share capital will be abolished, requirements for net assets will change and deletion of companies from the Commercial Register will become easier and faster in certain situations.

The Chamber submitted almost 20 amendment proposals for this draft act, and by today, the Ministry has taken several of the Chamber’s proposals into account. For example, as a result of the Chamber’s opposition, a provision was left out of the draft act, according to which if a creditor of a legal entity cannot satisfy their claims on the account of the assets of a legal entity, the creditor may request compensation of damages for themselves by a board member of the legal entity who has caused damages to the legal entity by violating their obligations. The Chamber strongly opposed this amendment because it would have significantly extended liability of board members and caused unequal treatment of creditors. Based on the proposal made by the Chamber, the Ministry also left out of the draft act the provision, which prohibited establishing in the articles of association that a share cannot be pledged if the list of shareholders is kept by the keeper of the Estonian register of securities. Processing of the draft Commercial Register Act reached the Parliament by the end of 2021 and according to the draft act, the majority of the amendments will enter into force on 1 February 2023.

We made a proposal to make the regulation for remote work more flexible
During previous years, the Chamber has repeatedly proposed to the state to amend the Occupational Health and Safety Act so that in case of remote work, employers would be responsible for the performance of only the requirements that they can control. A positive development is the fact that in 2021, the Ministry of Social Affairs presented a draft act that foresees exceptions for remote work. At the same time, it also imposes several unreasonable obligations on employers. Therefore we presented several proposals to the ministry in order to amend the draft act and make the exceptions regarding remote work more flexible, and ensure that there would be less overregulating. For example, we informed that entrepreneurs do not support the requirement according to which employers must design and equip a remote workplace even if the employer enables working onsite at the company and remote work is requested by the employee. According to the draft act, the amendments regarding remote work will enter into force at the beginning of 2023, but we made a proposal to make the date of entry into force earlier. As of the end of 2021, it was not known if and in which format will the draft act enter into force and if the ministry will take the proposals of entrepreneurs into account.

We stood against the global corporate income tax reform decreasing Estonia’s competitive advantage
The Chamber was against Estonia joining the global corporate income tax reform, because it makes the Estonian corporate income tax system less attractive and decreases our competitive advantage. Additionally, we face the real risk of losing in tax revenue. The planned corporate income tax reform will make the advantages of the Estonian income tax system for large group companies and their affiliates in Estonia non-existent. This, in turn, may decrease the interest of larger foreign companies in investing and creating jobs in Estonia. At the end of 2021, the European Union published a directive with which the member states transpose the global income tax reform into their law. In 2022, the Chamber will stand for ensuring that the directive has as little negative impact on the current Estonian corporate income tax system as possible.

We made a proposal to postpone the increase of the excise duty on fuels
Last year, the Chamber and other business organisations repeatedly sent to the Ministry of Finance as well as the Government the proposal to leave the excise duty on diesel fuel, natural gas and other fuels, and electricity on the current level, i.e. give up the plan to increase excise duty from 1 May 2022. The state heard us and postponed the excise duty increase by one year. Furthermore, the excise duties will be increased to a smaller extent.

We made efforts to have the state alleviate restrictions on foreign labour
In 2021, the Chamber made several proposals to the state in order to solve the problem related to quick fulfilment of the immigration quota. It is positive that the Ministry of the Interior has promised to develop a draft act in 2022, which would allow more aliens to work in Estonia on the basis of the residence permit beyond the immigration quota. For example, there is a plan for an amendment according to which aliens would have the right to request, after the end of the period of short-term employment, apply for the residence permit for employment for two years outside the quota. Furthermore, there is hope that in the future applying for residence permits beyond the quota will be open for aliens who are paid 1.5 times the Estonian average salary. The draft act will be prepared in 2022 and the amendments may enter into force from the beginning of 2023.

The Chamber’s work victory: some companies were exempt from the obligation to have their packaging reports audited
During recent years, we have repeatedly proposed to the state to release entrepreneurs from the obligation to audit packaging reports, because it means significant expenses for operators, but no positive impact. The state partially considered the Chamber’s proposal. In May 2021, amendment to the Packaging Act entered into force. According to the amendment, operators are required to have their packaging reports audited if they release more than 20 tons of packaging to the market in a year. Previously, the limit for the auditing obligation was 5 tons per year. As a result of the amendment, ca 600 entrepreneurs were exempt from the obligation to audit packaging reports in 2021.

