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The linked article really doesn't seem to imply that.
Under "Expanded definition of “virtual currency service”" it seems to apply exclusively to businesses.
My guess: it doesn't matter a damn what the exact language is, they'll use it any way they want. But secondly, I don't believe for one second that either open source wallet developers or holders of personal wallets, will be held liable using this kind of law.
I think they want to find a way to target anybody setting up stuff like ICOs, defi, investment schemes, etc. Basically any organized system of investment.
and a followup by that same individual after the Jan 2nd, 2022 MoF post:
"Not banning crypto, but effectively forcing all crypto to be custodian only. Which if effectively the same end result. [...]"
RT moo9000
Estonia did not only ban #defi, but they also banned #bitcoin.
You are not allowed to download wallet and hold #bitcoin anymore in Estonia.
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