An introductory stage, during which our experts organise a meeting with the Client to discuss its planned activities. At this stage, the company does not necessarily have to be established yet.

What does the Client do?

1. Prepares information on the shareholder, board members and other representatives;
2. Prepares general information on the type of capital financing and the origin of funds.
3. Prepares information on the planned business model: procedures for the provision of services, organising payment flows, customers, countries in which the service will be provided.
4. Prepares the list of existing documents or starts the drafting of the necessary documents.

Documents to be submitted:

- the CVs of the shareholder, board members and other representatives;
- a description of the service and its provision;
- general information on the type of planned capital financing and the origin of funds.

What do ComplyWise experts do?

- Provides advice regarding the applicable regulatory framework.
- Carries out an assessment of the initial business project and procedures.
- Assesses whether the authorisation process can be continued.
- Provides advice on documents to be submitted.

Holders of an Estonian ID card or e-Residency card and a growing number of holders of EU member states’ ID cards can establish a private limited company fully online. If an ID or e-Residency card is not available, a visit to a notary will be organised for the Client where foundation documents will be verified.  
* State fees and notary fees are included in the service fee

When the Client requires assistance with required documents, ComplyWise experts prepare following documents:
3.1. a programme of operations describing the intended types of crowdfunding services and the crowdfunding platform that it intends to operate, including where and how crowdfunding offers are to be marketed;
3.2. a description of governance arrangements and internal control mechanisms to ensure compliance with the Regulation, including risk management and accounting procedures;
3.3. a description of IT systems, resources and procedures for the control and safeguarding of the data processing systems;
3.4. a description of operational risks and the procedures for their management;
3.5. a description of prudential safeguards in accordance with Article 11 of Regulation (including financial forecasts for the following three years);
3.6. proof that prudential safeguards are met in accordance with Article 11 of Regulation;
3.7. a description of business continuity plan which, taking into account the nature, scale and complexity of the crowdfunding services, establishes measures and procedures that ensure, in the event of failure of the prospective crowdfunding service provider, the continuity of the provision of critical services related to existing investments and sound administration of agreements between the prospective crowdfunding service provider and its customers;
3.8. a description of internal rules aimed at preventing persons referred to in paragraph 2 of Article 8 of the Regulation from participating in crowdfunding services as project owners;

3.9. a description of procedures for outsourcing;
3.10. a description of procedures for handling customer complaints;
3.11. a description of the procedures for organising payment flows, including confirmation of whether the prospective crowdfunding service provider intends to provide payment services on its own or through a third party in accordance with Directive (EU) 2015/2366, or using the procedures in accordance with paragraph 5 of Article 10 of Regulation;
3.12. a description of the procedures to verify the completeness, correctness and clarity of the information contained in the key investment information sheet;
3.13. a description of procedures in relation to investment limits for non-sophisticated investors referred to in paragraph 7 of Article 21 of Regulation.

Submission of application: ComplyWise experts prepare and submit an application for authorisation.
4.1. What does ComplyWise do?
4.1.1. Submits a fully completed application and all necessary information, documents for the authorisation.
4.1.2. Receives information from Regulator regarding the starting the examination of the application for authorisation or on deficiencies to be addressed in the submitted application.
4.1.3. Provides the necessary additional explanations and support.

4.2. What does Regulator do?
4.2.1. Carries out an assessment of the completeness of the application within 25 working days (the assessment of the application as to the substance is not yet ongoing).
4.2.1. If the application is incomplete, Regulator sends a letter to ComplyWise and the Client indicating the deficiencies identified which need to be addressed.
4.2.3. If the application is complete, Regulator sends a letter to ComplyWise and the Client informing that an assessment of the application for authorisation has started.

4.3. List of documents to be submitted
4.3.1. application for authorisation as a crowdfunding service provider. 
4.3.2. a programme of operations describing the intended types of crowdfunding services and the crowdfunding platform that it intends to operate, including where and how crowdfunding offers are to be marketed;
4.3.3. a description of governance arrangements and internal control mechanisms to ensure compliance with the Regulation, including risk management and accounting procedures;
4.3.4. a description of IT systems, resources and procedures for the control and safeguarding of the data processing systems;
4.3.5. a description of operational risks and the procedures for their management;
4.3.6. a description of prudential safeguards in accordance with Article 11 of Regulation (including financial forecasts for the following three years);
4.3.7. proof that prudential safeguards are met in accordance with Article 11 of Regulation;
4.3.8. a description of business continuity plan which, taking into account the nature, scale and complexity of the crowdfunding services, establishes measures and procedures that ensure, in the event of failure of the prospective crowdfunding service provider, the continuity of the provision of critical services related to existing investments and sound administration of agreements between the prospective crowdfunding service provider and its customers;
4.3.9. documents certifying the identity of the natural persons responsible for the management of the prospective crowdfunding service provider;
4.3.10. CV and certificate from the criminal record register on absence of a criminal record from countries where the persons responsible for the management of the prospective crowdfunding service provider and shareholders who hold 20 % or more of the share capital or voting rights have carried out commercial activities. In addition, information on the education of the persons involved in the management and proving that those persons have sufficient knowledge, skills and experience, necessary to manage the prospective crowdfunding service provider;
4.3.11. a description of internal rules aimed at preventing persons referred to in paragraph 2 of Article 8 of the Regulation from participating in crowdfunding services as project owners;
4.3.12. a description of procedures for outsourcing;
4.3.13. a description of procedures for handling customer complaints;
4.3.14. a description of the procedures for organising payment flows, including confirmation of whether the prospective crowdfunding service provider intends to provide payment services on its own or through a third party in accordance with Directive (EU) 2015/2366, or using the procedures in accordance with paragraph 5 of Article 10 of Regulation;
4.3.15. a description of the procedures to verify the completeness, correctness and clarity of the information contained in the key investment information sheet;
4.3.16. a description of procedures in relation to investment limits for non-sophisticated investors referred to in paragraph 7 of Article 21 of Regulation.

Regulator carries out the assessment of the application as to the substance.

6.1. What does Complywise team do?
6.1.1. Provides answers to additional information requests by Regulator as soon as possible.
6.1.2. Corrects the submitted documents according to Regulator instructions.
6.1.3. Participates in meetings held by Regulator.

Regulator finalises the examination of the application and takes a decision on the issue or refusal to issue authorisation.