From 1 October 2026, Estonia will introduce a new data-based solution for reporting salary payment information to the Estonian Tax and Customs Board (ETCB). The change primarily affects the current Annexes 1 and 2 of the TSD declaration and is intended to make payroll tax reporting more automated, reduce manual work and minimise reporting errors.
The TSD reporting obligation itself remains. The monthly filing deadline continues to be the 10th day of the following month.
What Is Changing?
The key change is the reporting logic. Instead of preparing the declaration entirely in the current form-based way, companies will be able to send transaction-level source data to the ETCB, which then forms the declaration based on the submitted data.
Accounting / payroll software → data sent to ETCB → ETCB forms the declaration → declaration report returned → company/accountant reviews and confirms
- TSD Annexes 1 and 2 are replaced in e-MTA by one consolidated view.
- Resident and non-resident data will be shown together, and payments and repayments will no longer be separated into the current A- and B-part structure.
- Data can be transmitted directly from accounting or payroll software through a machine-to-machine interface.
- The current XML format for Annexes 1 and 2 can no longer be used from 1 October 2026. It is replaced by a new XBRL GL-based XML format.
- As a temporary transition solution, the current CSV format will continue to be supported until the end of 2027.
- Manual entry in e-MTA remains possible.
- According to the ETCB’s current guidance, the submission of TSD Annexes 3–8 remains unchanged at this stage.
Why Is ETCB Doing This?
The ETCB is moving from declaration-based reporting towards data-based reporting. The aim is to reduce the need to move information manually between systems and to make reporting more automated.
- less manual work and a lower risk of reporting errors
- faster feedback from the ETCB directly in the accounting or payroll software
- a more automated reporting process and lower administrative burden
A relevant privacy point for clients is that the ETCB does not receive access to the company’s accounting or payroll software. The company itself decides when data is sent to the ETCB.
Who Is Affected by This Change?
The change most directly affects companies that report taxable payments to individuals in TSD Annex 1 and/or Annex 2. In practice, the amount of preparation required depends on how payroll and TSD reporting are currently organised.
For some companies, the main work will be handled by their payroll service provider or software vendor. Others may need to update integrations, file formats or internal procedures before October 2026. For companies that currently manage TSD reporting manually, the upcoming changes may also be a good opportunity to consider whether introducing payroll or accounting software could make the reporting process more efficient.
What Action Is Needed: Practical Guidance by Starting Point
If your payroll is handled by Leinonen
The practical impact for the client may be limited. Leinonen can review the reporting process and ensure that the payroll and TSD submission process is adapted to the new requirements.
If you prepare payroll internally and use accounting/payroll software
Contact your software provider and confirm:
- Whether the software will support the data-based TSD solution from 1 October 2026;
- Whether the software supports a machine-to-machine connection with the ETCB;
- Whether the company must activate, configure or authorise anything itself;
- When the required software update will be available;
- Whether the new solution can be tested before October.
If you currently upload an XML file
This group requires particular attention. The current XML format used for TSD Annexes 1 and 2 will no longer be accepted from 1 October 2026. A company must therefore move to the new XBRL GL format, a machine-to-machine solution, or another supported submission method.
If you currently use CSV
An immediate technical change is not necessarily required on 1 October 2026. The ETCB has announced that the current CSV file will continue to be supported as a temporary transition solution until the end of 2027.
If you enter TSD manually in e-MTA
Manual entry remains available. The October 2026 change therefore does not mean that every company must purchase new software or establish a direct integration with the ETCB.
How Leinonen Can Help
The impact of the new TSD reporting model depends largely on how your payroll and TSD reporting are currently organised.
Leinonen can help you assess whether your current payroll or accounting solution is ready for the new reporting model, identify any changes required before October 2026, and support the transition to the new reporting process.
For clients whose payroll and TSD reporting are already handled by Leinonen, we will ensure that the reporting process is adapted to the new requirements.
What Does NOT Change on 1 October 2026?
The TSD reporting obligation does not disappear. The monthly filing deadline remains the 10th day of the following month. The first-stage change concerns salary payment data currently reported in Annexes 1 and 2. The ETCB current guidance states that submission of Annexes 3-8 remains unchanged at this stage.
Questions About the New TSD Reporting Model?
If you would like to know how the change to data-based TSD reporting affects your company, or want support preparing for 1 October 2026, please do not hesitate to contact Leinonen Estonia’s payroll and tax team.
