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Consumer credit rules change on November 20, 2026. Are your lending processes ready?
Lithuania’s revised Consumer Credit Law requires existing lenders to review advertising, credit agreements, consumer information, creditworthiness assessments, remuneration policies and staff competence. Businesses offering deferred payment or installment purchases must also assess whether their products fall within the expanded scope and whether registration is required.
In Latvia, large providers of qualifying buy now, pay later (BNPL) services must register with Latvijas Banka from November 20, 2026, unless an exemption applies. Consumer credit supervision transfers to Latvijas Banka on January 1, 2027.
For payment service providers, the Court of Justice of the European Union (CJEU) has confirmed that a customer’s gross negligence does not justify delaying an immediate refund of an unauthorized transaction.
Quick Navigation
Lithuania: new consumer credit rules from November 20, 2026
In force from: November 20, 2026 | Source: Consumer Credit Law No. XI-1253, as restated by Law No. XV-822 of April 16, 2026; Article 4 of the amending law.
Link | Link (ECOVIS article)
The Seimas adopted Law No. XV-822 on April 16, 2026. Published in the Lithuanian Register of Legal Acts on April 28, 2026, it restates the Consumer Credit Law to transpose the second Consumer Credit Directive (CCD II).
The new text enters into force on November 20, 2026. The transitional provisions exclude credit agreements concluded on or before November 19, 2026, except for the information requirements concerning interest rate changes, changes to contractual terms, overdrafts, termination of open-ended agreements and overrunning, which also apply to existing open-ended agreements.
Key changes
Credit scope and deferred payment exemptions. The law covers consumer credit up to EUR 100,000 and certain unsecured loans above that amount for residential property renovation.
Merchant-provided deferred payment remains outside the scope where all statutory conditions are met: no third-party lender grants the credit, no interest or other charges apply apart from permitted late-payment penalties, and the consumer pays in full within 50 calendar days of delivery or provision of the service.
For online merchants that are not micro, small or medium-sized enterprises (SMEs), the payment period is limited to 14 calendar days. A third-party lender must neither offer nor purchase the credit, and the arrangement must meet the statutory conditions on interest and other charges.
No unsolicited credit or prechecked consent. Credit may not be granted without the consumer’s prior request and express consent. Consent to a credit agreement or ancillary services cannot be presumed from silence, inactivity or default options such as prechecked boxes.
Creditworthiness assessment. Lenders must thoroughly assess creditworthiness under responsible lending principles, including limits on the ratio of debt payments to income. They must verify information using registers, information systems, supporting documents or other evidence.
Special categories of personal data and social media information may not be collected or assessed for this purpose. Assessment records must be retained for 10 years from the date the obligations under the credit agreement are fulfilled. Credit may be granted only where the assessment supports a reasonable conclusion that the consumer is likely to meet those obligations.
Automated assessments and refusal notices. Where creditworthiness is assessed using automated personal data processing, consumers must be informed of their right to human intervention. They may request an explanation, express their views and ask for the assessment and lending decision to be reviewed.
A refusal based on automated processing or register checks must be communicated immediately, and no later than 3 working days after the decision, free of charge and on a durable medium. The notice must include the information required for the relevant type of refusal.
Payment deferral. On a written request, lenders must defer installments, excluding interest, for up to 3 months where the consumer no longer meets the applicable debt-to-income requirement and at least one of the following conditions applies:
- the consumer’s marriage ends;
- the consumer’s spouse dies;
- the consumer or their spouse becomes unemployed or loses at least one third of their income;
- the consumer is assessed as having a disability level or a participation level of 55% or less;
- the consumer performs compulsory initial military service, excluding service organized in parts, or alternative national defense service.
Financial difficulties and debt advice. Lenders must establish processes and policies for identifying financial difficulties early. Consumers who are experiencing, or are likely to experience, difficulty meeting their credit obligations must be offered an accessible debt advice provider.
Why it matters
Lenders need to have their credit processes, consent screens, assessment models and refusal notices ready for agreements falling within the new rules from November 20, 2026.
