Baltic Fintech Legal Outlook

There are no initiatives in Estonia regarding the PSD3/PSR/FIDA.  

The fintech market is in a wait for the final texts of the regulations to be published to start preparing for the compliance with the new legal requirements. Among other requirements in the PSD3/PSR it is important to note that the positions of the European Parliament and the Council have indicated that the reauthorisation under the PSD3/PSR seems to be still on the table and inevitable for the payment institutions and e-money institutions once the PSD3/PSR are in force. As a result, the market has strong expectation that the local supervisory authority establishes clear framework and step-by-step process to guide firms through reapplication efficiently and transparently. 

There are no initiatives in Latvia regarding rhe PSD3/PSR/FIDA yet. Bank of Latvia has announced that work on necessary legislative changes will take place in the fourth quarter of 2026. 

The fintech market is in a wait for the final texts of the regulations to be published to start preparing for the compliance with the new legal requirements. Among other requirements in the PSD3/PSR it is important to note that the positions of the European Parliament and the Council have indicated that the reauthorisation under the PSD3/PSR seems to be still on the table and inevitable for the payment institutions and e-money institutions once the PSD3/PSR are in force. As a result, the market has strong expectation that the local supervisory authority establishes clear framework and step-by-step process to guide firms through reapplication efficiently and transparently. 

There are no initiatives in Lithuania regarding the PSD3/PSR/FIDA. 

The fintech market is in a wait for the final texts of the regulations to be published to start preparing for the compliance with the new legal requirements. Among other requirements in the PSD3/PSR it is important to note that the positions of the European Parliament and the Council have indicated that the reauthorisation under the PSD3/PSR seems to be still on the table and inevitable for the payment institutions and e-money institutions once the PSD3/PSR are in force. As a result, the market has strong expectation that the local supervisory authority establishes clear framework and step-by-step process to guide firms through reapplication efficiently and transparently. 

From the Estonian perspective the CCD II will play an important role in reshaping the BNPL market. Offering BNPL schemes has been very popular in Estonia both among credit providers and other entities as it is a largely unregulated area and provides notable profit. After the CCD II, a number of these companies providing BNPL schemes currently in Estonia would most likely need to obtain a license in order to keep providing such services. Also, BNPL providers are required to apply to BNPL clients the same requirements that are applicable to ordinary consumer borrowers. Hence, the influence of the CCD II to the Estonian non-bank lender and therefore fintech market is considerable.   

In Estonia, entities providing or intermediating consumer credit need to obtain a license from a competent authority. The process of and requirements for obtaining the license are comparable with those applicable to other financial institutions. Meanwhile, several other member states require only simple registration or authorisation from the credit service providers / credit intermediaries. As the CCD II does not introduce a unified licensing regime for the credit service providers / credit intermediaries, the entry barriers to the Estonian market remain higher for the credit service providers /credit intermediaries than in several other member states.   

In June 2024, the Ministry of Justice required feedback from parties affected by the CCD II on the implementation of the CCD II in Estonia. Among other, the Ministry of Justice and Digital Affairs asked for an opinion on the options left to the Member States regarding the extension of the scope of the CCD II, providing adequate explanations to the consumer, advisory services, creditworthiness assessment, etc. The Ministry of Justice and Digital Affairs released an update in May 2025 on the state of transposition of the CCD II, based on the feedback received. In their feedback, the majority of the parties affected by the CCD II supported maintaining the current scope to the greatest extent possible. On other issues, the approach was rather to extend, if possible, the current regulation of credit agreements related to residential real estate to other consumer credit agreements, as the new regulation is largely based on the Mortgage Credit Directive. A draft legislation is currently being prepared and expected to be published in 2026. 

Consumer lending was subject to very strict regulatory requirements in Latvia already before the adoption of the CCD II, as set forth in the Consumer Rights Protection Law (CRPL), including capping the total cost of credit to consumers, mandating thorough creditworthiness checks and extensive restrictions on advertising. Therefore, many of the requirements introduced by the CCD II will not require additional transposition into Latvian national legislation. 

For the reminder of requirements set out in the CCD II, the transposition into Latvian national legislation is under way, but has not yet been completed. The primary law for the transposition of the CCD II is the CRPL. However, full transposition will also require amendments to the Law “On Taxes and Duties,” the Credit Information Bureau Law, as well as Cabinet of Ministers (CM) Regulation No. 691 of 25 October 2016 “Regulations on Consumer Lending” and CM Regulation No. 772 of 13 December 2016 “Regulations on the Registration of Credit Intermediaries and Representatives of Credit Intermediaries.”  

