LT v13.3.0
content: ai_generated 100 sources retrieved model claude-opus-4-8 · 2026-06-27

Lithuania

LT schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 53 sourced findings · 113 sources in the cumulative register

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Law made at European Economic Area level that applies in Lithuania is covered once, on the European Economic Area page. This page covers Lithuania’s own layer: implementation, national authorities, national options and local enforcement.

Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Lithuania's payments regulatory posture this cycle shows a notable combination: active licence enforcement against a non-bank payment institution alongside continued growth in its MiCA-regulated crypto-asset perimeter. Lietuvos bankas revoked the electronic-money institution licence of Paytend Europe, UAB following an inspection that identified AML/CFT monitoring and internal-control failures. In the same period, Lietuvos bankas authorised Micar assets, UAB as a crypto-asset service provider under the Markets in Crypto-Assets Regulation, the fourth such authorisation in Lithuania, covering custody, exchange and order execution for retail and professional clients. Read together, these two developments indicate a market-access regime that is tightening on the licensing and conduct side for existing payment institutions while continuing to actively build out its licensed digital-asset provider base, a pattern consistent with an actively supervised fintech hub rather than a laxly regulated one.

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Lithuania operates a dual EMI/PI authorisation regime under the Bank of Lithuania, now supplemented by a completed MiCA CASP authorisation track that has fully replaced the former light-touch VASP registration model as of 1 January 2026.

Standing sub-brief · as of 27 June 2026378 words · last cycle 2026-10-18

Licensing, Authorisation & Market Access

Lithuania's market-access regime for non-bank payment firms is built on its transposition of EMD2 and PSD2 under the Law on Electronic Money and Electronic Money Institutions, supervised by the Bank of Lithuania as a single supervisor. The central distinction for any new entrant is between the two EMI tiers. An unrestricted (full) EMI must hold minimum initial capital of no less than EUR 350,000, and that authorisation confers EEA passporting after notification, opening the entire single market. A restricted-activity EMI, by contrast, carries no minimum capital requirement but is valid solely within Lithuania and cannot passport. This bank-PSP versus non-bank-PI/EMI framing matters: the entities discussed here are non-bank electronic-money institutions, not credit institutions, and the EUR 350,000 capital floor plus EEA passporting is the core economic reason Lithuania became the EU's largest non-bank EMI/PI hub, defining the market-access cost for new entrants.

Periodic update · new data 2026-10-18

Licensing, Authorisation & Market Access

Lietuvos bankas revoked the electronic money institution licence of Paytend Europe, UAB, a Chinese-owned payment firm, following an inspection that found AML/CFT monitoring and internal-control failures. This is a market-access event: the firm loses its authorisation to provide payment services in Lithuania, with direct consequences for any merchant, platform or correspondent relying on Paytend's Lithuanian licence to access EU payment rails. The revocation is a tightening development for the licensing and authorisation module, following an active 2026 Bank of Lithuania inspection programme.

For non-bank payment institutions and electronic money institutions operating in or through Lithuania, this is a reminder that authorisation under the jurisdiction's regime, including for an EMI with a cross-border client base, carries an ongoing compliance obligation whose breach can result in full licence withdrawal rather than a lesser remedial measure. The action is directly T1-sourced to Lietuvos bankas's own publication.

Outlook

Further licensing actions against other payment or e-money institutions identified through the same inspection programme would be consistent with the current enforcement trajectory. Market participants relying on Lithuanian-licensed non-bank payment institutions as a route to EU payment infrastructure access should treat this as an indication of active, not passive, supervision of that licence category.

6 earlier distinct update(s)
Periodic update · new data 2026-10-04

Licensing, Authorisation & Market Access

The Bank of Lithuania licensed Finance EU, operating under the brand Florrid, as the country's 16th licensed crowdfunding provider, placing Lithuania fifth in the EU by count of such licences. This confirms a continued high licensing pace in Lithuania's non-bank financial-services sector, extending beyond the EMI and payment-institution categories that have historically defined the country's market-access profile as a payments hub.

Alongside this new licence, the Bank of Lithuania has put forward draft amendments to the Law on Financial Institutions that would ease two procedural frictions for EMI and PI applicants and licensees. First, the deadline for a shareholder meeting to approve annual accounts would be extended from three months to five months, giving licensees materially more time to complete annual governance processes. Second, initial share capital could be deposited in an accumulation account at a licensed EMI or PI, rather than being restricted to a credit institution as is currently required; this would widen the pool of institutions through which a new applicant can satisfy its capital-deposit obligation during the licensing process.

Taken together, these developments indicate that Lithuania's market-access regime remains open and is being actively tuned for procedural ease, even as the jurisdiction's supervisor pursues concurrent prudential enforcement against an existing licensee in the same population. The market-access and conduct-enforcement postures are operating in parallel rather than in tension: new entry remains accessible while existing licensees face active supervisory scrutiny.

Outlook

The draft amendments to the Law on Financial Institutions have not yet been confirmed as adopted; their progress through the legislative process is the item to watch for EMI/PI applicants and licensees who would benefit from the extended accounts-approval deadline and the broadened capital-deposit option.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

Lithuania's payments-licensing base continued to expand this cycle: the Bank of Lithuania licensed Finance EU, operating under the brand Florrid, as the country's 16th crowdfunding provider, placing Lithuania fifth in the EU by crowdfunding-provider count. This is a concrete addition to the licensed population in a specific product category, crowdfunding, distinct from the electronic-money-institution and payment-institution licensing for which Lithuania is more broadly known.

Separately, the Bank of Lithuania consulted, between 3 and 17 August 2026, on a draft law that would allow initial share capital for newly established financial institutions to be deposited in an accumulation account at a licensed electronic money institution or payment institution, rather than exclusively at a credit institution as under the current framework. If enacted, this would materially lower a practical entry barrier: prospective new financial institutions would no longer need a banking relationship purely to hold initial share capital during the establishment process, potentially accelerating market entry for non-bank applicants. This is a consultation-stage draft law; it has not yet been enacted, and the consultation closed on 17 August 2026 without a reported outcome this cycle.

Outlook

The outcome of the August 2026 consultation on initial-capital deposit accounts is the clearest near-term item to watch, expected to surface around the fourth quarter of 2026. Continued growth in the crowdfunding-provider count would further reinforce Lithuania's positioning as a diversified non-bank financial-services licensing hub.

Periodic update · new data 2026-09-21

Licensing, Authorisation & Market Access

The Bank of Lithuania licensed Finance EU (Florrid) as its 16th crowdfunding provider this cycle, a development that places Lithuania fifth in the EU for the number of crowdfunding-provider licences issued. This sits on top of an already substantial standing population of licensed electronic money institutions and payment institutions: as of the July 2026 register, roughly 120 such entities operate from Lithuania, split approximately between 80 EMIs and more than 40 PIs. The crowdfunding development is notable less for its individual scale and more for what it confirms about Lithuania's licensing strategy: growth is occurring across multiple licence categories simultaneously, not solely within the EMI/PI base that has historically defined the jurisdiction's fintech-hub reputation.

This breadth matters for a market-access assessment. A licensing hub that grows only in its established category risks eventual saturation or diminishing differentiation; one that adds adjacent licence categories, as Lithuania has done with crowdfunding, signals continued regulatory capacity and appetite to process novel licence types alongside the existing EMI/PI caseload. The bank-PSP versus non-bank-PI/EMI distinction remains material here: none of this cycle's market-access activity involves a bank charter, and Lithuania's growth continues to be driven overwhelmingly by non-bank payment and e-money licensing routes.

Outlook

Watch whether the crowdfunding-licensing pace continues at a rate that would move Lithuania further up the EU ranking, and whether the roughly 120-strong EMI/PI population shows net growth or consolidation in the next reporting period.

Periodic update · new data 2026-09-11

Licensing, Authorisation & Market Access

The Bank of Lithuania's Resolution No. 247 amends EMI and PI governance requirements, introducing new governance, internal-control and client-fund-safeguarding standards, including a mandatory wind-down plan as a condition of continued authorisation for non-bank payment and e-money institutions. Most of the new provisions take effect from 1 January 2026, with the remaining requirements applying from 1 January 2027, giving licensees a staggered compliance runway rather than a single cutover date. This safeguarding mechanism is explicitly categorised as a wind-down-plan mandate, distinguishing it from a pure capital or segregation requirement and signalling that Lithuanian supervisors are focused on orderly market exit as much as ongoing operational soundness.

Separately, the Ministry of Finance has proposed raising the maximum supervisory contribution payable by payment and e-money institutions to the Bank of Lithuania, from the current 0.65 percent ceiling to 1 percent. This remains at proposal stage and has not been enacted; if adopted, it would represent a material increase in the direct funding cost of Bank-of-Lithuania supervision borne by the non-bank PI/EMI population specifically, distinct in mechanism and burden from the governance and safeguarding requirements introduced under Resolution No. 247.

