The Chamber's active role in representing the interests of the members

According to the articles of association, one of the most important aims of the Chamber is to represent the interests of its members in shaping Estonia’s economic policy and to participate in the submission of proposals for improving legislation.

In 2023, we worked through more than 7,500 pages of legislative materials and submitted 198 written opinions on drafts, drafting intentions, action plans and other documents to ministries, the Parliament and other state agencies. In addition, we made proposals to amend and supplement existing legislation. Representatives of the Chamber also participated in various working groups. In addition, we prepared reviews the most important changes to the law for businesses.

An overview of the most important activities and topics of 2023

• Business organisations demanded activities from the government that would not adversely affect the competitiveness of Estonian companies. 
• We proposed to increase the limits for audit and review.
• We sent our proposals for a coalition agreement to the new government.
• We proposed to reduce the number of public sector workers.
• The Chamber does not support car tax.
• We proposed to raise the tax-free cap on health promotion costs to €250 per quarter.
• We proposed to increase the tax-free limit on daily allowances for business trips abroad.
• The regulation of weekly rest periods should be amended because of the judgment of the European Court of Justice.
• The rules for variable hour agreements need to be made more lenient and flexible.
• The Chamber is sceptical about the proposal for the late payments regulation.
• In order to encourage the introduction of e-invoicing through the law, account must be taken of the increase in the costs for small businesses.
• Achievement: companies do not have to register thousands of new devices in the FOKA register.
• Achievement: employers will also be able to pay sickness benefit exempt of social tax to a pregnant worker who has fallen ill.
• We support a change that allows employees who have been sick for a long period of time to work part-time during their sick leave.
• Distribution of the immigration quota across sectors does not solve the real problem.
• We opposed the creation of unnecessary competition supervision procedures.
• According to the Chamber, Estonia should not have waived its participation in Expo 2025.
• The Chamber requested to drop raising environmental charges in 2024.
• We objected to the rapid increase of the state fee rates.
• The intention to develop the Climate Act is too general.
• The Chamber did not support raising the income tax on regular dividends.
• We objected to increasing the VAT rate on accommodation services to 22 per cent.
• We support the increase in road user charges for more polluting trucks.
• We proposed to waive changes to the credit institution’s advance payments.
• Organisation of value-based public procurement is a step in the right direction.
• The Chamber is critical of the planned waste reform.
• The Green Claims Directive is necessary to reduce green washing but needs a number of further improvements.
• The proposed obligation to repair goods should be more clearly and specifically formulated.
• The conditions for restricting the foundation of problematic companies must be specified in the law.
• Donations to help Ukraine could also be exempt from income tax in 2024.
• Two achievements in relation to packaging reporting.
• The process of termination of the employment contract due to decrease in the ability to work of an employee does not need to be changed.
• The Protection of Whistleblower Act must also provide protection against malicious notification.
• Shelter places and shelter arrangements need clearer rules.
• There should be no requirement that company cannot fulfil in practice.
• We support the rounding rules for 1 cent and 2 cent euro coins.
• Four achievements related to packaging.
• The state should also provide support measures to the vital service provider.
• The Chamber supports the state’s plan to abolish the obligation to issue paper purchase receipts.
• The new framework for labour market statistics must not increase the administrative burden on businesses.
• Procedural practices and information systems related to visas and residence permits must be made more user-friendly.
• On the proposal of the Chamber, the conditions of the support measure to ensure security of electricity supply were relaxed for companies.
• The Chamber opposes the prohibition on stopping vehicles on the sidewalk for the purpose of loading cargo.
• Fire safety requirements for the storage of combustible materials and hazardous substances should include limit quantities and restrictions for companies.
• Chamber’s achievement: the development support for entrepreneurship in south-east Estonia may also be used for sales and marketing activities in the foreign markets.
• We expressed support for changes that reduce the administrative burden on companies involved in articles of precious metal.
• The Chamber did not consider it justified to increase the food and veterinary supervision fee by up to 85 per cent.
• The Chamber supports the European Commission’s plan to introduce a single income tax system for head offices of small and medium-sized companies.
• The global minimum income tax requirements should be met once international guidelines are in place.
• The Chamber put forward a number of proposals for the proposed regulation of micro-qualification training.
• We support the European Commission’s proposal to reduce the burden on companies operating across borders.
• Draft legislation must not be processed at turbo speed.
• Protecting Estonia’s positions in EU legislation must become more transparent.