Where a lender has improperly assessed creditworthiness for reasons not attributable to the consumer, interest, penalties and other charges for late payment do not apply.
Recommended actions
Consumer credit providers, credit intermediaries and merchants offering deferred payment should:
- update precontractual information, consent screens and credit agreement templates before November 20, 2026;
- align creditworthiness rules with the new law and the Bank of Lithuania’s implementing rules, including recordkeeping and automated decision notices;
- assess whether deferred payment products meet all conditions of the 50-day or 14-day exemption;
- implement payment deferral procedures and processes for identifying customers in financial difficulty and referring them to debt advice.
Latvia: BNPL registration and consumer credit supervision changes
Dates: November 20, 2026, for BNPL registration; January 1, 2027, for the transfer of consumer credit supervision | Source: Amendments to the Consumer Rights Protection Law adopted on September 17, 2026, and Latvijas Banka Regulations No. 427 of October 19, 2026.
Link (September amendments) | Link (Regulations No. 427) | Link (August amendments) | Link (Unfair Commercial Practices Law amendments) | Link (Advertising Law amendments)
The Saeima adopted amendments to the Consumer Rights Protection Law (Patērētāju tiesību aizsardzības likums, PTAL) on September 17, 2026. They were published on October 1, 2026, and entered into force on October 15, 2026, with key provisions applying from November 20, 2026, and January 1, 2027.
They build on the PTAL amendments adopted on August 20, 2026, which transpose CCD II and largely apply from November 20, 2026.
Latvijas Banka adopted Regulations No. 427 on BNPL provider registration on October 19, 2026. Published on October 21, 2026, the regulations enter into force on November 20, 2026.
Key changes
Who must register. From November 20, 2026, a large company may provide the deferred payment services covered by PTAL Article 8.6 only if it is entered in the BNPL providers register maintained by Latvijas Banka, unless the statutory exemption applies.
For this regime, a deferred payment service means credit granted by the seller or service provider for its own goods or services, without another creditor and without interest or additional charges other than limited late-payment fees. A large company is one exceeding the SME thresholds in Commission Regulation (EU) No. 651/2014.
Registration is not required where the provider offers only exempt deferred payment services:
- payment in full within 50 days of delivery or provision of the service; or
- for a large company selling through online distance contracts, payment in full within 14 days, without the resulting claim passing to a third party.
Registration requirements. Under Regulations No. 427, applicants must prepare a consumer lending procedure covering credit granting, monitoring and creditworthiness assessment, together with a complaints procedure.
The rules also address an anti-money laundering and countering terrorist and proliferation financing (AML/CTPF) internal control system and the appointment of a responsible board member.
The relevant board member and shareholders holding at least 25% of capital or voting rights, directly or indirectly, must meet reputation and suitability requirements. These include no disqualification from holding relevant positions and no unexpunged conviction for the specified intentional property or economic crimes.
Application documents include reputation declarations, general consumer information, precontractual information and a draft credit agreement. The requirements to prepare and submit the AML/CTPF internal control system description and to designate a board member responsible for AML/CTPF take effect on July 10, 2027.
Reporting and ongoing obligations. Changes to the information specified in paragraph 15 of Regulations No. 427 must be reported immediately and no later than 7 working days after they take effect. Changes to reputation declarations must be reported as soon as they become known.
Providers must submit quarterly data by March 1, June 1, September 1 and December 1. The reporting covers new agreements, new credit granted, the credit portfolio and overdue loans by length of delay.
Latvijas Banka may suspend registration for up to 6 months or remove a provider from the register. A suspended provider may not conclude new credit agreements.
Registration and supervisory fees. Review of a BNPL registration application costs EUR 1,500.
From January 1, 2027, BNPL providers pay an annual fee of EUR 5,000 plus up to 0.033% of the average quarterly consumer credit portfolio. The total annual fee is capped at EUR 100,000, with a transitional cap of EUR 55,000 for licensed lenders and BNPL providers in 2027–2029.
