The Internal Security Service's (ISS) has been hit by the same access restriction and for the same reason.

The Enforcement Register (Estonian: Täitmisregister) is a state channel for authorities to query bank account data and place attachments. In 2025 the Chancellor of Justice found agencies had accessed bank secrecy data without a proper legal basis.

The required data tracker once functioning allows private citizens to see who has queried their bank data. Of authorities required to install the tracker, the Tax and Customs Board (MTA) and various bailiffs met the October 1 deadline and so can continue to access the register.

The PPA and the ISS, known in Estonian as Kapo, cannot as things stand.

Minister of Justice and Digital Liisa Pakosta (Eesti 200) told ERR that bank data is very sensitive data, necessitating additional security measures like the data tracker when it is viewed automatically by investigative agencies.

"From the data tracker you can see who has viewed your data, and so control is in the person's own hands. The Riigikogu gave investigative authorities access to the Enforcement Register only on condition that people whose accounts are queried can see it from October 1," Pakosta said.

"This means the Enforcement Register can be used to query data protected by bank secrecy only if the investigative authority is connected to the data tracker. The data tracker ensures that the person can check the state, not the state check the person."

Pakosta praised the Tax and Customs Board (MTA) and the bailiffs who joined the data tracker by the deadline - they will be able to continue to use the enforcement register. Initially the MTA had been barred from using it, as the PPA and the ISS continue to be.

"The worry is with the Police and Border Guard Board and the Internal Security Service, who did not get the necessary software solution ready by the deadline. Until it is ready, their use of the Enforcement Register in criminal proceedings is suspended," she continued, echoing a ministry announcement last week.

The Enforcement Register holds data on enforcement proceedings and acts as a channel for authorities to query bank account data. In July 2025 the Chancellor of Justice found agencies were accessing confidential bank data without a proper legal basis. This led to the suspension of the MTA's access, now restored as noted. The Financial Intelligence Unit's (FIU) access was also suspended at the time. The FIU primarily investigates money laundering.

The fix to the issues was the mandatory data tracker, letting people see who queried their data, which in turn followed the passing of the relevant legislation.

"It has now emerged that the Police and Border Guard Board and the Internal Security Service have not made the necessary integrations, and therefore their access to the Enforcement Register and e-arest must be closed," the ministry had announced last Thursday.

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