SEPA Request to Pay scheme (SRTP) for Fintech’s

Europe builds its own payment rail – SEPA request to pay scheme

For decades, businesses across Europe have had no real alternative to Visa and Mastercard at the point of payment. Every card transaction carries a fee of 1.5–3% routed through non-European networks – a cost that merchants absorb, consumers ultimately pay, and that flows out of the European economy entirely.

SRTP (SEPA Request to Pay) is European alternative for traditional card schemes.

It should work like this: you send a payment request directly to your customer’s banking app – with the amount, due date, and terms attached. They tap confirm. Money arrives instantly. No card networks. No intermediary fees. No card data. Settlement happens directly between banks, over the same SEPA infrastructure that already underpins every euro transfer in Europe.

It is a scheme developed and standardised by the European Payments Council, built on top of SEPA – the same infrastructure that processes trillions of euros annually across 36 countries. The EPC SRTP Scheme Rulebook V4.0 entered into force on 5 October 2025.

Where SRTP can it be applied?

SRTP is a messaging layer that sits between a commercial transaction and the payment itself. A payee – a merchant, a utility provider, a business – sends a structured payment request to the payer’s banking app. The payer sees exactly what they are paying, why, and by when. One tap confirms it. The payment executes instantly over SEPA rails.

SRTP is applicable in different scenarios: utility bill and tax collection, e-commerce checkout, point-of-sale payments, business-to-business invoice settlement, subscription and membership payments, and peer-to-peer transfers. As Bank of Lithuania Strategy states, SRTP could become a European alternative to local solutions (e.g. e-invoices) – replacing fragmented national tools with a single standardised scheme that works across all EU countries.

In practice, it can replace any payment scenario where today you rely on a manual bank transfer or pay card network fees to move money.

Strategic priority, not a future plan

The Bank of Lithuania’s Lithuanian Payments Market Strategy up to 2030, published in March 2026, makes SRTP Objective 7 under its strategic direction on Driving Innovation – one of innovation objectives for the entire Lithuanian payments market.

The infrastructure backing this is already operational. CentroLink – the Bank of Lithuania’s instant payment system connecting all Lithuanian banks and payment institutions – is the backbone through which SRTP payments will flow. Lithuania already has one of the most advanced instant payment infrastructures in Europe. As the Strategy notes, “instant payments are already widespread in Lithuania, and when used in conjunction with additional functionalities, such as interbank payment requests, they can offer new and more convenient services” – not only for peer-to-peer transactions, but for e-commerce, tax and utility bill collection, B2B settlements, subscriptions, and payments at physical points of sale.

For financial institutions operating connected through CentroLink, the regulatory framework is in place.

You can read the full strategy document at Lithuanian Payments Market Strategy

How Ecovis ProventusLaw can help you get there

Ecovis ProventusLaw is a law firm specialising in financial regulation, payments law, and relations with regulators. We help payment institutions, electronic money institutions, banks, and fintech companies navigate complex regulatory environments – from licensing to infrastructure integration.

Launching an SRTP-based business model is not purely a technology project. It is a regulatory journey that requires careful structuring, central bank engagement, and compliance readiness from the outset.

For established financial institutions – banks and electronic money institutions

Business model structuring and submission to the Bank of Lithuania. Before any technical integration begins, the proposed business model must be clearly defined, legally structured, and submitted to the Bank of Lithuania for assessment. We prepare a comprehensive business model description tailored to the SRTP framework – covering the scope of services, payment flows, participant roles, and compliance architecture – and manage the submission and dialogue process with the regulator on your behalf.

Regulatory risk assessment. Entering a new payment scheme carries licensing, operational, and conduct risks that must be identified early. We conduct a thorough regulatory risk assessment covering applicable EU and Lithuanian payment services law, PSD2/PSR obligations, and the specific requirements set out in the EPC SRTP Scheme Rulebook V4.0, ensuring your business model is built on solid legal ground from day one.

CentroLink scheme alignment. Access to CentroLink is a prerequisite for operating within the Lithuanian SRTP ecosystem. We support the full alignment process: reviewing technical and legal requirements for CentroLink participation, preparing the necessary documentation, and coordinating directly with the Bank of Lithuania to ensure your scheme is correctly structured for integration.

AML/CFT audit. CentroLink participation requires demonstrable compliance with anti-money laundering and counter-terrorism financing obligations. We perform a dedicated AML/CFT audit of your organisation’s policies, procedures, and controls – benchmarked against the Bank of Lithuania’s expectations and the latest EU AML framework – and deliver a clear remediation roadmap where gaps are identified. This is not a regulatory checkbox; it is a critical risk management tool for any institution handling instant, irrevocable payments at scale.

For fintech companies and new market entrants

The Strategy explicitly states that the Bank of Lithuania seeks to enable “all willing PSPs to develop innovative products based on European schemes.” The market is open – but the regulatory path to participation requires the right preparation. We assist new entrants with licensing strategy, business model design, and building the compliance infrastructure required to access the Lithuanian payments market and CentroLink on a sound legal footing.

Entering the SRTP market in Lithuania means navigating central bank relations, European payment scheme rules, and financial crime compliance simultaneously. For financial institutions and fintech companies that are ready to move, the regulatory framework is already in place.

Inga Karulaitytė-Kvainauskienė

Lawyer, Attorney at law, Partner, Head of Banking and Finance & FinTech, CAMS

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