ESMA Didn’t Say How Lithuania’s Cross-Border Clients Jumped 5,000x. Is It Because of Revolut?

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Lithuania's cross-border retail client base grew from roughly 500 in 2022 to more than 2.5 million just two years later, making it one of Europe's largest cross-border retail investment markets by client numbers. Finance Magnates concluded that the jump could only be attributed to Revolut.According to the Bank of Lithuania, the country had just 16 locally licensed investment firms at the end of 2025. Yet ESMA's data indicate that only one of them accounted for almost the country's entire cross-border retail client base. While the regulator does not identify the firm, its description can be matched almost line-by-line to Lithuania-registered Revolut Securities Europe UAB's filings, making it the closest documented match.From 500 Clients to Europe's Second-Largest Hub ESMA's July 2026 follow-up report to its peer review states that Lithuania was the second-largest jurisdiction in terms of cross-border retail clients and complaints. Germany is at the top with over 3.5 million retail clients using outbound cross-border investment services, while Cyprus stands at the third with more than 2 million retail clients.In Lithuania, the increase in retail clients served abroad is notable, as it is attributable to a single company. Complaints tied to the country's cross-border business rose from zero to 1,562 over the same period, while the number of retail clients served from Lithuania climbed from roughly 500 to more than 2.5 million. ESMA's separate report on the 2024 cross-border provision of investment services adds further detail. Firms based in Cyprus, Lithuania, Germany and Ireland together served 86% of all EU/EEA retail clients receiving cross-border services. Lithuania alone accounted for 24%. The same report identifies the five largest cross-border providers in the EU/EEA by client numbers as firms based in Lithuania, Cyprus (two firms), Germany and Ireland, each serving between 700,000 and 2.6 million retail clients.The Company Behind the Migration Revolut Securities Europe UAB was incorporated in Vilnius in June 2021 and received a Category B investment firm licence from the Bank of Lithuania later that year. It launched investment services in March 2023 and forms part of Revolut Holdings Europe UAB, which consolidates the group's regulated European entities. Under its MiFID II licence, the Lithuanian entity provides execution, portfolio management, investment advice, custody and related investment services. It operates in Lithuania and passports its services across all other EEA jurisdictions. During 2023, the company migrated in more than 1.1 million EEA-based customers from its UK affiliate, Revolut Trading Limited. By the end of that year, it reported serving more than 2.5 million customers, administering more than €3 billion in assets, including €2.96 billion in client securities held on the platform.That figure rose to €9.1 billion by the end of 2024, according to the company's most recent annual report. The chronology also aligns closely: Revolut Securities Europe launched in March 2023 and reported more than 2.5 million customers by year-end, shortly before Lithuania appeared in ESMA's 2024 data with a comparable cross-border client total.Read more: Digital Bank Revolut Reports 95% Revenue Jump, Record £344M ProfitA Migration, Not Necessarily New Demand The migration means that part of the Lithuanian firm's reported scale reflected an internal transfer within the Revolut group, rather than being generated solely through new customer growth at the Lithuanian entity. That distinction matters when interpreting ESMA's figures. The regulator's client totals do not represent unique individuals: one person may hold accounts with several firms or receive services from multiple providers. The data measure reported cross-border client relationships, not a distinct count of European investors.Finance Magnates reached out to Revolut to obtain details of their client migration to Lithuania, but had not received a response as of press time.This article was written by Tanya Chepkova at www.financemagnates.com.