The Chamber did not support the new requirements related to health checks
The Ministry of Social Affairs lead the development of the draft act that gives employers the obligation to commission from occupational health doctors, in addition to employee health checks, also the comprehensive analysis of the occupational health situation of the company and counselling of the occupational health doctor. The Chamber notified the Ministry that in the case of some of the entrepreneurs, establishing new requirements may be reasonable and necessary, but the solution included in the draft act should not be applicable as a minimum requirement for all employers, because that would mean over-regulation. Additionally, entrepreneurs lack surety that the situation would improve if amendments were to be entered into force. For example, it was highlighted that the occupational health doctors might not be able to assess or comprehend the problems related to a specific job and thus make proposals for designing a safer working environment. There is also the risk that the service will become burdensome and more expensive, primarily for small entrepreneurs. Additionally we proposed to the Ministry of Social Affairs, yet again, that family physicians could play a bigger role in performing health checks, especially in rural areas. At the end of 2021, it was not known if the Ministry would take the Chamber’s proposals into account.

We made a proposal to increase the tax-free limit for health promotion expenses
The Chamber turned to the Ministry of Finance and Ministry of Social Affairs with the proposal to increase the tax-free limit of health promotion expenses from the current €400 to €800 per year. Additionally, we made a proposal to add health tests (e.g. cardiac stress test, bloodwork), vaccinations (flu vaccine, vaccine against tick borne encephalitis) and paid health-care services (e.g. dental services, specialised doctor’s appointments) to the list of tax-free expenses. The ministries did not support the Chamber’s proposal.

Concluding short-term employment contracts may become simpler
During previous years, the Chamber has repeatedly proposed to the state to make the rules for concluding fixed-term employment contracts more flexible. Therefore it is very positive that in 2021, the Ministry of Social Affairs prepared a draft act that will give employers the right to conclude fixed-term employment contracts with the duration of up to 10 calendar days during six months without limit. We supported the planned amendment, but made four additional proposals to the ministry to ensure that the rules for concluding fixed-term employment contracts would be even more flexible. For example, we made a proposal to allow the new exception to be used during a period longer than just six months and that employers could have the right to conclude the fixed-term employment contract also without good reason. At the end of 2021, it was not known if, in which for and when the amendment concerning fixed-term employment contracts would enter into force.

Agreement on variable hours could be allowed to be used for smaller commercial companies and other sectors
The Chamber expressed its support to the amendments of the Employment Contracts Act that entered into force on 15 December 2021, which allow the major employers of the retail sector conclude variable hours agreements with their employees, i.e. agree on working time as a certain period. At the same time, we made a proposal to allow more flexible employment contracts to be concluded also by commercial operators with less than six employees. This proposal was not taken into account by the state. Furthermore, we informed the Ministry of Social Affairs as well as the Parliament that there is a need for variable hours´ agreements in others sectors besides retail.

European Union climate package needs detailed impact analysis
In the summer of 2021, the European Commission disclosed the climate package, which consists of more than ten legal acts and the volume of which is several thousand pages. In the letter sent to the ministry, we emphasised that the first step in Estonia should be to carry out a thorough impact analysis, which will help to understand, which solutions Estonia should prefer for achieving the climate goals. Furthermore, we also pointed out that the climate package should leave Estonia as many options as possible in order to decide how Estonia should achieve the climate goals agreed in the European Union. Work with the European Union climate agreement will continue in 2022.

We made yet another proposal for decreasing the administrative burden on employers in relation to fulfilling the legal instruments of seizure of salary
In 2021, the Chamber turned to the Parliament as well as the Ministry of Justice with the request to solve the concern of entrepreneurs in relation to fulfilling the legal instruments of seizure of salary. The problem concerns tens of thousands of employers who receive these instruments to seize salary of debtors from bailiffs. Fulfilling these requests is a complicated and time-consuming additional work for employers. In order to improve the situation, we made a proposal to amend the law so that in the future employers would be required to submit to the bailiffs information only on which account the employer’s salary is transferred. With this information, the bailiff will be able to deal with the specific account. The Chamber’s proposal was not taken into account and thus this problem was not solved in 2021.

The state should not collect additional fee from entrepreneurs for performing its core tasks
We were strongly against the amendments of the Competition Act according to which, certain monopolies should pay supervision fee to the Competition Board once a year. The amendment will have an impact on all entrepreneurs, because the monopolies are allowed to include the supervision fee in the price of services provided to final consumers. We informed the state that the core functions of the state, including supervision should still be funded from the state budget and not through imposing new fees. The Parliament did not listen to the Chamber’s critique and the amendments to the Competition Act entered into force on 1 January 2022.