The main proposed amendments to the above legislative acts include: 

• Credit intermediaries. Until now, the obligation to register with the Consumer Rights Protection Centre applied to the credit intermediary and a representative of a credit intermediary who offered a consumer credit whereby the repayment was secured by a real-estate mortgage or whose purpose was to acquire or retain rights to real estate. Once the amendments enter into force, the obligation for the credit intermediary and their representative to register applies regardless of whether the credit service is related to a real-estate mortgage or not. The credit intermediary or its representative, who is subject to the registration requirement, may provide their services only if they are registered in the relevant register.The register contains information on the services provided. Therefore, when introducing new consumer credit services, the credit service provider must promptly (i.e., no later than within seven business days after the respective changes enter into force) inform the registry and submit updated information and documents confirming these facts. 

• Ethics standards. The amendments will also establish professional ethics standards for the credit providers, credit intermediaries, and their representatives. It means there will be an obligation to reassess the remuneration system in such a way that employees would not be interested to violate the established business ethics standards when issuing credit or providing intermediary services. Remuneration may not depend on the number, amount, or proportion of the approved credit applications. The Consumer Rights Protection Centre has referred to the European Banking Authority’s guidelines on remuneration policies and practices related to the sale of retail banking products and services, which must be taken into account when designing remuneration policies. 

• Deferred Payment and BNLP. The CRPL will be supplemented with a new concept – the deferred payment service. According to the amendments of the CRPL the deferred payment service is understood only as a service in which no other credit provider is involved. Thus, it distinguishes the deferred payment service from BNPL, in which another credit provider is involved. The exemptions in the CRPL apply only to those loans in which no other credit provider is involved. That is, if the manufacturer, seller, or service provider itself (without the involvement of another credit provider) grants a deferred payment to the consumer so that the consumer can pay for that manufacturer’s, seller’s, or service provider’s goods or services, without applying an interest rate or other charges, and the payment must be made in full within 50 days, then the exemptions will apply. 

However, if this manufacturer, seller, or service provider is considered a large company, then the period within which full payment must be made is 14 days in order to apply the exemptions set out in the CRPL. The explanatory notes to the amendments mention that this will affect telecommunications service providers (e.g., LMT, Bite, Tele2), who offer the purchase of phones, computers, and other goods on a deferred payment basis. 

• Creditworthiness assessment. The obligation to assess the consumer’s ability to repay the loan is also planned to apply to credit granted as an overdraft facility that must be repaid within one month, as well as to credit agreements for which no interest or other fees are charged, or only an insignificant fee is required. 

As the proposed amendments have not yet been adopted by the Latvian Parliament, changes are still possible.  

The CCD II will play a significant role in reshaping the BNPL market in Lithuania, a service that has become increasingly popular across various industries, including e-commerce and telecommunications. Currently, many BNPL providers (among which there are notable fintech companies known for offering BNPL) operate in a regulatory grey area, as the service often falls outside the traditional scope of consumer credit regulations. After the transposition of CCD II, the credit providers will have to apply the same requirements to BNPL clients and to ordinary consumer borrowers.  

As a result, the implementation of the CCD II is expected to have a far-reaching impact on the Lithuania’s non-bank lending and fintech sectors. The directive aims to strengthen consumer protections while fostering a level playing field, which could challenge existing business models and demand operational adjustments from both new and established BNPL providers in Lithuania. 

The transposition of the CCD II into Lithuanian national legislation is currently under way. The Ministry of Finance of the Republic of Lithuania has already proposed draft amendments to the Law on Consumer Credit of the Republic of Lithuania. Under the proposed amendments the scope of the law will be broadened by increasing the maximum regulated credit amount from EUR 75,000 to EUR 100,000; regulation of deferred payment arrangements subject to strict conditions and short repayment periods will be introduced; certain existing exemptions will be removed, including those relevant for the BNPL models. 

In addition, the draft law introduces more detailed requirements relating to mandatory consumer warnings, pre-contractual information disclosures, and the provision of personalised and automated credit offers. Lithuania’s existing strict approach to responsible lending is maintained with the relevant provisions being technically aligned with the requirements of the CCD II. 

The draft amendments also introduce additional regulatory requirements for peer-to-peer lending platforms. These include the replacement of fixed share capital requirements with ongoing own-funds requirements, clearer rules on licensing and deadlines for the commencement of activities, provisions governing removal from the public registers, and strengthened governance, conflict-of-interest and transparency obligations. 

