RegRally Insights: EMI/PI Regulation – November 2025

This month’s regulatory roundup of EMI/PI landscape highlights intensified supervisory action, new EU-wide fraud-prevention measures, and significant shifts in financial oversight for 2026.

From the rollout of the EU beneficiary name-check in Lithuania and the publication of next year’s supervision fee rates, to targeted restrictions on institutions breaching capital requirements, recent decisions signal a continued focus on prudential stability, reporting discipline, and consumer protection.

Below is a summary of the key developments shaping the compliance landscape for banks, EMIs, PIs, and fintech market participants.

EU Beneficiary Name Check Rolled Out Across Lithuanian Financial Institutions

Banks, credit unions, and electronic money/payment institutions have begun verifying whether the payment recipient’s name matches the actual account holder — a new EU-wide safeguard aimed at reducing fraud and misdirected transfers.

The Bank of Lithuania has implemented the technical infrastructure in CENTROlink, enabling 70 institutions to launch the service. The name check appears before payment confirmation and may show:

  1. Full match – correct name.
  2. Close match – minor differences; the system suggests the correct name (company names must include legal form).
  3. No match – significant discrepancy, possibly fraud or error (often triggered by templates like “Mom” or “Electricity”).
  4. Unable to verify – e.g. non-Euro area transfers or technical issues; the provider must explain why.

Verification results are displayed only inside secure banking channels. Banks will never send emails or SMS with links asking clients to confirm a recipient.

Financial institutions should clearly inform customers about the new step, warn against phishing that misuses it, train staff to treat “no match” and “unable to verify” as potential fraud indicators, and update internal templates to avoid unnecessary mismatches.

Bank of Lithuania Publishes 2026 Supervision Fee Rates

The Bank of Lithuania has announced the maximum supervision fee rates and projected total fees for 2026 across different groups of supervised financial market participants.

Key figures:

  • Credit institutions (and non-EEA foreign bank branches): max rate 0.0153% of average annual assets; projected total €10.218m.
  • EEA-licensed foreign bank branches: 0.00513%; projected €0.590m.
  • Consumer credit lenders (excluding credit institutions): 0.0125%; projected €0.132m.
  • Electronic money institutions and foreign branches: 0.65%; projected €3.022m.
  • Payment institutions: 0.65%; projected €0.778m.
  • New category – issuers of asset-backed tokens: fee base is annual revenues; minimum contribution €3,000.

Total forecast across all categories: approx. €19.31m for 2026.

Implications for firms:

Supervised entities should reassess which fee base applies to them (e.g., assets, revenues) and incorporate the updated rates into their 2026 budgeting. Differences between categories remain significant, especially for fintech and crypto-related firms that have been newly brought under the supervisory perimeter. The updated schedule increases transparency and supports early financial planning for next year.

Bank of Lithuania Restricts AS Finora Group Due to Capital and Large-Exposure Breaches

The Bank of Lithuania has found that AS Finora Group has repeatedly failed to meet its own funds and large exposure requirements throughout 2024, while continuing to expand its operations. The regulator concluded that this growth is not aligned with responsible risk management and may compromise the institution’s stability.

To protect consumers, the Bank of Lithuania issued mandatory instructions:

  • AS Finora Group must present a plan to restore compliance and strengthen capital.
  • Finora Bank UAB is temporarily prohibited from entering into new lending transactions that increase total risk exposure.
  • Any deposit growth must be placed in low-risk assets.
  • These measures remain in force until explicitly lifted.

Practical takeaways for market participants:

  • Maintain strong capital buffers and continuously monitor own funds.
    • Keep significant exposures within regulatory limits.
    • Ensure growth strategies do not outpace risk management capacity.
    • Allocate deposits prudently, especially during periods of heightened supervisory attention.
    • Respond swiftly to supervisory instructions and maintain close alignment with regulatory expectations.

ValorPay Fined for Late Financial Reporting

The Bank of Lithuania fined ValorPay €12,000 for failing to submit its annual financial statements and regulatory reports on time; the institution admitted to the violations and remedied them, highlighting the importance of timely reporting and proactive communication with the supervisor.

Payment institutions and other supervised entities must ensure that their annual financial statements and regulatory reports are approved and submitted within the statutory deadlines. When delays or non-compliance are identified, they should be addressed without hesitation and, where applicable, proactively communicated to the supervisor. Early remediation and cooperation are key in mitigating regulatory consequences.

Court Cuts Fine for Capital Adequacy Breach, but Confirms Violation Is SeriousLithuania’s Supreme Administrative Court ruled that failing to meet its own funding requirements constitutes a serious breach with no tolerance threshold under the Law on Payment Institutions. Although the Bank of Lithuania correctly imposed a sanction after two periods of non-compliance, the court reduced the fine from €40,000 to €20,000 on the grounds of proportionality.

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