Supervision transfers to Latvijas Banka. From January 1, 2027, consumer protection supervision in financial services transfers from the Consumer Rights Protection Centre (PTAC) to Latvijas Banka.
Latvijas Banka will license consumer lenders, register credit intermediaries and their representatives, assist consumers in disputes and receive reports of possible breaches. It may impose a fine of up to EUR 75,000 on a legal person for unlicensed lending.
The consumer lender license application review fee is EUR 2,500. Registration application review fees for credit intermediaries and their representatives are EUR 500 for a natural person and EUR 1,000 for a legal person.
PTAC-issued licenses and registrations remain valid. The relevant existing Cabinet regulations continue to apply, with Latvijas Banka replacing PTAC where specified, until the new rules take effect and no later than December 31, 2027.
Broader consumer protection responsibilities. The legislative package also transfers supervision of unfair commercial practices, advertising and accessibility in financial services to Latvijas Banka from January 1, 2027. Its responsibilities include consumer complaints concerning investment, fund management, pension and payment services.
Latvijas Banka must issue financial services advertising rules by the end of 2027. During the transition, Chapter III of Cabinet Regulation No. 691 continues to apply to financial services advertising. AML/CTPF supervision of licensed consumer lenders also transfers to Latvijas Banka on January 1, 2027.
Why it matters
The BNPL registration requirement and the narrower exemption for large online merchants apply from the same date.
A large online merchant cannot rely on the 14-day exemption if payment extends beyond that period or the resulting claim passes to a third party. Its product must then be assessed under the applicable deferred payment or consumer credit regime.
Existing lenders and intermediaries also need to prepare for the change of supervisor, reporting obligations and fees.
Recommended actions
Merchants offering deferred payment in Latvia, consumer lenders and credit intermediaries should:
- assess whether each deferred payment product meets all conditions of the 50-day or 14-day exemption and identify the applicable registration or licensing requirements;
- prepare any required BNPL registration application for November 20, 2026;
- prepare the lending and creditworthiness procedures, complaints procedure, reputation declarations, consumer information and draft credit agreement required by Regulations No. 427;
- prepare the AML/CTPF internal control system description and arrange the responsible board member appointment for July 10, 2027;
- prepare for Latvijas Banka supervision, reporting and fees from January 1, 2027.
Read more: CCD II, BNPL and deferred payments in the Baltics
Unauthorized payments: gross negligence does not justify delaying refunds
Date: October 15, 2026 | Source: Court of Justice of the European Union, Case C-70/25, Tukowiecka.
Link (judgment) | Link (case overview)
In its judgment of October 15, 2026, the CJEU answered a question from a Polish court concerning an unauthorized payment. A bank customer lost approximately EUR 705 after entering her online banking details on a spoofed website during a phishing attack. The bank refused to refund her, arguing that she had been grossly negligent.
The Court held that Articles 73(1) and 74(1) of the revised Payment Services Directive (PSD2) do not allow a payment service provider to refuse an immediate refund on the ground that the payer made the unauthorized transaction possible through gross negligence.
Under Article 73(1), the provider must refund the amount immediately and, in any event, no later than the end of the business day following detection or notification of the transaction. This obligation is subject to the notification requirements in Article 71. The fraud exception applies where the provider has reasonable grounds to suspect fraud by the payer and communicates those grounds in writing to the relevant national authority.
Article 74 governs the subsequent allocation of losses between the provider and the payer. After refunding the transaction, the provider may seek recovery from the payer where the conditions for liability based on gross negligence are met. Under Article 72(2), the provider bears the burden of proving gross negligence.
Why it matters
The judgment interprets harmonized PSD2 rules and is relevant to payment service providers in Lithuania, Latvia and Estonia.
A complaint process that withholds a refund while the provider investigates suspected gross negligence does not comply with the Court’s interpretation. The provider must meet its immediate refund obligation and may subsequently pursue recovery based on proven gross negligence.
