Brazilian Fintechs Between PSD2 and PSD3: Why Lithuania Became the Default Entry Point and What Comes Next
The European Union reached a political agreement on 27 November 2025 regarding the Third Payment Services Directive (PSD3) and the new Payment Services Regulation (PSR), which will replace the PSD2/EMD2 framework that has governed European payment services since 2015 (Council of the European Union, 2025). The final compromise texts were published on 23 April 2026, while formal publication in the Official Journal of the European Union remains subject to final approval by the European Parliament and the Council. Full implementation is expected between the second half of 2027 and the third quarter of 2028. For Brazilian fintechs considering expansion into Europe, the regulatory window between these two milestones presents a strategic decision with a limited lifespan: obtain a license now under the PSD2/EMD2 regime—and benefit from grandfathering provisions—or wait for the new unified framework. Within that window, the choice of licensing jurisdiction has become a critical strategic consideration.
by Ana Queiroga