New 2025 Wind-Down Plan Rules: Key Steps for EMIs & PIs

On March 6, 2025, the Bank of Lithuania introduced new regulatory requirements for electronic money institutions (EMIs) and payment institutions (PIs). One of the key changes under Resolution No. 03-33 of the Board of the Bank of Lithuania is the obligation for EMIs and PIs that have commenced electronic money issuance or payment service provision activities by 8 April 2025 to prepare a wind-down plan within six months from that date. Additionally, EMIs and PIs must prepare a wind-down plan within six months from the date they commence electronic money issuance or payment service provision activities.

Moreover, PIs or EMIs applying for or participating in the CENTROlink payment system will not only have to prepare a wind-down plan but also all other required documents in compliance with the Republic of Lithuania Law on Payments.

What is a Wind-Down Plan?

A wind-down plan is a structured strategy for safely winding down operations if needed, ensuring minimal disruption to clients and the financial system. The plan should be practical, clear and actionable.

What should your Wind-Down Plan include?

At a minimum, your wind-down plan must cover:

• Scenarios and Action Steps – Identify potential shutdown scenarios and outline the steps for each case.
• Stakeholder Impact & Communication – Define affected groups, specify the number of persons in each group, estimate the impact, and outline how you will keep stakeholders informed.
• Key Risk Indicators – Establish warning signs that might trigger a wind-down decision, set up a process to monitor them, and define the form and procedure.
• Customer List & Outreach Plan – Develop a structured approach to maintaining an up-to-date list of electronic money holders and payment service users. Ensure you can quickly contact them if needed.
• Regulatory Notification & Decision-Making – Clarify how and when you will notify the Bank of Lithuania about the wind-down decision and specify the responsible persons for this task.
• Financial & Non-Financial Resources – Detail the funding, operational, and human resources needed to manage the process smoothly.
• Implementation Timeline & Risk Management – Define clear deadlines, responsibilities, and measures to manage specific risks that could impact a smooth wind-down process.
• Ongoing Review & Reporting – Establish a structured approach to updating the plan, including the periodic review process, responsible persons, and cases requiring immediate review.

How to prepare for a wind-down plan

With the deadline fast approaching, it’s essential to start preparing as soon as possible. Here’s what you should do:

• Start drafting your wind-down plan based on the Resolution’s requirements.
• Engage key team members – your management, compliance, and risk officers should be involved in the process.
• Assess your financial, operational, and resource readiness to ensure your plan is realistic and executable.
• Establish a reporting and monitoring framework to track implementation and ensure timely updates.

Legal assistance of ECOVIS ProventusLaw

At ECOVIS ProventusLaw, we specialise in regulatory compliance and can help you develop a wind-down plan that fully meets the Bank of Lithuania’s requirements. Our team offers:

• Tailored wind-down plan preparation and review.
• A gap analysis to identify potential compliance risks.
• Strategic guidance to ensure a smooth implementation process.
• Assistance in revising internal documentation to align with regulatory changes.

Don’t wait until the last minute! Contact ECOVIS ProventusLaw today, and let’s ensure your institution is fully prepared for the upcoming regulatory changes.