Recommended actions
Banks, payment institutions and electronic money institutions should:
- review fraud and complaint procedures so that unauthorized transactions are refunded immediately and no later than the applicable next-business-day deadline, unless there are reasonable grounds to suspect fraud by the payer and those grounds are communicated in writing to the relevant national authority;
- update customer communications and contractual terms that make refunds conditional on the absence of gross negligence;
- establish a separate process for recovering losses where the payer’s gross negligence can be proven.
Our view
For existing consumer credit providers, the immediate priority is to ensure that the new requirements are reflected in daily operations. Advertising, consumer information, credit agreements, creditworthiness assessments, remuneration policies and staff competence need to be reviewed together.
Lenders must also be able to demonstrate what information they assessed, how they reached a lending decision and what they communicated to the consumer. Payment deferral and debt advice obligations require procedures that enable staff to identify financial difficulties and respond appropriately.
The Tukowiecka judgment reinforces the importance of having a clear process for unauthorized payments. Providers must distinguish the immediate refund obligation from the subsequent assessment of whether losses can be recovered from the payer.
Merchants and other businesses offering deferred payment should assess their products against the actual conditions of the exemptions. Interest-free financing does not, by itself, place a product outside consumer credit regulation. Where registration is required, preparing an application is only one part of becoming ready to operate under the new rules.
How ECOVIS ProventusLaw can help
We help existing consumer credit providers implement the new requirements and advise businesses whose products may fall within consumer credit regulation for the first time.
Our support includes:
- Credit agreements, advertising and consumer information: reviewing advertising, credit agreements, precontractual disclosures and other consumer communications, including consent mechanisms and product tying and bundling arrangements.
- Creditworthiness and automated decisions: preparing or updating assessment rules, recordkeeping requirements and refusal notices, including procedures for human intervention, explanations and review of automated assessments.
- Remuneration and staff competence: preparing or updating remuneration policies and documentation for assessing employees’ knowledge and skills and managers’ qualifications and experience.
- Customers in financial difficulty: developing early detection policies, restructuring and payment deferral procedures, and arrangements for referring customers to debt advisors.
- Product classification and intermediary status: assessing deferred payment, installment and rent-to-own models, applicable exemptions, credit intermediary status and whether intermediation is ancillary to the business’s main activity.
- Registration and licensing: preparing applications and supporting documents, including inclusion in Lithuania’s Public List of Consumer Credit Providers and registration in Latvia’s BNPL providers register, and advising on the permissions required in each Baltic jurisdiction.
- Data protection and financial crime compliance: reviewing personal data processing and applicable requirements for preventing money laundering and terrorist financing.
- Unauthorized payments and complaints: reviewing refund and complaint procedures, customer communications and arrangements for recovering losses where gross negligence can be proven.
- Latvian supervisory transition: preparing lenders and intermediaries for Latvijas Banka supervision, reporting requirements and fees.
Contact our team to review your consumer credit documents and processes before November 20, 2026, or to assess whether your business needs to register.
Why ECOVIS ProventusLaw
ECOVIS ProventusLaw specializes in FinTech, RegTech and DefTech, together with corporate and M&A work, so a lender, payment business or platform can get regulatory, corporate and transaction advice from the same team as it grows.
Consumer protection rules span several areas of law: a single checkout involves payment law, consumer credit rules and contract law at the same time, and the new consumer credit regime adds data protection to that mix through automated creditworthiness decisions. Our lawyers and compliance specialists work together, so their advice considers how a fee, a contract term or a license will work in your product and procedures. Our lawyers in Lithuania, Latvia and Estonia work as one team. Clients usually deal directly with a partner as a single point of contact, which helps when the same product is offered in more than one Baltic market. Our financial services work is ranked by IFLR1000 (Financial services regulatory; Banking and finance), The Legal 500 (Fintech; Banking, finance and capital markets) and Chambers and Partners in its FinTech and Europe guides.
ECOVIS ProventusLaw is a top-tier business law firm operating across Lithuania, Latvia and Estonia and is part of the ECOVIS International network present in more than 90 countries worldwide.
credit rules change on November 20, 2026. Are your lending processes ready?
