Lithuania Amended Its Accessibility Law Twice in 2026 — and Closed the Fintech Loophole
The fine is modest: €500 to €15,000. What makes Lithuania worth reading is that it has already rewritten its accessibility law twice this year — and one of those changes plugs a gap we haven't seen closed anywhere else.
Quick answer
Lithuania's EAA law — the Gaminių ir paslaugų prieinamumo reikalavimų įstatymas (GPPRĮ), Law No. XIV-1633 — applied from 28 June 2025 and has been amended twice in 2026: by Law No. XV-760 (10 March, effective 1 April) and Law No. XV-907 (12 May). The sanction is a warning, a fine of €500–€15,000, or a decision restricting or prohibiting market availability — and since April 2026 a fine and a restriction can be imposed for the same violation. Four authorities enforce it, coordinated by a dedicated inter-agency commission. The 2026 amendment also redefined consumer banking services by service type rather than provider type.
The fintech fix
This is the change worth copying, and we haven't seen another member state make it.
Originally, "consumer banking services" in the Lithuanian law were tied to the formal status of the provider — a bank or licensed financial institution. The 1 April 2026 amendment replaced that with a functional test: the category now covers any economic operator providing one of the specifically listed services — credit, investment services, payment services, e-money.
The gap that closes is obvious once stated. Under a provider-status definition, a non-bank fintech offering a functionally identical payment or credit product could argue it fell outside the banking category altogether. Lithuania removed the argument.
| Before 1 April 2026 | Since 1 April 2026 | |
|---|---|---|
| Test | Who the provider is (bank or licensed financial institution) | What the service is |
| Covers | Licensed institutions | Any economic operator providing credit, investment, payment or e-money services |
| Non-bank fintech | Could argue it was outside scope | In scope |
If you operate a fintech in the EU, this is the drafting change to watch for elsewhere — and in Lithuania, it already applies to you.
What the sanctions are
Enforcement proceedings begin either on complaint — from a consumer, end user, state or municipal institution, consumer association or other interested party — or on the authority's own initiative where it has sufficient grounds to suspect a violation.
Three outcomes are available:
- a warning (įspėjimas);
- a fine of €500 to €15,000, set according to mitigating and aggravating circumstances;
- a decision restricting or prohibiting the product's availability on the market.
The 2026 amendment tightened two things. A fine and a restriction decision can now be imposed together for the same violation, where previously they operated more separately. And authorities can now impose restrictive measures without waiting for the full violation-review protocol to conclude — meaning the market measure can land before the paperwork finishes.
Appeals run under the Law on Public Administration or the Law on Administrative Proceedings.
The €500–€15,000 range puts Lithuania in the lower-middle of the EU: above Slovakia's €6,000 accessibility tier, well below Croatia's €132,720 or Czechia's €400,000. But note the structure — the warning is a formal statutory outcome, not just informal practice, which points to the same escalation-first design seen in Estonia and Austria.
Four authorities, and a commission to coordinate them
Lithuania's supervisory map, in the Ministry's own words:
| Authority | Covers |
|---|---|
| Valstybinė vartotojų teisių apsaugos tarnyba (State Consumer Rights Protection Authority) | «vartotojų bendrosios paskirties kompiuterių aparatinės įrangos sistemos» (consumer general-purpose computer hardware), self-service terminals, «elektroninės skaityklės» (e-readers), telecoms terminal equipment, banking, e-books, e-commerce — and, since the 2026 amendment, audiovisual-access devices |
| Lietuvos transporto saugos administracija (Lithuanian Transport Safety Administration) | Transport service elements |
| Ryšių reguliavimo tarnyba (Communications Regulatory Authority) | Electronic communications services |
| Radijo ir televizijos komisija (Radio and Television Commission) | Audiovisual media services — with the AV-access device function moved away from it in 2026 |
Four is light by regional standards — Latvia splits services seven ways, Slovenia eight. And the Consumer Rights Protection Authority now holds by far the broadest remit of the four, which makes it most businesses' likely counterparty.
