RegRally Insights: EMI/PI Regulation

Welcome to the RegRally Insights: EMI/PI Regulation, September 2025 edition. This issue brings you the latest regulatory updates from the Bank of Lithuania, including new transparency tools for SMEs, licensing developments, supervisory insights, strengthened reporting requirements, and payment system safeguards.

Bank of Lithuania Launches Business Payment Services Fee Comparison Tool

To support small and medium-sized enterprises (SMEs), the Bank of Lithuania now publishes payment service fees for businesses on its dedicated comparison website. The platform enables SMEs to compare offers for: quickly

Payment service plans and account management
Executed and received payments
Business cards and cash operations
Card and online payment acceptance services

The tool covers fees from 30+ banks, credit unions, payment and electronic money institutions, allowing SMEs to select the most cost-effective and tailored options.

A 2024 survey revealed that 72% of SMEs rely on a single provider, and 66% have not considered switching in the past two years, underscoring the need for greater transparency and informed decision-making.

Recommendations:

Increase transparency and competitiveness – present fees in clear, comparable formats.
Offer flexible service packages – adapted to business size, activities, and international needs.
Communicate opportunities proactively – inform SMEs about alternative services and innovations.

Explore the Business Payment Services Fee Comparison Website here.

Bank of Lithuania Grants UAB Bondea a Crowdfunding Service Provider License

The Bank of Lithuania has granted UAB Bondea a license to operate as a crowdfunding service provider under the EU Crowdfunding Regulation.

Scope of authorisation:

Intermediary services in loan granting
Distribution of transferable securities or instruments issued by project owners or SPVs (without obligation to subscribe)
Accepting and transmitting orders related to securities and instruments
Applying credit scoring to projects, setting pricing, and determining interest rates

With this approval, Lithuania now has 16 licensed crowdfunding service providers, ranking 5th in the EU by number of licensed platforms.

Bank of Lithuania: 2024 Overview of Electronic Money and Payment Institutions

The Bank of Lithuania published its 2024 overview of the electronic money and payment institutions (EMI/PI) sector, highlighting continued growth and strengthening performance.

119 EMIs and PIs served 2.2 million active clients at the end of 2024 – a 30% increase year-on-year.
Licensed activity revenues rose 15% to EUR 571 million.
Sector profit more than doubled to EUR 40.2 million.
The report also covers supervisory actions and regulatory priorities for the sector.

Recommendations for market participants:

Assess expansion opportunities – rising client demand creates space for new solutions.
Optimise profitability models – doubled profit signals strong potential for efficiency gains.
Strengthen compliance – with growth comes closer supervisory attention; proactive risk management is key.

Bank of Lithuania Adopts Rules for Verification of Payee in CENTROlink

By Resolution No. 03-123 of 26 August 2025, the Bank of Lithuania approved the Rules for the Verification of Payee (VoP) in the CENTROlink payment system, effective 28 August 2025.

The Rules define the regulatory framework for the VoP service, covering:

admission, suspension, and removal of participants;
rights and obligations of the Bank of Lithuania and participants;
personal data processing requirements;
operational risk management and business continuity safeguards.

Recommendations for participants:

Align internal policies with admission, suspension, and removal procedures.
Review obligations and service requirements to ensure compliance.
Strengthen technical and operational safeguards for risk management and continuity.

Bank of Lithuania Issues Reporting Requirements for EMIs and PIs

The Bank of Lithuania introduced detailed financial, operational, and statistical reporting requirements for electronic money and payment institutions.

The framework requires:

accurate and complete reporting using approved forms (e.g., Balance Sheet EM008_01, Off-Balance Sheet Report, Profit and Loss Statement, Statement of Changes in Equity, Report on Funds Held in Accounts);
proper segregation of client funds;
timely correction of errors before submission or within five working days if identified later.

Minor discrepancies below thresholds may not require correction, but significant inaccuracies must be addressed. The rules emphasize accountability, strong internal controls, and transparent documentation to safeguard client funds and ensure reporting integrity.

Recommendations for institutions:

Ensure timely and accurate submissions in line with approved forms and instructions.
Strengthen internal controls to detect and correct errors proactively.
Maintain complete records supporting transparency and segregation of client assets.