How to Vote No on the Ventus Restructuring Plan and File an Objection

New here? Read my investigation of the plan first: https://www.karsten.me/money/ventus-restructuring-recovery/. Everything below builds on it.

Voting no is not enough. If the plan gets its votes, a court still has to approve it, and only a creditor who voted no and sent a written position can ask that court to refuse. So there are three steps: vote no, email your written position, and send the court your application. This guide walks you through all three. Further down there are AI prompts that draft the email and the court application for you.

I am not a Ventus investor and not an Estonian lawyer. I read the law and the official notices so you don’t have to start from zero. This is not legal advice, and nothing here guarantees the court agrees with you.

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://www.riigiteataja.ee/et/akt/111112025013; https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimiskava-projekti-teade/2026/9/24/2653915

Step 1: Vote no. By 12 October.

Log in to the creditor portal and vote no: https://ventus.energy/en/auth/login. Take a screenshot that shows your vote and the date. While you are in there, save the plan, its annexes and your claim details. The notice says the plan stays in the portal only until 12 October. Don’t leave it to the last evening. Tallinn is an hour ahead of Berlin.

Not voting is not voting no. Only a creditor who voted against the plan can ask the court to refuse it. Can’t get into the portal? Email the adviser at [email protected] right away, say the portal won’t let you in and that you vote no, and keep the email.

Sources: https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimiskava-projekti-teade/2026/9/24/2653915; https://www.riigiteataja.ee/en/akt/501122025005

Already voted yes and changed your mind? Only a creditor who voted against the plan can ask the court to refuse it, and the plan says votes sent by email are disregarded. Neither the plan nor the official notice says whether a vote can be changed, and I found no rule on it in the Reorganisation Act. Aleks Bleck of Northern Finance, who voted yes on camera, says in his video that the portal lets you. Check the portal first. If it won’t let you, email the adviser at [email protected] by 12 October, say that you withdraw your yes vote and vote no, and ask for that statement to be entered in the voting record. I can’t tell you it will be accepted.

Documents obtained by the author: the plan’s §1.5.

Step 2: Email your written position. Also by 12 October.

Send an email to [email protected]. Say that you voted no and why. Ask for your no vote and your reasons to go into the voting record. The notice sets no language and no signature rule for this email. Keep a copy of what you sent.

Skip this email and, by the official notice, you lose the right to challenge the plan in court. The email doesn’t replace your vote, and your vote doesn’t replace the email. Do both.

Step 3: Ask the court to refuse the plan

If the plan passes the vote, your application has to reach Harju County Court by 19 October. That is the date in the opening notice. If the vote fails and the court is asked to approve the plan anyway, you get 14 days from the day that request is published in Ametlikud Teadaanded, Estonia’s official gazette. Either way, write it now. Don’t wait for the result. Haven’t heard the result by 19 October? File anyway.

Address it to Harju County Court, civil case 2-26-16225. Send it through the court’s e-toimik portal or by email to [email protected]. Using email instead of the portal can require a good reason. If you can’t log in to the portal from abroad, say so in your email. An application sent only to Ventus or to the adviser has not been filed.

Sources: https://www.kohus.ee/kohtute-kontaktid/maakohtud/harju-maakohus; https://www.riigiteataja.ee/et/akt/120062026021; https://www.riigiteataja.ee/et/akt/117062025004; https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimiskava-projekti-teade/2026/9/24/2653915

You can do this yourself, without a lawyer (Code of Civil Procedure §217(1)). The court works in Estonian. File in another language and the court will ask you for an Estonian translation and set a deadline for it (Code of Civil Procedure §33). So send the Estonian version as your application. Put the English version behind the Estonian one in the same PDF, then sign that PDF. A PDF is fine. How is just below. Email has a 20 MB limit.

