Bank mergers no longer interrupt cash-access provider duties

Credit institutions that grow through mergers or take over another bank's business now stay inside Latvia's cash-access regime without a gap.Likumi Under Latvijas Bankas noteikumi Nr. 428, adopted on 9 November 2026, a bank that emerges from a merger with a listed cash-disbursement provider is itself treated as a provider from the moment the merger takes effectVestnesis, and must meet the cash-disbursement and in-person financial-service duties from that dateVestnesis.

Provider status turns on three cumulative tests in Kredītiestāžu likuma 73.1 panta pirmā daļaLikumi: the bank serves payment accounts of European Union resident consumers in LatviaLikumi, and at the previous 31 December it held at least five per cent of client payment accountsLikumi and at least five per cent of resident household deposits across Latvian-registered credit institutions, Latvian branches of foreign credit institutions and Latvian branches of credit institutions registered in other member statesLikumi.

Latvijas Banka maintains the provider list, publishes it each year by 1 February and informs each credit institution of its inclusion or removal. New point 4.1 adds an off-cycle update: where a reorganisation, a transfer of a credit institution's undertaking, or any other event transferring a credit institution's obligations occurs after 31 December of the previous year and affects whether a credit institution meets the statutory criteriaLikumi, Latvijas Banka may revise the list outside the annual cycleLikumi.

New point 4.2 covers reorganisation by merger (apvienošana). Where a listed provider is absorbed and the acquiring company is a credit institution — one registered in Latvia, a foreign credit institution, or a credit institution registered in another member state with a branch in LatviaVestnesis — that after the reorganisation continues to offer payment-account services to European Union resident consumers in LatviaLikumi, the acquirer counts as a provider from the date the reorganisation takes effectVestnesis. From that date it must comply with the enactments governing the cash-disbursement service and in-person provision of financial services.

New point 4.3 closes the year-end timing gap. Where a merger by acquisition closes between 1 January and 1 February of the current calendar yearLikumi, the acquirer's provider status is judged on the combined position — its own plus every absorbed credit institution's client payment accounts and resident household depositsLikumi — measured against the five-per-cent tests at 31 December of the previous calendar yearVestnesis. The same combined measurement applies where a transfer of a credit institution's undertaking closes in that window: the acquirer's own accounts and deposits are added to those taken over from the transferor.

The amendments also retire the self-contained definition of "aktīvais klients" — previously a resident natural person with at least two non-fee payments from accounts held at the provider in the preceding six months — and provide instead that the term is used in the sense given by Latvijas Banka's rules on preparing and submitting supervisory reports. Separately, the channel for filing ATM-network information with Latvijas Banka is widened: besides the heightened-security system used under the electronic information-exchange rules, a provider may now file in any other manner agreed with Latvijas Banka in writing.

Legal basis: Latvijas Bankas noteikumi Nr. 428 of 9 November 2026 amending Latvijas Bankas 2024. gada 28. oktobra noteikumus Nr. 330 "Skaidrās naudas izmaksas pakalpojuma pārvaldības noteikumi", issued under Kredītiestāžu likuma 73.1 panta piektā daļa and elaborating that article's pirmā daļa criteria.