What an Estonian subcontractor has to have in place on a main contractor site: MTR, TTKI, insurance, safety

A main contractor in Estonia does not let a crew onto site on a verbal understanding. Before arriving, the subcontractor closes off five separate legal items, and each of them is checked separately: the entry in the register of economic activities, confirmation in the contracting chain, the worker card, the liability insurance policy and the occupational safety documents. None of them substitutes for another.

Below is the list in the form a procurement department usually asks for it. After that each item is set out on its own: what it is, who issues it, where the main contractor checks it directly, and by which point the document has to exist.

The most frequent mistake when checking an Estonian subcontractor is looking for a licence. There is none. Construction runs on an economic activity notice: the undertaking itself informs the state that it is starting to operate in a given field. Supervision over the requirements applying to the construction undertaking and to the competent person is exercised by the Consumer Protection and Technical Regulatory Authority (TTJA), and it happens during the activity rather than before it starts.

From that follows the practical conclusion for procurement. The existence of an entry does not mean anyone checked the undertaking in advance; it means the undertaking has taken on responsibility for conforming to the requirements. The substance sits in two fields of the entry: the field of activity and the competent person. The requirement is worded so that the undertaking must have a legal relationship with a competent person, and the competence of the undertaking corresponds to the qualification of the undertaking itself and of the persons acting on its behalf.

Since 25.06.2025 the new TTJA information system Tarvik (tarvik.ttja.ee) runs alongside MTR, and all economic activity notices and authorisations, including those in the construction field, are being transferred into it from MTR. In practice that means a subcontractor entry may sit in either of two systems, and the absence of a company from the familiar mtr.ttja.ee does not yet mean there is no entry.

The check itself takes a few minutes and needs no authentication: mtr.ttja.ee offers unauthenticated services, a search of authorisations and notices and a search of undertakings. There are three things worth looking at there, not one.

Since 1 October 2023, large construction sites, contracting chains and the workers admitted to the site are registered in the contracting chain and working time registration information system (TTKI) in the e-services environment of the Estonian Tax and Customs Board.

The obligation does not arise on every project. Registration covers works and sites where the work lasts more than 30 working days and at least 20 people are engaged at the same time, or where the total volume exceeds 500 person-days. The requirements apply to sites started after 1 October 2023, and also to continuing sites expected to finish later than 1 October 2024. Anything below those thresholds is not entered into TTKI.

The key point is the sequence of steps rather than the fact of registration. A subcontractor cannot confirm itself on a site that is not yet in the system, and a worker cannot be marked by an undertaking that has not itself been confirmed in the chain. If the main contractor enters the subcontractor on the morning of the day the crew is due to start, the crew will not start.

Two things worth separating, because they are confused most often. The MTR entry relates to the undertaking and is tied to no project. TTKI registration relates to the project and to the chain on it. An undertaking with a flawless MTR entry that is not confirmed in TTKI does not get onto site, and conversely, confirmation in the chain does not replace the sectoral notice.

On a large site the entry and exit of every person and the duration of their presence are registered electronically. The means of identification is the worker card, a chip card the undertaking obtains for every worker admitted to the site.

The obligation is worded directly: every construction undertaking obtains, for all the workers it admits to the site, a card serving as a means of identification. The obligation lies with the employer, not with the main contractor and not with the worker. Cards are issued by the card provider through its own web environment. The card number and the registration system in use are not entered into TTKI by the undertaking - that data reaches the system from the provider.

For procurement there is one question here better asked before the contract than after. Does the whole crew have cards, including the people the subcontractor plans to add at the peak stage? A card is not issued instantly, and it is the most frequent bottleneck when a crew is reinforced mid-project. If a subcontractor scales its make-up, it should be able to name the lead time for putting an additional carded person on site. And one limitation worth remembering as a site manager: the worker card is a registration device, not proof of qualification. It replaces neither professional qualification, nor the site induction, nor permits for particular types of work.

Estonia does not sell one construction insurance but several different products covering different risks: operating liability insurance, construction activity liability insurance, employer liability insurance, product liability insurance and professional indemnity. A main contractor usually asks for the first two.

What exactly is required is set by the contract, not by the market. The general conditions of building contracts ETU 2013 put it this way: where the contract so provides, the contractor shall, before the works start but no later than 5 working days after the contract is concluded, take out at its own cost a contractor all risks (CAR) insurance contract and a civil liability insurance contract. Where both types are required they may be contained in a single insurance contract, but the requirements for each type apply separately rather than in aggregate.

For CAR the same document sets a benchmark: the minimum indemnity limit must be no lower than the contract price excluding turnover tax, and the maximum deductible must correspond to the amount agreed in the contract. For civil liability insurance it is the other way round: the minimum indemnity limit and the maximum deductible are agreed separately by the parties, and in the absence of agreement the contractor is entitled to set those amounts at its own discretion. From which follows a consequence worth saying out loud: there is no market norm for a liability sum insured. If a specific figure matters to you, it has to be written into the contract before signing.

Two ETU 2013 conditions are breached in subcontractor offers more often than the rest. First: the insurance contract is concluded for the specific building and works as a separate object of insurance - the policy has to name the building or its address, and the indemnity limits have to apply to that project rather than in aggregate across all the projects the contractor insures. Second: unless the contract agrees otherwise, the client is named as the beneficiary in the CAR contract. The contractor hands the policy and a copy of the terms to the client no later than before the works start, and the cover has to run for the whole period of performance.

And what liability insurance does not do. It covers damage caused by the works: to third parties, to the existing building, to other people's property on site. It does not cover redoing the work itself. A poorly executed joint is not an insured event but a contractual question: of stage acceptance, of a warranty security and of a written guarantee.

Occupational safety requirements in construction are laid down by the Government regulation on occupational health and safety requirements in construction. For a subcontractor, four things follow from it, and they are checked on site rather than on paper.

The contents of the safety plan are a ready-made checklist of what a subcontractor has to be able to describe for its own scope: the sequence and duration of the stages, a list of dangerous works with indicative timing and the contacts of the responsible person, the arrangements for removing waste, measures against the spread of noise, vibration and air pollution into the immediate neighbourhood of the site, the plan for erecting and dismantling scaffolding, the asbestos works plan, the instructions for emergencies and the arrangements for first aid.

From the contract side, ETU 2013 adds that the contractor itself develops the occupational health and safety requirements relating to its own works, including the risk assessment, the safety plan and the emergency plan, applies them on site, supervises their fulfilment and appoints a person responsible for occupational safety. The practical check for procurement is a single one: ask not for the general policy of the undertaking, but for the risk assessment covering the type of work you are actually buying, and the name of the responsible person on your project specifically. Everybody has a document about safety in general. Not everybody has a risk assessment for drywall works in an occupied building.

Novashop has worked as a subcontractor in Estonia since 2014, and we send the document pack before mobilisation rather than on request after the works have started. It contains the MTR entry, a valid liability insurance policy, and the qualifications and CVs of the crew.

After that the contractual part begins, and for a site manager it matters more than the registers. We work to a fixed quote, with no advance payment and under a written contract. The contract fixes a matrix of stage deadlines, and acceptance runs stage by stage against a checklist: your site manager has the list of what gets signed before the next stage starts in advance. In terms of make-up we field anything from a crew of 2 specialists to a combined team of up to 12 people.

In TTKI we confirm ourselves and mark our workers once we have the project data from the main contractor, which is why we ask for that data at contract signature rather than the day before mobilisation. If what you need is reinforcement of your own crew rather than a scope contract, that is a separate format: the people work inside your structure and under your site management, and the documentation and HR side stays with us.