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CENTROlink provides EEA-licensed non-bank EMIs/PIs direct SEPA/SEPA Instant/TARGET2/SWIFT access via technical agreement with the Bank of Lithuania, bypassing commercial correspondents at sub-commercial fees; access gated by KYC/reputation assessment; safeguarding-bank de-risking is the offsetting constraint.
The offsetting live operational constraint, however, sits at the safeguarding-bank layer. Securing a willing safeguarding-account partner can take new EMI applicants months — a de-risking dynamic that is the principal practical counterweight to CENTROlink's access advantage. The asymmetry, in other words, is not that non-banks lack settlement access — they have it directly from the central bank — but that they may still struggle to obtain the commercial safeguarding relationships that the safeguarding rules in W1b require.
Outlook
The W12 trajectory is established. The direct central-bank settlement access is a confirmed standing position and the defining structural advantage of the Lithuanian hub. The forward watch item is the safeguarding-bank de-risking trend, which is the binding constraint on the speed at which new entrants can become operational, and whether it tightens further as AML supervisory intensity rises.
Correspondent Banking, Settlement & Access
AMLA conducted a survey of payment service providers and electronic-money institutions operating through agents and distributors on Central Contact Points, running until 15 September 2026. The survey is designed to feed forthcoming technical standards on when a host state may require a Central Contact Point from a PSP or EMI operating cross-border through an agent or distributor network. This is a structural, supranational-level development rather than a Lithuania-specific action, but it bears directly on how non-bank PSPs and EMIs based in or passporting through Lithuania structure their cross-border agent and distributor presence across the EEA.
The practical constraint this addresses is access and representation: a PSP or EMI relying on agents and distributors in other member states needs clarity on when the host state can insist on a local Central Contact Point as a condition of that cross-border activity continuing unimpeded. For Lithuania's large population of licensed EMIs and PIs, many of which operate cross-border through exactly this agent-and-distributor model, the eventual technical standards arising from this survey will materially affect how settlement and access arrangements are structured outside Lithuania itself.
This is distinct from a bank-versus-non-bank access question; the Central Contact Points framework applies specifically to how non-bank PSPs and EMIs maintain cross-border representation and compliance contact points, rather than to correspondent banking relationships in the traditional sense. No Lithuania-specific correspondent-banking or sponsor-bank-dependence development was identified this period beyond this structural, EEA-wide survey.
The technical standards that will result from AMLA's Central Contact Points survey, closed 15 September 2026, are the item to watch: once published, they will set the concrete threshold for when a host state can require a local Central Contact Point, directly affecting the cross-border operating model of Lithuania-licensed PSPs and EMIs using agents and distributors elsewhere in the EEA.
3 earlier distinct update(s)
Correspondent Banking, Settlement & Access
Lithuania's CENTROlink infrastructure, the Bank of Lithuania's payment-settlement system open to both bank and non-bank participants, is reported to have processed 379.7 million payments in 2025, up 28.9% year over year, with instant payments comprising 68% of all Lithuanian payment volume in 2025. CENTROlink's analytical significance sits in the bank-versus-non-bank access dimension: as a settlement system open to licensed electronic money institutions and payment institutions directly, rather than requiring indirect access through a correspondent bank relationship, it structurally reduces the settlement-access asymmetry that non-bank payment firms otherwise face in many other jurisdictions.
This growth figure rests on a single lower-tier source this cycle and has not been corroborated against a Bank of Lithuania primary publication, so it should be treated as a reported rather than confirmed volume figure pending further sourcing.
Corroboration of the CENTROlink 2025 volume figures against a Bank of Lithuania primary publication is the clearest item to watch to confirm the scale of instant-payments growth. Continued strong CENTROlink volumes would reinforce Lithuania's structural position as a jurisdiction where non-bank payment institutions have direct, rather than intermediated, settlement access.
Correspondent Banking, Settlement & Access
The defining feature of Lithuania's correspondent-banking and settlement-access picture is the bank-versus-non-bank access asymmetry that CENTROlink resolves for eligible payment institutions. CENTROlink gives eligible PIs and EMIs direct access to SEPA payment rails and instant-payment capabilities without relying on a traditional correspondent-banking relationship with a commercial intermediary bank. This is structurally significant because it removes what is, in many jurisdictions, the principal access bottleneck for non-bank payment institutions: dependence on a correspondent bank willing to provide settlement access, with the attendant de-risking exposure that such relationships often carry.
By routing settlement access through the central bank's own infrastructure rather than through commercial correspondent relationships, Lithuania has effectively converted what is elsewhere an access-dependency risk into a structural competitive advantage for its licensed non-bank population. This is the module's analytical spine for Lithuania specifically: the asymmetry that typically disadvantages non-banks relative to banks in accessing settlement infrastructure is substantially narrowed here.
Watch whether the central-bank-mediated access model CENTROlink represents continues to differentiate Lithuania from jurisdictions where non-bank PIs/EMIs remain dependent on commercial correspondent-banking relationships, and whether growth in CENTROlink's participant base further entrenches this advantage.
Correspondent Banking, Settlement & Access
The Bank of Lithuania has issued guidance to banks on opening accounts for clients that are themselves electronic-money institutions or payment institutions. This guidance addresses directly the structural asymmetry between bank and non-bank payment-services providers that defines this module's analytical spine: non-bank PSPs frequently depend on maintaining banking relationships to access settlement and correspondent infrastructure, and that dependency creates a persistent point of vulnerability where a bank's own risk appetite, rather than the non-bank PSP's regulatory standing, determines continued market access.
By issuing guidance specifically addressed to banks on this question, the Bank of Lithuania is treating account-access friction for EMI/PI clients as a supervisory concern in its own right, separate from the direct governance and safeguarding requirements imposed on the EMI/PI institutions themselves under Resolution No. 247. This reflects an implicit acknowledgement that tightening the non-bank side of the regulatory perimeter is only half of the access equation; the bank side's willingness to serve these clients is the other half, and this guidance is a direct intervention on that second half.
Whether this guidance measurably improves banks' willingness to open and retain accounts for Lithuania's 71 EMIs and 45 PIs, or whether de-risking pressure on the bank side persists despite the guidance, is the key access-dynamic question to track in subsequent cycles.
Sources and findings (4 unique sources · R-3/R-4)
Electronic money and payment institutions can become direct CENTROlink participants if they meet applicable requirements, with eligibility depending on the country of licensing and national supervisory procedures, and an Article 35a PSD2 document of compliance referenced for access.
CENTROlink provides direct access to SEPA Credit Transfer, SEPA Instant, TARGET2 and cross-border SWIFT, and Lithuanian PIs and EMIs can join by signing a technical agreement with the Bank of Lithuania, bypassing commercial correspondent banks for SEPA rails at published fees below commercial correspondent rates.
- [W12-E3] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/news/centrolink-is-expanding-its-instant-payment-services re-verified
The Bank of Lithuania performs regular assessments of participants' activities, related risks and reputation to ensure CENTROlink is used only by reliable market participants, rejecting connection applications and disconnecting institutions where warranted.
- [W12-E4] T3 Derived: Probable in_forcehttps://www.financiallicensemarket.com/blog/lithuanian-emi-license-complete-guide-2026 re-verified
Securing a safeguarding account with a willing banking partner has become a significant practical challenge for new Lithuanian EMI applicants as banks have become more selective in relationships with payment institutions, with many applicants spending months securing safeguarding infrastructure.