What is distinctive is Article 5, which establishes a Products and Services Accessibility Coordination Commission — a standing inter-agency body sitting alongside the regulators, written into the statute itself. Spain created a coordinating Technical Unit by royal decree in 2026; most other member states leave inter-agency coordination informal. Given how much of this series is a catalogue of fragmentation problems, Lithuania built an institutional answer to it into the law from the start.
The e-book certification scheme
Lithuania has something we haven't found anywhere else in the EU: an operating certification scheme for accessible publications.
The Lietuvos audiosensorinė biblioteka (Audiosensory Library, LAB) has run it since March 2024, verifying EPUB files against WCAG 2.2 AA. It predates the EAA's application date by more than a year.
For publishers, that is a concrete compliance route rather than an interpretive exercise — you submit the file and get a determination. Elsewhere, e-book accessibility is left to the publisher's own assessment against EN 301 549. If you publish e-books into the EU, the Lithuanian scheme is worth knowing about even if Lithuania is not your main market, because a LAB-certified EPUB is evidence you can carry elsewhere.
Scope: the whole rail network
One design choice is worth flagging for transport operators. Lithuania applies the full accessibility requirements across its entire national rail network, without the urban, suburban and regional carve-outs that most member states take from the Directive's optional exclusions.
Urban and suburban road transport is treated the other way — limited to non-integrated interactive self-service terminals only. So the mode matters more in Lithuania than the geography.
The standard features
Micro-enterprises providing services are fully exempt (Art. 7(1)) — under ten employees, revenue or balance-sheet assets under €2 million.
The funding trap applies: an operator that accepts funding specifically to improve accessibility forfeits the disproportionate-burden exception — the same rule we've noted in Poland, Luxembourg, Denmark and Finland.
112 emergency requirements apply only from 28 June 2027 — an option the Directive allows and several member states have taken.
Collective standing exists — complaints can be filed by state or municipal bodies, consumer associations or other interested parties on a consumer's behalf.
Has it been enforced yet?
No fines or restriction decisions have been reported. Lithuania's position is unusual in that the framework has been moving underneath the enforcement: the law that applied on 28 June 2025 is not the law in force today, and the second 2026 amendment landed in May. A regulator working through its first cases has been doing so against a shifting text.
What this means for your business
- Check whether you are newly in scope. If you provide credit, payment, investment or e-money services in Lithuania without being a licensed bank, the April 2026 amendment brought you into the consumer-banking category. That is the single most likely reason a business's Lithuanian assessment is now out of date.
- Expect the Consumer Rights Protection Authority. It covers most product categories plus banking, e-books and e-commerce, and gained AV-access devices in 2026.
- Don't rely on the fine being the worst outcome. Since April 2026 the authority can restrict or prohibit market availability and fine you for the same violation, and can impose the restriction before completing its review protocol.
- If you publish e-books, use the LAB certification scheme.
Frequently asked questions
What is the EAA fine in Lithuania?
€500 to €15,000, set according to mitigating and aggravating circumstances. A warning or a market restriction/prohibition can be imposed instead — or, since April 2026, a fine and a restriction together.
Has the law changed since it took effect?
Yes, twice in 2026 — Law No. XV-760 (effective 1 April) and Law No. XV-907 (12 May).
I'm a fintech, not a bank. Am I covered?
In Lithuania, yes. Since April 2026 consumer banking services are defined by the service provided — credit, investment, payment, e-money — not by the provider's licence status.
Who enforces it?
Four authorities, coordinated by a statutory Products and Services Accessibility Coordination Commission. The State Consumer Rights Protection Authority has the broadest remit.
Is there a way to get e-books certified?
Yes. The Audiosensory Library has certified EPUB files against WCAG 2.2 AA since March 2024 — the only such scheme we've found operating in the EU.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Official text: Law No. XIV-1633 (GPPRĮ) (e-TAR)
- Latvia's EAA fine — the neighbouring market where products carry €20,000 and services carry nothing
- Estonia's EAA penalty — the third Baltic model, with no punitive fine at all
Sourcing note: the €500–€15,000 range and the enforcement outcomes come from the Ministry of Social Security and Labour's official implementation guidance (May 2026 edition), which quotes the governing article directly, corroborated by Lithuanian legal commentary. We have not yet been able to read the consolidated statute text itself, so this page does not yet quote it directly.