These draft amendments remain subject to review and approval by the Parliament of the Republic of Lithuania, and the final adopted version of the legislation may differ from the current draft. In addition, the Bank of Lithuania plans to revise a number of legal acts applicable to consumer credit providers in 2026. 

The EU AML package will have a significant impact on the Estonian Money Laundering and Terrorist Financing Act (MLFTPA) and the guidelines of the competent authorities. This is mainly due to the directly applicable EU regulations and second level regulations to be adopted by the AMLA as a result of which the Estonian specific regulations will – to the large extent – be revoked (except for the AMLD which needs to be transposed to the local legislation). 

It is still under discussion whether existing laws will be amended in accordance with the AMLD or will a new regulation be adopted. The bill for an amended or new regulation is expected to be published by the Ministry of Finance in Q1 2026. 

The EU AML package will have a significant impact on the Latvian Law on Prevention of Money Laundering and Terrorism and Proliferation Financing (LPMLTPF) and the regulations issued by the supervisory authorities. This is mainly due to the directly applicable EU regulations and second level regulations to be adopted by the AMLA as a result of which the Latvian specific legislation will – to the large extent – be revoked (except for the matters set out in AMLD which needs to be transposed to the local legislation). 

The legislator and the competent authorities have started the implementation processes, and the obliged entities (including fintech companies) should closely monitor the proposed amendments to the LPMLTPF and guidelines of the competent authorities. 

The EU AML package will have a significant impact on the Law on the Prevention of Money Laundering and Terrorist Financing and the regulations issued by the supervisory authorities. This is mainly due to the directly applicable EU regulations and second level regulations to be adopted by the AMLA as a result of which the Latvian specific legislation will – to the large extent – be revoked (except for the matters set out in AMLD which needs to be transposed to the local legislation). 

The legislator and the supervisory authorities will soon start with the implementation processes and the obliged entities (including fintech companies) should closely monitor the proposed amendments to the respective law and accompanying regulations and guidelines issued by the supervisory authorities. Up till now, the authorities have had few public discussions on the new legislation, however, various associations of market participants are becoming increasingly more active in aligning their questions and clarifications for the local and EU supervisory authorities. 

Estonia holds a backlog of being the “go-to” jurisdiction for companies wishing to operate on the crypto-asset sphere. Estonian was especially popular for obtaining VASP licenses (Estonia used to have more than 2000 VASPs) as well as the jurisdiction to go during the ICO boom. However, even prior to the adoption of the MiCAR, Estonia tightened the rules for the VASPs due to which the VASPs in Estonia were required to undergo re-licensing process. As a result of this, the number of VASPs dropped significantly to less than 50 VASPs in 2025. Similarly, when the ICOs were at their peak in the world during 2017-2018, Estonia was the jurisdiction companies often chose for conducting their ICOs. The lack of legislative prohibitions or straight-cut rules was intentional so as not to interfere with technological development. It was believed that Estonia was the pioneer for adopting requirements for crypto services, which added an additional layer of trust for the ICO investors. 

In relation to the application of the MiCAR, Estonia introduced its Act for Markets in Crypto-Assets (AMCA) in June 2024. The regulation in the AMCA was to be expected for some time but did not introduce anything revolutionary. In relation to the AMCA, it has been welcoming for the Estonian VASPs that the Estonian regulator introduced maximum transition period allowing the VASPs in Estonia to operate under their current license until 1 July 2026. This has given the Estonian VASPs sufficient time to prepare for the licensing process under the MiCAR with due care. At the same time, it has been unfortunate that Estonia did not introduce a simplified transition for companies operating under the VASP license. As the VASPs in Estonia had been subject to more stringent requirements and had gone through the re-licensing process during the last few years, it was expected that there would be adapted rules for a simplified transition. 

As part of the AMCA, there have been no other guidelines adopted in Estonia by the competent authorities. This is expected considering the amount and comprehensiveness of the secondary legislation on the EU level for the MiCAR. Some licensing forms (e.g. for the suitability assessments) have been put in place by the Estonian FSA for a long time ago and are also expanded to the CASPs. The Estonian FSA has held introductory webinars on how to prepare for licensing and published guidance on the application package on its website. Also, the Estonian FSA has seemed to put human resources to this specific matter in order to ensure efficient and timely application process.  

