Four markets, one euro foundation, no domestic card scheme
Estonia, Latvia, Lithuania, and Finland are four payment markets that share the euro, the SEPA schemes, and a highly banked population. None of them runs a domestic card network, so an acquirer entering Tallinn, Riga, Vilnius, and Helsinki connects to the same credit transfer rails and the same card brands in all four. The markets differ on three points: how the payer is identified, the dominant channel for online commerce, and the role of cash in in-person payments.
| Country | Euro since | Central bank | Retail clearing | Dominant identification method |
|---|---|---|---|---|
| Estonia | January 1, 2011 | Eesti Pank | No domestic system: ESTA closed on January 31, 2014, and banks clear through pan-European infrastructure | Smart-ID, Mobile-ID, ID card |
| Latvia | January 1, 2014 | Latvijas Banka | EKS (Elektroniskā klīringa sistēma), run by the central bank since 1998 | Smart-ID, eParaksts |
| Lithuania | January 1, 2015 | Lietuvos bankas | CENTROlink, run by the central bank since 2016 | Smart-ID, national ID card |
| Finland | January 1, 1999 (cash in 2002) | Suomen Pankki | STEP2-T and RT1 from EBA Clearing | Finnish Trust Network: bank and mobile credentials |
In these four markets, the euro credit transfer, instant or not, fills the role that a domestic payment scheme plays elsewhere. The SEPA schemes handle account-to-account transfers, and cards grew on top of them without ever facing a domestic competitor. That absence weighs on acceptance costs. Merchants have no cheaper domestic routing to switch to, unlike the co-badging used in France or Denmark.
These gaps show up in the mix of payment methods that merchants offer. In Finland, cards and bank buttons account for most payments, while in Estonia the credit transfer initiated from online banking remains the most common method. In Latvia, contactless cards lead in-person payments, and cash is still part of everyday use. Lithuanian consumers make a larger share of their everyday payments online than consumers in any other euro-area country.
Smart-ID: authentication comes before payment
Smart-ID is an electronic identification and remote signing service operated by the Estonian company SK ID Solutions AS. It is used in Estonia, Latvia, and Lithuania. The same credential gives access to online banking, government services, and insurance contracts, and it is used to sign legal documents. SEB and Swedbank rolled it out in all three countries at once in 2017, so authentication there is a shared market building block rather than each institution’s own choice. A payment service provider entering the region plugs into the authentication method the population already uses.
SplitKey is the Cybernetica cryptographic architecture that Smart-ID is built on. It splits the private signing key into two parts, one kept on the user’s device and the other on the server. The PIN is not stored anywhere. It unlocks the device’s share locally, but that share cannot sign on its own, while the server holds the other share and acts only when the first one is presented. Compromising either side alone therefore cannot produce a valid signature. This property made QSCD certification possible without dedicated hardware on the user’s side.
- Don’t build your own SCA flow in the Baltics: banks offer Smart-ID and Mobile-ID, and users reject everything else.
- Check coverage country by country before promising a single flow: Smart-ID is deployed in all three Baltic states, but Finland runs on a different framework.
- Keep authentication and signing separate: the same credential serves both, but the contractual liability attached to each is different.
- Use an identity broker rather than bilateral integrations, unless your volumes justify the opposite.
Finland: the bank trust network and bank buttons
The Finnish Trust Network is Finland’s framework for strong electronic identification, set up in 2017 and supervised by Traficom, the Finnish Transport and Communications Agency. Unlike Smart-ID in the three Baltic countries, it does not rely on a single credential. Instead, it splits roles between two types of player. Banks and mobile operators issue the identification methods, and brokers aggregate them and resell them to online services under a single standard contract.
- Identity providers: Finnish banks and mobile operators, each issuing its own strong identification method.
- Identity brokers: intermediaries that aggregate these methods and resell them to online services, contract and technical integration included.
- Legal framework: the Finnish Act on Strong Electronic Identification and Electronic Trust Services (617/2009), amended in 2019.
- Practical effect: a merchant signs with one broker and gets every bank, instead of negotiating bank by bank.
TUPAS is the bank identification protocol that preceded the Finnish Trust Network and was used in Finland for almost 20 years. It became obsolete on September 30, 2019, when the transition period set by Traficom’s regulation ended. It met neither eIDAS requirements nor Finnish data protection rules. The name still appears in technical documentation, where it signals an integration that has not been updated since then.
Bank button pricing is negotiated commercially between the merchant and its aggregator. No scheme rulebook sets the price, and no regulatory cap comparable to card interchange applies. The trade-off lies in the transaction’s legal status. The payment is a credit transfer, irrevocable once executed, so there are no chargebacks and no card-style dispute window.
