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Lithuania is set to lay the legal groundwork to protect its payments infrastructure in the event of war within its borders.
Under draft amendments to Lithuania’s Law on Payments published by the Seimas on June 25, 2025, the Bank of Lithuania will implement an offline card payment system allowing consumers to make payments without an internet connection, even if their account has insufficient funds or is subject to legal restrictions.
The offline payment mode, which would only be activated during general or partial mobilisation, is intended to enable citizens to access essential goods despite communication disruptions.
However, only payment service providers (PSPs) with a mobilisation order contract would be required to provide this functionality. It is expected that the Bank of Lithuania would determine further operational conditions by means of an official resolution.
Under the proposed amendment, if offline transactions exceed account balances or breach restrictions outside an official mobilisation period, the payment recipient, that is the merchant, enabling such transactions will bear liability for it.
The draft amendments, which were approved by Seimas members and will be sent to the Principal Committee for approval, aim to ensure that during times of unrest, people can still access money.
Payments preparedness
The move to step up payments preparedness to withstand a possible wartime scenario echoes sentiment in other European countries that border Russia, with concerns being voiced across multiple industries.
As covered by Vixio, in April 2025, Lithuania published its payments strategy, which emphasised operational resilience and cybersecurity.
In the strategy, Gediminas Šimkus, chair of the board of the Bank of Lithuania, described payments as the “bloodstream” of the country’s economic and financial system.
Similarly, in March, Sweden’s Riksbank published its latest Payments Report, in which it warned that urgent measures were needed to ensure people can still pay for essential goods during crises.
It said that the resilience of Sweden’s payment system was under pressure due to global instability.
In the report, the Riksbank highlighted the need for offline card payments and continued access to cash as critical safeguards in times of increasing uncertainty, arguing that with geopolitical tensions rising, Sweden’s payments infrastructure must be strengthened to handle potential disruptions.
At the same time as it launched its payments strategy, the Bank of Lithuania also disclosed plans to develop and test an emergency payment infrastructure, regulate offline card payments for use during network disruptions and encourage households to use multiple PSPs to reduce reliance on a single system.
As countries and central banks act to prepare payment systems for national emergencies, there are also increasing demands to protect cash payments.
Concerns about operational resilience in societies that have completely moved over to digitised payments systems have been heightened by a series of outages at British retail banks.
These outages highlighted the costs as well as the scale of disruption that can be caused in payments systems if digital technology breaks down either by accident or due to malicious activity.
New York recently passed legislation prohibiting retailers from refusing cash as a payment method, one of a number of jurisdictions that have passed cash mandates in the US since 2019.