Taken together, the confirmed governance and safeguarding tightening under Resolution No. 247 and the proposed supervisory-fee increase describe a market-access environment that remains open to non-bank PI/EMI licensees but is raising both the operational-compliance floor and, potentially, the direct cost of ongoing supervision. This carries the bank-PSP versus non-bank-PI/EMI distinction explicitly: these requirements target the EMI and PI licence categories specifically, distinct from the separate prudential and supervisory framework applicable to Lithuania's licensed banks.

Outlook

The remaining tranche of Resolution No. 247 provisions applicable from 1 January 2027 is the next concrete date to watch for full implementation of the new governance and safeguarding regime. Whether the Ministry of Finance's proposed supervisory-contribution increase to 1 percent proceeds to enactment, and on what timeline, will determine the scale of the additional funding-cost burden facing Lithuania's EMI/PI population.

Periodic update · new data 2026-09-08

Licensing, Authorisation & Market Access

The Bank of Lithuania consented to Checkout Payments Group Limited's acquisition of BLUE EMI LT, UAB, a confirmed, primary-source-evidenced inbound clearance that reinforces Lithuania's function as a receiving jurisdiction for cross-border payments M&A. In the same window, PAYTEND EUROPE, UAB lost its electronic money institution licence, a confirmed revocation drawn directly from the Bank of Lithuania's own EMI register. A third supervisory action, an interim restriction barring a payment institution from serving new and existing customers pending inspection, was also recorded this cycle; the substantive AML/CFT basis for that action is addressed by the financial-integrity monitor's own coverage rather than here, but its occurrence is relevant to the licensing and market-access picture insofar as it demonstrates the Bank of Lithuania exercising active portfolio supervision across its licensed non-bank population.

Read together, an inbound acquisition clearance, a licence revocation, and an interim restriction occurring within a single supervisory window indicate that the Bank of Lithuania is functioning as both a growth-enabling and a risk-based enforcement authority concurrently. This is a materially different picture from a purely permissive licensing hub, and it should inform how prospective entrants and acquirers weigh Lithuania's EMI/PI licensing environment: market access remains open and functioning, evidenced by the cleared acquisition, but active supervision of the existing licensed population is a live and demonstrated feature of the regime, not a theoretical one.

Outlook

Watch for whether the interim restriction on the affected payment institution is resolved through remediation or further licence action, and for any additional M&A activity in the Lithuanian EMI/PI sector following the Checkout Payments Group clearance, which may signal continued inbound consolidation interest in the jurisdiction's non-bank payments population.

Periodic update · new data 2026-08-11

Licensing, Authorisation & Market Access

Lithuania's crypto-asset licensing framework completed a structural transition this cycle. The national Virtual Asset Service Provider (VASP) registration regime, which had allowed crypto firms to operate under a lighter-touch registration model, ended on 1 January 2026 and has been replaced by Bank of Lithuania authorisation of crypto-asset service providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCA) framework. This is a market-access-defining event: firms previously operating under VASP registration must now hold a full Bank of Lithuania CASP authorisation, a materially higher bar for market entry and continued operation.

Set against this, Lithuania's core electronic-money-institution and payment-institution licensing base continues to grow: approximately 120 licensed entities are on the register as of July 2026, comprising roughly 80 EMIs and more than 40 PIs, reinforcing Lithuania's position as one of the European Union's leading non-bank payments licensing hubs. The Bank of Lithuania has also introduced dedicated fintech supervisory contact points, announced 7 April 2026, a market-access-relevant development that signals a more accessible, dialogue-based engagement channel for firms navigating licence applications and ongoing supervisory relationships alongside the more formal authorisation process itself.

This distinction between bank and non-bank market access matters structurally: the CASP authorisation route and the EMI/PI licensing route are both non-bank frameworks, administered by the Bank of Lithuania as prudential supervisor rather than through a separate banking licence, meaning firms choosing Lithuania as a market-access base are, in practice, choosing into a jurisdiction whose supervisory architecture treats non-bank payment and crypto-asset firms as a first-class, directly supervised population rather than as an adjunct to bank-centric regulation.

The scale of the licensed EMI/PI base, at approximately 120 entities split roughly 80 EMIs to more than 40 PIs, also means that any single supervisory or enforcement action sits within a comparatively large population, a scale factor relevant to how market-access risk should be read at the jurisdiction level.

Outlook

The key market-access question for the next cycle is how quickly firms previously operating under the lapsed VASP registration model secure full CASP authorisation, and whether any firms exit the market rather than complete that transition. Continued growth in the EMI/PI licence count, from its current base of approximately 120 entities, would confirm that the fintech-dialogue mechanism and Lithuania's broader market-access reputation continue to attract new licence applications despite the rising compliance bar addressed under the conduct and safeguarding lens.

Sources and findings (4)
  1. T1https://www.lb.lt/en/authorisation-of-electronic-money-institutionsretrieved
  2. T1https://www.lb.lt/en/emi-prudential-requirements-and-ratiosretrieved
  3. T3https://advapay.eu/emoney-and-payment-institution-licensing/e-money-institution-license-in-lithuania/retrieved
  4. T3https://www.flagright.com/post/key-compliance-laws-in-lithuania-for-financial-institutionsretrieved

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The Bank of Lithuania's revised Resolution No 247 safeguarding/governance regime (internal control, risk management, protection of received funds) has applied in full since 1 January 2026, alongside the wind-down-plan requirement (in force since 9 April 2025) and, from 1 January 2026, numerical limits on investment of safeguarded client funds.

Standing sub-brief · as of 27 June 2026304 words · last cycle 2026-10-12

Conduct, Safeguarding & Promotions

Safeguarding is the live conduct theme for Lithuania's non-bank EMIs and PIs, and it is the principal customer-fund-protection backstop in a sector with no FSCS-equivalent deposit guarantee. Under the Bank of Lithuania's framework, EMIs and PIs must safeguard client funds by one of three routes: segregation in a separate account at a credit institution in Lithuania, another Member State, or the central bank; investment in secure, liquid, low-risk assets such as government, central-bank or company bonds rated at least BBB, short-term deposits and qualifying collective investment schemes; or insurance or guarantee. The choice directly affects operational risk and the selection of bank partners, and it carries the bank versus non-bank distinction at its heart — these protections substitute for the deposit-guarantee architecture that covers bank-PSP deposits.

Periodic update · new data 2026-10-12

Conduct, Safeguarding & Financial Promotions

Lithuania's electronic money institutions and payment institutions have operated, since 1 January 2026, under full compliance with Resolution No 247 as amended by Resolution No 03-33. This national instrument governs governance, internal control, risk management and the safeguarding of received funds for licensed EMIs and PIs. Its commencement brought into effect numerical investment limits on safeguarded client funds, a quantification of what the EU EMD2 baseline expresses only in the qualitative language of 'secure, liquid, low-risk assets.'

The shift from qualitative to quantitative standard is significant for how Lithuanian-licensed firms demonstrate safeguarding adequacy. Under the general EU-level wording, firms and supervisors have historically retained considerable latitude in determining what instruments and concentrations count as sufficiently secure, liquid and low-risk for safeguarding purposes. Resolution No 247's numerical limits remove much of that latitude for Lithuanian-licensed entities specifically, replacing interpretive judgement with a bright-line compliance benchmark. For a firm managing a safeguarding portfolio, this means the question is no longer solely 'is this asset class appropriate' but 'does this allocation sit within the specified numerical limit.'

This commencement sits atop, rather than replaces, the broader governance and internal-control requirements also contained in Resolution No 247, which apply alongside the safeguarding limits. Together these obligations position Lithuania's safeguarding and governance regime as materially more specified than the EU directive text alone would produce, a distinction that matters when comparing the EMI/PI regulatory environment in Lithuania against other Baltic and wider-EU licensing jurisdictions that have not layered an equivalent national quantification onto the EMD2 baseline.

Outlook

The principal open question following full commencement is supervisory follow-through: whether the Bank of Lithuania actively tests licensed EMIs and PIs against the new numerical investment limits in the ordinary course of supervision, and whether any gaps surfaced through that testing produce enforcement activity. No enforcement action tied specifically to the numerical limits has been identified to date. Firms licensed in Lithuania should expect safeguarding-adequacy reviews to reference the quantified benchmark going forward rather than the more general EU-level standard alone.

3 earlier distinct update(s)
Periodic update · new data 2026-10-04

Conduct, Safeguarding & Financial Promotions

The Bank of Lithuania restricted EMI Verified Payments from onboarding new clients, encumbering assets, or extending lending, following a capital and shareholder-lending inspection failure, with a remediation deadline of 1 October 2026 for restoring capital adequacy. This is an active, dated supervisory enforcement action against a licensed electronic-money institution, carrying a specific restriction on the firm's ability to conduct its core onboarding and lending functions until the capital position is restored.

