Financial Institutions and Fintech Licensing in the EU
Comprehensive advisory on financial institution licensing, passporting and regulatory compliance across the European Union and beyond.
We help payment institutions, electronic money institutions and other payment service providers connect to SEPA through the Bank of Lithuania’s CENTROlink system, directly or via a CENTROlink participant. Once connected, they can open individual IBAN accounts for their clients.
Single Euro Payments Area (SEPA) is an EU initiative that harmonises electronic euro payments, so that paying in euro across borders is as easy as paying at home. SEPA covers EU/EEA countries and a number of other European countries, including the United Kingdom and Switzerland.
CENTROlink is a payment system operated by the Bank of Lithuania (the central bank and a member of the Eurosystem), providing the payment gateway to the Single Euro Payments Area (SEPA). The Bank of Lithuania provides technical access to SEPA for banks and financial institutions via its own infrastructure.
Direct access to SEPA through CENTROlink for non-banks. Payment service providers (PSPs) licensed in the EEA, including payment institutions and electronic money institutions, can connect to SEPA directly through CENTROlink without an intermediary commercial bank. CENTROlink processes a wide range of SEPA schemes, including credit transfers, direct debits and instant payments, at low cost.
Who can join SEPA through CENTROlink. A Lithuanian licence is not required. Credit institutions, payment institutions and electronic money institutions established in the EEA can apply for direct participation in CENTROlink.
CENTROlink participation is subject to the Bank of Lithuania’s onboarding and assessment process, including KYC and risk assessment.
Payment service providers that do not join CENTROlink directly can connect as addressable BIC holders (ABIC holders).
ABIC holders with an existing agreement with the Bank of Lithuania can operate under it until 30 December 2026. For important objective reasons, the Bank of Lithuania may allow an ABIC holder to operate until 30 June 2027.
From 1 January 2027, ABIC holders are registered by CENTROlink participants. To do this, a participant must have been in CENTROlink for at least 12 months and have processed at least 100,000 payment orders in the last 12 months. This does not apply if the ABIC holder belongs to the participant’s group and has the same ultimate beneficial owners. The participant must also have adequate anti-money laundering, fraud prevention and sanctions controls, confirmed by an independent audit. The participant checks the provider before applying and stays responsible for it.
| Direct access | Indirect access | |
|---|---|---|
| How it works | You join CENTROlink yourself | You connect via a CENTROlink participant |
| Who can use it | EEA-licensed PSPs | PSPs licensed in SEPA countries, subject to conditions |
| Contact with the Bank of Lithuania | Direct | Via the participant; directly only on technical questions |
| Who checks you | Bank of Lithuania | The participant. The Bank of Lithuania decides on registration. |
| SEPA schemes | SCT, SCT Inst, SDD Core | SCT, SCT Inst |
We have supported multiple payment and electronic money institutions through the CENTROlink connection process with the Bank of Lithuania.
According to the Bank of Lithuania, connecting to CENTROlink involves four stages:
This is an indicative timeline. Under the CENTROlink Rules, the Bank of Lithuania makes its decision within 20 working days after receiving all required documents and any requested clarifications.
From 1 January 2027, SEPA Direct Debit (SDD) through CENTROlink is significantly cheaper. The flat €0.04 fee per payment is replaced by tiered fees, down to €0.0035 per payment from 1 million payments a month – up to 91% less. SCT and SCT Inst fees stay tiered, from €0.012 down to €0.003 per payment. In both cases, the more payments you process per month, the lower the fee per payment.
| Payment orders per month (per BIC) | SCT and SCT Inst* | SDD |
|---|---|---|
| Up to 40,000 | €0.012 | €0.025 |
| Up to 250,000 | €0.011 | €0.025 |
| Up to 500,000 | €0.010 | €0.012 |
| Up to 850,000 | €0.009 | €0.0095 |
| Up to 1,000,000 | €0.005 | €0.0055 |
| From 1,000,000 | €0.003 | €0.0035 |
* SCT and SCT Inst payment orders are counted together. Fees apply to each payment order sent or received.
Other fees
To join CENTROlink directly
To register an ABIC holder (submitted by the CENTROlink participant)
Payment service providers licensed in the European Economic Area (EEA) can join directly: electronic money institutions, payment institutions, banks, specialised banks and credit unions. A Lithuanian licence is not required.
Yes, if they meet the requirements. As a rule, institutions licensed outside Lithuania submit documents confirming compliance with Article 35a PSD2, prepared under the rules of the country that issued their licence. Institutions licensed in Lithuania submit a compliance report instead. In both cases, the Bank of Lithuania may request an independent audit report.
SEPA Credit Transfer (SCT), SEPA Instant Credit Transfer (SCT Inst) and SEPA Core Direct Debit (SDD Core). Providers connected through a participant can use SCT and SCT Inst only.
CENTROlink fees depend on the payment scheme and monthly payment volume. For example, SCT and SCT Inst fees start from EUR 0.003 per payment. Other fees include a one-off BIC connection fee, fees for additional schemes, a monthly minimum fee per BIC and an annual participation fee. The current amounts are published by the Bank of Lithuania.
Not in CENTROlink. Electronic money and payment institutions must safeguard client funds by another method allowed by law. CENTROlink’s safety advantage is in settlement: payments are settled through the Central Bank and covered in advance, without a commercial bank in between.
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