02/09/25
The Bank of Lithuania has adopted significant amendments to financial and activity reporting obligations for Electronic Money Institutions (EMIs), Payment Institutions (PIs), and newly licensed Crypto-Asset Service Providers (CASPs). These measures, effective from January 2026, reshape compliance frameworks across the payments and digital assets sector.
📑 The new framework introduces three key instruments:
Resolution No. 03-259 amends the rules and forms for financial and activity reporting, including new investment activity disclosures.
Resolution No. 03-83 updates reporting requirements for EMIs and PIs.
A new resolution establishes rules and reporting templates for CASPs and issuers of asset-referenced tokens, covering financial, capital adequacy, and operational data from Q1 2026. Together, these changes align with the EU’s evolving regulatory landscape, including MiCA and PSD2, while reinforcing supervisory oversight by the Bank of Lithuania.
🔎 Compared with prior frameworks, the revisions expand both the scope and detail of reporting obligations. For EMIs and PIs, the focus shifts to greater transparency on investment activities and prudential metrics. For CASPs, the newly approved forms represent the first formalised reporting regime in Lithuania, closing a regulatory gap ahead of MiCA’s full application in December 2024. The approach is consistent with other EU jurisdictions, yet Lithuania’s early adoption of CASP reporting demonstrates a proactive supervisory stance.
💡 Practically, this means EMIs and PIs will face enhanced data-gathering and compliance costs, particularly in capital and liquidity reporting. CASPs and token issuers will need to adapt swiftly, as the 2026 implementation date leaves little time for building internal reporting infrastructure. Institutions with cross-border operations must also ensure that Lithuanian reporting is harmonised with obligations in other EU member states, avoiding duplication or inconsistency.
📌 In summary, the Bank of Lithuania’s updated resolutions bring Lithuanian financial and crypto reporting frameworks in line with EU standards, while raising the bar for compliance. Firms operating in these sectors should begin preparing well ahead of 2026, assessing governance structures, data systems, and internal reporting controls.
At NUR-Legal.com, we advise EMIs, PIs, and CASPs on regulatory compliance, reporting obligations, and licensing matters. Our team can guide your institution through these changes and ensure your business is fully aligned with Lithuanian and EU requirements.
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Nurlan Mamedov