We stood against the law allowing a small group of employees and employers extending the terms and conditions of their collective agreements on the entire sector
The state took into account several of the Chamber’s proposals to make the representation criteria stricter for the trade unions and employers’ confederations that are allowed to extend the terms and conditions of collective agreements. Initially, the Ministry of Social Affairs wanted to establish the requirement of representation only for employers’ confederation, but by the proposal of the Chamber, the representation criterion was also established for trade union. By the proposal of the Chamber, the ministry also doubled the representation criterion of the employers’ confederation. The amendments to the Collective Agreements Act entered into force on 22 November 2021.

We made a proposal for establishing a voluntary health fund
In March, we contacted the Ministry of Finance with the proposal to establish a voluntary health fund or health savings account where a person or their employer could collect money and if necessary the employee could use these funds for paying for healthcare services. Establishing a health fund would be an additional opportunity for the employee to cover expenses related to unexpected health concerns and that would mean additional funding for our health care system. Conditionally, this fund could also be compared to the third pillar of pensions. The Ministry of Finance did not consider establishing the health fund necessary.

We were against imposing a pollution charge on plastic packaging waste
The Chamber and several specialised associations were strongly against the proposal of the Ministry of the Environment to establish a pollution charge for non-recycled plastic packaging waste at €370 per ton. Establishing the pollution charge would increase motivation to leave the plastic packaging quantities undeclared, thereby increasing unfair competition. It would also be difficult to perform supervision over the new charge. Additionally, if the new charge would be established, there would be a risk of double taxation. At the end of 2021, it was not known if the Ministry of the Environment would be giving up their idea or not.

Labour market services and assistance should be more motivating for going back to work
In the autumn of 2021, the Ministry of Social Affairs came up with the idea of reorganising the rules for offering labour market services and assistance in order to ensure better flexibility of the system in the future and react operatively to the changes of the labour market as well as the needs of the target groups. The Chamber let the ministry know that amending the regulations might be necessary to a certain extent, but the biggest challenge in the field of employment today is to motivate people to come to the labour market and that cannot be done only through amending regulations. We have received feedback from companies that unemployed persons are not willing to go back to work, because the unemployment benefits paid to them do not motivate quick return to work. Considering that many areas and regions in Estonia face labour shortages, it is an important problem that should be dealt with and it would be important to find a solution for that within the framework of the same draft act. The draft act will be prepared in 2022.

The Chamber was against establishing a target for recycling of sales packaging
Together with several specialised associations, we were against establishing a target for recycling of sales packaging, because it is difficult for the state to carry out supervision over this requirement and additionally, the change would bring along an unreasonable expense for honest packaging operators. The state heard our critique and gave up establishing the target.

Several of the Chamber’s proposals were entered into the whistle blower’s protection act
The Ministry of Justice took into account several of the Chamber’s proposals regarding the draft Notifier Protection Act, which is also known as the Whistle Blower’s Protection Act. For example, initially the draft act stated that only email address, telephone number, regular mail or direct meeting can be considered as internal or external notification channel. The Chamber made a proposal to allow other solutions to be used as the notification channel, for example an online platform. The Ministry of Justice heard the Chamber’s proposal and changed the wording so that it would be technology neutral. By the Chamber’s proposal, the draft act now also includes a provision that allows group companies sharing or jointly managing internal notification channels. Previously, the draft act stated that the notification channels can be shared only by companies that have up to 249 employees, but there was no exception for group companies. With the request from the Chamber, the ministry has explained in a clearer manner, in which cases does the new law protect the whistle blower and in which cases it does not. The new act will enter into force on 1 June 2022.

We were against increasing bureaucracy
The Chamber was against several initiatives, which would mean more administrative burden and increased expenses for companies, but would not help to improve the situation. For example, we informed the Ministry of Social Affairs that Estonia should not support the European Union salary transparency directive, according to which employers would have several additional obligations, e.g. developing career rules, and large companies would have new reporting obligations. The Chamber highlighted that establishing the directive would not facilitate decreasing the gender pay gap, but will significantly increase the administrative burden on Estonian companies.

Additionally, the Chamber did not support the initiative by the European Commission, which would increase the number of the companies that have to describe sustainability-related circumstances in their activity report, e.g. environmental and social impact of their activities, human resources management, following of human rights, fight against corruption. We understand the need to solve problems related to sustainability, but we doubted if constant increasing of administrative burden on companies in several areas would be the most reasonable and targeted measure for that.

