KogoPay UAB
Vilnius, Lithuania
The Bank of Lithuania revoked the EMI license of KogoPay UAB in August 2025 after identifying multiple serious compliance failures including failure to meet minimum funds requirements, persistent delays in financial reporting, and insolvency where liabilities exceeded assets. The firm acknowledged it could not meet its obligations or secure a recovery plan. A prior fine of €30,000 had been issued in 2024 for safeguarding and reporting violations, indicating an escalating enforcement pattern. The revocation led to formal bankruptcy proceedings. This case highlights the risks for EMIs operating in Lithuania's fintech-friendly but increasingly strict regulatory environment, particularly regarding capital adequacy and timely supervisory reporting.
Verified from source: The Bank of Lithuania revoked KogoPay UAB's electronic money institution license and applied to initiate bankruptcy proceedings after the company failed to meet own funds requirements, delayed mandatory financial reports, and was found insolvent with liabilities exceeding assets. KogoPay admitted it could not meet its obligations.
- Demonstrates that EU EMI regulators are escalating from fines to full license revocations for persistent non-compliance
- Reinforces the importance of capital adequacy and timely reporting for BaaS-adjacent EMI and PI firms operating in the EU
- May prompt other EU national competent authorities to tighten oversight of smaller EMI licensees
- Signals increased insolvency risk awareness for firms holding client funds under EMI licenses