Business organisations demanded activities from the government that would not adversely affect the competitiveness of Estonian companies 
In October, the Chamber, together with 33 business organisations, approached the government to ensure that in the recession no decisions were taken that were detrimental to the competitiveness of Estonian companies. For example, in our appeal, we pointed out that, in the current situation, it is not reasonable to introduce new taxes or raise existing taxes that have not been incorporated into legislation. We understand the desire of the state to move towards a balanced state budget, but this objective must not take precedence. We also pointed out that besides maintaining Estonia’s independent defence capability, the country’s priority must be to improve the competitiveness of the business environment or at least to preserve it. At the end of 2023, the Minister of Finance confirmed it was unwise to impose new taxes in the current recession situation. 

We proposed to increase the limits for audit and review 
At the end of May, we approached the Ministry of Finance with a proposal to raise audit and review thresholds, which have remained unchanged since 2016. Raising the thresholds would help reduce the costs and workload of accounting entities. The Ministry of Finance has promised to implement the Chamber’s proposal. The corresponding draft act is due to be finalized in early 2024, and under the original plan, the new audit and review limits should begin to apply to the 2024 annual report.   

We sent our proposals for a coalition agreement to the new government 
In April, we sent our comments and proposals to the new government regarding the implementation of the coalition agreement of the coalition for 2023-2027. We mainly touched on the subject of tax policy. For example, we pointed out that tax changes must not be made in a hurry and without impact analysis. In addition, we stressed that before introducing new taxes or increasing tax rates, every effort must be made to collect the taxes imposed so far and to use all measures to reduce public expenditure that do not directly concern the provision of primary public services.   

We proposed to reduce the number of public sector workers 
In early September, the Chamber proposed to the Ministry of Finance to reduce the number of employees in those public sector organizations involved in policymaking, administration, management, grant-sharing and supervision. Above all, we meant ministries, various agencies and inspectorates, grant-providing organisations and social security funds. According to our proposal, the number of people working in the aforementioned organisations could be reduced by 10 per cent in 2024 and by 10 per cent in 2025 as well. The aim of the amendments was to make the work of the public sector more efficient and to reduce the costs of the state budget. 

The Chamber does not support car tax 
We informed the Ministry of Finance in October that the Chamber does not support the introduction of any new tax, including motor vehicle tax, in the current recession situation. We also submitted a number of proposals to amend the draft act if the Ministry still wants to introduce a car tax. For example, we proposed omitting a point in the draft that provides for an annual tax based on the age of the vehicle and a registration fee for private individuals. According to the Chamber, such a distinction is not in accordance with the polluter pays principle. In addition, we proposed to amend the draft legislation so that the car tax should only be paid on vehicles entered in the Estonian motor register which are in active use and have valid motor third party liability insurance and the tax period would be related to the validity of the insurance. By the end of 2023, the draft act of the car tax failed to reach the Parliament.

We proposed to raise the tax-free cap on health promotion costs to €250 per quarter 
In March 2023, we proposed to both the Ministry of Finance and the Ministry of Social Affairs to increase the tax-free limit on employee health promotion costs from the current 100 euros to 250 euros per employee per quarter. In addition, we proposed to supplement the list of tax-free costs for health promotion with costs for health services and massage services so that employers have more open opportunities to support the promotion of the health of their employees, including prevention and alleviation of both mental and physical health problems. The ministries did not take the Chamber’s proposal into account. 

We proposed to increase the tax-free limit on daily allowances for business trips abroad 
At the end of March, together with the Estonian Association of International Road Carriers, the Estonian Employers’ Confederation and the Estonian Federation of Construction Companies, we proposed to renew the tax-free cap on daily allowances for business trips abroad, which has remained unchanged since 2016. We proposed raising the tax-free limit on daily allowances for business trips abroad for the first 15 days up to 75 euros per day, for the remaining 16-31 days up to 50 euros per day. In addition, we proposed an alternative solution to eliminate the difference in the tax-free threshold by day and to set a single limit for all days over a month of up to EUR 65 per day. The Chamber’s proposal was not taken into account. 