In parallel, the Bank of Lithuania opened a consultation on how fines are calculated and on when a breach counts as minor. Running this procedural consultation at the same time as an active capital-adequacy enforcement action against a licensee suggests the regulator is using current casework to inform, or at minimum co-occurring with, a broader review of how its enforcement discretion is exercised and communicated.

The combination of an open licensing pipeline, described separately under W1a, and this active conduct-enforcement action against an existing licensee indicates that the Bank of Lithuania's conduct and safeguarding supervision is operating with genuine teeth rather than as a formality attached to an otherwise permissive licensing regime. For firms operating in or entering the Lithuanian EMI/PI market, this restriction stands as a concrete illustration of how capital-adequacy and shareholder-lending failures are treated once identified through inspection.

Outlook

The 1 October 2026 deadline for Verified Payments to restore capital adequacy is the immediate marker: whether the firm meets that deadline determines whether the Bank of Lithuania escalates its restriction further. The outcome of the fine-calculation and minor-breach consultation is a further item to watch, as it may recalibrate how future conduct breaches of this kind are assessed and penalised going forward.

Periodic update · new data 2026-09-21

Conduct, Safeguarding & Financial Promotions

The Bank of Lithuania ordered EMI Verified Payments to restore capital adequacy by 1 October 2026, and in the interim barred the firm from onboarding new clients, from encumbering assets, and from extending lending, pending a further supervisory decision. This is a conduct and prudential enforcement action against a licensed non-bank payment institution, distinguishing it clearly from a bank-charter conduct matter: the tools available to the regulator here are licence-condition restrictions rather than the broader prudential toolkit available against a bank, but they are nonetheless severe in practical effect, freezing the firm's ability to grow its book while remediation is pending.

The action is a useful counterweight to this cycle's market-access growth narrative. Lithuania's EMI/PI population continues to expand, but the Verified Payments order demonstrates that the Bank of Lithuania is willing to intervene decisively in an existing licensee's operations when capital adequacy is deficient, rather than treating licensing growth and supervisory intensity as being in tension. The fixed 1 October 2026 deadline gives this action a concrete near-term resolution point.

Outlook

Watch whether Verified Payments restores capital adequacy by the 1 October 2026 deadline or whether the restriction escalates toward licence suspension or revocation, and whether this action prompts closer market attention to capital-adequacy compliance across Lithuania's broader EMI population.

Periodic update · new data 2026-08-11

Conduct, Safeguarding & Financial Promotions

Lithuania's non-bank payments sector faces a significant conduct and prudential-framework transition over 2026 and 2027. A provisional agreement on the third Payment Services Directive and the accompanying Payment Services Regulation (PSD3/PSR) was reached on 27 November 2025, with formal publication expected in the first half of 2026 and entry into force anticipated around 2027. Under this migration, Lithuania's electronic-money-institution population will transition into a unified 'payment institution authorised to issue e-money' category, a structural reclassification of the licence form itself. This is a conduct-and-authorisation-framework change rather than a change in permitted underlying activity, but it will require licensed firms to track the final legislative text closely once published, since the precise mechanics of the migration remain to be confirmed.

Alongside the EU-level PSD3/PSR track, Lithuania has tightened its own national conduct and governance requirements for 2026. The corporate tax rate applicable to Lithuanian payment institutions rose to 17 percent from 1 January 2026, up from 16 percent, a direct cost increase layered onto the compliance bar. More significantly for day-to-day conduct and governance, money-laundering reporting officers, risk leads and IT leads at Lithuanian PIs and EMIs must now be Lithuania-resident, and outsourced part-time MLRO arrangements are no longer accepted. This raises the operational-substance bar meaningfully: firms that previously relied on outsourced or non-resident compliance leadership must now build in-country governance capacity, a change that affects the non-bank PI/EMI population specifically rather than Lithuania's bank-licensed institutions, which have generally maintained in-country governance structures already.

Outlook

The publication of the final PSD3/PSR legislative text, expected in the first half of 2026, is the key event to track for conduct and safeguarding purposes: it will confirm the precise scope of the unified e-money-issuing payment institution category and may adjust the anticipated 2027 entry-into-force date. In parallel, the practical effect of the new in-country MLRO, risk and IT residency requirements on Lithuania's approximately 120 licensed EMIs and PIs — whether it prompts consolidation, exit, or simply increased local hiring — is the operational question for the next cycle.

Sources and findings (4)
  1. T1https://www.lb.lt/en/faq/what-client-fund-safeguarding-requirements-apply-to-payment-or-e-money-institutionsretrieved
  2. T1https://www.lb.lt/en/emi-prudential-requirements-and-ratiosretrieved
  3. T3https://ecovis.lt/new-compliance-requirements-for-electronic-money-and-payment-institutions/retrieved
  4. T3https://key2law.com/en/licences/emi-licences/lithuaniaretrieved

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BoL is MiCA NCA for ART/EMT issuers and CASPs; ART/EMT requirements from 30 June 2024, MiCAR full from 30 Dec 2024; LT Law on Markets in Crypto-Assets in force 25 July 2024; EMT issuance restricted to authorised EMIs/credit institutions; CASP transition cut-off 1 Jan 2026.

Horizon · 2026-01 (±quarter)Lithuania CASP licensing cut-off for transitioning VASPsin_force_pending · T3
Standing sub-brief · as of 27 June 2026296 words · last cycle 2026-10-18

Stablecoins & Digital Money

The Bank of Lithuania is the national competent authority for licensing and supervising MiCAR entities, covering both asset-referenced token and e-money token issuers and crypto-asset service providers. ART and EMT issuer requirements applied from 30 June 2024, with MiCAR applying fully from 30 December 2024; Lithuania transposed the framework via the Law on Markets in Crypto-Assets, in force since 25 July 2024. A structurally important feature is that only authorised EMIs or credit institutions may issue e-money tokens. This creates a direct bridge to the W1a licensing module: a Lithuanian unrestricted EMI licence doubles as the regulatory status required to act as a MiCA EMT issuer, making Lithuania a natural hub for euro-stablecoin issuance and pulling the non-bank EMI population directly into the stablecoin space alongside credit institutions.

Periodic update · new data 2026-10-18

Stablecoins & Digital Money

Lietuvos bankas authorised Micar assets, UAB as a crypto-asset service provider under the Markets in Crypto-Assets Regulation, the fourth such authorisation granted in Lithuania. The authorisation covers custody, exchange and order execution for both retail and professional clients, extending the range of licensed digital-asset services available under Lithuania's MiCA regime. This authorisation places Lithuania second in the Nordic-Baltic region for CASP authorisations, behind Finland, continuing a steady build-out of the jurisdiction's licensed digital-money and crypto-asset-services perimeter.

Separately, and on the electronic-money side of digital money regulation, Bank of Lithuania Resolution 247, recast by Board Resolution No. 03-33 of 6 March 2025, together with Resolution No. 03-119, entered into force on 1 January 2026. These resolutions establish safeguarding and governance requirements for Lithuanian electronic money institutions, with the safeguarding mechanism built around segregation of client funds. This is a standing structural requirement for EMIs operating in the jurisdiction, distinct from but complementary to the MiCA CASP authorisation track, since EMIs and CASPs are licensed under separate regimes even where a single corporate group may hold both authorisation types.

Taken together, these two developments show Lithuania continuing to build out both strands of its digital-money regulatory architecture: electronic money under a safeguarding-focused national regime, and crypto-assets under the directly applicable MiCA framework, with authorisation activity continuing in the latter.

Outlook

Continued CASP authorisation activity at a similar pace is the expected trajectory absent any signalled change in Lietuvos bankas's approach. The practical effect of the EMI safeguarding resolutions on existing Lithuanian e-money institutions' operational practices is a relevant area to watch as the 1 January 2026 effective date is now in force.

Sources and findings (4)
  1. T1https://www.lb.lt/en/markets-in-crypto-assetsretrieved
  2. T3https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/lithuania/retrieved
  3. T3https://gofaizen-sherle.com/emi-license/lithuaniaretrieved
  4. T3https://tet.lt/mica-license-in-lithuania/retrieved

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Operational resilience is governed by DORA (Regulation (EU) 2022/2554), directly applicable since 17 January 2025, supervised by the Bank of Lithuania as integrated financial supervisor across banks, insurers, EMIs/PIs and investment firms. Obligations cover ICT risk management, major-incident reporting (4h/72h/1-month), resilience testing, ICT third-party oversight and a Register of Information. Lithuania operates the REGATA system for JSON-format incident reporting.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open this jurisdiction's page on Dataprotection.gi →

Standing sub-brief · as of 27 June 2026237 words · last cycle 2026-09-28

Operational Resilience & Critical Infra

The Digital Operational Resilience Act, Regulation (EU) 2022/2554, has been directly applicable since 17 January 2025, and the Bank of Lithuania, acting as an integrated financial supervisor, oversees compliance across banks, insurers, EMIs and PIs, and investment firms. The obligations span ICT risk management, major-incident reporting on the 4-hour, 72-hour and 1-month cadence, resilience testing, ICT third-party oversight, and the maintenance of a Register of Information. Operationally, Lithuania runs the REGATA system for JSON-format incident reporting. Because the Lithuanian fintech sector relies heavily on cross-border cloud and outsourcing arrangements, the DORA Register of Information and the ICT third-party oversight regime are a material operating constraint for both bank and non-bank entities supervised here.