Sources: https://www.riigiteataja.ee/et/akt/120062026021; https://www.riigiteataja.ee/et/akt/117062025004; https://www.kohus.ee/kohtute-kontaktid/maakohtud/harju-maakohus

What goes in:

the court and the case number
your name, address, email and phone
your Estonian personal ID code if you have one, otherwise your date of birth
your claim: how much you lent, and through which loans
what you ask for: that the court refuse to approve the plan
your reasons and your evidence
a numbered list of attachments
your signature

Attach proof of your no vote and your written position. You can attach my article too. It lists its sources.

How to sign it digitally

You need a qualified electronic signature. Under EU law one from any EU country counts in all of them (eIDAS Regulation, Article 25(3)). I signed my own report to the Estonian police this way in August: a German signing service, a PDF, an email. They registered it.

Germany: D-Trust’s sign-me. You need your Personalausweis, its 6-digit PIN and the AusweisApp on your phone. Save your application as a PDF/A. Register at https://cloud.sign-me.de/signature/start, identify yourself with the Ausweis, upload the PDF, choose “qualified” as the signature level, confirm, and download the signed PDF. No PIN? sign-me also offers video identification for a fee.
Latvia, Lithuania, Estonia: Smart-ID at the qualified level, eParaksts or your ID card. Sign through Dokobit or your national app and download the signed file.
Anywhere else in the EU: a qualified e-signature from your national eID or a signing service.
Outside the EU: print it, sign it by hand and post it to the court so it arrives by the deadline. Or have an Estonian lawyer sign and file for you.

Send the signed file itself, not a scan or a printout. The signature lives in the file.

Sources: https://www.riigiteataja.ee/et/akt/120062026021; https://www.riigiteataja.ee/en/akt/501122025005; https://eur-lex.europa.eu/eli/reg/2014/910/oj/eng

What to write: grounds that fit what I found

The court wants three things from you: which rule the plan breaks, your evidence, and how that harms your claim. Use your own words. A copied list of accusations won’t do it. The findings and their sources are in my article: https://www.karsten.me/money/ventus-restructuring-recovery/

Start with the valuations. The rule is §28(5)(11): a plan must have a reasonable prospect of preventing insolvency or keeping the business viable. This one rests on three things.

Atlasa. An unbuilt plant valued at €5 million today and €40 million later, in every scenario. The package has no construction budget for it, no funding schedule and no earnings calculation behind the €40 million. Management supplied the value.
Jugla. Its state subsidy of €2.29 million a year ends in mid-2027, and the revenue forecast jumps 64% anyway. The plan lists crypto mining at Jugla as a project in development. The only document that says who is behind it is the appraisal: RocketBTC, paying €2.34 million a year from 2027. RocketBTC’s own website said on 5 October that the company is still in formation, and the contract appendix in the appraisal is a heading with nothing under it.
The cash. The plan expects €31.5 million of spare cash from operations in five years. The twelve project companies that filed 2025 accounts made €2 million between them, and lose about €275,000 without the subsidy. Even the worst case needs €57.4 million from selling or refinancing assets, more than half of it in the final month.

Only two of the plants have an independent valuation. Most of the rest turn up after you’ve voted.

You can also argue that bankruptcy would pay you more (the “best-interest test”). Then you have to show it: what you would get in each case, who gets paid before you, and when.

Documents obtained by the author: the plan’s §§7.2.4, 7.3.1 and 11.2; Annexes 3, 4, 7 and 8; 2025 annual accounts of the twelve project companies, Lursoft extracts of August and October 2026.

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://ventus.energy/uploads/Juglas_Jauda_valuation.pdf; https://www.rocketbtc.com/privacy; https://www.rocketbtc.com/risk-disclosure

The Act lists eleven reasons a court may refuse a plan. Viability and the best-interest test are two of them. Six more points fit what my article has found. Each still needs your own explanation of how it harms your claim. Where you can’t prove a fact, say what you know, name the document that would show the rest, and ask the court to obtain it.

