Secretary General of the Ministry of the Interior Tarmo Miilits laid out the minister's position in a letter.

"The Moscow Patriarchate's influence over the Estonian Orthodox Church of the Moscow Patriarchate (MPEÕK) will not diminish, despite changing the church's name or removing references to the Moscow Patriarchate, the Russian Orthodox Church, and the Patriarch from its statutes. As seen from both the statutes and the accompanying letter, these changes are merely cosmetic. Such a rewording of the statutes may only give the appearance of reduced influence, but in reality, the Moscow Patriarchate's control remains unchanged, both administratively and canonically," Miilits wrote to Vicar Bishop Daniel of the Tallinn Diocese of MPEÕK.

"The Ministry of the Interior has a clear expectation that you will review the text of the statutes again in light of the observations outlined in this letter and adopt a version that completely eliminates any influence stemming from ties to the Moscow Patriarchate or the Russian Orthodox Church in the governance and activities of the church operating here," the secretary general stressed.

Subordination relationship with Moscow remains

In its analysis, the Ministry of the Interior disagreed with MPEÕK's claim that the Moscow Patriarchate's right to approve and enforce its decisions will disappear when the statute is amended.

It said it still refers to the 1993 Tomos, which state the Estonian Orthodox Church together with the churches of Latvia and Moldova belong to the Moscow Patriarchate. This means that essentially nothing has changed.

"Since, according to the 1993 Tomos, the Estonian Orthodox Church of the Moscow Patriarchate (MPEÕK) is governed in accordance with the regulations of the Holy Synod of the Moscow Patriarchate and the decrees of the Patriarch of Moscow and all Russia, it is inaccurate to claim (as you did in the accompanying letter dated August 31, 2024) that "the patriarch cannot issue any binding directives to the church on administrative matters", Miilits emphasized. "It must be acknowledged that even if the new version no longer explicitly mentions the patriarch's approval of decisions, it is still referenced indirectly through the Tomos."

The official pointed out that, in addition to not confirming the decisions of the plenary assembly or not agreeing with them, the patriarch likely also has other opportunities to influence the activities and decisions of the MPEÕK.

"Thus, it is impossible to claim that any changes have been made concerning the administrative dependence of the Estonian Orthodox Church of the Moscow Patriarchate (MPEÕK) on the Moscow Patriarchate, particularly in relation to the activities of the General Assembly," Miilits summed up.

MPEÕK is not independent but self-governing

The Ministry of the Interior also disagrees with MPEÕK's statement that it is now independent. It considers the church to be self-governing.

"In the 1993 Tomos, it is stated that "the Estonian Orthodox Church is independent in ecclesiastical-administrative, ecclesiastical-economic, ecclesiastical-educational, and ecclesiastical-civil matters, while remaining under the canonical jurisdiction of the Moscow Patriarchate." This defines the limits of its independence. As it currently stands, the Estonian Orthodox Church of the Moscow Patriarchate (MPEÕK) is neither an independent nor an autonomous church, but rather a "self-governing" or "self-administering" church," the secretary general wrote.

The Estonian Orthodox Church is not a suitable name

The ministry also rejected MPEÕK's wish to change its name to the Estonian Orthodox Church, finding that such a form of name does not comply with the Law on Churches and Congregations.

It said the name is too similar to the Estonian Apostolic Orthodox Church (EAÕK).

Miilits also said it is misleading as the names suggest it is a church that includes all Estonian Orthodox, which is not factually accurate.

Disagreements about history

The Ministry also commented on the historical facts presented in the new version of MPEÕK's statute and the Tomos referred to., It said they do not fully correspond to the positions commonly held about the history of the Orthodox Church in Estonia.

"Presenting historical facts in the statutes of a religious organization is not legally prohibited. However, the key question is the purpose and legal relevance of including such facts, as well as whether these historical facts are accurate and truthful," said Miilits.

Finally, the Ministry of the Interior highlighted questions regarding the wording of the new version of the MPEÕK statute.

At the same time, the Ministry of the Interior was pleased that Bishop Daniel confirmed in his letter that MPEÕK will continue contacts with EAÕK in order to canonically overcome the schism of Orthodoxy that arose in Estonia in the 1990s.

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