Periodic update · new data 2026-09-28

Operational Resilience & Critical Infrastructure

DORA-aligned incident-reporting expectations, requiring initial notification within four hours and follow-up reporting within seventy-two hours, are now an explicit supervisory expectation for Lithuania-licensed electronic money institutions. This represents the operational-resilience dimension of the broader supervisory tightening evident elsewhere in Lithuania's payments sector this cycle, extending beyond capital-adequacy and licensing enforcement into incident-response timeliness as a distinct compliance expectation for EMIs operating in the jurisdiction.

This expectation applies specifically to the bank-and-EMI-regulated population rather than to non-bank payment institutions uniformly, reflecting the bank-PSP versus non-bank-PI/EMI distinction that runs through Lithuania's broader payments-supervision architecture: prudentially significant entities face the more demanding incident-reporting cadence associated with DORA alignment.

Outlook

Whether DORA-aligned incident-reporting expectations are extended explicitly to payment institutions as well as electronic money institutions, and how compliance with the four-hour/seventy-two-hour cadence is supervised in practice, are the items to watch as this expectation becomes embedded in ordinary supervisory practice.

2 earlier distinct update(s)
Periodic update · new data 2026-09-21

Operational Resilience & Critical Infrastructure

CENTROlink, the Bank of Lithuania's payment-infrastructure platform, processed 379.7 million payments in 2025, an increase of 28.9% year over year, with instant payments now accounting for 68% of total volume. The platform's participant community has grown to more than 200 financial institutions drawn from more than 20 countries, with more than 140 active participants as of the most recent update. This scale and growth rate together represent a structural competitive advantage rather than a single-cycle event: CENTROlink gives eligible payment institutions direct access to SEPA and instant-payment rails through the central bank itself, obviating the need for a correspondent-banking relationship with a commercial intermediary bank.

The resilience dimension of this infrastructure is inseparable from its growth: a platform now carrying nearly 380 million payments annually, with more than two-thirds processed as instant payments, is infrastructure whose continuous availability has become systemically important to the EMI and PI sector's day-to-day operations. The year-over-year growth rate of 28.9% also indicates the platform is still absorbing incremental participant and volume growth rather than approaching any evident capacity ceiling.

Outlook

Watch for continued growth in CENTROlink's participant count and transaction volume in the next reporting period, and for any operational-resilience disclosures addressing capacity planning given the platform's sustained high growth rate.

Periodic update · new data 2026-09-08

Operational Resilience & Critical Infrastructure

Trade-press reporting this cycle suggests the Bank of Lithuania introduced cyber-resilience stress testing in 2026. This rests on a single Tier-4 source without corroboration to a primary regulatory publication, and is therefore carried as a low-confidence, watch-status development rather than a confirmed operational-resilience measure. No further detail on the scope, frequency, or supervised-entity population subject to any such stress testing was available this cycle.

Outlook

Watch for primary-source corroboration of the cyber-resilience stress-testing claim in a future cycle; until such corroboration is available, this should be treated as an unconfirmed signal rather than a settled feature of Lithuania's operational-resilience supervisory framework.

Sources and findings (3)
  1. T1https://www.lb.lt/en/digital-operational-resilience-act-doraretrieved
  2. T3https://vendorica.com/supervisory/national-authorities/bank-of-lithuania/retrieved
  3. T3https://www.baltictimes.com/dora_in_the_baltics__what_financial_entities_in_estonia__latvia___lithuania_must_know/retrieved

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Card-scheme compliance follows the EU Interchange Fee Regulation (EU) 2015/751, capping interchange at 0.2% for debit and 0.3% for consumer credit card transactions; Lithuania is among Member States not permitting surcharging on fee-regulated cards. Visa/Mastercard publish Lithuania intra-location interchange schedules; PCI DSS and scheme rulebooks apply. Instant rails are mandated by the EU Instant Payments Regulation (EU) 2024/886, with Verification of Payee in force.

Standing sub-brief · as of 27 June 2026251 words · last cycle 2026-06-27

Scheme & Network Compliance

Card-scheme economics in Lithuania are fixed by the directly applicable Interchange Fee Regulation, Regulation (EU) 2015/751, which caps per-transaction interchange at no more than 0.2% for debit and 0.3% for consumer credit cards, prohibits territorial restrictions, and restricts the Honour-All-Cards rule. Lithuania does not permit surcharging on fee-regulated cards, a position corroborated by Tier-3 legal analysis listing Lithuania among the non-surcharging Member States. Together the caps and the no-surcharge regime fix acquirer and merchant economics for card flows in the jurisdiction and frame the competitive pricing environment for both bank and non-bank acquirers.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://eur-lex.europa.eu/eli/reg/2015/751/oj/engretrieved
  2. T3https://www.swlaw.edu/sites/default/files/2025-08/Article%205%20-%20Vihuto.pdfretrieved
  3. T2https://www.mastercard.com/europe/en/business/support/merchant-interchange-rates.htmlretrieved
  4. T3https://crassula.io/guides/licenses/lithuania-pi/retrieved

#

Lithuania's defining cross-border infrastructure is CENTROlink, the Bank of Lithuania's payment system giving EEA-licensed PSPs (including non-bank EMIs/PIs) direct access to SEPA Credit Transfer, SEPA Instant, TARGET2 and SWIFT, bypassing commercial correspondent banks. The corridor focus is EU/EEA SEPA euro flows, with remittance and cross-border PSPs (TransferGo, Wise, Paysera) serving Nordic, Western and Southern European corridors.

Standing sub-brief · as of 27 June 2026253 words · last cycle 2026-09-21

Payment Corridor Dynamics

CENTROlink, operated by Lietuvos bankas, is the structural spine of the Lithuanian payments corridor. It provides SEPA Credit Transfer, SEPA Instant, TARGET2 and SWIFT access to all EEA-licensed PSPs, including non-bank EMIs and PIs. The participant community exceeds 200 institutions from over 20 countries, with more than 140 active participants, and the system also offers Verification of Payee and a Proxy Lookup Service. The throughput metrics define the corridor's trajectory: 379.7 million payments were processed in 2025, a 28.9% year-on-year increase, and instant payments accounted for 68% of all Lithuanian payments that year. The core access fact rests on the Bank of Lithuania's primary CENTROlink page, while the throughput figures are sourced from Tier-3 reporting and would be strengthened by primary statistical confirmation.

Periodic update · new data 2026-09-21

Payment Corridor Dynamics

Transaction values processed through CENTROlink have exceeded €838 billion, with payment service providers from 20 countries using the platform. This corridor-scale figure, read alongside the 379.7-million-payment annual volume reported under operational resilience, indicates that CENTROlink functions as a genuine cross-border payment corridor for participating PSPs rather than a purely domestic clearing mechanism. The roughly two-thirds instant-payment share within CENTROlink's volume suggests the corridor dynamics here increasingly favour real-time settlement over batch-processed transfers.

The corridor's structural significance is that it gives Lithuanian-licensed PSPs, and the broader community of 20-country participants using the platform, direct SEPA and instant-payment access without routing through a correspondent-banking chain. This is a meaningfully different corridor architecture from a jurisdiction reliant on commercial correspondent banks for cross-border settlement, and it is a factor likely to continue supporting Lithuania's attractiveness as a licensing and processing hub for PSPs seeking efficient euro-area corridor access.

Outlook

Watch whether the €838 billion transaction-value figure continues its growth trajectory in line with CENTROlink's participant and volume growth, and whether additional countries' PSPs join the 20-country user base in the next reporting period.

1 earlier distinct update(s)
Periodic update · new data 2026-09-08

Payment Corridor Dynamics

CENTROlink, the Bank of Lithuania's payment system, processed 379.7 million payments in 2025, an increase of 28.9 percent year on year, with instant payments now accounting for 68 percent of total volume. This is a confirmed, primary-source data point evidencing continued strong growth in Lithuania's domestic and cross-border payment corridor activity, and the instant-payments share indicates the corridor is shifting decisively toward faster-payment rails rather than legacy batch processing.