Who keeps getting paid in full? A plan must set out the creditors it does not affect and the reasons (§21(1)4²). This plan exempts “platform, IT, office and identification service agreements”, budgets about €1.9 million a year for overheads, and names no contractor and no price. Ventus told me its staff sit in sister companies like White Label Solution, which kept 61 cents of every euro it billed last year: €457,000 profit on €752,000. A plan that falls short of §21 can be refused under §28(5)(5).
Is the insider class complete? Creditors connected with the company must vote as a separate group (§21(3)). The Bankruptcy Act says who counts: board members, shareholders above 10%, subsidiaries and their board members, anyone with a significant common economic interest, and anyone else the court finds close to the company (§117). The plan’s insider class has three names. I see two that are missing. White Label Solution belonged to Timma and to Jansons’s company, half each, until they handed it to Ventus’s CMO four days after the Bafin announcement. Ventus says its own staff sit there. If that company lent through the platform, it belongs in the insider class and not in yours. And the promoters hold shares in Ventus through a company that owns 15% of it. If they lent through the platform, they vote in your class today. Tell the court why that is a common economic interest, and ask it to have the list checked. Grounds: §28(5)(6) and (8).
How were the votes counted? The Act says the number of votes is proportional to a creditor’s principal claim (§24(2)). The plan counts the recognised claim: €83.89 million, of which €18.33 million is interest that accrued up to 25 August and was never paid out. More than a fifth of all votes rests on interest. Ask the court whether that matches the Act. Ground: §28(5)(6).
What does the bankruptcy comparison leave out? Ventus’s own plan puts the bankruptcy payout at 62.1% of claims. That estimate counts plants, cash and half of the money Ventus is owed. It has no line for money clawed back from insiders, none for claims against management, and none for anything recovered from the people who sold Ventus its assets. The best-interest test compares your recovery under the plan with a bankruptcy (§26(2)). If you raise it, the court has to value the assets itself (§28(3¹)). If the court brings in an expert at your request, you pay the deposit for the expert (§31(5¹)). If it isn’t paid by the date the court sets, the court denies the request (§31(5²)).
Did the court have jurisdiction at all? Under the EU Insolvency Regulation the case belongs where Ventus has its centre of main interests, and the court must state the grounds for its jurisdiction (Articles 3 and 4). Any creditor may challenge the opening decision on that ground (Article 5). Ask the court to say on what facts it placed Ventus’s centre of main interests in Estonia, and list the facts that point to Riga: no office, employees or payroll in Estonia, management and staff in Riga, nearly all the plants in Latvia and Lithuania. I found no separate appeal for this in the Act, so raise it in your written position and again in your court application. Cite Politsei- ja Piirivalveamet, teatis kriminaalmenetluse alustamata jätmises nr 26230101295, 24.08.2026, reference 3.2-1/28788-2, and ask the court to obtain it.
Where are the accounts? A reorganisation petition must come with the company’s financial statements for the previous year (§7(3)), and the court opens proceedings only if the petition meets the Act’s requirements (§8(1)). Ventus Energy Group OÜ has never filed an annual report. The Estonian register lists both 2024 and 2025 as not submitted. The balance sheet and forecast tables in the plan’s annexes are not annual accounts. The court opened the case, so it must have been given something. Ask what it was, and why creditors weren’t shown it.

Two more points for the same request. The plan must show the value of pledged assets, both in bankruptcy and under the plan (§21(1)1¹). Krustpils was pledged to an outside company nine days before Ventus filed. Jugla was pledged to the same company days after the court order, for a debt of up to €1.95 million. Ask where the plan shows what those pledges leave for you. And the court may hold a hearing before it decides (§28(4)). Ask for one.

One question belongs in your written position to the adviser and again in your court application. The court order is dated 18 August 2026. A Ventus holding company took the remaining 51% of Jugla with effect from 26 August and pledged those shares to an outside company the next day. The Krustpils pledges were replaced by new ones on 4 September, and three days later a man from the pledge holder’s address was left as the only member of the Krustpils board.

The company has to tell the adviser about transactions outside its regular business (§11(1)(5)). On paper that covers only Ventus’s own deals, and these were done by its subsidiaries. He knows the result anyway: the plan he wrote with Ventus counts Jugla at 100%.