The number of Estonian VASPs who will obtain the CASP license under the MiCAR in Estonia is still hard to predict. The companies are evaluating the pros and cons of different jurisdictions thoroughly and are not tied to the jurisdiction where they have specifically obtained their VASP license. It can be assumed that the first Estonian VASPs would receive their CASP license under MiCAR in Q1 of 2026 and this number will grow in time until the end of the grandfathering period (July 2026). However, the practice from the other member states where the grandfathering period has already lapsed (including Latvia and Lithuania) has shown that the number of existing VASPs applying for CASP license is limited. The same can be expected for Estonia and therefore the final number of Estonian VASPs who obtain the CASP license under the MiCAR in Estonia will stay relatively low. Such trend is mainly due to strict and comprehensive rules under the MiCAR which would require from small businesses high compliance shift. Also, the competition between member states for most friendly crypto jurisdiction seems to be still ongoing, and the winner is yet unknown. This will influence also the companies applying for the CASP license on a first-time basis.  

Latvia is eager to establish itself as a key player in the cryptocurrency landscape, with both politicians and the supervisory authority actively encouraging CASPs to consider Latvia as their preferred jurisdiction for licensing, and they are backing their words with concrete actions: 

• Supervisory fees payable by CASPs are said to be the best in the Baltics. Although models for calculation of the supervisory fees applied by various countries differ significantly and hence are difficult to compare, Latvian politicians acted upon calls by the industry (its most influential representative being the Latvian Blockchain Association (LBAA)) and agreed on a supervisory fee model that has a competitive edge over the ones applicable in Estonia and Lithuania. The supervisory fee is set in Latvia at up to 0.6% of gross CAS-related income (to be determined annually by the Bank of Latvia), but no less than 3000 EUR. The licensing fee is set at 2500 EUR for the CASP license. 

• Innovation Centre and Regulatory Sandbox operated by the Bank of Latvia. The Latvian FSA, which for the CASPs will be the Bank of Latvia, has put in place various mechanisms to assist CASPs in entering the market. The regulatory sandbox can be used to test fintech ideas in real life. The innovation centre, on the other hand, offers practical help during the so-called pre-licensing stage via dedicated consultations by the employees of the Bank of Latvia. For additional information, check out fintechlatvia.eu. 

• Access to the Bank of Latvia retail payment system (EKS) and SEPA: in a groundbreaking step, the Bank of Latvia opened access to its retail payment system EKS and hence also to SEPA to licensed payment service providers and thus also to CASPs who provide payment services. 

• Payment of share capital in crypto and other developments. To popularise the usage of crypto, amendments to Latvian Commercial Law were adopted, making it possible to pay share capital of a company (any company, not just CASPs) by crypto. Discussions are also ongoing about the possible integration of CASPs providing crypto exchange services to the systems used for payment of taxes. 

• The right to keep client’s funds in an account in the Bank of Latvia. In addition to granting access to the payment systems, the Bank of Latvia also wanted to provide an option for CASPs to keep a client’s funds in an account in the Bank of Latvia. Hence, a respective provision is even envisaged in the Latvian Law on Crypto-Asset Services (the LCAS). This innovative idea was struck down by the ECB as incompatible with the core role of central banks. Accordingly, the Bank of Latvia will be following the ECB’s policy on access to central bank accounts of July 2024, whereby only the moneys necessary for payment execution (settlement) may be placed in such an account with the remainder thereof being transferred to a bank for safekeeping. To this end, the local AML guidelines have been further revised to allow banks to adopt a more cooperative stance towards those engaged in the crypto sphere. 

• No quotas for the licenses. Everyone that meets MiCAR requirements is welcome! 

To supplement MiCAR, LCAS was adopted in the summer of 2024, with the ten brief articles thereunder focusing on establishing supervisory mandate of the Bank of Latvia and introducing the above-described competitive licensing and supervision fees.   

Transition period applicable to the existing VASPs ended on 30 June 2025.  In 2025, the Bank of Latvia issued two CASP licenses. During the same year, it received six CASP license applications, while 12 companies remained in the pre-licensing stage. 

In recent years Lithuania has been a popular jurisdiction for virtual currency service providers to choose to register themselves. The Lithuanian government adopted a fintech friendly stance, and, prior to MiCA coming into force, had a relatively straightforward registration regime for virtual currency exchange operators and depositary virtual currency wallet operators. Lithuania has been proactive in aligning its legislation with MiCA, and the government’s regulatory approach has now shifted to ensure high compliance and prudential standards, with an emphasis on consumer protection, anti-money laundering/ counter-financing of terrorism (AML/CFT) and operational resilience. The stricter regime has led to market consolidation and the de-registration of a number of virtual currency service providers. At the same time, regulatory efforts are now focused on supporting well-prepared, compliant and financially sound providers in obtaining licences under MiCA and continuing to operate under the new framework, while ensuring that any wind-downs of virtual currency service providers that do not seek to obtain authorisation under MiCA are carried out in an orderly manner. 

