For an international founder running an Estonian company, the first point about the TSD reform is its date: EMTA announces 1 October 2026. The end of 2027 concerns the transitional CSV option. Confusing those dates could leave a business relying on a payroll export that no longer works. However, a small employer does not necessarily need to buy a direct software connection simply because reporting is becoming more automated.
I separate the change into two questions: how payment information reaches the tax authority, and who remains responsible for it. This analysis uses EMTA's own guidance and the legislation in Riigi Teataja, including the wording taking effect on 1 October. I distinguish the announced service from my recommendations for running payroll. The aim is to understand the business decision before choosing a technical solution. Information checked on 25 September 2026.
What changes in October, and where 2027 fits
According to EMTA’s TSD guidance, a single payroll-payments view replaces the separate Annex 1 and Annex 2 views. It brings together residents, non-residents, payments and repayments. When information is sent from accounting software, EMTA builds the declaration from it and the business or accountant confirms the result.
The same guidance says that submission of Annexes 3–8 is initially unchanged. Sending payroll information therefore does not establish that dividends or fringe benefits have also been declared. The EMTA reporting programme contains several stages with different dates.
| Date | Meaning |
|---|---|
| 1 October 2026 | New TSD payroll-payments solution starts |
| Until the end of 2027 | Temporary support for the current CSV upload |
| 1 April 2027 | EMTA’s announced new VAT return launch; a separate change |
The official sources reviewed do not support 1 October 2027 as the launch date of this TSD change. A service launch date is also distinct from the tax period to which an individual payment belongs.
Choose between software integration, upload and manual entry
The replacement XML must use the XBRL GL structure. An existing file does not become compatible merely because it still has an .xml extension: the software must generate the new structure. The current CSV upload is a transitional option, and manual entry in e-MTA remains available.
EMTA’s 24 March 2026 developer briefing explicitly describes direct machine-to-machine integration as optional. The company initiates sending information; this reform does not give EMTA unrestricted access to its accounting software. A direct connection requires compatible software and appropriate access rights.
My recommendation is to make the choice proportionate to the business. An employer with one or two payments should compare integration costs with the time needed for manual entry. A larger payroll team should ask its supplier to demonstrate sending, error feedback, correction and confirmation in the actual software package it uses. A general compatibility claim does not prove that the whole process is available.
The legal filing duty and responsibility remain
Income Tax Act § 40(2) ties withholding to making the payment. Sections 40(4) and 40(5) require the withheld income tax and the declaration by the tenth day of the following month. These duties also appear in the wording effective from 1 October 2026. A different reporting interface does not itself change tax rates or turn wage taxation into accrual accounting.
Under Taxation Act § 85(4), a declaration submitter must provide information known to be correct and confirm its accuracy. Section 87 governs signing and representation. My reading is that an EMTA-generated declaration is not an independent assessment that the employer selected the right payment category or tax exemption.
Where an error or missing information has caused tax to be understated, § 89(1) requires prompt written notification to the tax authority. The obligations for fringe benefits, dividends and other relevant expenses and payments under Income Tax Act § 54 also need to be considered separately. A new payroll screen does not fulfil them on the employer’s behalf.
Example: September salary paid in October
Assume a company pays September salary on 5 October 2026 and a separate bonus on 20 October. Both are October payments. Describing the first amount as September salary does not put it into September’s TSD: the actual payment determines the starting point for income-tax withholding and reporting.
If October salary is paid on 5 November, that payment belongs in November instead. This example addresses payment timing; minimum social tax and other special rules still need separate consideration.
| Payment made | TSD period | Ordinary filing deadline |
|---|---|---|
| 5 October: September salary | October 2026 | 10 November 2026 |
| 20 October: bonus | October 2026 | 10 November 2026 |
| 5 November: October salary | November 2026 | 10 December 2026 |
The practical implication is to reconcile the declaration against payment records and bank transactions. The accrued payroll total alone does not establish that every payment belongs to the right month or that no record has been duplicated. Automation is useful only if the underlying dates and classifications are correct.
An uploaded file is not a confirmed TSD
EMTA’s technical briefing treats upload, processing feedback and declaration confirmation as distinct stages. Receipt of a file does not establish that every record passed processing. Successfully processed data do not by themselves establish that the declaration is confirmed. The current exchange requirements are in EMTA’s technical specifications.
I recommend assigning responsibility for reviewing warnings, correcting source records and confirming the final declaration. If a software response is unclear, first establish what was accepted. Resending an entire file without checking should not be the default response to uncertainty.
For the first transition month, I would reconcile payment type, month and amount for each person, followed by tax totals. I would also examine a repayment, a non-resident payment and a board member’s fee where those occur. These are my proposed controls for the employer’s process; they are not an additional reporting form imposed by EMTA.
I judge the new service by how much rekeying it removes and how clearly each reported payment can be traced afterwards. The explanation for the tax treatment must survive even when producing the declaration takes only seconds.
Prepare the submission channel, source records and approval process. XML users need a compatible export; CSV provides transition time; manual entry remains an option. The employer still has to classify payments correctly, confirm accurate information and meet its statutory filing and payment duties.
To assess your company’s payroll reporting readiness, contact AccRes. We can start with how you currently submit TSD and the payments your business actually makes.