The regulation of weekly rest periods should be amended as result of the judgment of the European Court of Justice 
At the end of November, the Chamber proposed to the Ministry of Economic Affairs and Communications that the wording of the regulation on weekly rest periods provided for in the Employment Contracts Act be amended in such a way that the daily consecutive rest period of an employee working on the basis of a schedule, together with the consecutive weekly rest period, must be at least 36 hours and other employees must have at least 48 hours. The proposal is the result of a ruling by the European Court of Justice that found that daily rest periods should also be added to weekly rest periods. This means that, according to the new interpretation, an employee working on the basis of a schedule in Estonia must be given an uninterrupted rest period of 47 hours once a week instead of the previous 36 hours and at least 59 hours for other employees instead of the previous 48 hours. Thus, without amendment of the Employment Contracts Act, the uninterrupted rest period will be extended by the daily rest period, i.e. 11 hours, and many employers will have to rearrange the existing work schedules. The Chamber’s proposal was not taken into account, and the Labour Inspectorate has confirmed that work schedules must be consistent with the new interpretation from early 2024. 

The rules for variable hour agreements need to be made more lenient and flexible 
From 15 December 2021 to 14 June 2024, an employer operating in the retail sector will be able to conclude a variable-hour agreement with their employee, i.e. to agree on working time for a specified period, if certain conditions are met. According to the Chamber, the current restrictions on entering into a variable hour agreement are too rigid and therefore we made several proposals to the Ministry of Social Affairs to lighten the rules. Among other things, we proposed allowing variable-hour agreements to be concluded in other sectors, and smaller employers could also be able to conclude such agreements. As of the end of 2023, it was not known if and what changes were planned to be made to the regulation of variable-hour agreements. 

The Chamber is sceptical about the proposal for the late payments regulation 
We oppose the European Commission’s proposal for the regulation setting a maximum 30-day deadline for payment of the invoice, imposing an obligation to charge default interest and EUR 50 in debt collection costs for each delay and adding an obligation for Member States to monitor the timely payment of invoices. Such an initiative is overregulation and the European Commission should not intervene in such detail in business-to-business relations. At the end of 2023, it was not known what the Estonian position on this initiative would be. 

In order to encourage the introduction of e-invoicing through the law, account must be taken of the increase in the costs for small businesses
In April, the Ministry of Finance disclosed the idea of amending the Accounting Act, according to which companies will have the opportunity to require the seller to submit an e-invoice. The Chamber estimates that the proposed change is overregulation, leading to higher burden and cost increases for small businesses. The Ministry of Finance came forward with the corresponding draft act at the end of 2023 and the procedure for this draft will continue in 2024. 

Achievement: companies do not have to register thousands of new devices in the FOKA register
In February 2023, the Chamber proposed to the Riigikogu not to pass the draft on Amendments to the Atmospheric Air Protection Act, initiated by the Environment Commission, which would have placed an obligation on companies to register up to 20,000 additional devices, such as refrigerated cars and heat pumps, in the FOKA Register. The Parliament listened to us and the draft act was not passed as a law. This prevented an extensive increase in administrative burden for businesses. 

Achievement: employers will also be able to pay sickness benefit exempt of social tax to a pregnant worker who has fallen ill 
On 1 December 2023, a proposal by the Chamber entered into force in the Social Tax Act, according to which employers are also able to pay sickness benefit free of social tax to pregnant workers if they so wish. In the past, this was only possible for a non-pregnant worker. 

We support a change that allows employees who have been sick for a long period of time to work part-time during their sick leave 
In May, the Ministry of Social Affairs came up with a draft amendment to the Health Insurance Act, according to which an employee is permitted to agree with the employer in the future that the employee may work at least part-time during the sick leave if he or she has been on the sick leave for two months. The Chamber supports this amendment, but in order to increase the freedom of agreement between the employee and the employer, we proposed that the employee may, by agreement between the parties, take up work earlier during the sick leave, that is to say from the 30^th day of sick leave. By the end of 2023, it was not known if and how the ministry would move forward with this draft act.

