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The Bank of Lithuania's revised Resolution No 247 safeguarding/governance regime (internal control, risk management, protection of received funds) has applied in full since 1 January 2026, alongside the wind-down-plan requirement (in force since 9 April 2025) and, from 1 January 2026, numerical limits on investment of safeguarded client funds.
The live conduct development is the Bank of Lithuania's Resolution No 03-33, amending Resolution No 247 on internal control, risk management and safeguarding. In force since 9 April 2025, it introduces wind-down plan requirements, caps the proportion of safeguarded client funds that may be invested in safe, liquid, low-risk assets at a maximum of 70%, and imposes detailed reconciliation requirements where multiple safeguarding methods are used in combination. The practical effect is to raise compliance cost and constrain treasury optimisation of safeguarded funds. This single-source vendor-corroborated position is asserted at High rather than Confirmed confidence and would benefit from primary-text confirmation.
Outlook
The W1b trajectory is escalating: the safeguarding regime is tightening, and Resolution No 03-33 is the concrete marker of that direction this cycle. Looking forward, the EU PSD3/PSR package is the broader vector likely to layer further conduct and safeguarding obligations onto Lithuanian EMIs and PIs. The reconciliation and wind-down requirements introduced in April 2025 should be read as the leading edge of a tightening supervisory posture rather than a settled endpoint.
Conduct, Safeguarding & Financial Promotions
Lithuania's electronic money institutions and payment institutions have operated, since 1 January 2026, under full compliance with Resolution No 247 as amended by Resolution No 03-33. This national instrument governs governance, internal control, risk management and the safeguarding of received funds for licensed EMIs and PIs. Its commencement brought into effect numerical investment limits on safeguarded client funds, a quantification of what the EU EMD2 baseline expresses only in the qualitative language of 'secure, liquid, low-risk assets.'
The shift from qualitative to quantitative standard is significant for how Lithuanian-licensed firms demonstrate safeguarding adequacy. Under the general EU-level wording, firms and supervisors have historically retained considerable latitude in determining what instruments and concentrations count as sufficiently secure, liquid and low-risk for safeguarding purposes. Resolution No 247's numerical limits remove much of that latitude for Lithuanian-licensed entities specifically, replacing interpretive judgement with a bright-line compliance benchmark. For a firm managing a safeguarding portfolio, this means the question is no longer solely 'is this asset class appropriate' but 'does this allocation sit within the specified numerical limit.'
This commencement sits atop, rather than replaces, the broader governance and internal-control requirements also contained in Resolution No 247, which apply alongside the safeguarding limits. Together these obligations position Lithuania's safeguarding and governance regime as materially more specified than the EU directive text alone would produce, a distinction that matters when comparing the EMI/PI regulatory environment in Lithuania against other Baltic and wider-EU licensing jurisdictions that have not layered an equivalent national quantification onto the EMD2 baseline.
The principal open question following full commencement is supervisory follow-through: whether the Bank of Lithuania actively tests licensed EMIs and PIs against the new numerical investment limits in the ordinary course of supervision, and whether any gaps surfaced through that testing produce enforcement activity. No enforcement action tied specifically to the numerical limits has been identified to date. Firms licensed in Lithuania should expect safeguarding-adequacy reviews to reference the quantified benchmark going forward rather than the more general EU-level standard alone.
3 earlier distinct update(s)
Conduct, Safeguarding & Financial Promotions
The Bank of Lithuania restricted EMI Verified Payments from onboarding new clients, encumbering assets, or extending lending, following a capital and shareholder-lending inspection failure, with a remediation deadline of 1 October 2026 for restoring capital adequacy. This is an active, dated supervisory enforcement action against a licensed electronic-money institution, carrying a specific restriction on the firm's ability to conduct its core onboarding and lending functions until the capital position is restored.
In parallel, the Bank of Lithuania opened a consultation on how fines are calculated and on when a breach counts as minor. Running this procedural consultation at the same time as an active capital-adequacy enforcement action against a licensee suggests the regulator is using current casework to inform, or at minimum co-occurring with, a broader review of how its enforcement discretion is exercised and communicated.
The combination of an open licensing pipeline, described separately under W1a, and this active conduct-enforcement action against an existing licensee indicates that the Bank of Lithuania's conduct and safeguarding supervision is operating with genuine teeth rather than as a formality attached to an otherwise permissive licensing regime. For firms operating in or entering the Lithuanian EMI/PI market, this restriction stands as a concrete illustration of how capital-adequacy and shareholder-lending failures are treated once identified through inspection.
The 1 October 2026 deadline for Verified Payments to restore capital adequacy is the immediate marker: whether the firm meets that deadline determines whether the Bank of Lithuania escalates its restriction further. The outcome of the fine-calculation and minor-breach consultation is a further item to watch, as it may recalibrate how future conduct breaches of this kind are assessed and penalised going forward.
