Bank of LithuaniaLicense Revocationcritical

Alternative Payments

Vilnius, Lithuania

The Bank of Lithuania revoked the operating license of an electronic money or payment institution after identifying 10 separate regulatory violations. The case gained additional significance when one of the violations — related to direct debit services — was referred to the Court of Justice of the European Union (CJEU) for further adjudication. While the specific institution was not named in the source material and the action is described as predating June 2025, it represents a notable example of aggressive enforcement by the Bank of Lithuania against licensed payment service providers. Lithuania is one of the most popular jurisdictions for EMI/PI licensing in Europe, and license revocations in this market have broad implications for the fintech and BaaS ecosystem. The CJEU referral could set precedent for how direct debit services are regulated across the EU.

Verified from source: The Bank of Lithuania revoked the license of Alternative Payments, a payment institution, citing 10 violations. The Lithuanian Supreme Administrative Court (LVAT) has referred one issue to the CJEU—whether Alternative Payments unlawfully provided direct debit services without the necessary license.

Implications
  1. License revocations in Lithuania signal heightened enforcement risk for fintechs relying on Lithuanian EMI/PI licenses
  2. CJEU referral could establish EU-wide precedent for direct debit service regulation
  3. BaaS providers operating through Lithuanian licenses face increased compliance expectations
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