Distribution of the immigration quota across sectors does not solve the real problem 
The Ministry of the Interior proposed 1,303 as an immigration quota for 2024, which is distributed across different areas. The Chamber wants the immigration quota to remain freely distributed. Since the demand for foreigners and the need of Estonian entrepreneurs for residence permits falling under the immigration quota are significantly higher than the immigration quota, the distribution of the quota cannot solve the real problem but involves an additional artificial restriction. The ministry took the Chamber’s proposal into account, at least in part, because there will be just over a thousand residence permits out of the quota for 2024 will be for free distribution in 2024. 

We opposed the creation of unnecessary competition supervision procedures 
The Chamber opposed the plan of the Ministry of Justice to introduce a new type of procedure for dealing with antitrust violations, the competition oversight procedure, during which the Competition Authority would have extensive rights to penalize companies for antitrust violations during the administrative procedure. In the opinion of the Chamber, the existing regulation on misdemeanour proceedings could be supplemented instead of creating a new type of procedure. By the end of 2023, this draft act had not entered the proceedings of the Riigikogu. 

According to the Chamber, Estonia should not have waived its participation in Expo 2025 
The Chamber has previously repeatedly supported Estonia’s participation in the 2025 Osaka Expo. It was very surprising to us that Estonia decided not to participate in Expo. We proposed to review this decision, but it found no support from politicians. It is unclear how and why the decision not to participate in Expo was reached. We approached different ministries and the Foreign Affairs Committee of the Riigikogu on this topic, but we did not get a good answer to our questions. In our opinion, it is particularly important for Estonia as a small country and in the current security situation to take advantage of all possibilities to make itself more visible and tell its story. 

The Chamber requested to drop raising environmental charges in 2024
In September, the Ministry of Climate came up with a draft to establish new pollution charge rates for the release of pollutants into ambient air, water bodies, groundwater and soil and for the disposal of hazardous waste and shale waste. The Chamber saw a number of significant problems in the draft act. For example, the increase in environmental charges was not related to the verified extent of the resulting environmental impact, there was no impact analysis, the draft was hastily prepared and the environmental charges were set only until 2027, which does not provide sufficient investment certainty for companies. We proposed not to increase environmental charges in 2024 and, in cooperation with the affected companies, to develop a reasoned and long-term environmental charges system in 2024, but this proposal was not taken into account by the Ministry of Climate or the Environmental Commission of the Parliament. The Parliament passed the amendments in December 2023 and the fees will increase from 1 July 2024. 

We objected to the rapid increase of the state fee rates 
In September, the Ministry of Finance issued a draft to increase, as a matter of urgency, the state fee related to environmental protection permits, maritime sector and land transport, as well as the state fee for activities performed on the basis of the Railways Act, the Building Code, the recognition of professional qualifications and the Electronic Communications Act. The Chamber informed both the Ministry and the Finance Committee of the Riigikogu that it was not reasonable to increase state fees without justification and as a matter of urgency. For example, the draft act included a provision to increase the state fee for environmental protection permits by four times, but there were no substantive reasons for this. Neither the Ministry nor the Parliament took our criticism into account. 

The intention to develop the Climate Act is too general
The Ministry of Climate took the first steps to work out a climate law in 2023. In September, an intention to develop a climate law was prepared in order to set climate targets, promoters, financial resources and accompanying commitments based on economic sectors. According to the Chamber, the intention to develop was too general and broad and there was no reference to more precise activities and the effects they might have. For example, the intention to develop was not specific enough to provide legal clarity, legal certainty and investment certainty for companies. The drafting of the Climate Act will continue into 2024.

The Chamber did not support raising the income tax on regular dividends 
The Chamber opposed an amendment to the Income Tax Act, under which the income tax rate on regular dividends will rise from the current 14 per cent to 22 per cent from 2025. This change reduces confidence of companies in a stable tax environment and also reduces investment security. Criticism from the Chamber was not taken into account, with the change coming into effect from 1 January 2025. 

We objected to increasing the VAT rate on accommodation services to 22 per cent 
The Chamber opposed the idea of the Ministry of Finance to increase the VAT rate on the accommodation sector from 9 per cent to 22 per cent. Nor did we consider it right for the amendment to be dealt with as a matter of urgency and without a substantive discussion. In June, the Riigikogu made the decision to increase the VAT rate on accommodation to 13 per cent from 2025.

