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Definition of a complaint

Lithuania has separate definitions of complaint for consumer business and non-consumer business. A “consumer dispute” is defined as “a disagreement between a consumer and a seller or service provider regarding the fact and/or law issues arising out of the consumer contract”.

The complaint must be submitted in writing in order to qualify as a complaint.

A non-consumer complaint is defined as “a complainant’s written appeal submitted to a financial market participant stating a violation of the rights or legitimate interests of a person related to the services provided by the financial market participant or contracts made, and requesting to satisfy the complainant’s complaint”.

The complaint must be submitted in writing in order to qualify as a complaint

Definition of a complainant

A consumer is defined as

“a natural person:

1) Concluding the financial services contract with the financial market participant, except for professional clients, to meet personal, family or household needs;

2) The insured, beneficiary, aggrieved third person or other person, in case the financial services are aimed at their personal, family or household needs, while the financial market participant at the moment of the conclusion for the contract was aware or had to be aware about the purpose of financial services;

3) Whose rights and obligations in respect of the financial market participant are related to the financial services contract, even if he is not the financial services contractual party, provided that in the relations with the financial market participant such a person has no aims related to business or professional activities.”

The relevant definition for a non-consumer complaint is “a person who has filed a complaint concerning the services provided by a financial market participant and/or contracts made with a financial market participant, i.e., a current or potential policyholder, insured person, beneficiary, aggrieved party, client of another financial market participant, potential client or his representative”. Lloyd’s understands that this definition includes both individuals and corporate entities.

Application of Lloyd’s procedure and local complaint regulations

All insurance policies written on a freedom of services or establishment basis. Please note that Lloyd’s is required to report data regarding both consumer and non-consumer complaints. When submitting reports to Lloyd’s please indicate if any of the complaints are non-consumer.


Consumer complaints
A written response must be given to the complainant within 14 days of receiving the complaint. The response must be detailed and well-reasoned and documents that support the insurer’s decision must be attached.

Non-consumer complaints
When the complaint is received the insurer must inform the complainant of its complaint handling procedure. A written response must be given within 30 days of receipt of the complaint.

Additional information on what must be included in responses to complaints is available on Crystal.

EDR scheme and eligibility

Bank of Lithuania
Supervision Service
Žirmunu g. 151
LT-09128 Vilnius

Tel: +370 5 268 0029

Please note that the Bank of Lithuania will only deal with complaints if:

  • The underlying policy is subject to Lithuanian law.
  • The complainant is a consumer.
  • The complainant has referred its complaint within one year of the date when the complaint was originally submitted to the insurer.

There is therefore no referral right to the Bank of Lithuania for non-consumer complaints

Local Regulatory Reporting Requirements

Annual report to the Bank of Lithuania in respect of establishment business only. This is submitted on behalf of Lloyd’s underwriters by Lloyd’s General Representative for Lithuania.

Lloyd’s Complaint Notice

The new complaints notice for Lithuania LSW1849 has been produced. It is available on the Lloyd’s Wordings Repository and is referenced in the Pre-contractual notification and Insurance documents sections of Crystal