Compounding this growth in throughput, non-bank payment institutions and electronic money institutions gained direct access to the TARGET payment system from 6 October 2025. This is a structural market-access development for the corridor: it extends settlement-system participation beyond the traditional bank-only perimeter, allowing non-bank PIs and EMIs to settle directly rather than through a sponsoring bank intermediary, which has implications for settlement risk, cost, and speed for the non-bank segment of Lithuania's payments sector.

Outlook

Watch for continued CENTROlink volume and instant-payments-share growth in subsequent reporting periods, and for early evidence of how non-bank PIs and EMIs are utilising direct TARGET access in practice, which would clarify whether the structural access change is translating into measurable corridor-level effects.

Sources and findings (4)
  1. T1https://www.lb.lt/en/centrolinkretrieved
  2. T1https://www.lb.lt/en/news/centrolink-is-expanding-its-instant-payment-servicesretrieved
  3. T3https://blog.voveid.com/lithuania-emi-pi-compliance-2026/retrieved
  4. T3https://stripe.com/resources/more/payments-in-lithuaniaretrieved

#

Lithuania is the EU's largest EMI/PI hub by licence count (second only to the UK in Europe), hosting 280+ fintech companies serving ~30 million clients across Europe, the majority being Revolut users. The market has matured from a 2016-2021 licensing boom (12 to 87 EMIs) into consolidation, with the number of active EMIs declining to ~76 in 2024 and growth now driven by scaling incumbents rather than new entrants. Paysera is the largest domestic EMI; major foreign players include Revolut, SumUp, Payhawk and Airwallex.

Standing sub-brief · as of 27 June 2026266 words · last cycle 2026-10-18

Industry Structure & Commercial

Lithuania is the EU's largest EMI/PI hub by licence count, second only to the UK in Europe, hosting roughly 282 fintech companies serving around 30 million clients across Europe — approximately 28 million of them via Revolut. In 2024 Lithuanian EMIs and PIs processed EUR 152 billion, a 30% year-on-year increase. The structural story, however, is one of maturation rather than continued expansion: active EMIs declined from a 2021 peak of 87 to roughly 76 in 2024, reflecting one new EMI against six closures. Growth is now driven by scaling incumbents rather than by new entrants, with the competitive structure shaped by firms such as Paysera as the largest domestic EMI, Revolut as the largest user base, and foreign and marketplace licensees including Payhawk and Vinted.

Periodic update · new data 2026-10-18

Industry Structure & Commercial Dynamics

Lietuvos bankas's reduction of CENTROlink operating fees by half, effective 1 May 2025, with a reduced rate of EUR 0.003 per payment for participants processing more than one million payments per month, continues to shape the commercial economics of payment processing through Lithuania. CENTROlink is Lietuvos bankas's payment-infrastructure platform providing direct access to euro payment systems for both bank and non-bank participants, and a fee reduction of this scale materially lowers the cost of high-volume payment processing for electronic money institutions and payment institutions that have chosen Lithuania as their operating base.

This fee structure is a structural commercial-dynamics development rather than a single-event one: it continues to reinforce Lithuania's positioning as a cost-competitive jurisdiction for payment institutions seeking direct infrastructure access rather than relying on correspondent or sponsor-bank arrangements elsewhere in the eurozone. Combined with the continued growth of Lithuania's licensed payment and crypto-asset-service-provider base evidenced elsewhere this cycle, the CENTROlink economics are one structural factor supporting the jurisdiction's continued attractiveness to high-volume payment processors.

Outlook

The CENTROlink fee structure, now well embedded since its May 2025 effective date, is not expected to change materially in the near term absent a new Lietuvos bankas announcement. Its continued effect will be visible primarily through sustained or growing participation by EMIs and PIs using CENTROlink for direct infrastructure access rather than indirect correspondent routes.

2 earlier distinct update(s)
Periodic update · new data 2026-09-28

Industry Structure & Commercial Dynamics

Lithuania's standard corporate income tax rate rose to 17% from 1 January 2026, up from 16%, a general fiscal change applying uniformly to payment institutions and electronic money institutions domiciled in the jurisdiction as to any other Lithuanian company. This marginally raises the domestic cost baseline for firms licensed in Lithuania, though it is not a sector-specific measure and does not itself alter Lithuania's competitive position relative to other EU payments hubs applying their own respective national tax rates.

Separately, Lithuania's CENTROlink payment system is reported to have processed 379.7 million payments in 2025, up 28.9% year over year, with instant payments comprising 68% of all Lithuanian payment volume in 2025. This growth figure, if accurate, would indicate continued strong uptake of instant-payments infrastructure within the jurisdiction's payment-processing volume, consistent with Lithuania's broader positioning as a high-volume EMI/PI licensing hub. This figure currently rests on a single lower-tier source this cycle and has not been corroborated against a Bank of Lithuania primary publication.

Outlook

Corroboration of the CENTROlink 2025 volume and growth figures against a Bank of Lithuania primary publication would strengthen confidence in the instant-payments growth narrative. The corporate-tax increase is not expected to materially alter Lithuania's competitive positioning as a payments-licensing hub on its own.

Periodic update · new data 2026-09-11

Industry Structure & Commercial Dynamics

Lithuania's non-bank payment sector comprises 71 electronic-money institutions and 45 payment institutions currently operating in the jurisdiction, a standing market-structure fact confirming Lithuania's position as a leading EU fintech-licensing hub. This scale of licensee concentration provides essential context for reading the governance and safeguarding tightening introduced under Bank of Lithuania Resolution No. 247 and the proposed supervisory-contribution increase from the Ministry of Finance: a jurisdiction hosting this many non-bank licensees carries correspondingly high stakes in calibrating new governance and funding requirements without eroding its competitive position as a licensing destination.

The TransferGo EMI licence expansion, enabling EU-wide payment-card issuance alongside the firm's existing money-transfer and account services, is a concrete illustration of continued product-level growth within this licensee population even as the regulatory floor is being raised. The expansion did not disclose transaction or investment figures, but it demonstrates that established non-bank payment institutions continue to view Lithuania's EMI framework as a viable platform for expanding into new product categories such as card issuance, rather than a jurisdiction from which to retreat in the face of tightening governance requirements.

Outlook

Whether Lithuania's EMI and PI licensee counts continue to grow, hold steady, or begin to contract as the new governance, safeguarding and potential fee-increase requirements take full effect will be the key structural indicator to watch in coming cycles, as it will reveal whether the jurisdiction's competitive positioning as a fintech-licensing hub is being maintained or eroded by the current tightening trajectory.

Sources and findings (4)
  1. T3https://thepaypers.com/fintech/interviews/lithuanias-fintech-evolution-from-licencing-boom-to-strategic-scaleupretrieved
  2. T3https://thebanks.eu/articles/e-money-institutions-in-the-fintech-ecosystem-of-Lithuaniaretrieved
  3. T3https://www.paysera.com/v2/en-GB/blog/fintech-storyretrieved
  4. T3https://thepaypers.com/fintech/interviews/inside-lithuanias-fintech-rise-how-to-build-an-ecosystemretrieved

AML/CFT failings are the dominant driver of LT EMI licence revocations: Transactive Systems UAB (EUR 280k fine + revocation), PAYRNET (insolvency, EUR 7m irrecoverable intra-group payment, criminal referral), Eurojust-coordinated ~EUR 2bn laundering case.

Standing sub-brief · as of 27 June 2026249 words · last cycle 2026-09-28

Legal & Litigation

Enforcement is an active and escalating theme for the Lithuanian payments market. The Bank of Lithuania determined that EMI Transactive Systems UAB seriously and systematically infringed AML/CFT requirements, imposing a EUR 280,000 fine and revoking its licence; the firm had been the second-largest EMI/PI by 2022 turnover at EUR 13.1 billion and had failed to properly identify clients and apply enhanced due diligence. The Transactive case sets the enforcement bar for the hub and confirms that AML failings are the dominant driver of Lithuanian EMI licence revocations. It pairs with the PAYRNET revocation — driven by insolvency, an irrecoverable EUR 7 million intra-group payment and a criminal referral — and with the Eurojust-coordinated laundering case of approximately EUR 2 billion.

Periodic update · new data 2026-09-28

Legal & Litigation

The Bank of Lithuania has ordered electronic money institution Verified Payments to restore capital adequacy by 1 October 2026, and pending a separate decision has barred it from taking new clients, encumbering assets, or lending. This is an ongoing supervisory action rather than a concluded matter: the restriction is explicitly described as provisional pending a further Bank of Lithuania decision, meaning the ultimate outcome for Verified Payments — whether restoration of capital adequacy resolves the matter, or whether further restrictions follow — remains open.

Alongside this specific action, the Bank of Lithuania has opened a consultation on amending its fine-calculation procedure and minor-breach criteria, a procedural development that would affect how future enforcement penalties are calculated and categorised across the payments sector generally, separate from the Verified Payments matter itself. Together, these two developments indicate an escalating legal and litigation posture from the regulator this cycle: an active case against a specific under-capitalised entity, combined with a broader procedural reform to the enforcement-penalty framework.

