title: LT — Consumer Protection & APP Fraud (W10) | World Payments Monitor canonical: https://payments.gi/jurisdictions/lithuania/w10/ ### W10 Consumer Protection & APP Fraud Probable re-verified 2026-10-18 · changed 2026-08-11 The Bank of Lithuania acts as the out-of-court dispute resolution body for consumer disputes with financial market participants: consumers must first complain to the provider (15-working-day reply), then may apply to the Bank within one year; its decisions are recommendatory. Payment services dominate complaints (62%), with EMIs at 23% of complaints. The Bank applies a risk-based complaint-handling model and has pushed fraud-prevention obligations on EMIs/PIs; EU-level APP-fraud/IBAN-name-check duties arrive via the Instant Payments Regulation and PSD3/PSR. Horizon · 2026 Current window PSD3/PSR and EU APP-fraud / IBAN-name-check duties_Current window_ Standing sub-brief · as of 27 June 2026 225 words · last cycle 2026-08-05 #### Consumer Protection & APP Fraud The Bank of Lithuania acts as the out-of-court dispute resolution body for consumer disputes with financial market participants. Consumers must first complain to the provider, which has 15 working days to reply, extendable to 35, and may then apply to the Bank within one year; the Bank's decisions are recommendatory rather than binding. Payment services dominate the complaint caseload at 62%, with banks at 41% and EMIs at 23%, and the Bank applies a risk-based complaint-handling model while directing EMIs and PIs to recognise and prevent fraud. The complaint statistics are sourced from Tier-3 reporting and flagged accordingly. The recommendatory, non-binding nature of this ADR mechanism, combined with a rising fraud-complaint trend, shapes the consumer-protection exposure of Lithuanian EMIs. The more consequential change is arriving at EU level: APP-fraud and IBAN-name-check duties reach Lithuanian EMIs and PIs via the Instant Payments Regulation and the prospective PSD3/PSR package. #### Outlook The W10 trajectory is stable domestically but faces a material forward shift. The PSD3/PSR package is expected to layer enhanced consumer-protection and fraud-prevention duties, including IBAN-name-check and Verification of Payee, onto Lithuanian EMIs and PIs, though its timing and final form remain uncertain and it is logged at the year-band horizon as proposed. The interaction between the recommendatory domestic ADR regime and the harder EU-level fraud-prevention duties is the key watch item. Periodic update · new data 2026-08-11 #### Consumer Protection & APP Fraud Lithuania's non-bank payments population faces a tightening consumer-protection trajectory heading into 2026, centred on two specific operational priorities: mandatory IBAN-name-check verification across payment rails, and readiness for authorised-push-payment (APP) fraud liability allocation. Both are assessed-confidence developments reflecting an operational compliance calendar for Lithuanian EMIs and PIs rather than a single discrete regulatory instrument, and both point toward a materially higher consumer-facing protection standard than has previously applied to non-bank payment service providers operating in Lithuania. The IBAN-name-check obligation requires payment service providers to verify that the name associated with a payee account matches the account holder before a transfer completes, a control specifically designed to reduce misdirected-payment and authorised-push-payment fraud at the point of transaction rather than after the fact. Readiness for APP-fraud liability allocation is the companion obligation: it requires Lithuanian PSPs to have clear internal frameworks for how liability is apportioned between sending and receiving institutions when a customer is defrauded into authorising a payment, mirroring liability-allocation regimes being adopted elsewhere in the EU payments market. Together, these two obligations shift meaningful operational and potentially financial risk onto payment service providers that have not previously had to build this specific control and liability infrastructure. The key open question for the next cycle is the precise enforcement timeline and scope for APP-fraud liability allocation among Lithuanian PSPs: current sourcing establishes the obligation as an operational priority for 2026 but does not yet confirm a hard compliance deadline or a detailed liability-split methodology. Confirmation of either would sharpen current assessed-confidence judgments and allow a clearer read on the compliance cost this obligation will impose on Lithuania's approximately 120 licensed EMIs and PIs. **Sources and findings (4 unique sources · R-3/R-4)** 1. [W10-E1] T1 Derived: Confirmed [in_force https://www.lb.lt/en/disputes-between-consumers-and-financial-market-participants](https://www.lb.lt/en/disputes-between-consumers-and-financial-market-participants) re-verified 2026-06-27 The Bank of Lithuania operates an out-of-court dispute resolution mechanism for disputes between consumers and financial market participants, providing a toll-free information line and a defined consumer application procedure. 2. [W10-E2] T3 Derived: Probable [in_force http://www.draudikai.lt/en/useful-information/complaints-procedure](http://www.draudikai.lt/en/useful-information/complaints-procedure) re-verified 2026-06-27 A consumer must first apply in writing to the financial market participant, which must reply within 15 working days (extendable to 35); if unsatisfied the consumer may apply to the Bank of Lithuania within one year, and the Bank mediates before issuing a decision that has the nature of a recommendation. 3. [W10-E3] T3 Derived: Probable [in_force https://www.vixio.com/insights/pc-complaints-about-payment-services-drop-sharply-lithuania-according-central](https://www.vixio.com/insights/pc-complaints-about-payment-services-drop-sharply-lithuania-according-central) re-verified 2026-06-27 Per the Bank of Lithuania, complaints about payment services accounted for 62% of all grievances, with banks attracting 41% of complaints and electronic money institutions 23%; the regulator adopted a risk-based complaint-handling model and noted a rise in fraud-related cases, including scams inducing consumers to take out loans. 4. [W10-E4] T1 Derived: Confirmed [in_force https://www.lb.lt/en/news/bank-of-lithuania-financial-service-providers-must-recognise-fraud-and-apply-measures-to-prevent-it](https://www.lb.lt/en/news/bank-of-lithuania-financial-service-providers-must-recognise-fraud-and-apply-measures-to-prevent-it) re-verified 2026-06-27 The Bank of Lithuania directs financial market participants, particularly EMIs and PIs, to recognise fraud and apply prevention measures, responding urgently to fraud information and factoring complaints into supervisory planning.