Consumer Credit and Buy Now Pay Later (BNPL) Licensing in the EU

ECOVIS ProventusLaw helps international financial institutions and financial technology (FinTech) companies establish and expand consumer credit operations in the European Union (EU) through Lithuania, Latvia and Estonia.

We advise non-bank lenders, BNPL providers, peer-to-peer (P2P) lending platforms, credit institutions, payment institutions and electronic money institutions on licensing, registration and consumer credit compliance. For businesses entering the EU, we assess how a Baltic operation fits their intended markets and which permissions are needed for the proposed lending activities.

Our team also advises regulatory technology (RegTech) providers developing credit assessment, customer onboarding and compliance solutions for lenders.

Consumer credit licensing and registration

The appropriate authorization depends on who provides the credit, how the product works, where consumers are located and which licenses the business already holds.

We assess direct lending, BNPL, financing offered through merchants and credit intermediation. This includes determining whether a deferred payment arrangement falls within consumer credit rules or qualifies for an exemption.

Our licensing and registration services include:

• Assessing the proposed business model and authorization requirements in each target country.
• Advising on the legal entity and ownership structure.
• Preparing the application and required documents, including information about shareholders and management and the creditworthiness assessment and responsible lending rules.
• Representing clients before supervisory authorities and responding to their questions.

Establishing consumer credit operations in the Baltic States

Our lawyers in Lithuania, Latvia and Estonia coordinate market entry and regulatory work across the three countries. We help clients assess the requirements of each jurisdiction before choosing where to establish their business or expand an existing operation.

Lithuania: consumer credit provider registration

For a non-bank lender applying under the Lithuanian Law on Consumer Credit, authorization takes the form of inclusion in the Public List of Consumer Credit Providers maintained by the Bank of Lithuania.

For credit institutions, payment institutions and electronic money institutions, we assess the registration provisions applicable to their existing licenses and proposed activities.

To be included in the Public List of Consumer Credit Providers, the following documentation needs to be provided:

• Application to be included in the Public List of Consumer Credit Providers.
• Information on the register where the Bank of Lithuania can verify the company’s basic data, including the identity of its managers.
• Information on the managers and on shareholders holding 20% or more of the capital or voting rights or able to exercise decisive influence over the company, with documents confirming that they meet the reputation, qualification and experience requirements.
• Rules for assessing the creditworthiness of borrowers and for responsible lending.

The statutory decision period is 30 working days from receipt of all required documents and information. Requests for missing or corrected information affect the timetable, so this period should not be treated as the total time needed to prepare and complete registration.

A business continuity plan is required for P2P lending platform operators, not for consumer credit providers.

Latvia: consumer lending licensing

Non-bank consumer lenders currently obtain a license from the Consumer Rights Protection Centre. Licensing and supervision transfer to Latvijas Banka on January 1, 2027.

A separate registration regime applies from November 20, 2026 to certain large merchants providing their own deferred payment services. We distinguish these arrangements from BNPL financed by a third-party lender and identify the applicable authorization route.

Our team supports licensing, registration, preparation of consumer documentation and compliance with the relevant supervisory requirements.

Estonia: creditor and credit intermediary licenses

Non-bank creditors and credit intermediaries operating in Estonia generally require an operating license from Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority, under the Creditors and Credit Intermediaries Act.

We assess licensing requirements, prepare application documents and review governance arrangements, consumer contracts and lending procedures.

As of November 4, 2026, Estonia’s legislation implementing the revised Consumer Credit Directive (Draft Act 947 SE) remains before Parliament. We distinguish existing obligations from proposed changes when advising on product launches and compliance preparations.

Serving European markets from a Baltic operation

A national consumer credit license or registration does not give a passport to lend to consumers elsewhere in the EU/EEA. A non-bank lender needs authorization or registration in each country where it lends.