Lithuania’s revised Consumer Credit Law requires existing lenders to review advertising, credit agreements, consumer information, creditworthiness assessments, remuneration policies and staff competence. Businesses offering deferred payment or installment purchases must also assess whether their products fall within the expanded scope and whether registration is required.
In Latvia, large providers of qualifying buy now, pay later (BNPL) services must register with Latvijas Banka from November 20, 2026, unless an exemption applies. Consumer credit supervision transfers to Latvijas Banka on January 1, 2027.
For payment service providers, the Court of Justice of the European Union (CJEU) has confirmed that a customer’s gross negligence does not justify delaying an immediate refund of an unauthorized transaction.
Quick Navigation
Lithuania: new consumer credit rules from November 20, 2026
In force from: November 20, 2026 | Source: Consumer Credit Law No. XI-1253, as restated by Law No. XV-822 of April 16, 2026; Article 4 of the amending law.
Link | Link (ECOVIS article)
The Seimas adopted Law No. XV-822 on April 16, 2026. Published in the Lithuanian Register of Legal Acts on April 28, 2026, it restates the Consumer Credit Law to transpose the second Consumer Credit Directive (CCD II).
The new text enters into force on November 20, 2026. The transitional provisions exclude credit agreements concluded on or before November 19, 2026, except for the information requirements concerning interest rate changes, changes to contractual terms, overdrafts, termination of open-ended agreements and overrunning, which also apply to existing open-ended agreements.
Key changes
Credit scope and deferred payment exemptions. The law covers consumer credit up to EUR 100,000 and certain unsecured loans above that amount for residential property renovation.
Merchant-provided deferred payment remains outside the scope where all statutory conditions are met: no third-party lender grants the credit, no interest or other charges apply apart from permitted late-payment penalties, and the consumer pays in full within 50 calendar days of delivery or provision of the service.
For online merchants that are not micro, small or medium-sized enterprises (SMEs), the payment period is limited to 14 calendar days. A third-party lender must neither offer nor purchase the credit, and the arrangement must meet the statutory conditions on interest and other charges.
No unsolicited credit or prechecked consent. Credit may not be granted without the consumer’s prior request and express consent. Consent to a credit agreement or ancillary services cannot be presumed from silence, inactivity or default options such as prechecked boxes.
Creditworthiness assessment. Lenders must thoroughly assess creditworthiness under responsible lending principles, including limits on the ratio of debt payments to income. They must verify information using registers, information systems, supporting documents or other evidence.
Special categories of personal data and social media information may not be collected or assessed for this purpose. Assessment records must be retained for 10 years from the date the obligations under the credit agreement are fulfilled. Credit may be granted only where the assessment supports a reasonable conclusion that the consumer is likely to meet those obligations.
Automated assessments and refusal notices. Where creditworthiness is assessed using automated personal data processing, consumers must be informed of their right to human intervention. They may request an explanation, express their views and ask for the assessment and lending decision to be reviewed.
A refusal based on automated processing or register checks must be communicated immediately, and no later than 3 working days after the decision, free of charge and on a durable medium. The notice must include the information required for the relevant type of refusal.
Payment deferral. On a written request, lenders must defer installments, excluding interest, for up to 3 months where the consumer no longer meets the applicable debt-to-income requirement and at least one of the following conditions applies:
- the consumer’s marriage ends;
- the consumer’s spouse dies;
- the consumer or their spouse becomes unemployed or loses at least one third of their income;
- the consumer is assessed as having a disability level or a participation level of 55% or less;
- the consumer performs compulsory initial military service, excluding service organized in parts, or alternative national defense service.
Financial difficulties and debt advice. Lenders must establish processes and policies for identifying financial difficulties early. Consumers who are experiencing, or are likely to experience, difficulty meeting their credit obligations must be offered an accessible debt advice provider.
Why it matters
Lenders need to have their credit processes, consent screens, assessment models and refusal notices ready for agreements falling within the new rules from November 20, 2026.