We support the increase in road user charges for more polluting trucks 
The Chamber supported a proposal by the Ministry of Economic Affairs and Communications to increase the road toll on trucks for trucks belonging to the more polluting EURO-exhaust class from 1 January 2024. The change is necessary to incentivise more road transport operators to invest in less polluting trucks. At the same time, we proposed to the Ministry not to increase the road toll for trucks with exhaust gas class EURO VI or less polluting. This proposal was not taken into account. Road user charges for trucks increased from 1 January 2024. 

We proposed to waive changes to the credit institution’s advance payments 
The initial version of the draft act provided that from 2025, the 22 per cent rate would apply to advance payments by credit institutions instead of the current 14 per cent. The Chamber opposed the change because it would reduce the availability of loan capital for all businesses. The Riigikogu decided in June to increase the tax rate on advance payments to 18 per cent. 

Organisation of value-based public procurement is a step in the right direction 
The Chamber supported the plan of the Ministry of Finance to introduce strategic principles for public procurements, according to which, public procurements would have to become more environmentally sustainable, socially responsible and supportive towards innovation. 

The Chamber is critical of the planned waste reform
The Chamber does not support the introduction of a fee for placing packaging on the market or a target collection rate or recycling rate for sales packaging. We also asked several questions and made suggestions regarding the idea of the Ministry to switch to collection from the place where packaging waste is generated. We are critical of the waste reform because it will lead to additional costs for companies in tens of millions of euros, but it is not clear whether and how the planned changes will contribute to meeting the environmental targets. The Ministry of Climate will prepare the respective draft act in the first half of 2024. 

The Green Claims Directive is necessary to reduce green washing but needs a number of further improvements 
In spring, the European Commission published a proposal for a Green Claims Directive obliging companies to submit reasoned and verified environmental claims and labels on products and services. Green claims include, for example, the following claims: “packaging made of 30% recycled plastic”, “carbon neutral transport” and “bee-friendly juice.” The Chamber supports the aim of the directive, but stressed that the solution to be created must be simple, must not impose unreasonable costs and administrative burdens on businesses, and that the requirements contained in the directive must also be subject to effective supervision by the supervisory authorities. The debate on the wording of the Directive will continue in 2024. 

The proposed obligation to repair goods should be more clearly and specifically formulated
The Chamber generally supports the European Commission’s proposal for a regulation on the improvement of goods, which requires manufacturers of certain goods to be obliged to repair goods if the consumer so requests. We consider it positive that, according to the Commission’s proposal, repairers are not obliged to repair goods free of charge, but we believe that the proposal could be clarified in terms of situations in which repairs should be considered impossible. The debate on the proposal for a regulation will continue in the EU in 2024. 

The conditions for restricting the foundation of problematic companies must be specified in the law 
In November, the Ministry of Justice revealed the idea of amending the Commercial Register Act, which seeks to limit the foundation of potentially troubled companies. According to the idea, there would be a restriction in the law that in the case of repeated infringements (in particular, failure to submit the annual report, as well as other possible problems such as difficulty of contacting, number of unmanaged companies, number of deletions initiated by the registrar, etc.) it would not be possible to start a new company. The Chamber will support the initiative only if the law sets out specific conditions and circumstances, when restrictions will apply to a company, and the changes do not disproportionately restrict the freedom to conduct a business. The corresponding draft act is expected to be finalized in spring 2024.

Donations to help Ukraine could also be exempt from income tax in 2024 
In September, the Chamber approached the Ministry of Finance and the Finance Committee of the Parliament with a proposal to extend for at least one year the exemption for companies under which donations made to assist Ukraine are not subject to income tax if the donation is made to the following organisations: NGO Estonian Refugee Aid, NGO Mondo, Ukrainian Cultural Centre, National Defence Promotion Foundation, Estonian Red Cross, Estonian Rescue Association and Rotary Club Tallinn Vanalinn. The Parliament initiated a draft amendment to the Income Tax Act in 2023, which included the proposal of the Chamber, but unfortunately the Parliament failed to pass the draft legislation in 2023.

