Access to critical financial services
The availability of funds is an important precondition for the resilience of society in a crisis situation and in the event of a threat to the state. The National Security Law defines critical financial services, the continuity of which must be ensured in all circumstances, so that funds can be accessed and settled even in emergency situations. Such services are cash and non-cash payments provided by credit institutions. Taking into account the regulatory framework and the criteria set by Latvijas Banka, these services are provided by four banks in Latvia: Swedbank AS, AS SEB banka, AS Citadele banka, and Luminor Bank AS Latvia Branch (critical financial service providers).
In accordance with Latvijas Banka Regulation No 252 of 9 October 2023 on the Management of Critical Financial Services, providers of critical financial services shall ensure the availability of both non-cash and cash payments in the event of a threat to the state.
For cashless money, this means that citizens and businesses remain able to make basic settlements even in situations where part of the payment infrastructure is unavailable. This includes:
- the execution of credit transfers between credit institutions and the Treasury, even if the STEP2 payment system is not available;
- the possibility to pay with payment cards offline, purchasing basic necessities for an amount up to EUR 200, in cases where the internet or card infrastructure is not available;
- alternative payment filing solutions for legal entities if the online systems used on a daily basis are not functioning (this requirement will enter into force on 1 December 2026).
The availability of cash is ensured through a network of critical ATMs. Latvijas Banka, in cooperation with providers of critical financial services throughout Latvia, including all State cities, has established a network of critical ATMs, comprising at least 100 ATMs. The location map of critical ATMs is available on the website of Latvijas Banka. In order to ensure that cash is available to the widest possible range of citizens, critical financial service providers shall plan the minimum amounts of cash to be provided at critical ATMs in such a way that at least EUR 500 per day can be issued to one of their customers, as well as for one payment card issued by another financial market participant (and not only by the critical financial service provider), irrespective of the number of payment cards issued to that customer or the number of payment accounts opened by the service provider.
Critical financial service providers are also subject to additional requirements for the resilience of cash infrastructure in a crisis situation. Critical ATMs must be available at least 14 hours a day, must have access to cash, and must ensure uninterrupted connection to information systems and a stable electricity supply.
By the end of 2025, key accessibility requirements for critical financial services were introduced as part of the transition period. In the area of non-cash settlements, the possibility to make payments offline was extended by expanding the range of traders with whom such settlements are available. In the area of cash settlement, the development of continuous power supply solutions for the network of critical ATMs continued in cooperation with critical financial service providers.
With the introduction of offline card payments for the purchase of essential goods, Latvia became the first country in the euro area to provide its citizens with such an opportunity. This significantly improved the ability of society to function in crisis situations.
In order to assess the preparedness of critical financial service providers and other involved parties to deal with crisis situations, Latvijas Banka organised an accessibility test of critical financial services in 2025. Within the framework of the test, possible crisis scenarios were played out in cooperation with providers of critical financial services, involved merchants, the Ministry of Finance, the Ministry of Defence, and the Treasury. The lessons learned from the test were used to improve regulation and strengthen coordination mechanisms.
In 2025, Latvijas Banka continued to implement communication activities, informing citizens about critical financial services and the handling of money in crisis situations. The information material "Learn about cash and other financial services in a situation of crisis" was also updated. Representatives of Latvijas Banka also participated in neighbourhood civil protection seminars organised by Riga City Council, providing explanations on the availability of financial services in crisis conditions and recommendations on how to better prepare for such situations in terms of funds.
Latvijas Banka plans to further improve the framework for critical financial services in 2026 by regularly checking the implemented solutions, introducing additional alternative payment solutions for companies, and evaluating other measures to strengthen the operational resilience of the financial system, taking into account the current risks and the improved national framework for the resilience of critical infrastructure.
In 2025, Latvijas Banka actively participated in the Baltic-Nordic cooperation activities aimed at strengthening the operational resilience of the financial sector, taking into account cross-border interdependencies and geopolitical risks. It is planned to continue this work in 2026, as well as to share with other European countries Latvia's experience in providing critical financial services.