Outlook

The 1 October 2026 deadline is the clearest near-term marker: whether Verified Payments restores capital adequacy by that date will determine whether the Bank of Lithuania proceeds with further restrictions or eases the current ones. The outcome of the fine-calculation-procedure consultation would separately signal whether the regulator intends a more calibrated or a more stringent enforcement-penalty framework going forward.

Sources and findings (4)
  1. T1https://www.lb.lt/en/news/transactive-systems-uab-faces-fine-and-licence-revocationretrieved
  2. T1https://www.lb.lt/en/news/licence-of-uab-payrnet-revoked-for-serious-violations-bankruptcy-proceedings-to-be-initiatedretrieved
  3. T3https://resources.fenergo.com/blogs/scandal-as-a-service-aml-lessons-from-lithuania-s-2-billion-caseretrieved
  4. T1https://www.lb.lt/en/news/bank-of-lithuania-urges-electronic-money-and-payment-institutions-to-comply-with-capital-requirementsretrieved

#

Merchant acquiring sits within the PSD2 Annex I service catalogue (acquiring is a licensable PI/EMI service) and the EU Interchange Fee Regulation governs merchant service charge transparency, including individually-specified MSC components and prohibition of Honour-All-Cards distortions. Chargeback/dispute mechanics are scheme-driven (Visa/Mastercard rulebooks); high-risk merchant treatment and onboarding risk are embedded in AML/CDD obligations supervised by the Bank of Lithuania.

Standing sub-brief · as of 27 June 2026217 words · last cycle 2026-06-27

Merchant Acquiring & Risk

Merchant acquiring in Lithuania is governed by the transparency provisions of the Interchange Fee Regulation. Under Regulation (EU) 2015/751, each acquirer must offer and charge merchant service charges individually specified by card category and brand, unless the payee requests blended charges in writing, and must disclose in payee agreements the MSC, interchange and scheme fees per card category and brand. On the licensing side, a Lithuanian PI licence authorises the full PSD2 Annex I service catalogue, which includes merchant acquiring — meaning non-bank payment institutions can act as acquirers alongside banks under the same statutory service framework.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T1https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32015R0751retrieved
  2. T3https://crassula.io/guides/licenses/lithuania-pi/retrieved
  3. T3https://www.adyen.com/knowledge-hub/interchange-fees-explainedretrieved

#

The Bank of Lithuania actively fosters innovation via its award-winning Newcomer Programme (one-stop pre-application consultation), a regulatory sandbox (live-environment testing up to 6 months, extendable to 12), the LBChain blockchain sandbox, an AI sandbox, and open-banking promotion under PSD2. Lithuania was an early SCT Inst adopter and the ecosystem is layering newer controls (Verification of Payee, IBAN-name check) ahead of PSD3/PSR.

Standing sub-brief · as of 27 June 2026221 words · last cycle 2026-09-21

Product Innovation & Market Development

The Bank of Lithuania operates a deliberate suite of innovation facilitators that functions as a regulatory-attractiveness lever. These include a regulatory sandbox offering live-environment testing for up to six months, extendable to twelve; the award-winning Newcomer Programme, a one-stop pre-application consultation service that won the Fintech Regtech Global Award in 2023; the LBChain blockchain sandbox; and an AI sandbox for testing fraud-detection and compliance applications. Lithuania was also an early adopter of PSD2 open banking, requiring bank API access for third-party providers. This module addresses the thematic regulatory product-access view — sandboxes, open banking and innovation infrastructure — and is kept distinct from the discrete product launches and authorisations carried in W13.

Periodic update · new data 2026-09-21

Product Innovation & Market Development

Checkout.com's acquisition of Blue EMI, a Bank-of-Lithuania-authorised issuer of euro-backed stablecoins for institutional use, together with the establishment of a Checkout.com Lithuania Technology Centre, signals a structural convergence between Lithuania's EMI licensing base and stablecoin product capability. This is a thematic product-access development distinct from a single commercial transaction: it reflects Lithuania's accumulated EMI licensing infrastructure being positioned by an international acquirer as a platform for stablecoin-adjacent product development specifically, rather than for conventional payment processing alone.

The product-innovation significance here rests on the combination of two previously distinct capabilities: Lithuania's deep bench of licensed EMIs, and a specific MiCA-authorised stablecoin issuer among them. An acquirer choosing to combine these by acquisition, rather than building stablecoin-issuance capability from scratch elsewhere, is a signal about the relative maturity and attractiveness of Lithuania's existing licensing infrastructure for this specific product category.

Outlook

Watch for whether other international payments firms follow a similar acquisition-led entry pattern into Lithuania's EMI/stablecoin-issuer base, and whether Checkout.com's new Lithuania Technology Centre becomes a hub for further product launches in the jurisdiction.

1 earlier distinct update(s)
Periodic update · new data 2026-09-08

Product Innovation & Market Development

A Verification of Payee service was reportedly introduced within CENTROlink during 2025, positioned as part of the wider push under Lithuania's 2023-2028 Fintech Strategy toward account-to-account payment rails. This rests on a single Tier-4 trade-press source and has not been corroborated to a primary regulatory publication this cycle, so it is carried as an assessed, watch-status product development rather than a confirmed one.

Outlook

Watch for primary-source confirmation of the Verification of Payee feature's scope and rollout status within CENTROlink, and for further product developments under the 2023-2028 Fintech Strategy's account-to-account rail push in subsequent cycles.

Sources and findings (4)
  1. T1https://www.lb.lt/en/regulatory-sandboxretrieved
  2. T1https://www.lb.lt/en/newcomer-programmeretrieved
  3. T3https://www.govilnius.lt/investment-business/fintech-retrieved
  4. T3https://noda.live/articles/open-banking-in-lithuaniaretrieved

#

The Bank of Lithuania acts as the out-of-court dispute resolution body for consumer disputes with financial market participants: consumers must first complain to the provider (15-working-day reply), then may apply to the Bank within one year; its decisions are recommendatory. Payment services dominate complaints (62%), with EMIs at 23% of complaints. The Bank applies a risk-based complaint-handling model and has pushed fraud-prevention obligations on EMIs/PIs; EU-level APP-fraud/IBAN-name-check duties arrive via the Instant Payments Regulation and PSD3/PSR.

Horizon · 2026 (±year)PSD3/PSR and EU APP-fraud / IBAN-name-check dutiesproposed · T3
Standing sub-brief · as of 27 June 2026225 words · last cycle 2026-08-05

Consumer Protection & APP Fraud

The Bank of Lithuania acts as the out-of-court dispute resolution body for consumer disputes with financial market participants. Consumers must first complain to the provider, which has 15 working days to reply, extendable to 35, and may then apply to the Bank within one year; the Bank's decisions are recommendatory rather than binding. Payment services dominate the complaint caseload at 62%, with banks at 41% and EMIs at 23%, and the Bank applies a risk-based complaint-handling model while directing EMIs and PIs to recognise and prevent fraud. The complaint statistics are sourced from Tier-3 reporting and flagged accordingly.

Periodic update · new data 2026-08-11

Consumer Protection & APP Fraud

Lithuania's non-bank payments population faces a tightening consumer-protection trajectory heading into 2026, centred on two specific operational priorities: mandatory IBAN-name-check verification across payment rails, and readiness for authorised-push-payment (APP) fraud liability allocation. Both are assessed-confidence developments reflecting an operational compliance calendar for Lithuanian EMIs and PIs rather than a single discrete regulatory instrument, and both point toward a materially higher consumer-facing protection standard than has previously applied to non-bank payment service providers operating in Lithuania.

The IBAN-name-check obligation requires payment service providers to verify that the name associated with a payee account matches the account holder before a transfer completes, a control specifically designed to reduce misdirected-payment and authorised-push-payment fraud at the point of transaction rather than after the fact. Readiness for APP-fraud liability allocation is the companion obligation: it requires Lithuanian PSPs to have clear internal frameworks for how liability is apportioned between sending and receiving institutions when a customer is defrauded into authorising a payment, mirroring liability-allocation regimes being adopted elsewhere in the EU payments market. Together, these two obligations shift meaningful operational and potentially financial risk onto payment service providers that have not previously had to build this specific control and liability infrastructure.

Outlook

The key open question for the next cycle is the precise enforcement timeline and scope for APP-fraud liability allocation among Lithuanian PSPs: current sourcing establishes the obligation as an operational priority for 2026 but does not yet confirm a hard compliance deadline or a detailed liability-split methodology. Confirmation of either would sharpen current assessed-confidence judgments and allow a clearer read on the compliance cost this obligation will impose on Lithuania's approximately 120 licensed EMIs and PIs.