There should be no charge for the traders for the settlement of consumer disputes
While at the moment, settlement of disputes between traders and consumers is free of charge at the consumer disputes committee, it might become a service for a fee. Namely, the Ministry of Economic Affairs and Communications has prepared a draft act that imposes traders with the obligation to pay to the state a processing fee of up to €150 if the consumer disputes committee satisfies a consumer’s claim against the trader. The Chamber informed the ministry that entrepreneurs are against this amendment. We see that the amendment might pose a risk of malicious complaints being filed to the committee and force traders to satisfy all small-value consumer complaints. At the end of 2021, it was not known if the ministry would give up the plan to establish the fee or not.

We made proposals regarding the Public Procurements Act
In April, the state sent for approvals, the draft act for the amendment of the Public Procurements Act and related acts, which foresees several new things in the field of public procurements. For example, there is a plan to extend the regulation for reasoning business secrets for all public procurements and not only for the tendering procedure. We supported several of the planned amendments and we also made proposals for improving the law. By the end of 2021, the draft act was being processed by the Parliament.

Data of the Commercial Register should be made available without a charge
Last year, the Chamber repeatedly turned to the state with the proposal to make data contained in the Commercial Register available for companies free of charge as quickly as possible. Such change allows companies to fulfil their legal obligations, e.g. those related to the Money Laundering and Terrorist Financing Prevention Act in a simpler and cheaper manner. Furthermore, the amendment would allow easier and cheaper background checks on transaction partners. The state promised that they will make the data on companies and ownership relations of companies freely available for everyone in machine-readable format as soon as possible, but is questionable if this will happen in 2022.

The Chamber was against several unreasonable amendments of the Packaging Act
For example, the draft act stated that the food that is meant for immediate consumption and does not require processing should, from the year 2026, be packaged in reusable packaging. This means that for example, canned fish, curd desserts and cheeses should have been packaged in reusable packaging in few years. We were against this amendment, because this obligation would have extended to too many foods and today there is no respective technology. Furthermore, the requirement for reusable packaging may also be in contradiction with the principle of free movement of goods. The Chamber was also strongly against the proposal to establish a 50-cent sales price for single-use food packaging. If initially, the Parliament was supposed to pass this draft act in 2021, the opposition from the Chamber and various specialised associations meant that the processing has not been completed and the discussions continue in 2022.

Entrepreneurs have now the opportunity to share their tax behaviour assessment with their transaction partners
In September 2021, with the support from the Chamber, the Tax and Customs Board created an opportunity for companies to share their tax behaviour assessment with their business partners if they wish. The assessment shows how the company seems to the Tax and Customs Board. A company can decide if and to which persons the Tax and Customs Board should provide access to the company’s tax behaviour assessment. Previously, the Tax and Customs Board was allowed to share such assessment only with the concerned company.

Failure to submit annual reports in due time should be more visible
The Chamber proposed to the Ministry of Justice to highlight better in the e-Commercial Register that a company has failed to submit their annual report in due time. The respective information should be visible in the e-Commercial Register similarly to the declarations that have not been submitted or information on tax arrears. The ministry informed the Chamber that the respective modification will be made to the e-Commercial Register in the near future.

We made several proposals for alleviating the covid-19 crisis
In January we and the Finnish Chamber turned to the governments of Estonia and Finland to have the states alleviate the planned restrictions on travel. Although the joint address of the chambers was not taken into account, we initiated a dialogue. For example, our proposal was discussed by the prime ministers of both countries during their first meeting. In March, we turned to the Ministry of Social Affairs with the wish to allow vaccination of employees at work. Such option was created, but much later than we had hoped. In April, we submitted several proposals for amendments to the government’s plan, which gives individuals, companies and the states instructions for limiting the spread of covid-19 according to the risk levels and gives and overview of the short- and long-term activities in relation to solving the covid-19 crisis.

We made a proposal according to which occupational health doctors should communicate more with employers upon researching occupational illnesses
The Ministry of Social Affairs took into account the previous proposal of the Chamber and added to the draft act the principle according to which the law should clearly state that upon diagnosing occupational illnesses, the occupational health doctor should also communicate with the employer. The current wording of the Act allows occupational health doctors to establish a causal relation between the occupational illness and working environment only on the basis of documents and statements of the employee. The draft act obliges the occupational health doctors to visit, if necessary, the working environment when investigating the occupational illness. It is also commendable that the draft act clearly states that the occupational health doctor should also talk to the employee, and if necessary, ask additional health data from the employee. According to the draft act, the amendments will enter into force on 1 September 2022.

It should be possible to decrease the interest rate on postponed tax arrears also in 2022
In December 2021, the Chamber turned to the Ministry of Finance with the proposal to extend the right of the Tax and Customs Board to decrease the interest rate on postponed tax arrears to the extent of 100 percent from the date of passing the decision to postpone until the end of the year 2022. The amendment would help some sectors, e.g. hospitality sector overcome the economic difficulties. At the end of 2021, it was not yet known if the state would take the Chamber’s proposal into account.