Ask him: what did the other 51% cost, who paid, and what is the plant now pledged for? Don’t count on an answer. He wrote this plan with Ventus. So put the same three questions to the court. If these count as Ventus’s own transactions, he wasn’t told and creditors were harmed, that is a ground for refusal under §28(5)(1). And if he was told and waved it through, the court should hear that too.

Documents obtained by the author: the plan’s §§1.1, 3.1.3, 3.2.2, 6.1–6.3, 10 and 11.1; Annexes 1–5; 2025 annual accounts of White Label Solution, Lursoft extract; Lursoft ownership records for White Label Solution; Ventus’s written answers to the author, November 2025; Lursoft commercial-pledge extracts for Juglas Jauda; Estonian Police and Border Guard Board notice No. 26230101295 of 24 August 2026; DEKO magazine, June 2026; Lursoft register extract for Juglas Jauda of 7 October 2026; PJ Serviss current and historical board records; Greenpower and RSGA register records; Lursoft commercial-pledge records for PJ Serviss, as transcribed on 10 September 2026.

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://www.riigiteataja.ee/akt/114032025017; https://eur-lex.europa.eu/eli/reg/2015/848/oj/eng; https://ariregister.rik.ee/eng/company/16964065/Ventus-Energy-Group-O%C3%9C; https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimisteade/2026/8/25/2640998; https://ariregister.rik.ee/eng/company/17067652/VENTUS-Employee-and-Partnerships-Stock-Options-O%C3%9C; https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Verbrauchermitteilung/unerlaubte/2026/meldung_2026_05_18_ventus_energy_group.html; https://www.lursoft.lv/komerckilas/40103644174?l=en, paywalled

Let AI write the first draft

An AI tool can turn your reasons into a tidy Estonian draft. It will also make things up, and Estonian courts have warned about exactly that. You sign it, so you check it. If your AI tool can’t open links, paste the article and this guide into the chat first.

Source: https://www.kohus.ee/ajakirjanikule/uudised/tehisaru-abil-koostatud-menetlusdokumendid-tuleb-hoolikalt-ule-kontrollida

Prompt 1: your written position

I lent money to Ventus Energy Group OÜ. It is in reorganisation proceedings at Harju County Court in Estonia, case 2-26-16225. Creditors vote on its plan until 12 October 2026. I am voting no, and I have to email a written position to [email protected] by 12 October 2026.

Read this article first. It sets out what is wrong with the plan and lists its sources: https://www.karsten.me/money/ventus-restructuring-recovery/
The official notice with the deadline: https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimiskava-projekti-teade/2026/9/24/2653915

Write my written position as an email. Say that I voted no, and ask for my no vote and my reasons to be entered in the voting record. Give my reasons from the article, each in two or three plain sentences, and say for each how it harms me as a lender. Use only what the article and the notice say. Do not invent facts, dates, legal provisions or court decisions. If you cannot open a link, tell me and I will paste the text.

Before you write, ask me for my name, the amount I lent and anything else you need. Write in the language I am using with you.

Prompt 2: your court application

Now write my application to Harju County Court in case 2-26-16225, asking the court to refuse to approve the reorganisation plan of Ventus Energy Group OÜ.

The law is the Estonian Reorganisation Act. English translation: https://www.riigiteataja.ee/en/akt/501122025005
The Estonian text, which is the one that counts: https://www.riigiteataja.ee/et/akt/111112025013
If the plan was accepted in the vote, the basis is §26. If it was not accepted and the court is asked to approve it anyway, the basis is §29². There the §28(5) grounds apply through §36(1)(1). Ask me which applies. If I don’t know yet, write the §26 version and tell me what changes for §29².

Use the grounds in this guide: https://www.karsten.me/money/ventus-voting-no-objection-guide/
Use the facts in this article: https://www.karsten.me/money/ventus-restructuring-recovery/
For each ground give the rule with its section number, the facts and where they come from, and how it harms my claim. Do not invent facts, dates, legal provisions or court decisions. If you cannot confirm a section number from the Act, say so.