Where a lender has improperly assessed creditworthiness for reasons not attributable to the consumer, interest, penalties and other charges for late payment do not apply.
Recommended actions
Consumer credit providers, credit intermediaries and merchants offering deferred payment should:
- update precontractual information, consent screens and credit agreement templates before November 20, 2026;
- align creditworthiness rules with the new law and the Bank of Lithuania’s implementing rules, including recordkeeping and automated decision notices;
- assess whether deferred payment products meet all conditions of the 50-day or 14-day exemption;
- implement payment deferral procedures and processes for identifying customers in financial difficulty and referring them to debt advice.
Unauthorized payments: gross negligence does not justify delaying refunds
Date: October 15, 2026 | Source: Court of Justice of the European Union, Case C-70/25, Tukowiecka.
Link (judgment) | Link (case overview)
In its judgment of October 15, 2026, the CJEU answered a question from a Polish court concerning an unauthorized payment. A bank customer lost approximately EUR 705 after entering her online banking details on a spoofed website during a phishing attack. The bank refused to refund her, arguing that she had been grossly negligent.
The Court held that Articles 73(1) and 74(1) of the revised Payment Services Directive (PSD2) do not allow a payment service provider to refuse an immediate refund on the ground that the payer made the unauthorized transaction possible through gross negligence.
Under Article 73(1), the provider must refund the amount immediately and, in any event, no later than the end of the business day following detection or notification of the transaction. This obligation is subject to the notification requirements in Article 71. The fraud exception applies where the provider has reasonable grounds to suspect fraud by the payer and communicates those grounds in writing to the relevant national authority.
Article 74 governs the subsequent allocation of losses between the provider and the payer. After refunding the transaction, the provider may seek recovery from the payer where the conditions for liability based on gross negligence are met. Under Article 72(2), the provider bears the burden of proving gross negligence.
Why it matters
The judgment interprets harmonized PSD2 rules and is relevant to payment service providers in Lithuania, Latvia and Estonia.
A complaint process that withholds a refund while the provider investigates suspected gross negligence does not comply with the Court’s interpretation. The provider must meet its immediate refund obligation and may subsequently pursue recovery based on proven gross negligence.
Recommended actions
Banks, payment institutions and electronic money institutions should:
- review fraud and complaint procedures so that unauthorized transactions are refunded immediately and no later than the applicable next-business-day deadline, unless there are reasonable grounds to suspect fraud by the payer and those grounds are communicated in writing to the relevant national authority;
- update customer communications and contractual terms that make refunds conditional on the absence of gross negligence;
- establish a separate process for recovering losses where the payer’s gross negligence can be proven.
Latvia: BNPL registration and consumer credit supervision changes
Dates: November 20, 2026, for BNPL registration; January 1, 2027, for the transfer of consumer credit supervision | Source: Amendments to the Consumer Rights Protection Law adopted on September 17, 2026, and Latvijas Banka Regulations No. 427 of October 19, 2026.
Link (September amendments) | Link (Regulations No. 427) | Link (August amendments) | Link (Unfair Commercial Practices Law amendments) | Link (Advertising Law amendments)
The Saeima adopted amendments to the Consumer Rights Protection Law (Patērētāju tiesību aizsardzības likums, PTAL) on September 17, 2026. They were published on October 1, 2026, and entered into force on October 15, 2026, with key provisions applying from November 20, 2026, and January 1, 2027.
They build on the PTAL amendments adopted on August 20, 2026, which transpose CCD II and largely apply from November 20, 2026.
Latvijas Banka adopted Regulations No. 427 on BNPL provider registration on October 19, 2026. Published on October 21, 2026, the regulations enter into force on November 20, 2026.
Key changes
Who must register. From November 20, 2026, a large company may provide the deferred payment services covered by PTAL Article 8.6 only if it is entered in the BNPL providers register maintained by Latvijas Banka, unless the statutory exemption applies.