Sources and findings (4)
  1. T1https://www.lb.lt/en/disputes-between-consumers-and-financial-market-participantsretrieved
  2. T3http://www.draudikai.lt/en/useful-information/complaints-procedureretrieved
  3. T3https://www.vixio.com/insights/pc-complaints-about-payment-services-drop-sharply-lithuania-according-centralretrieved
  4. T1https://www.lb.lt/en/news/bank-of-lithuania-financial-service-providers-must-recognise-fraud-and-apply-measures-to-prevent-itretrieved

#

sentinel: Lithuania's AML/CFT regime rests on the Law on the Prevention of Money Laundering and Terrorist Financing (LPMLTF), transposing EU AML directives. The Bank of Lithuania supervises AML measures of financial institutions; the Financial Crime Investigation Service (FNTT/FCIS) is the FIU receiving STRs. The 2024 Third National Risk Assessment flagged crypto operators and EMI/PI as very-high-risk sectors. Payments-context position carried per Sentinel feed; no original AML analysis performed.

Standing sub-brief · as of 27 June 2026238 words · last cycle 2026-06-27

AML/CFT & Financial Crime (Sentinel-fed)

This module is sourced from the Sentinel feed, and the intelligence here is attributed to that feed rather than re-analysed within the World Payments Monitor. Per Sentinel, Lithuania's AML/CFT framework rests on the Law on the Prevention of Money Laundering and Terrorist Financing, transposing the EU AML directives, with the FNTT acting as the Financial Intelligence Unit. The 2024 Third National Risk Assessment identified very-high money-laundering and terrorist-financing risk in the crypto-operator and e-money/payment-institution sectors, which together filed 97% of suspicious transaction reports in 2023. Recent amendments established a right for financial institutions to exchange information about clients suspected of ML/TF. The full Sentinel coverage is available via the amlwatcher.com Lithuania surface from which this intelligence is drawn.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T3sentinel:https://salv.com/blog/lithuania-removes-information-sharing-blocks-for-banks-and-fintechs/
  2. T?FIM (sentinel.gi) per-JID baseline profile — Lithuania — Lithuania applies the EU AML/CFT acquis (AMLD transposition, forthcoming AMLR/6AMLD) via the Law on Prevention of Money Laundering and Terrorist Financing, supervised by the Financial Crime Investigation Service (FNTT/FCIS) and the Bank of Lithuania for financial/EMI/crypto obliged entities. A fast-growing EMI and VASP licensing hub has produced recurring supervisory failures alongside genuine enforcement escalation and EU-funded institutional reform.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure

#

CENTROlink provides EEA-licensed non-bank EMIs/PIs direct SEPA/SEPA Instant/TARGET2/SWIFT access via technical agreement with the Bank of Lithuania, bypassing commercial correspondents at sub-commercial fees; access gated by KYC/reputation assessment; safeguarding-bank de-risking is the offsetting constraint.

Standing sub-brief · as of 27 June 2026262 words · last cycle 2026-10-04

Correspondent Banking, Settlement & Access

This module's analytical spine is the bank versus non-bank access asymmetry, and in Lithuania that asymmetry is largely resolved in favour of non-banks by CENTROlink. Via CENTROlink, EEA-licensed non-bank EMIs and PIs can join SEPA, SEPA Instant and TARGET2 by signing a technical agreement with the Bank of Lithuania, with the Article 35a PSD2 document of compliance referenced, thereby bypassing commercial correspondent banks at published fees below commercial correspondent rates. Access is gated by KYC, risk and reputation assessment, and the Bank rejects applications and disconnects participants to maintain system reliability. Direct central-bank settlement access for non-banks is the structural differentiator of Lithuania versus jurisdictions where EMIs remain dependent on commercial correspondent or safeguarding banks, and it reduces counterparty dependency materially.

Periodic update · new data 2026-10-04

Correspondent Banking, Settlement & Access

AMLA conducted a survey of payment service providers and electronic-money institutions operating through agents and distributors on Central Contact Points, running until 15 September 2026. The survey is designed to feed forthcoming technical standards on when a host state may require a Central Contact Point from a PSP or EMI operating cross-border through an agent or distributor network. This is a structural, supranational-level development rather than a Lithuania-specific action, but it bears directly on how non-bank PSPs and EMIs based in or passporting through Lithuania structure their cross-border agent and distributor presence across the EEA.

The practical constraint this addresses is access and representation: a PSP or EMI relying on agents and distributors in other member states needs clarity on when the host state can insist on a local Central Contact Point as a condition of that cross-border activity continuing unimpeded. For Lithuania's large population of licensed EMIs and PIs, many of which operate cross-border through exactly this agent-and-distributor model, the eventual technical standards arising from this survey will materially affect how settlement and access arrangements are structured outside Lithuania itself.

This is distinct from a bank-versus-non-bank access question; the Central Contact Points framework applies specifically to how non-bank PSPs and EMIs maintain cross-border representation and compliance contact points, rather than to correspondent banking relationships in the traditional sense. No Lithuania-specific correspondent-banking or sponsor-bank-dependence development was identified this period beyond this structural, EEA-wide survey.

Outlook

The technical standards that will result from AMLA's Central Contact Points survey, closed 15 September 2026, are the item to watch: once published, they will set the concrete threshold for when a host state can require a local Central Contact Point, directly affecting the cross-border operating model of Lithuania-licensed PSPs and EMIs using agents and distributors elsewhere in the EEA.

3 earlier distinct update(s)
Periodic update · new data 2026-09-28

Correspondent Banking, Settlement & Access

Lithuania's CENTROlink infrastructure, the Bank of Lithuania's payment-settlement system open to both bank and non-bank participants, is reported to have processed 379.7 million payments in 2025, up 28.9% year over year, with instant payments comprising 68% of all Lithuanian payment volume in 2025. CENTROlink's analytical significance sits in the bank-versus-non-bank access dimension: as a settlement system open to licensed electronic money institutions and payment institutions directly, rather than requiring indirect access through a correspondent bank relationship, it structurally reduces the settlement-access asymmetry that non-bank payment firms otherwise face in many other jurisdictions.

This growth figure rests on a single lower-tier source this cycle and has not been corroborated against a Bank of Lithuania primary publication, so it should be treated as a reported rather than confirmed volume figure pending further sourcing.

Outlook

Corroboration of the CENTROlink 2025 volume figures against a Bank of Lithuania primary publication is the clearest item to watch to confirm the scale of instant-payments growth. Continued strong CENTROlink volumes would reinforce Lithuania's structural position as a jurisdiction where non-bank payment institutions have direct, rather than intermediated, settlement access.

Periodic update · new data 2026-09-21

Correspondent Banking, Settlement & Access

The defining feature of Lithuania's correspondent-banking and settlement-access picture is the bank-versus-non-bank access asymmetry that CENTROlink resolves for eligible payment institutions. CENTROlink gives eligible PIs and EMIs direct access to SEPA payment rails and instant-payment capabilities without relying on a traditional correspondent-banking relationship with a commercial intermediary bank. This is structurally significant because it removes what is, in many jurisdictions, the principal access bottleneck for non-bank payment institutions: dependence on a correspondent bank willing to provide settlement access, with the attendant de-risking exposure that such relationships often carry.

By routing settlement access through the central bank's own infrastructure rather than through commercial correspondent relationships, Lithuania has effectively converted what is elsewhere an access-dependency risk into a structural competitive advantage for its licensed non-bank population. This is the module's analytical spine for Lithuania specifically: the asymmetry that typically disadvantages non-banks relative to banks in accessing settlement infrastructure is substantially narrowed here.

Outlook

Watch whether the central-bank-mediated access model CENTROlink represents continues to differentiate Lithuania from jurisdictions where non-bank PIs/EMIs remain dependent on commercial correspondent-banking relationships, and whether growth in CENTROlink's participant base further entrenches this advantage.

Periodic update · new data 2026-09-11

Correspondent Banking, Settlement & Access

The Bank of Lithuania has issued guidance to banks on opening accounts for clients that are themselves electronic-money institutions or payment institutions. This guidance addresses directly the structural asymmetry between bank and non-bank payment-services providers that defines this module's analytical spine: non-bank PSPs frequently depend on maintaining banking relationships to access settlement and correspondent infrastructure, and that dependency creates a persistent point of vulnerability where a bank's own risk appetite, rather than the non-bank PSP's regulatory standing, determines continued market access.

By issuing guidance specifically addressed to banks on this question, the Bank of Lithuania is treating account-access friction for EMI/PI clients as a supervisory concern in its own right, separate from the direct governance and safeguarding requirements imposed on the EMI/PI institutions themselves under Resolution No. 247. This reflects an implicit acknowledgement that tightening the non-bank side of the regulatory perimeter is only half of the access equation; the bank side's willingness to serve these clients is the other half, and this guidance is a direct intervention on that second half.