Two achievements in relation to packaging reporting
An initial version of the draft act stated that companies would have to provide data on single-use plastic food packaging and beverage cups to the packaging register for the first time by 31 March 2024, but the data would have to be for 2023. In the opinion of the Chamber, it is not reasonable to impose an obligation retroactively. The Ministry listened our opinion and postponed the obligation to provide data for one year. The Ministry of Climate also took into account the Chamber’s second suggestion that records of food packaging and beverage cups should not be kept on a piece-by-piece basis, but on a weight basis. 

The process of termination of the employment contract due to decrease in the ability to work of an employee does not need to be changed 
In May, the Ministry of Social Affairs unveiled a draft amendment to the Employment Contracts Act, which, among other things, included a number of important changes in connection with termination of the employment contract due to decrease in the ability to work of the employee. For example, the draft act included the idea that in the future an employer must comply with the term for advance notice of termination of an employment contract if the termination of the employment relationship is due to a decrease in the ability to work due to the state of health. According to the current law, an employment contract may be cancelled without observing the notice period if, taking into account all the circumstances and the mutual interest, it cannot reasonably be required to continue the contract until the agreed term or the notice period expires. The draft also included a requirement that an employer may cancel an employment contract if an employee has been unable to perform duties due to health for six months. Under current law, that deadline is four months. According to the Chamber, these amendments are not indispensable and make the process of terminating the employment contract unreasonably long. By the end of 2023, it was not known if and how the ministry would move forward with this draft. 

The Protection of Whistleblower Act must also provide protection against malicious notification 
At the end of May, the Ministry of Justice came out with an updated version of the Professional Whistleblower Protection Act, also known as the Whistleblower Protection Act. The Chamber supports the purpose of the act and considers it positive that several of the Chamber’s earlier proposals have been entered into the act. At the same time, we submitted several additional comments on the draft to the Ministry. For example, as one possible negative effect, we pointed out that people can start making malicious, unsubstantiated and abusive reports and this can cause very serious harm to businesses. We therefore consider it extremely important that the necessary measures are in place to mitigate such a risk. At the end of 2023, the procedure for the draft act was pending in the Parliament. 

Shelter places and shelter arrangements need clearer rules 
In May, the Ministry of the Interior introduced a draft act to amend the Emergency Act and the Building Code, which establish requirements for sheltering places and the sheltering order. The Chamber informed the Ministry that the establishment of shelter places and the organisation of sheltering needed regulation, but since there were several unclear and problematic points in the original version of the draft act, we objected to the speedy processing of the draft act. For example, the original version of the draft act did not clearly state which buildings were obliged to establish a public or non-public shelter. The procedure for the draft act will continue in 2024. 

There should be no requirement that company cannot fulfil in practice 
The European Commission came out in 2023 with a proposal for a regulation banning products resulting from forced labour on the union market. The Chamber fully supports this principle. At the same time, it is unclear whether and how, for example, Estonian companies can determine that their cooperation partner or cooperation partner of a cooperation partner has not used forced labour in a third country. It also raises questions about whether and how Estonian supervisory authorities can control the use of forced labour in third countries.

We support the rounding rules for 1 cent and 2 cent euro coins 
The Chamber supports the plan of the Ministry of Finance that traders will be obliged to round the cost of the cart to the nearest five cents if the buyer pays in cash. This means that when the change takes effect, the trader should not give back 1 and 2 cents to the buyer. The change will make it possible to reduce the burden and costs for traders in relation to 1 and 2 cents. The respective draft act will be finalized in spring 2024. 

Four achievements related to packaging 
In early May, nearly 30 changes to the Packaging Act came into effect, with several planned changes not included in the law as proposed by the Chamber. For example, mandatory measures to reduce food packaging and beverage cups were not included in the law on a proposal from the Chamber. One such measure was a 50cent price for packaging and a beverage cups. In addition, the packaging undertakings are not obliged to take back free of charge from the waste stream the packaging waste of goods sold and to place a packaging container at each store. On the Chamber’s proposal, the deadline for drawing up an action plan to describe measures to reduce single-use plastic food packaging and beverage cups, which originally should have been made by 1 May 2023, became longer, but on the Chamber’s proposal, the deadline extended to 1 September. 