For this regime, a deferred payment service means credit granted by the seller or service provider for its own goods or services, without another creditor and without interest or additional charges other than limited late-payment fees. A large company is one exceeding the SME thresholds in Commission Regulation (EU) No. 651/2014.
Registration is not required where the provider offers only exempt deferred payment services:
- payment in full within 50 days of delivery or provision of the service; or
- for a large company selling through online distance contracts, payment in full within 14 days, without the resulting claim passing to a third party.
Registration requirements. Under Regulations No. 427, applicants must prepare a consumer lending procedure covering credit granting, monitoring and creditworthiness assessment, together with a complaints procedure.
The rules also address an anti-money laundering and countering terrorist and proliferation financing (AML/CTPF) internal control system and the appointment of a responsible board member.
The relevant board member and shareholders holding at least 25% of capital or voting rights, directly or indirectly, must meet reputation and suitability requirements. These include no disqualification from holding relevant positions and no unexpunged conviction for the specified intentional property or economic crimes.
Application documents include reputation declarations, general consumer information, precontractual information and a draft credit agreement. The requirements to prepare and submit the AML/CTPF internal control system description and to designate a board member responsible for AML/CTPF take effect on July 10, 2027.
Reporting and ongoing obligations. Changes to the information specified in paragraph 15 of Regulations No. 427 must be reported immediately and no later than 7 working days after they take effect. Changes to reputation declarations must be reported as soon as they become known.
Providers must submit quarterly data by March 1, June 1, September 1 and December 1. The reporting covers new agreements, new credit granted, the credit portfolio and overdue loans by length of delay.
Latvijas Banka may suspend registration for up to 6 months or remove a provider from the register. A suspended provider may not conclude new credit agreements.
Registration and supervisory fees. Review of a BNPL registration application costs EUR 1,500.
From January 1, 2027, BNPL providers pay an annual fee of EUR 5,000 plus up to 0.033% of the average quarterly consumer credit portfolio. The total annual fee is capped at EUR 100,000, with a transitional cap of EUR 55,000 for licensed lenders and BNPL providers in 2027–2029.
Supervision transfers to Latvijas Banka. From January 1, 2027, consumer protection supervision in financial services transfers from the Consumer Rights Protection Centre (PTAC) to Latvijas Banka.
Latvijas Banka will license consumer lenders, register credit intermediaries and their representatives, assist consumers in disputes and receive reports of possible breaches. It may impose a fine of up to EUR 75,000 on a legal person for unlicensed lending.
The consumer lender license application review fee is EUR 2,500. Registration application review fees for credit intermediaries and their representatives are EUR 500 for a natural person and EUR 1,000 for a legal person.
PTAC-issued licenses and registrations remain valid. The relevant existing Cabinet regulations continue to apply, with Latvijas Banka replacing PTAC where specified, until the new rules take effect and no later than December 31, 2027.
Broader consumer protection responsibilities. The legislative package also transfers supervision of unfair commercial practices, advertising and accessibility in financial services to Latvijas Banka from January 1, 2027. Its responsibilities include consumer complaints concerning investment, fund management, pension and payment services.
Latvijas Banka must issue financial services advertising rules by the end of 2027. During the transition, Chapter III of Cabinet Regulation No. 691 continues to apply to financial services advertising. AML/CTPF supervision of licensed consumer lenders also transfers to Latvijas Banka on January 1, 2027.
Why it matters
The BNPL registration requirement and the narrower exemption for large online merchants apply from the same date.
A large online merchant cannot rely on the 14-day exemption if payment extends beyond that period or the resulting claim passes to a third party. Its product must then be assessed under the applicable deferred payment or consumer credit regime.
Existing lenders and intermediaries also need to prepare for the change of supervisor, reporting obligations and fees.
Recommended actions
Merchants offering deferred payment in Latvia, consumer lenders and credit intermediaries should:
- assess whether each deferred payment product meets all conditions of the 50-day or 14-day exemption and identify the applicable registration or licensing requirements;
- prepare any required BNPL registration application for November 20, 2026;
- prepare the lending and creditworthiness procedures, complaints procedure, reputation declarations, consumer information and draft credit agreement required by Regulations No. 427;
- prepare the AML/CTPF internal control system description and arrange the responsible board member appointment for July 10, 2027;
- prepare for Latvijas Banka supervision, reporting and fees from January 1, 2027.
