RegRally Insights: Consumer Protection Regulation, August 2026

Consumer credit regulation is undergoing significant changes across the Baltic region. In Lithuania, the new consumer credit framework will introduce changes to creditworthiness assessments, responsible lending, advertising and reporting requirements from November 2026. In Latvia, a proposed reform would substantially change the supervision of financial consumer protection, transferring key functions from the Consumer Rights Protection Centre to Latvijas Banka.

This month’s RegRally highlights the developments most relevant to consumer credit providers, credit intermediaries, P2P lending platforms and other businesses providing financial services to consumers in Lithuania and Latvia.

Lithuania: new consumer credit rules to apply from November 2026

Date: 16 July 2026 | Source: Lietuvos bankas
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Lietuvos bankas approved amendments to its resolutions regulating consumer credit. The amendments will enter into force on 20 November 2026 and implement the revised Lithuanian Consumer Credit Law adopted by the Seimas on 16 April 2026, which transposes Directive (EU) 2023/2225 on consumer credit agreements.

The amendments also introduce changes concerning the regulation of peer-to-peer lending platform operators.

One important change concerns interest-free and fee-free consumer credit. The EU Consumer Credit Directive removed the previous exemption for such products, which are used in practice, among other things, by telecommunications companies.

The revised creditworthiness assessment and responsible lending rules, therefore, introduce a specific exception to the general 40% debt-service-to-income (DSTI) limit. Lenders may apply a DSTI ratio of up to 60% where:

• the credit is provided under a linked interest-free and fee-free agreement; and
• the credit finances the purchase of a phone, modem or router required for voice or internet access services.

The amendments also introduce more detailed requirements for the statutory consumer credit advertising warning “Dėmesio! Skolintis pinigus kainuoja.” They further refine reporting requirements and the public lists of consumer credit lenders, P2P platform operators and consumer credit intermediaries.

What this means for businesses

The changes require affected businesses to review not only their legal documentation, but also how consumer credit products are structured, assessed and advertised in practice.

Businesses offering interest-free or fee-free financing linked to telecommunications products should specifically determine whether their products qualify for the new 60% DSTI exception and ensure that the qualifying conditions are consistently documented.

The revised advertising requirements also mean that existing marketing materials should not simply be carried forward after November 2026 without review.

Recommended actions

Consumer credit providers and relevant P2P operators should:

• prepare for the 20 November 2026 entry into force;
• review creditworthiness assessment and responsible lending procedures against the revised rules;
• identify products that may qualify for the 60% DSTI exception and document the eligibility criteria;
• update consumer credit advertising templates and mandatory warning statements;
• review agreements, customer journeys and internal procedures affected by the revised Consumer Credit Law;
• verify reporting obligations and public-list registration requirements;
• ensure compliance teams and relevant business functions are prepared for the new requirements before they take effect.

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Latvia: consumer financial services supervision may move to Latvijas Banka from 2027

Date: 23 July 2026 | Source: Saeima – Proposed transfer of financial consumer protection supervision to Latvijas Banka
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The Saeima Budget and Finance (Tax) Committee conceptually supported amendments to the Consumer Rights Protection Law that would gradually transfer supervision of consumer rights in financial services to Latvijas Banka, starting in 2027.

The function is currently performed by the Consumer Rights Protection Centre (PTAC).

Under the proposed framework, Latvijas Banka would assume responsibility for:

• licensing and supervision of consumer lenders;
• registration and supervision of credit intermediaries and their representatives;
• supervision of financial services advertising and unfair commercial practices;
• examination of consumer complaints and assistance with dispute resolution;
• supervision of compliance with consumer financial services requirements.

The proposed reform would also introduce an indefinite-term licensing model, with Latvijas Banka establishing requirements for issuing, suspending and cancelling licences.

A unified reporting system for suspected violations is also planned, with confidentiality protections for whistleblowers. Latvijas Banka would have powers to impose sanctions for significant breaches, including unlicensed lending and unregistered credit intermediation.

Most provisions are proposed to enter into force on 1 January 2027, while certain rule-making powers would apply from 1 January 2028. Existing CRPC licences and registrations would remain valid during the transition.

The proposed amendments still need to pass the remaining stages of the legislative process.

What this means for businesses

The proposed reform would represent a significant change in the supervisory model for financial consumer protection in Latvia.

Consumer lenders and credit intermediaries should prepare for a more integrated financial-sector supervisory framework, in which licensing, advertising, unfair commercial practices, and consumer complaints would fall under the supervision of the country’s central bank.

The reform is not yet final, so businesses should distinguish between proposed requirements and rules already in force. Nevertheless, the direction of travel provides a useful indication of the supervisory environment businesses should prepare for.

Recommended actions

Latvian consumer lenders and credit intermediaries should:

• monitor the progress of the amendments through the remaining legislative stages;
• assess how the proposed transfer of supervision could affect their licensing and registration arrangements;
• prepare for the transition to Latvijas Banka supervision and the proposed indefinite-term licensing model;
• review consumer credit advertising and commercial practices against the expected supervisory framework;
• assess whether internal compliance and reporting arrangements are ready for interaction with the new supervisor;
• plan for changes to supervisory fees and related regulatory costs.

Businesses should also avoid treating the proposed framework as final until the legislative process is complete.

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Key takeaways for consumer credit businesses

The latest developments in Lithuania and Latvia point to several practical priorities:

• Prepare early for the Lithuanian rules.
  The revised Lithuanian consumer credit framework takes effect on 20 November 2026, leaving businesses a defined implementation deadline.
• Review products, not only policies.
  The new DSTI exception may affect how certain interest-free and fee-free financing products are structured and assessed.
• Treat advertising as a compliance issue.
  Consumer credit marketing materials and mandatory warning statements will be subject to review under the revised Lithuanian rules.
• Expect closer integration of financial consumer supervision in Latvia.
  The proposed transfer of supervisory functions to Latvijas Banka could bring consumer credit regulation closer to the broader prudential and conduct supervision framework applicable to financial institutions.
• Separate enacted requirements from proposed reforms.
  The Lithuanian changes have a confirmed entry-into-force date, while the Latvian reform remains subject to the legislative process.

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Need assistance?

Our financial services and regulatory specialists advise consumer credit providers, P2P lending platforms and credit intermediaries on:

• Consumer credit regulatory compliance
• Creditworthiness assessment and responsible lending
• Consumer credit agreements and documentation
• Consumer credit advertising and marketing compliance
• P2P lending regulation
• Licensing and regulatory authorisations
• Regulatory reporting and supervisory requirements
• Consumer protection and unfair commercial practices
• Regulatory inspections and remediation
• Lithuanian and Latvian financial services regulation

If you have questions regarding the regulatory developments covered in this edition or would like to assess your consumer credit compliance ahead of the upcoming changes, our team will be happy to assist.