Consumer credit rules should not be imposed on payment in instalments without a fee
The Chamber informed the Ministry of Justice that Estonia should not support the amendment to the Consumer Credits Directive according to which the rules of the Consumer Credits Directive would be applicable also for the contracts in the case of which credit is given without an interest or additional fees. According to this, the requirements of the directive should be fulfilled by, for example, companies that offer payment in instalments for a sofa by not charging additional fee for it. As a result of the amendments, such companies might have the additional obligation to apply for activity license, requirements for employee competence and requirement to present pre-contract information on credit. In the Chamber’s opinion, it is not reasonable to treat such companies as equals of creditors.

The Chamber did not support establishing a national quality assessment system for refresher training institutions
In the spring of 2021, the Ministry of Education and Research came up with the idea to develop a quality assessment instrument to establish these providers of refresher trainings who are able to ensure acceptable quality. The Chamber is against establishing the national quality assessment system for refresher training institutions, because that would mean unreasonable administrative burden and expenses to the public sector as well as educational institutions, but at the same time it does not ensure automatically high-quality refresher training. Furthermore, there is a risk that the amendment would unreasonably restrict the market of refresher training. Discussion of the draft act will continue in 2022.

The Chamber’s work victory: it is no longer required to obtain a safety card for each hazardous chemical
By the proposal of the Chamber, the cases when an employer is not required to obtain a safety card of hazardous chemical were added to the legal act in May 2021. Hazardous chemicals are, among others, dish washing liquid, laundry capsules and other domestic chemicals available for everyone in normal grocery stores. Safety cards are no longer required if the hazardous chemicals are offered to the public or if the hazardous chemical is equipped with sufficient information so that employers could apply relevant measures for risk management.

We made 22 proposals for the amendment of the Public Water Supply and Sewerage Act
The Chamber and several specialized associations submitted several proposals to the Ministry of the Environment for amending the draft act. The proposals concerned directing hazardous substances and other pollutants to the sewerage, calculation of the fee for pollution exceeding the limits, informing of consumers of the test samples and requirements for persons responsible for the work of potable water and waste water facilities. The Ministry of the Environment took into account several of the proposals. Discussions on the draft act will continue in 2022.

The general terms and conditions for assistance granted from the recovery facility became more entrepreneur-friendly as a result of the proposals made by the Chamber
The Ministry of Finance took into account the most important proposals of the Chamber regarding the draft regulation that establishes the general terms and conditions for the assistance (approximately 900 million euros) paid on the basis of the European Union recovery and resilience facility. For example, the initial version of the draft act stated that if the state gives up the plan to implement a reform or investment agreed on in the recovery plan, the state will reclaim the assistance allocated for the project of the entrepreneur. This means that entrepreneurs would have had to pay back the assistance also if they had not violated any of the conditions applicable for obtaining the assistance. With the proposal from the Chamber, the Ministry of Finance left this provision out of the regulation.

A person providing a service through a platform should not be considered as an employee
The Chamber of Commerce informed the Ministry of Social Affairs that Estonia should not support the European Union directive that changes the contracts of persons providing services through platforms into employment contracts. This directive is not necessary, because Estonia already has a functioning regulation for assessing if a person providing a service through a platform is working under employment contract or provides a service based on a contract under the law of obligations. Furthermore, as far as is known to us, there are currently no major issues with the social guarantees for persons providing services through platforms, because in many cases the service is provided additionally besides the main job, or the fee earned from the service is sufficient to obtain health insurance. Therefore, the directive will mean over-regulating and unreasonably decreases flexibility of working through a platform. By the end of 2021, Estonia had not yet formed its position regarding the directive.

Legislative drafting should be made more transparent
We made several proposals to the state for making lobbying more honest and improve the transparency and clarity of the entire legislative drafting process. For example, we made a proposal that if an amendment is made in a legal act by a proposal of an interest group, at least the explanatory memorandum should clearly state, which interest group made the respective proposal. This principle should be applicable in all cases, irrespective of if the interest group made the proposal orally at a meeting or the proposal was sent in writing.

Our lawyers advised almost 170 companies
Members of the Chamber of Commerce actively used the services of our lawyers in 2021. The lawyers advised our members in all the important areas, which the companies have to deal with in their daily activities (e.g. contracts, labour law, public procurements). Consultations related to contracts continued to be the most popular among entrepreneurs. We helped companies with drawing up various contracts (mainly sales contracts and contracts for services), making amendments to contracts and carrying out analyses of contracts.