Include: the court and the case number; my name, address, email and phone; my personal ID number or date of birth; my claim; the request that the court refuse to approve the plan; my reasons; a numbered list of attachments (proof of my no vote, my written position, the article); the date and a signature line.

Ask me for my details and the dates of my vote and my email first. Write the application in Estonian and put an English translation below it.

Prompt 3: check it

Check the application you just wrote against the article, the guide and the Act linked above. List every statement the sources do not support, every section number you could not confirm, and anything missing from the list of what the application must include. Then give me the corrected Estonian text and the English translation.

Read what it wrote before you sign. Every sentence goes out under your name. The Estonian text of the Act is the one that counts. The English one is a translation.

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://www.riigiteataja.ee/et/akt/111112025013

Want to go further? Talk to a lawyer in Estonia.

Questions this guide doesn’t answer? Whether there is a fee, what to translate, what happens after the court decides: that is what an Estonian lawyer is for. One thing to know now: if the court approves the plan anyway, you can appeal within 15 days of the published notice, but only if you filed the application in step 3 (§37).

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://www.riigiteataja.ee/et/akt/111112025013

Four more ways to stop it

None of these replaces the vote, the written position or the court application. Do those first. The Act has more tools than a no vote and a refusal request. I have tested none of them, and each one needs an Estonian or Latvian lawyer. Nobody at Ventus is going to tell you they exist.

Ask the court to end the proceedings now. The court ends a reorganisation early if the company turns out to be permanently insolvent or the conditions for opening it have fallen away (§40(2)), if the company “squanders the property thereof or performs a transaction which damages the interests of obligees” (§41), or if it “has submitted incorrect information about the claims” (§43). The plan’s own figures show negative equity of €16.2 million and a loss of €7.8 million in eight months. The Krustpils pledges were replaced by new ones on 4 September, after the court order. The insider list has three names. Who is allowed to make that request is the first question for a lawyer.

File for bankruptcy before the plan is approved. The court parks a bankruptcy petition while the reorganisation runs (§11(1)4). It “continues with hearing the bankruptcy petition” if the plan is refused or the proceedings end (§40¹). Once a plan is approved, no petition can be filed on a claim the plan covers (§49(1)). So for your loan claim, this door closes on approval day. The normal route, filing because you weren’t paid, needs a claim that is already due. But the law has others. If a company tells its creditors or the public that it can’t meet its obligations, a creditor can file whether his own claim is due or not. But Ventus says it can pay, so you would have to prove it can’t. The court can also ask you for a deposit up front. Talk to a lawyer before you file.

Open a second front in Latvia. EU law allows secondary insolvency proceedings in another member state where the company has an establishment (Article 3(2)). Ventus’s office, staff and most of its borrowers are in Latvia. A Latvian administrator would deal with the assets located there, and a loan is located where the borrower runs its business.

Hold the adviser to his job. The adviser works under the supervision of the court and of his professional chamber (§§19¹–19³). He sits on that chamber’s disciplinary panel himself. A complaint about him would go to the Bar instead, because he is also an advocate (§19³(3)). He has to tell the court promptly if it becomes clear that the company is insolvent. Put the numbers to him in writing and ask what he has reported.

Documents obtained by the author: the plan’s balance sheet as of 31 August 2026 and §§3.1.3 and 6.3; Lursoft commercial-pledge records for PJ Serviss, as transcribed on 10 September 2026; Estonian Police and Border Guard Board notice No. 26230101295 of 24 August 2026; DEKO magazine, June 2026.

Sources: https://www.riigiteataja.ee/en/akt/501122025005; https://www.ametlikudteadaanded.ee/ee/Saneerimisn%C3%B5ustaja%20Kristo%20Teder/saneerimismenetluse-teated/saneerimisteade/2026/8/25/2640998; https://www.riigiteataja.ee/akt/114032025017; https://eur-lex.europa.eu/eli/reg/2015/848/oj/eng; https://kpkoda.ee/aukohus/

Discover more from Karsten Philip Aichholz

Subscribe to get the latest posts sent to your email.

Additional menu