The state should also provide support measures to the vital service provider 
The Government Office prepared a 132-page draft Civil Crisis and National Defence Act which, among other things, supplements the list of vital services and changes the criteria of providers of vital services. The Chamber proposed a number of amendments to the draft act and found that state support measures had been disregarded alongside the obligations of vital service providers. The procedure for the draft act will continue in 2024. 

The Chamber supports the state’s plan to abolish the obligation to issue paper purchase receipts 
In October, the Ministry of Economic Affairs and Communications disclosed the intention to develop a draft amendment to the Consumer Protection Act, by which it wishes to abolish the trader’s obligation to issue default purchase receipts to the consumer and gives the trader the opportunity to stop sending the consumer a monthly duplicate paper invoice by post. The Chamber supports the proposed changes. The corresponding draft act is expected to be completed in 2024.

The new framework for labour market statistics must not increase the administrative burden on businesses 
The European Commission came up with a proposal in 2023 for a regulation on labour market statistics for European companies, including statistics on, for example, salaries, vacancies and the gender pay gap. The Chamber informed Statistics Estonia that Estonia should support the initiative only if this does not result in an increase in administrative burden for Estonian companies. This principle has been taken into account in Estonian positions. The debate on the proposal for a regulation will continue in the EU in 2024. 

Procedural practices and information systems related to visas and residence permits must be made more user-friendly 
The Ministry of the Interior plans to change the regulations, procedural processes and information systems related to the residence and working of foreigners in Estonia. In February 2023, the Chamber informed the Ministry that it considered it very necessary to harmonise procedural practices in this area and to establish and develop information systems in order to reduce the workload of foreigners, their employers and public authorities and to enhance supervision. In addition, we drew the attention of the Ministry to a number of problems today and proposed different solutions. For example, we proposed to speed up the process of applying for visas and residence permits. The Ministry of the Interior will reveal the respective draft act in early 2024. 

On the proposal of the Chamber, the conditions of the support measure to ensure security of electricity supply were relaxed for companies 
On 4 June, a support measure came into force by which the state supports ensuring security of electricity supply for those companies that have been most affected by high energy prices. The support measure will allow such companies to apply for a subsidy of up to €500, 000, depending on the size of the company, for the installation of equipment for the production of renewable energy. In the original version of the draft act, the conditions for receiving support were significantly stricter than those currently in force. For example, the applicant company must have been directly involved in the Ukrainian, Russian or Belarusian market, but the conditions for granting the grant were relaxed on a proposal from the Chamber. 

The Chamber opposes the prohibition on stopping vehicles on the sidewalk for the purpose of loading cargo 
The Ministry of Climate wants to make an amendment to the Traffic Act, under which it will be forbidden to stop a vehicle on the sidewalk for loading cargo in the future. According to the Chamber, moving on the sidewalk must be safe, but at the same time companies must also be given reasonable opportunities to load goods. Draft proceedings are expected to resume in 2024. 

Fire safety requirements for the storage of combustible materials and hazardous substances should include limit quantities and restrictions for companies 
At the end of the year, the Ministry of the Interior prepared a draft regulation on fire safety requirements for the storage of combustible materials and hazardous substances, which significantly changes the existing storage rules. The Chamber found it was necessary for businesses to create reasonable limits and restrictions on storage requirements so that restrictions on businesses in different areas were not unrealistically complicated. 

Chamber’s achievement: the development support for entrepreneurship in Southeast Estonia may also be used for sales and marketing activities in the foreign markets 
In October, the Southeast Estonian Business Development support measure entered into force, which included, among other things, the Chamber’s proposal to amend the wording of the supported activities in such a way that they could also be used for foreign markets. 

We expressed support for changes that reduce the administrative burden on companies involved in articles of precious metal 
In June, the Ministry of Economic Affairs and Communications published a draft act to amend the Precious Metal Products Act, which included several proposals to reduce the administrative burden on businesses. The Chamber supports the proposed changes. For example, we expressed support for the amendment to make the register of name labels fully electronic, to remove the restriction on retail sales and to extend the period of validity of the registration from one year to ten. The proposed changes will primarily affect manufacturers, importers and wholesale and retail companies of articles of precious metal. It was not known at the end of 2023 when the changes would take effect. 