Read more: CCD II, BNPL and deferred payments in the Baltics
Our view
For existing consumer credit providers, the immediate priority is to ensure that the new requirements are reflected in daily operations. Advertising, consumer information, credit agreements, creditworthiness assessments, remuneration policies and staff competence need to be reviewed together.
Lenders must also be able to demonstrate what information they assessed, how they reached a lending decision and what they communicated to the consumer. Payment deferral and debt advice obligations require procedures that enable staff to identify financial difficulties and respond appropriately.
The Tukowiecka judgment reinforces the importance of having a clear process for unauthorized payments. Providers must distinguish the immediate refund obligation from the subsequent assessment of whether losses can be recovered from the payer.
Merchants and other businesses offering deferred payment should assess their products against the actual conditions of the exemptions. Interest-free financing does not, by itself, place a product outside consumer credit regulation. Where registration is required, preparing an application is only one part of becoming ready to operate under the new rules.
How ECOVIS ProventusLaw can help
We help existing consumer credit providers implement the new requirements and advise businesses whose products may fall within consumer credit regulation for the first time.
Our support includes:
- Credit agreements, advertising and consumer information: reviewing advertising, credit agreements, precontractual disclosures and other consumer communications, including consent mechanisms and product tying and bundling arrangements.
- Creditworthiness and automated decisions: preparing or updating assessment rules, recordkeeping requirements and refusal notices, including procedures for human intervention, explanations and review of automated assessments.
- Remuneration and staff competence: preparing or updating remuneration policies and documentation for assessing employees’ knowledge and skills and managers’ qualifications and experience.
- Customers in financial difficulty: developing early detection policies, restructuring and payment deferral procedures, and arrangements for referring customers to debt advisors.
- Product classification and intermediary status: assessing deferred payment, installment and rent-to-own models, applicable exemptions, credit intermediary status and whether intermediation is ancillary to the business’s main activity.
- Registration and licensing: preparing applications and supporting documents, including inclusion in Lithuania’s Public List of Consumer Credit Providers and registration in Latvia’s BNPL providers register, and advising on the permissions required in each Baltic jurisdiction.
- Data protection and financial crime compliance: reviewing personal data processing and applicable requirements for preventing money laundering and terrorist financing.
- Unauthorized payments and complaints: reviewing refund and complaint procedures, customer communications and arrangements for recovering losses where gross negligence can be proven.
- Latvian supervisory transition: preparing lenders and intermediaries for Latvijas Banka supervision, reporting requirements and fees.
Contact our team to review your consumer credit documents and processes before November 20, 2026, or to assess whether your business needs to register.
Why ECOVIS ProventusLaw
ECOVIS ProventusLaw specializes in FinTech, RegTech and DefTech, together with corporate and M&A work, so a lender, payment business or platform can get regulatory, corporate and transaction advice from the same team as it grows.
Consumer protection rules span several areas of law: a single checkout involves payment law, consumer credit rules and contract law at the same time, and the new consumer credit regime adds data protection to that mix through automated creditworthiness decisions. Our lawyers and compliance specialists work together, so their advice considers how a fee, a contract term or a license will work in your product and procedures. Our lawyers in Lithuania, Latvia and Estonia work as one team. Clients usually deal directly with a partner as a single point of contact, which helps when the same product is offered in more than one Baltic market. Our financial services work is ranked by IFLR1000 (Financial services regulatory; Banking and finance), The Legal 500 (Fintech; Banking, finance and capital markets) and Chambers and Partners in its FinTech and Europe guides.
ECOVIS ProventusLaw is a top-tier business law firm operating across Lithuania, Latvia and Estonia and is part of the ECOVIS International network present in more than 90 countries worldwide.
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