Alignment of MiCA with domestic/national legislation: On 11 July 2024, the Lithuanian parliament, the Seimas, approved the draft Law on Crypto-Asset Markets prepared by the Ministry of Finance, which establishes new requirements for the conduct of activities for CASPs. The Law on Crypto-Asset Markets entered into force on 25 July 2024. Furthermore, the Bank of Lithuania issued the licensing rules for CASPs which entered into force on 30 December 2024 and set out the procedure for submitting and examining applications for a CASP licence. The Commission for Coordinating the Protection of Objects of Importance to National Security assesses and approves certain shareholdings or voting rights in excess of 25% in CASP applicants. The Bank of Lithuania is the designated national competent authority responsible for licensing and supervising crypto asset market participants. In the supervision of crypto-asset market participants in the field of AML/CTF, the Bank of Lithuania closely cooperates and exchanges information with the FNTT. 

In accordance with Article 143(3) of MiCA, Member States were able to adopt a transitional period and Lithuania initially opted for a Transition Period until 1 June 2025, but then on 8 May 2025, following industry feedback, extended it to 1 January 2026.  

Authorisation Process: On 17 December 2024, the Bank of Lithuania adopted new Licensing Rules for CASPs, which cover the following information about the CASP authorisation procedure: 

• the documents to be submitted for a CASP licence application, including form, language and content requirements, as well as the standard forms of CASP licence application annexes that must be completed by an applicant for a CASP licence; 

• the procedure for submission and examination of a CASP licence application, including processing times; 

• how to modify or extend the scope of a CASP licence; and 

• which changes in submitted information have to be notified to the Bank of Lithuania. 

Once clearance from the National Security Commission is obtained and the CASP licence application is prepared in accordance with requirements set out in the Licensing Rules for CASPs, the application can be submitted to the Bank of Lithuania. It is also important to note that, in addition to the documents and information specified in the Licensing Rules for CASPs, applicants must submit to the Bank of Lithuania the documentation and information required for: 

• a qualifying holdings assessment for any natural or legal persons who directly or indirectly – whether individually or acting in concert – hold 10% or more of the shares or voting rights (or who otherwise exert significant influence) in a Lithuanian entity applying for a CASP licence; 

• a fit and proper assessment for each individual proposed as a manager of the CASP. 

The fee for the assessment of a CASP licence application is EUR 2,425. 

The timeframe for the assessment of CASP’s authorisation application in Lithuania is the same as set forth in MiCA: 

The Bank of Lithuania shall assess whether the application is complete and verify that all information specified in Article 62(2) of MiCA (as further detailed in the Licensing Rules for CASPs) has been provided within 25 working days from the date of receipt of the application. If the application is not complete, the Bank of Lithuania shall set a deadline by which the applicant must provide the missing information.  

The Bank of Lithuania shall assess a CASP’s application and make a reasoned decision to grant or refuse a licence to the applicant within 40 working days from the date of receipt of the complete application. 

During the assessment, but no later than the 20th day of the assessment period, the Bank of Lithuania may request any additional information necessary to complete the assessment. The assessment period is suspended from the day the Bank of Lithuania requests the missing information until the day responses are received from the applicant. The assessment period can be suspended for no more than 20 working days. In practice, an applicant for a CASP licence can expect that preparing a high‑quality application may take approximately 2-3 months under optimal circumstances, while the application assessment process at the Bank of Lithuania may take approximately 9‑12 months. 

The transitional period during which virtual asset service providers were required to obtain authorisation in accordance with MiCAR ended in Lithuania on 31 December 2025. As of 1 January 2026, virtual asset service providers that do not hold a licence are no longer permitted to provide crypto-asset-related services.  

As of the beginning of January 2026, 3 companies hold a licence issued by the Bank of Lithuania, granting them the right to provide crypto-asset services in Lithuania as well as in other EU Member States. Crypto-asset services may also be provided in Lithuania by crypto-asset service providers licensed in other EU Member States, provided that they have been duly notified to provide services in Lithuania. 