A bank license, including a Lithuanian specialized bank license, can be passported across the EU/EEA. Payment institutions and electronic money institutions may grant credit only within the limits of payment services law: in connection with payment services, as an ancillary activity and repayable within 12 months.

We assess the authorization and consumer protection requirements in each intended market and the structure and permissions that fit the product.

Consumer credit compliance and CCD II

The revised Consumer Credit Directive (CCD II), Directive (EU) 2023/2225, changes the rules for consumer lending and brings additional products within scope. Its implementation requires businesses to review their contracts, internal procedures and the way customers apply for and receive credit.

Lithuania’s revised Law on Consumer Credit applies from November 20, 2026. For businesses operating across the Baltics, we assess the applicable national provisions and transitional arrangements separately.

We assist with:

• Credit agreements and customer information: preparing or reviewing contractual terms, pre-contractual disclosures and explanations of credit products.
• Advertising and digital applications: reviewing websites, apps, merchant checkout processes, customer consent and mandatory information.
• Creditworthiness assessment: reviewing permitted data sources, assessment procedures and records supporting lending decisions.
• Automated assessments: preparing customer notices, explanations and procedures for human intervention and review.
• Governance and staff requirements: preparing remuneration policies, competence documentation and management suitability submissions.
• Customers in financial difficulty: reviewing procedures for identifying payment difficulties, restructuring, complaints and referrals to debt advice services.
• Ongoing supervision: assisting with regulatory reporting, inspections and measures to address issues identified by supervisors.

We also advise on data protection and anti-money laundering and counter-terrorist financing requirements relevant to the business.

Legal support for FinTech and RegTech companies

FinTech lenders and BNPL operators

FinTech companies offer consumer credit through digital channels: BNPL applications, financing embedded in e-commerce checkouts, digital lending platforms and credit features added to payment or electronic money services.

We advise on product structure and the respective roles of the merchant, platform and creditor. We assess how lending can be combined with activities under an existing payment or electronic money license. We also advise on concluding credit agreements online, including customer identification and providing information on a durable medium that allows customers to store and reproduce it unchanged.

RegTech and lending technology providers

RegTech providers and financial institutions integrating new technology need to understand how the service fits within the regulated lending process.

We assess whether a provider’s role is limited to supplying software or includes activities that may constitute credit intermediation or another regulated service.

For credit scoring, onboarding and compliance solutions, we advise on:

• The personal data used in creditworthiness assessments and the conditions for its use.
• Customer information and human review procedures for automated assessments.
• Contracts allocating responsibilities between financial institutions, platforms and technology suppliers.
• Outsourcing arrangements and documentation supporting the financial institution’s compliance obligations.

Why ECOVIS ProventusLaw

ECOVIS ProventusLaw has completed more than 40 licensing processes end to end in Lithuania, Latvia and Estonia.

Our lawyers in the three Baltic States work as one team. You communicate directly with a partner who coordinates the specialists involved in your matter.

Our Banking, Finance and FinTech department has separate teams for regulatory advice, compliance support, and anti-money laundering and compliance audits. Our data protection specialists advise on personal data use and automated decision-making in lending.

ECOVIS ProventusLaw is ranked by IFLR1000, The Legal 500 and Chambers and Partners. Through ECOVIS International, we can coordinate with professionals in more than 90 countries.

More about P2P lending platform licensing.
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More about ECOVIS experience.

Discuss your consumer credit plans

Tell us which products you intend to offer, which countries you plan to serve and which licenses or registrations your business already holds. Our team can assess the authorization requirements and the legal work needed to launch, expand or adapt your operations.

LEGAL ADVISORY NOTICE: ECOVIS ProventusLaw is a licensed Law Firm. We are NOT a consumer credit provider, we do NOT issue personal or business loans, and we do NOT offer credit lines or financing services. Our services are strictly limited to legal advisory, regulatory consulting, and assistance with consumer credit licensing for businesses. This website does not offer any financial credit products to the public.