KAPO has been blocked from accessing the register by the Justice Ministry for failing to implement a data tracker tool by the October 1 deadline, and the Police and Border Guard Board (PPA) has been hit by the same block.

Palloson says the legislation permits KAPO to continue accessing the register without installing the tracker, at least in the case of national security matters.

"It has now become clear that the Police and Border Guard Board and KAPO have not established the necessary interfaces, which means that these agencies' access to the Enforcement Register and the e-arrest system must be closed. I ask the Center of Registers and Information Systems (RIK) to arrange the immediate technical shutdown of the services," Justice Ministry Deputy Secretary General Mari-Liis Mikli wrote in a letter to the RIK.

However, KAPO Director General Palloson says that, under the Code of Enforcement Procedure, the requirement for a technical solution — in this case a data tracker — does not apply to security authorities when performing tasks stipulated in the Security Authorities Act or conducting security vetting specified in the State Secrets and Classified Information of Foreign States Act.

"Consequently, we request continued access to the Enforcement Register and the e-arrest system for the performance of tasks stipulated in Section 6 of the Security Authorities Act and for conducting security vetting under the State Secrets and Classified Information of Foreign States Act," he wrote.

Palloson also specified which data KAPO wants its right to query restored: the existence of a bank account, account balance, account statement, persons authorized to use the account, who the beneficial owner of the account holder is, and whether a safe deposit box exists.

The KAPO director general confirmed that since October 1 his authority has not made any queries via the Enforcement Register as part of criminal proceedings, and has now also technically disabled the corresponding type of query.

"We also confirm that KAPO has taken measures to ensure the lawfulness of data processing and exercises sufficient oversight over it," Palloson noted.

The Enforcement Register (Estonian: Täitmisregister) is a state channel allowing authorities to query bank account data and place attachments. In 2025 Chancellor of Justice Ülle Madise found agencies had been accessing confidential bank data without the correct legal basis. The solution was the data tracker, which lets individuals see who has queried their data. Legislation putting this in place passed at the Riigikogu, with the installation deadline set at October 1. Other authorities initially blocked but now able to access the register, having installed the tracker, are the Tax and Customs Board (MTA) and the Financial Intelligence Unit (FIU), which combats money laundering.

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