RegRally Insights: Consumer Protection Regulation

Welcome to the August 2025 edition of RegRally Insights: Consumer Protection Regulation. This is the month’s briefing, spotlighting key regulatory moves shaping consumer protection across the EU. We break down the latest developments, highlight persistent compliance gaps, and outline practical steps to help you stay ahead of evolving regulatory standards.

The Bank of Lithuania updates complaint handling rules, invites comments

The Bank of Lithuania has published a draft amendment to the 2013 Resolution on complaint handling by financial market participants (FMPs). The changes expand the list of FMPs covered, clarify the definition of a complaint, and strengthen safeguards to ensure impartial and objective complaint review. Companies must allocate sufficient resources, provide regular staff training, and review compliance with the rules at least every two years.

The draft also modernises reporting: complaint data must be submitted in JSON format via the REGATA system from 2026 onwards, with new forms allowing classification by service type, nature, and cause. This will improve data quality and enable more effective supervision. Additionally, information on complaint procedures must be made accessible via remote service channels such as mobile apps. Payment and e-money institutions will transition from their current reporting framework to the updated rules.

Our recommendations:

Financial market participants should carefully analyse the draft amendments, particularly the operational impacts of new reporting formats, expanded data requirements, and staff training obligations. Institutions should assess whether current complaint-handling policies align with the clarified definitions and impartiality requirements. Given the consultation deadline of 3 October 2025, market participants are encouraged to submit remarks or proposals to the Bank of Lithuania to ensure practical implementation and proportionate compliance obligations.

EU online dispute resolution platform shut down – businesses must update websites

As of 20 July 2025, the EU’s Online Dispute Resolution (ODR) platform has been permanently closed under Regulation (EU) 2024/3228, which repealed Regulation (EU) No 524/2013. This means businesses engaged in e-commerce are no longer required to display links to the ODR platform on their websites or in general terms and conditions.

The shutdown also deleted all consumer dispute-related data stored on the platform. The State Consumer Rights Protection Authority (VVTAT) advises companies to review and update their online content, ensuring all references to the ODR platform are removed. Going forward, Lithuanian consumers with disputes should turn to VVTAT via the system www.vtis.lt. For purchases from other EU/EEA online shops, complaints should be submitted through the European Consumer Centre Lithuania (ecc.lt).

Our recommendations:

Businesses and their legal advisors should promptly revise website content, contractual terms, and consumer-facing documents to remove outdated references to the ODR platform. Compliance checks should be integrated into regular website audits to avoid misleading information. Companies should also update customer service protocols to direct consumers to the appropriate dispute resolution channels (VVTAT or ECC) and ensure staff are aware of the new process. This will safeguard compliance and reduce legal or reputational risks.