Where each country clears, and what the regulation has required since 2025
Retail clearing is the infrastructure that exchanges and clears low-value payments between banks before they settle in central bank money. The four countries organize it differently. Latvijas Banka and Lietuvos bankas each run a national system themselves: EKS in Latvia and CENTROlink in Lithuania. Estonia has had no domestic rail since 2014, and Finland relies on EBA Clearing’s systems. The same euro credit transfer therefore goes through different processing chains depending on the market, as any treasurer comparing crediting times across the four countries will notice.
| Country | Bulk credit transfers | Instant credit transfer | Alias registry | Key takeaway |
|---|---|---|---|---|
| Estonia | STEP2-T (EBA Clearing) | TIPS and RT1, depending on the bank | No national registry | The only country in the region with no domestic infrastructure: clearing is entirely pan-European |
| Latvia | EKS, Latvijas Banka | EKS, open to instant payments since August 28, 2017 | Instant Links, Latvijas Banka, since 2021 | The central bank runs the clearing system, the alias registry, and a payee verification service |
| Lithuania | CENTROlink, Lietuvos bankas | CENTROlink | No national registry | CENTROlink also serves non-bank institutions from across the EEA, which makes it a European rail disguised as a national one |
| Finland | STEP2-T (EBA Clearing) | RT1 (EBA Clearing) | Centralized registry planned under the national instant payments rulebook | No domestic public infrastructure; governance runs through the Payments Council led by Suomen Pankki |
ESTA was Eesti Pank’s retail clearing system. It closed at the end of the day on January 31, 2014. The central bank had cut its price to €0.02 per payment, but the cut did not keep participants on board. The banks operating in Estonia are subsidiaries of Nordic groups already connected to STEP2, and they kept that connection rather than use the national rail. Estonian domestic payments have been cleared through pan-European infrastructure ever since.
- Check each partner bank’s actual clearing and settlement mechanism (CSM): two banks in the same country may settle one in TIPS and the other in RT1, with different cutover times.
- Latvia’s per-transaction limit is €100,000 at system level (Latvijas Banka): a supplier payment above that amount must go through another channel.
- Treat Verification of Payee as a user journey, not a check: a close match result requires a user decision, and it breaks poorly designed batches.
- Don’t assume there is an alias registry: among the three Baltic countries, only Latvia offers one at national level.
Siirto: Finland builds its own in-store payment
Finland is the Nordic country without a unified national mobile payment solution. Three competing wallets have split a small market, and none has reached the coverage of Swish in Sweden or Vipps in Norway. The Payments Council led by the central bank set out to build a common solution, and its implementation was entrusted to Siirto Brand Oy in October 2025. No rollout timetable has been published so far.
The rulebook published in 2024 sets out four principles that define the future instrument. It will use European standards rather than proprietary ones, which ties the service to existing common schemes. The user registry will be centralized rather than spread across participating institutions. The operating model will stay open to market players, who will be able to take part in developing the scheme. Finally, the instrument will carry its own brand, so consumers can recognize it when they pay at the checkout.
- MobilePay Finland has about 2.8 million users under the Vipps MobilePay AS banner (Vipps MobilePay 2024 annual report), a penetration rate well below that of Denmark, Norway, and Sweden.
- Pivo, OP Financial Group’s wallet launched in 2013, has been discontinued (Norges Bank, Payments in the Nordics, December 2025).
- Siirto has existed since 2017 as a P2P transfer service; what is new is its mandate for the physical point of sale.
- Settlement will run on the existing SEPA instant rails: the rulebook mandates common European standards and does not create a parallel rail.
Lithuania: CENTROlink, EMI licenses, and what they cost
CENTROlink is the payment platform that Lietuvos bankas has operated since 2016. It gives payment institutions and e-money institutions direct access to SEPA, with no sponsor bank in between. A connected institution issues its own IBANs and does not have to route its payments through a competitor to reach the rail. That infrastructure decision explains why Lithuania became the regulatory home of a large share of Europe’s fintechs.
The service covers SEPA credit transfers, instant credit transfers, TARGET, and Swift, with SEPA Request-to-Pay added in the second half of 2025. Participation is open to any PSP authorized in the EEA, not just Lithuanian providers. A French or German fintech can therefore connect without relocating. Most of these firms still seek their license in Lithuania, because the regulator that runs the rail is also the one that grants the license.
| Route | What it requires | What it provides | Its limits |
|---|---|---|---|
| Indirect participation through a sponsor bank | A commercial contract, bank due diligence, often a security deposit | An IBAN and rail access without a heavy license | Dependence on a third party that may be a competitor and can terminate |
| Direct participation through CENTROlink | An EMI or PI license in the EEA, a technical connection, scheme membership | Own IBANs, direct access to SCT, SCT Inst, TARGET, and Swift | Operational and prudential requirements closely monitored by Lietuvos bankas |
| Banking license | Regulatory capital, governance, ECB or national supervision depending on size | Deposit taking, lending, full infrastructure access | Cost and lead time far beyond an EMI license |
Revolut’s path in Lithuania combines a banking license with an e-money license. In December 2018, the European Central Bank granted a specialized bank license to Revolut Technologies UAB on a proposal from Lietuvos bankas. The same month, the Lithuanian central bank issued an e-money institution license to Revolut Payments UAB. Banking operations began in 2020. A pan-European bank was thus built on a rail run by a central bank.
