Vilnius is Europe's #1 EMI licensor. The licence is the product.

Frequently asked

• How long does Bank of Lithuania actually take to authorise an EMI or PI in 2026?

  Bank of Lithuania publishes a ~3-month assessment baseline for an electronic money institution and a ~6-month baseline for a specialised bank, against an EU norm of six-to-twelve months. The Newcomer programme and the Innovation Hub are formal pre-application channels — managing directors are expected to be on first-name terms with their case officer and answer ad-hoc questions within a working day. The speed advantage is the structural reason Vilnius wins EU passporting hubs over Amsterdam, Dublin, or Luxembourg; it is also the structural reason supervisory expectations on AI-touched flows are higher than buyers expect when they arrive from less-regulated markets. Areza ships the public-facing licence-disclosure layer; the application work sits with your regulatory counsel.

• What does DORA actually change for a Vilnius EMI or PSP since 17 January 2025?

  DORA has been in full application since 17 January 2025. Every AI vendor your fintech onboards now sits inside the mandatory ICT third-party register, with an obligation to support incident reporting on a four-hour initial and 72-hour intermediate clock. Practical effects: vendors without an EU-region sub-processor list, without ISO 27001 receipts, and without a documented incident-disclosure path get filtered at procurement. Areza ships the diligence pack — TIA, SCC mapping, DPA, model card, sub-processor list, DORA incident-reporting template — at engagement start, not as a six-week back-and-forth. Penalties under DORA run up to 2% of annual worldwide turnover for in-scope entities, so the procurement bar is non-negotiable.

• What does the EU AI Act mean for AI-driven credit decisions made by Lithuanian lenders?

  Creditworthiness evaluation of natural persons is classified Annex III high-risk under the EU AI Act. Articles 9-17 provider obligations apply, plus Article 26 deployer obligations and an Article 27 Fundamental Rights Impact Assessment before first deployment. The headline deadline is 2 August 2026; penalties under Article 99 are EUR 15M or 3% of global annual turnover, whichever is higher. Fraud detection is explicitly carved out — important for the Stripe Radar, Featurespace, and Sift layer. For NEO Finance, Bankera, and any other Lithuanian consumer-lending or BNPL entity, this rewrites the model-governance stack and the consumer-disclosure surface. Areza's Foundation product handles the public-facing disclosure layer; the model-governance work sits with your in-house risk team and the named LT model-risk vendors.

• What is the BLIK and PSD3 readiness picture for Lithuanian payment institutions in 2026?

  BLIK is a Polish instant-payment scheme rather than a Lithuanian one; the equivalent in Lithuania is the SEPA Instant rail under Bank of Lithuania supervision, with Vilnius PSPs typically routed through CENTROlink, the BoL-operated SEPA gateway. The bigger 2026 readiness question is PSD3 plus the Payment Services Regulation: trilogue is live, transposition window expected 2026-2027, and the EMI category is set to merge into payment institutions. IBAN-name verification becomes mandatory, behavioural transaction monitoring requirements expand, and SCA carve-outs shift in narrow places. Every Vilnius PSP roadmap for 2026-2027 turns on these dates. Marketing claims that ignore the transition window age badly inside a year.

• How does MiCA interact with the existing Lithuanian crypto-asset service provider stack?

  MiCA has been fully applicable across the EU since 30 December 2024. Bank of Lithuania is the competent authority for crypto-asset service providers, and a Lithuanian MiCA authorisation passports across EU27 the same way PSD2 does. Bankera, Paysera (limited scope), and several smaller LT licensees sit inside the regime. The marketing posture shifts materially from the pre-MiCA Baltic crypto landscape: regulated disclosure standards, supervisory expectations on AI-touched flows, and consumer-protection requirements all tighten. Areza ships the MiCA-specific disclosure surface as part of the Foundation product, alongside the EMI and PI surfaces — they share content infrastructure but diverge on the regulator-facing detail.

• Which KYC and AML vendor should a Vilnius fintech procure in 2026?

  The defensible shortlist runs Ondato and iDenfy on the LT-native side — both compete head-to-head with the international defaults inside Baltic banks and EMIs — plus Onfido (now Entrust IDV), Sumsub, ComplyAdvantage, and Trulioo internationally. The 2026 development to track: Sumsub integrated ComplyAdvantage's Mesh AI risk-intelligence layer as foundational AML data fabric across KYC, KYB, and transaction monitoring. PSD3 plus PSR will require IBAN-name match verification across all PSPs in the transition, so any vendor selection should be re-validated against PSD3 readiness. Areza does not sell the KYC stack; we ship the bilingual disclosure surface and the AI-search citation layer around it.

• Should a Lithuanian fintech run growth in-house or use an agency like Areza?

  The honest split is hybrid. Mature in-house growth teams own brand, paid, and lifecycle, while Areza ships the AI search infrastructure — schema, AI-overview-friendly content, programmatic content per country × product × disclosure permutation, regulated-product disclosure layers in LT and EN — that the in-house team measures and iterates. For a 20-200 FTE Vilnius EMI without a senior growth hire, the typical Areza engagement is a six-month retainer combining Foundation + AI Search + Voice Agent + Knowledge Bot, landing around EUR 6,500-9,500 setup plus EUR 900-1,400 per month. Pricing is published on the site; Lithuanian buyers expect that, and Areza is a Vilnius-headquartered home-market operator rather than a London or Stockholm agency parachuting in.