Conduct, Safeguarding & Financial Promotions
The Bank of Lithuania ordered EMI Verified Payments to restore capital adequacy by 1 October 2026, and in the interim barred the firm from onboarding new clients, from encumbering assets, and from extending lending, pending a further supervisory decision. This is a conduct and prudential enforcement action against a licensed non-bank payment institution, distinguishing it clearly from a bank-charter conduct matter: the tools available to the regulator here are licence-condition restrictions rather than the broader prudential toolkit available against a bank, but they are nonetheless severe in practical effect, freezing the firm's ability to grow its book while remediation is pending.
The action is a useful counterweight to this cycle's market-access growth narrative. Lithuania's EMI/PI population continues to expand, but the Verified Payments order demonstrates that the Bank of Lithuania is willing to intervene decisively in an existing licensee's operations when capital adequacy is deficient, rather than treating licensing growth and supervisory intensity as being in tension. The fixed 1 October 2026 deadline gives this action a concrete near-term resolution point.
Watch whether Verified Payments restores capital adequacy by the 1 October 2026 deadline or whether the restriction escalates toward licence suspension or revocation, and whether this action prompts closer market attention to capital-adequacy compliance across Lithuania's broader EMI population.
Conduct, Safeguarding & Financial Promotions
Lithuania's non-bank payments sector faces a significant conduct and prudential-framework transition over 2026 and 2027. A provisional agreement on the third Payment Services Directive and the accompanying Payment Services Regulation (PSD3/PSR) was reached on 27 November 2025, with formal publication expected in the first half of 2026 and entry into force anticipated around 2027. Under this migration, Lithuania's electronic-money-institution population will transition into a unified 'payment institution authorised to issue e-money' category, a structural reclassification of the licence form itself. This is a conduct-and-authorisation-framework change rather than a change in permitted underlying activity, but it will require licensed firms to track the final legislative text closely once published, since the precise mechanics of the migration remain to be confirmed.
Alongside the EU-level PSD3/PSR track, Lithuania has tightened its own national conduct and governance requirements for 2026. The corporate tax rate applicable to Lithuanian payment institutions rose to 17 percent from 1 January 2026, up from 16 percent, a direct cost increase layered onto the compliance bar. More significantly for day-to-day conduct and governance, money-laundering reporting officers, risk leads and IT leads at Lithuanian PIs and EMIs must now be Lithuania-resident, and outsourced part-time MLRO arrangements are no longer accepted. This raises the operational-substance bar meaningfully: firms that previously relied on outsourced or non-resident compliance leadership must now build in-country governance capacity, a change that affects the non-bank PI/EMI population specifically rather than Lithuania's bank-licensed institutions, which have generally maintained in-country governance structures already.
The publication of the final PSD3/PSR legislative text, expected in the first half of 2026, is the key event to track for conduct and safeguarding purposes: it will confirm the precise scope of the unified e-money-issuing payment institution category and may adjust the anticipated 2027 entry-into-force date. In parallel, the practical effect of the new in-country MLRO, risk and IT residency requirements on Lithuania's approximately 120 licensed EMIs and PIs — whether it prompts consolidation, exit, or simply increased local hiring — is the operational question for the next cycle.
Sources and findings (4 unique sources · R-3/R-4)
- [W1b-E1] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/faq/what-client-fund-safeguarding-requirements-apply-to-payment-or-e-money-institutions re-verified
A payment or e-money institution must safeguard client funds either by depositing in a separate account at a credit institution (Lithuania or another Member State) or investing in secure, liquid low-risk assets, defined to include government/central-bank/company bonds rated no less than BBB and traded on a stock exchange, short-term deposits up to one year, and qualifying collective investment schemes.
- [W1b-E2] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/emi-prudential-requirements-and-ratios re-verified
An EMI directly receiving client funds must safeguard them by holding them in a separate account opened with a credit institution of Lithuania (or a foreign credit institution's branch in Lithuania), a credit institution of another Member State, the Bank of Lithuania or another central bank, in line with the statutory safeguarding methods.
- [W1b-E3] T3 Derived: Probable in_forcehttps://ecovis.lt/new-compliance-requirements-for-electronic-money-and-payment-institutions/ re-verified
The Bank of Lithuania adopted Resolution No 03-33 amending Resolution No 247 on internal control, risk management and safeguarding of received funds; institutions must comply with wind-down plan requirements from 9 April 2025, and a maximum of 70% of client funds to be safeguarded may be invested in safe, liquid, low-risk assets, with detailed reconciliation requirements where multiple safeguarding methods are used.
- [W1b-E4] T3 Derived: Probable in_forcehttps://key2law.com/en/licences/emi-licences/lithuania re-verified
The Bank of Lithuania requires management and persons with significant control to pass fit-and-proper tests and applicants to submit a detailed business plan, programme of operations, risk-management framework, safeguarding measures and descriptions of internal procedures and IT infrastructure.