- Prepare a documented safeguarding plan: where customer funds are held is a recurring supervisory checkpoint.
- Don’t depend on a single connection: CENTROlink is a single point of failure, and a suspended participation halts the business.
- Plan for DORA from the license application onward, including the ICT third-party register and resilience testing.
- Know the difference between an EMI license and a banking license: an EMI license allows neither deposit taking nor on-balance-sheet lending.
Cards, cash, and habits: four curves, not one
Cash use varies widely across these four markets. Finland and Estonia are among the most cashless markets in the euro area, with below-average cash shares at the point of sale. Lithuania deviates from the average in the other direction, and Latvia’s latest survey shows a drop in cashless payments. The four countries therefore do not form a uniform block when it comes to designing an acceptance plan.
| Country | Measure | Result | Source and date |
|---|---|---|---|
| Finland | Share of payment instruments at the point of sale, by number | 27% cash, 57% cards, more than 10% mobile apps | ECB, SPACE 2024 |
| Estonia | Share of payment instruments at the point of sale, by number | 57% card or connected device, 39% cash; 70% of person-to-person payments made digitally | Eesti Pank, January 14, 2025 |
| Latvia | Ratio of cashless to cash payments | 74% vs. 26% in August 2025, after 78% / 22% in February 2025 and 58% / 42% in February 2017 | Latvijas Banka, Payment Radar, survey by SIA Latvijas Fakti |
| Lithuania | Cash share at the point of sale, by number | 68% in 2019, down from 75% in 2016 | Lietuvos bankas, payment habits survey |
| Lithuania | Digital channel use by account holders | 94% used online banking, 69% a mobile payment app | Lietuvos bankas, 2022 survey |
The euro-area average is the benchmark: 52% cash and 39% cards at the point of sale, by number (ECB, SPACE 2024). Finland and Estonia are far more cashless than this average, and Lithuania far less so on the latest available measure. These indicators are not comparable. Latvijas Banka publishes a ratio of cashless to cash payments, Lietuvos bankas a point-of-sale share, and the ECB a share by instrument. Adding the three series together produces a number that matches no existing measure.
Cash use and attachment to cash availability are two different measures. In Estonia, 89% of residents say they are satisfied with their access to cash, against a euro-area average of 87%, and 44% keep cash at home, against 35% (Eesti Pank, January 14, 2025). Both shares exceed the euro-area average in a country where 57% of in-person payments are made by card or connected device. What people want is cash that is available when needed, regardless of how often they use it.
- Contactless is universal: 81% of Lithuanian cardholders used it at the point of sale (Lietuvos bankas, 2022 survey).
- The IFR interchange caps apply in all four countries: under the EU Interchange Fee Regulation, 0.2% for debit and 0.3% for credit on EEA consumer cards.
- There is no domestic routing to arbitrage: the cost levers are scheme fees and the acquirer’s margin.
- Instant credit transfers are the card’s real competitor in the region, not an international wallet.
Operating in the region: whom to contract with, what breaks
Banking in the three Baltic countries is concentrated and dominated by Nordic groups. Swedbank and SEB have been present since the privatizations of the 1990s and 2000s. Luminor, formed in 2017 by merging the Baltic operations of Nordea and DNB, describes itself as the region’s third-largest financial services provider. Blackstone took a €1 billion majority stake in it in 2019. On July 20, 2026, OTP Bank signed an agreement to acquire all of its shares from the Blackstone-led consortium and DNB, subject to regulatory approval.
| Channel | Estonia | Latvia | Lithuania | Finland |
|---|---|---|---|---|
| E-commerce: expected local method | Bank button and payment initiation | Bank button and card | Payment initiation and card | Bank button (verkkopankkimaksu) |
| Payer authentication | Smart-ID, Mobile-ID | Smart-ID, eParaksts | Smart-ID, ID card | Finnish Trust Network via a broker |
| Instant credit transfer | TIPS or RT1, depending on the bank | EKS, phone number alias via Instant Links | CENTROlink | RT1 |
| In-store mobile payment | Tokenized cards in Apple Pay and Google Pay | Tokenized cards | Tokenized cards | MobilePay, with Siirto coming to the point of sale |
- Estonian e-residency is not a shortcut to a bank account. More than 135,000 e-residents from 185 countries, 5,556 companies formed in 2025, and €125 million in public revenue that year (e-Residency, 2026): incorporating is easy, but opening an account still depends on each bank’s compliance checks.
- Documentation that mentions TUPAS has been obsolete since September 30, 2019: reject any Finnish integration built on it.
- Never assume a domestic rail: ask each partner bank for its actual CSM and cut-off times, country by country.
- Verification of Payee has been live in all four countries since October 9, 2025: bulk credit transfer files with approximate payee names now trigger a flood of alerts.
- A Baltic multi-country setup is not a uniform one: three languages, three supervisors, national clearing in Latvia (EKS) and Lithuania (CENTROlink) but none in Estonia, and one shared identity provider (Smart-ID).