RegRally Insights: EMI/PI Regulation – March 2026

This edition of our Fintech RegRally newsletter highlights recent supervisory actions and decisions of the Bank of Lithuania, reflecting a continued focus on governance, risk management, and regulatory compliance across the financial sector.

Recent developments demonstrate a dual regulatory approach. On the one hand, the regulator continues to support market growth, as illustrated by licence expansions and an active consultative agenda for 2026. On the other hand, supervisory scrutiny remains strong, with enforcement actions targeting deficiencies in ICT risk management, outsourcing, and AML/CTF compliance.

Court practice further reinforces the importance of proportionality in supervisory measures, particularly in high-impact decisions such as licence revocation. At the same time, ongoing approvals for acquisitions, management appointments, and market participation underscore the need for timely engagement with regulatory procedures.

Below, we provide a structured overview of the key updates and practical takeaways to help financial market participants navigate evolving regulatory expectations and mitigate compliance risks.

Bank of Lithuania Expands Licence and Imposes Sanctions Following Inspection

The Bank of Lithuania expanded the electronic money institution licence of UAB “TransferGo Lithuania”, authorising additional services, including cash withdrawals from payment accounts, the issuance of payment instruments, and the processing of incoming payments.

Separately, following an unplanned inspection of AB “Mano bankas”, the regulator identified deficiencies in ICT/security risk management, as well as in outsourcing arrangements. An administrative agreement was concluded, including a €90,000 fine for inadequate monitoring of third-party cloud service providers and shortcomings in outsourcing contracts, as well as public disclosure of violations related to insufficient second-line resources for ICT and security risk oversight.

Bank of Lithuania announcement of 2026 consultative events

The Bank of Lithuania announced 17 consultative events planned for 2026, covering:

1. DORA implementation;

2. AML/CTF;

3. payment services;

4. upcoming Consumer Credit Law amendments;

5. licensing;

6. third-party risk management;

7. resolution and other topics.

Events are held remotely. Financial market participants should monitor the Bank of Lithuania’s 2026 events schedule and register for relevant sessions, particularly those covering DORA, AML/CTF, payment services and the forthcoming Consumer Credit Law amendments.

Decisions of the Bank of Lithuania Financial Market Supervision Committee

Four decisions adopted:

1. NEXTEDGE HOLDINGS LTD (Israel) approved to directly, and a natural person indirectly, acquire e-money institution UAB BLENDER LITHUANIA.
2. Ieva Naudžiūnaitė approved to serve as deputy head of administration of the Lithuanian Central Credit Union (LCKU).
3. Euronet Polska Sp.z.o.o. added to the Public List of E-Money Institutions as agent of UAB ZEN.COM.
4. Amendments to Nasdaq Baltic Member Rules submitted by AB Nasdaq Vilnius recognised as compatible — changes relate to manual trade reporting under updated Commission Delegated Regulation (EU) 2017/583.

Institutions involved in acquisitions, management appointments, agent network expansions, or rulebook changes should ensure that they follow the Bank of Lithuania’s timely notification and approval procedures.

Nasdaq members should review the updated Baltic Member Rules regarding manual trade reporting obligations.

Decisions of the Bank of Lithuania Financial Market Supervision Committee

Four decisions adopted:

1. Tesonet Global UAB approved to indirectly acquire a qualifying holding (>10%, <20%) in e-money institution UAB “Elektroninių pinigų bitė”, and approved to indirectly gain decisive influence over peer-to-peer lending platform and consumer credit provider UAB “Finansų bitė”
2. Settlement agreement with Emerchantpay Limited entered into force, the company had challenged the Bank of Lithuania’s objection to its acquisition of UAB “PHOENIX PAYMENTS”; under the agreement, Emerchantpay waives its claims and may submit a new notification which the Bank of Lithuania will assess based on new factual circumstances; confirmed by the Supreme Administrative Court of Lithuania.
3. Aki Sanne approved as a board member candidate of ERGO Life Insurance SE.
4. UAB Inchcape Insurance Broker added to the insurance brokers list (now 106 firms).

Entities planning qualifying holding acquisitions or management appointments should ensure all required notifications and supporting documentation are submitted to the Bank of Lithuania in a timely manner. Firms whose acquisition applications were previously objected to should note that resubmission based on new factual circumstances remains a viable option.

Vilnius Court Finds Licence Revocation Disproportionate in AML Case

The Vilnius Regional Administrative Court annulled the part of the Bank of Lithuania’s decision revoking the payment institution licence of Majestic Financial UAB, finding it disproportionate and insufficiently reasoned.

Although the revocation followed AML/CFT findings, the court held that the authority failed to demonstrate actual harm, identify aggravating factors or properly assess the company’s remediation measures, including strengthened AML procedures, exit from high-risk clients, staff training and a retrospective transaction review.

Referring to CJEU and ECtHR case law, the court emphasised that licence revocation is an extreme measure and must be used only where less restrictive sanctions would be ineffective. The case was returned to the Bank of Lithuania for the imposition of a proportionate measure. The judgment is not final and may be appealed.