Outlook

Whether this guidance measurably improves banks' willingness to open and retain accounts for Lithuania's 71 EMIs and 45 PIs, or whether de-risking pressure on the bank side persists despite the guidance, is the key access-dynamic question to track in subsequent cycles.

Sources and findings (4)
  1. T1https://www.lb.lt/en/centrolinkretrieved
  2. T3https://crassula.io/guides/licenses/lithuania-pi/retrieved
  3. T1https://www.lb.lt/en/news/centrolink-is-expanding-its-instant-payment-servicesretrieved
  4. T3https://www.financiallicensemarket.com/blog/lithuanian-emi-license-complete-guide-2026retrieved

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Trailing-12m LT commercial activity centred on inbound acquisitions of LT-licensed assets and MiCA-entry licensing: Checkout.com/Blue EMI; Ebury/ArcaPay; Robinhood Europe UAB first CASP licence; DriveWealth licensed; Revolut mortgages.

Standing sub-brief · as of 27 June 2026285 words · last cycle 2026-10-18

Commercial Intelligence (M&A, Investment & Product)

This module carries discrete commercial events from the trailing-twelve-month window. Two M&A events lead the set, both completed: Checkout.com acquired Blue EMI, a licensed issuer of euro stablecoins, and established a Lithuania Technology Centre; and Ebury acquired ArcaPay to increase competition in the Baltic corporate banking sector. The deal values for both transactions were not publicly disclosed. The Checkout.com/Blue EMI acquisition is analytically the more significant: it shows Lithuanian-licensed EMI assets, in this case a euro-stablecoin issuer, being acquired as a route to MiCA EMT issuance and Baltic market access.

Periodic update · new data 2026-10-18

Commercial Intelligence & Fintech

Lietuvos bankas's authorisation of Micar assets, UAB as a crypto-asset service provider under the Markets in Crypto-Assets Regulation is, in addition to its licensing significance, a discrete commercial event this cycle: the firm becomes the fourth CASP authorised in Lithuania, and the authorisation covers custody, exchange and order execution services for both retail and professional clients. No financial terms or transaction value were disclosed in connection with this licensing event, consistent with its nature as a regulatory authorisation rather than a funding round or acquisition.

This specific, dated authorisation event is distinct from any structural market-trend reading of Lithuania's crypto-asset sector: it is one named firm receiving one named authorisation on a specific date, placing Lithuania second in the Nordic-Baltic region for CASP authorisation count behind Finland. No other discrete commercial event — M&A transaction, funding round, or product release — was identified for Lithuania's payments or fintech sector this cycle.

Outlook

Further discrete CASP authorisation events are plausible given the continued pace of Lithuania's licensing activity in this category, though no specific additional transaction was identified this cycle beyond the Micar assets authorisation itself.

4 earlier distinct update(s)
Periodic update · new data 2026-10-12

Commercial Intelligence & Fintech

Checkout.com, the UK-headquartered payments company, completed its acquisition of UAB Blue EMI, a Lithuania-licensed electronic money institution and crypto-asset service provider that issues euro-backed stablecoins for institutional use. As part of the transaction, Checkout.com established a Lithuania Technology Centre. The deal's financial terms were not publicly disclosed, and the exact completion date has not been independently confirmed to the day; the transaction was reported in January 2026.

The acquisition is notable for what it signals about the commercial value of Lithuania's EMI licensing base to acquirers with stablecoin-adjacent ambitions. UAB Blue EMI's dual capability, as both a licensed EMI and a crypto-asset service provider issuing euro-backed stablecoins, made it a target whose value lies substantially in its regulatory permissions rather than only its existing book of business. Checkout.com's decision to also stand up a technology centre in Lithuania, rather than simply absorbing the licence and relocating operations, suggests an intent to build out rather than merely acquire regulatory access.

As a discrete commercial event, this acquisition is distinct from any broader structural trend toward EMI consolidation in the Baltic market; it is reported here as the specific event it is, not as evidence of a wider M&A pattern. The amount not being publicly disclosed limits what can be inferred about the valuation placed on stablecoin-capable EMI licences in the current market, though the strategic logic of acquiring institutional-grade euro-stablecoin issuance capability inside the EU's regulatory perimeter is consistent with broader industry interest in MiCA-compliant stablecoin infrastructure.

Outlook

Whether this acquisition prompts further similar transactions targeting Lithuania-licensed EMIs with stablecoin or crypto-asset service capability is not yet determinable from available evidence. The Lithuania Technology Centre commitment suggests Checkout.com intends sustained investment in the Lithuanian operation rather than a licence-and-exit strategy, which if borne out would be a modestly positive signal for the depth of Lithuania's fintech commercial ecosystem.

Periodic update · new data 2026-09-21

Commercial Intelligence & Fintech

Two discrete commercial events define this module's Lithuania signal this cycle. First, Checkout.com's acquisition of Blue EMI, a Bank-of-Lithuania-authorised issuer of euro-backed stablecoins for institutional use, was completed alongside the establishment of a Checkout.com Lithuania Technology Centre; the transaction's value was not publicly disclosed. Second, TransferGo secured an expanded EMI licence from the Bank of Lithuania in March 2026, enabling EU-wide card issuance; this transaction's value was also not publicly disclosed.

Both events are specific, dated commercial developments rather than structural market-analysis findings, distinguishing them from this cycle's W6/W9 material: the Checkout.com/Blue EMI deal is a discrete M&A event, and the TransferGo licence expansion is a discrete product/licensing-release event, even though both connect thematically to the broader stablecoin-convergence and EMI-licensing-growth themes appearing elsewhere in this cycle's Lithuania coverage.

Outlook

Watch for further disclosed or undisclosed M&A activity targeting Lithuania's licensed EMI base, and for confirmation of TransferGo's EU-wide card-issuance rollout following its expanded licence.

Periodic update · new data 2026-09-11

Commercial Intelligence & Fintech

TransferGo has obtained an expanded electronic-money-institution licence from the Bank of Lithuania, enabling EU-wide payment-card issuance in addition to its existing core money-transfer and account services. This is a discrete commercial-licensing event: a specific, named product-capability expansion by a specific operator, distinct from any structural market-wide trend. The amount associated with this licensing expansion was not publicly disclosed, and no separate investment or transaction value was reported alongside the announcement.

The event is best read as a data point confirming that Lithuania's EMI licensing framework continues to accommodate meaningful product expansion for established non-bank payment institutions, occurring in the same period as the governance and safeguarding tightening under Resolution No. 247. Whether other Lithuania-licensed EMIs pursue comparable card-issuance or product-expansion licence upgrades in coming cycles will indicate whether this is an isolated commercial event or the leading instance of a broader product-expansion pattern among Lithuania's non-bank licensee population.

Outlook

Subsequent cycles should be checked for further product-expansion or licence-upgrade announcements among Lithuania's EMI and PI population, which would help distinguish whether the TransferGo expansion is an isolated event or part of a broader pattern of product diversification within the jurisdiction's fintech-licensing hub.

Periodic update · new data 2026-08-11

Commercial Intelligence & Fintech

The Bank of Lithuania expanded TransferGo's electronic money institution licence in March 2026 to add EU-wide card issuance capability, a discrete, completed commercial event rather than a structural regulatory change. TransferGo reports 9 million registered users across 160 countries, and the licence expansion allows the firm to issue payment cards across the European Union under its existing Lithuanian EMI authorisation. The transaction value or investment associated with this licence expansion was not publicly disclosed.

This event is illustrative of a broader pattern in Lithuania's non-bank payments market: firms build a single Lithuanian EMI licence and then use EU-wide passporting rights to launch products, such as card issuance, across the full European Union market without requiring separate national authorisations in each destination jurisdiction. TransferGo's expansion sits alongside the broader licensing and market-access developments addressed elsewhere this cycle, including the CASP-authorisation transition and the continued growth of Lithuania's roughly 120-strong EMI/PI licence base, as evidence of continued commercial activity and product development within Lithuania's non-bank payments licensing regime even as compliance obligations tighten on parallel tracks.

Outlook

The key commercial-intelligence question for the next cycle is whether other Lithuania-licensed EMIs follow TransferGo's pattern of expanding into card issuance or other new product categories under their existing licences, which would further evidence Lithuania's role as a product-launch base for cross-border payments firms. Any future disclosure of the commercial or investment value associated with the TransferGo card-issuance expansion, currently undisclosed, would also sharpen the commercial picture.

Sources and findings (3)
  1. T3https://investlithuania.com/fintech-overview-2026/retrieved
  2. T3https://thepaypers.com/fintech/interviews/lithuanias-fintech-evolution-from-licencing-boom-to-strategic-scaleupretrieved
  3. T3https://www.plasma.to/learn/tools/stablecoin-regulation-map/lithuaniaretrieved
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