The Chamber did not consider it justified to increase the food and veterinary supervision fee by up to 85 per cent 
In December, the Ministry of Regional Affairs and Agriculture came out with a proposal to increase the hourly rate for food and veterinary supervision activities by 40 and 85 per cent respectively from the new year. According to the Chamber, raising the fee to such a large extent is not justified because, for example, wages have increased around 10 per cent and inflation has been only 4 per cent in Estonia during the year. The Ministry decided to increase the fee for food and veterinary supervision by 25 per cent from the new year, i.e. in a volume significantly smaller than initially planned, due to criticism from companies. 

The Chamber supports the European Commission’s plan to introduce a single income tax system for head offices of small and medium-sized companies 
The European Commission has drawn up a proposal for a directive on the tax system for the head offices of small and medium-sized companies operating cross-border, which allows small and medium-sized companies operating in other Member States through one or more permanent establishments to apply only the tax system of the head office, i.e. the state in which the company is established. The Chamber supports such a solution. The debate on the proposal will continue in the EU in 2024. 

The global minimum income tax requirements should be met once international guidelines are in place 
The Ministry of Finance has prepared a draft amendment to the Income Tax Act which transposes the EU Minimum Income Tax Directive into Estonian law. Estonia makes use of the derogation from the directive and does not immediately transpose the entire directive in the draft, but only imposes on the ultimate parent company established in Estonia an obligation to designate the group entity submitting the minimum tax declaration in the country applying the minimum tax. The Chamber welcomes the fact that Estonia has decided to use the derogation proposed in the directive. However, we believe that companies should only be required to meet new obligations once all minimum income tax requirements have been agreed at international level. 

The Chamber put forward a number of proposals for the proposed regulation of micro-qualification training 
In October, the Ministry of Education and Research came out with a draft amendment to the Adult Education Act, which, among other things, adds requirements related to the provision of micro-qualification training to the Act and specifies the requirements for adult trainers and in-service training institutions. The Chamber supports a number of planned changes, but we also put forward a number of proposals to amend the draft act. For example, we proposed to specify the rules for quality assessment and to reduce the state fee for quality assessment of the curriculum group. The procedure for the draft act will continue in 2024. 

We support the European Commission’s proposal to reduce the burden on companies operating across borders 
In 2023, the European Commission came out with a proposal for a directive on the digitisation of company law aimed at eliminating and reducing the formalities for companies to use company data in cross-border situations. For example, the creation of an EU company certificate, the introduction of an EU digital proxy and the relaxation of the requirements for legalisation and translation of documents will help to reduce the burden on businesses. The Chamber supports these changes. The debate on the proposal for a directive will continue in the EU in 2024.

Draft legislation must not be processed at turbo speed 
During the year, the Chamber was repeatedly dissatisfied with the ministries’ legislative practice, where in the case of drafts that have a significant impact on the business environment, the ministries gave business organisations a few working days to express their opinion. In September, for example, together with 35 business organisations, we sent an opinion to the government that the turbo-speed processing of the laws was damaging the economy and asked for a halt to the procedure for urgent drafts. 

Protecting Estonia’s positions in EU legislation must become more transparent 
During the year, we made several proposals to ministries on how to better involve different interest groups in shaping Estonia’s positions on European Union initiatives. For example, we are not satisfied with the fact that the Ministry is sending dozens or even hundreds of pages of documents related to the EU proposal to stakeholders, but the content, purpose and background of the initiative have not been briefly explained by the Ministry. We also pointed out the problem that if Estonia confirms its position on the EU initiative, then as a general rule there will be no more communication between the state and interest groups thereafter. Therefore, there is no overview of the future process and it is difficult to assess how successfully our officials and politicians defend Estonia’s interests in Brussels. As a result of the Chamber’s addresses, the engagement process improved over the course of the year, and the protection of Estonia’s positions in EU legislation has also become somewhat more transparent. 

Lawyers gave advice to 100 companies
Members of the Chamber actively used the services of our lawyers in 2023. Lawyers advised members on all the key areas faced by companies in their day-to-day activities (e.g. contracts, labour law, public procurement). Entrepreneurs continued to have a strong interest in contract consultations. We helped companies draw up different types of contracts, introduce contract changes, and carried out contract analyses.