The use of AI solutions by the Estonian financial institutions is becoming more and more popular, especially among fintech companies providing financial services online. This trend was confirmed by a survey conducted by the Estonian FSA in March 2025 among supervised entities and published in late 2025. The survey specifically showed that AI is widely used by the financial institutions in Estonia, mainly in pilot or early implementation stages, with efficiency and decision-support identified as the main benefits. 

Estonia has been relatively active in relation to boosting the use of AI-based applications both in the public and private sector. In 2019, the Estonian government introduced an expert report (the so-called Kratt report) on how to advance the use of AI in the public and private sector. After this, Estonia has also introduced National AI Strategies for 2019–2021, for 2022–2023 and currently for 2024–2026. The National AI Strategies also introduced legal initiatives for regulating AI in Estonia. In light of the EU AI Act, these initiatives were redirected towards solving specific problems that needed to be regulated and were able to be regulated independently from the EU regulations. According to the National AI Strategy for 2024–2026, the aim is to support the implementation of the EU AI Act within Estonia, including establishing a supervisory framework for developing and using AI. However, Estonia’s specific legal initiatives on AI as well as the National AI Strategy for 2024–2026 establishing the goals for implementing EU regulation put little to no attention to the use of AI specifically in the financial sector. To date, Estonian competent authorities have not issued sector-specific guidance on the use of AI in financial services and it is unlikely that such guidelines will be introduced in the near future. The EU AI Act establishes a binding framework that will apply fully as from 2026, with its most significant obligations for financial institutions taking effect at that stage. 

The survey by the Estonian FSA indicated also that from a supervisory perspective the key areas of focus in relation to AI are data protection, governance, model reliability, cybersecurity, and ensuring meaningful human oversight, as AI increasingly influences institutions’ business models and risk profiles. 

Fintech companies should therefore start reviewing what AI systems they already use and which AI systems they plan to implement before the EU AI Act becomes applicable.  It is also important to assess which requirements of the EU AI Act will apply to those systems once the relevant obligations take effect and prepare an internal action plan for compliance. The action plan can be submitted to the competent authorities in the case of a respective inquiry. 

Fintech companies should therefore start reviewing what AI systems they already use and which AI systems they plan to implement before the EU AI Act becomes applicable. Also, fintech companies should analyse the requirements from the EU AI Act applicable to the use of such AI systems and prepare the action plan for becoming compliant. The action plan can be submitted to the competent authorities in the case of a respective inquiry.

The use of AI in the financial sector has been increasing exponentially. According to a survey conducted by the Bank of Latvia in the first half of 2024, 34 Latvian financial market participants are already using AI solutions in their work. According to the survey, AI solutions are used in all financial market segments, although the most frequent users are deemed to be investment brokerage companies, insurance companies and investment management companies.  

Up until the adoption and coming into force of the EU AI Act, the Bank of Latvia has exercised limited supervision on the application of AI by financial institutions, and it is expected that as the application of the EU AI Act approaches, the competent authorities will increase the level of supervision going onwards. 

Lithuania, as an EU member state, is preparing for the implementation of the EU AI Act by adapting to new requirements and promoting responsible AI use across various sectors, including public administration, the economy and the financial sector. The Ministry of Economy and Innovation is leading the implementation of the EU AI Act in Lithuania, working closely with institutions such as Lithuania the Communications Regulatory Authority and the State Data Protection Inspectorate. National efforts include: a review of existing national laws (such as those related to data protection and consumer rights) to ensure alignment with the EU AI Act’s requirements, education and awareness initiatives and support for innovation.  

In terms of areas where Lithuania could excel, the local fintech community increasingly views AI as a field with strong leadership potential. AI technologies are already being applied in Lithuania’s financial sector, particularly for enhancing risk assessment and fraud detection. For instance, financial institutions are using AI tools to ensure compliance with AML (anti-money laundering) and KYC (know-your-customer) requirements, thereby reducing administrative burdens and improving accuracy.  

With the EU AI Act, fintech companies utilising artificial intelligence solutions will need to prepare for potential new regulations and compliance requirements specific to artificial intelligence. 

As the digital euro is still under development no steps have been currently taken. On 29th September 2025 Eesti Pank organised an international conference, where the importance of digital euro was discussed by various experts. More information on it can be found here. 

As the digital euro, including respective legal framework, is still under development at the EU / ECB level, Latvian authorities currently have not engaged in individual action for the introduction of digital euro.  

As the digital euro is still under development no steps have been currently taken.