Digital Investment Platforms Capture 31% of Europe’s Cross-Border Retail Clients

Europe’s cross-border investment market is increasingly being shaped by a small number of digital-first firms capable of reaching customers across national borders without building a separate local operation in every country. The latest figures from the European Securities and Markets Authority (ESMA) show just how concentrated that market has become. In 2025, investment firms based in Lithuania served 4.9 million cross-border retail clients, representing 31% of the European total. Cyprus, a long-established centre for investment services, served 4.2 million.

The striking detail is that Lithuania’s result came from only two reporting investment firms. Their combined customer base exceeded that of 78 firms from Cyprus, illustrating how digital distribution, regulatory access and scalable execution services can reshape competition in financial services.

This is not simply a story about one country overtaking another. It is a story about the economics of reaching millions of customers across a fragmented market—and about the growing gap between platforms that can scale efficiently and firms still competing through more traditional operating models.

Lithuania’s Rapid Rise Changes Europe’s Competitive Map

According to ESMA’s report, investment firms based in Lithuania served 4.9 million cross-border retail clients in 2025, accounting for 31% of the 15.5 million clients reported across Europe.

Cyprus ranked second, with 4.2 million clients, or 27% of the total. The figures establish Lithuania as the largest home jurisdiction by reported cross-border retail client numbers for the year.

The speed of that change is notable. Lithuania-based investment firms reported only around 500 cross-border clients in 2022. By 2025, the number had reached 4.9 million.

The reporting landscape also changed. In 2024, ESMA counted one Lithuania-based firm with 2.6 million cross-border clients. In 2025, the number of reporting firms increased to two, and the combined client base rose by nearly 90%. That equates to approximately 2.4 million clients per firm on average, the highest average among the jurisdictions covered by the report.

These figures reveal a market where scale can emerge quickly when a platform combines broad geographic reach with a product that can be distributed across borders. But the increase should not be attributed entirely to organic growth at an existing company. The addition of a second reporting firm contributed to the change, and ESMA's published figures do not identify how the total was divided between the two providers.

Two Firms, Millions of Customers and an Unconfirmed Identity

ESMA did not name the two Lithuanian investment firms. Records from the Bank of Lithuania suggest that the established provider is likely Revolut Securities Europe, while Robinhood Europe appears to be the most plausible second firm.

Robinhood's annual report confirms that it received a Lithuanian MiFID licence in April 2025 and completed passporting before launching stock-token derivatives and crypto perpetual futures across parts of Europe on June 30.

However, Robinhood does not disclose a corresponding European client count. Its involvement therefore cannot be used to establish how many of the 4.9 million reported clients belonged to it, or to confirm the allocation between the two firms.

The distinction matters because regulatory records and product-launch announcements can help identify possible market participants, but they do not substitute for disclosed customer data. The source supports a strong inference about the companies involved, not a definitive identification of both firms or their respective market shares.

ESMA separately reported that one Lithuanian firm served retail clients in all 29 other EU and European Economic Area countries. The report did not establish whether that finding referred to the same company as the Lithuanian firm ranked among Europe's five largest cross-border providers by client numbers.

Even with these limitations, the broader result is clear. Lithuania has become a major base for investment platforms distributing services across Europe, and the number of reporting firms alone does not capture the scale of their reach.

Digital Distribution Is Concentrating the Market

The Lithuanian figures sit within a wider pattern of concentration across Europe's cross-border investment industry.

The five largest cross-border investment firms served 70% of reported clients in 2025. The top 10 accounted for 82%, while the top 20 reached 91%. The remaining 329 firms collectively served less than 4% of the reported client base.

That distribution is difficult to reconcile with a market in which customer reach is evenly spread among providers. Instead, a relatively small group of firms accounts for the overwhelming majority of cross-border retail relationships.

Digital platforms have an important role in making this scale possible. A provider can use a centralised technology platform and a regulatory framework that permits cross-border services to reach customers in multiple countries without replicating its entire operation in each market.

This does not mean every operational or legal requirement disappears when a firm expands across borders. Nor does it mean all investment services can be delivered in the same way. The advantage is that a scalable platform can distribute certain services across a much wider customer base than a business dependent on separate, locally built operations.

For smaller investment firms, the competitive challenge is substantial. Competing with a platform that already serves millions of customers can be difficult when customer acquisition, technology development and operational processes must be funded from a much smaller base.

Yet concentration does not automatically mean that smaller firms have no viable role. It does mean that they need a clear reason for customers to choose them, rather than assuming that geographic presence alone creates a competitive advantage.

Execution Services Dominate the Customer Relationship

The type of service offered helps explain the market's structure.

ESMA found that execution services were provided to 87% of active cross-border clients. Portfolio management accounted for 11%, while investment advice represented less than 1%. None of the five largest firms offered investment advice.

Execution services allow customers to place investment orders through a provider. The service can be delivered through a digital interface, with much of the customer interaction taking place through the platform rather than through individual advisers.

This model is compatible with broad distribution because the same core product and technology can support many customers across multiple jurisdictions. As customer numbers rise, the platform can expand its reach without necessarily increasing every category of operating cost in direct proportion to its client base.

Portfolio management and investment advice involve different service relationships. Their smaller shares in the cross-border figures suggest that the market measured by ESMA is heavily oriented toward execution rather than personalised advice.

That distinction should not be overlooked. The number of clients served is a measure of reach, not a complete measure of the depth or quality of the relationship. A large execution-led platform and an advice-focused business may serve very different customer needs, even when both operate within the investment industry.

The data therefore highlights the strength of execution-led distribution without proving that execution is universally the better model. It is the dominant model within the reported cross-border retail market.

The Business Value Comes From Scale and Reach

A cross-border investment platform's commercial advantage depends partly on its ability to reach customers efficiently. When one technology platform can serve customers in many countries, the company has an opportunity to spread the cost of its core infrastructure across a larger base.

That can support wider distribution and make it easier to introduce additional services to existing customers. However, the ESMA figures do not quantify the profitability of individual providers, their customer acquisition costs or the revenue generated per client. The client numbers demonstrate scale, not the financial performance behind it.

The same caution applies to the comparison between Lithuania and Cyprus. Cyprus remains a significant centre, with 4.2 million cross-border clients across the firms reported. Lithuania's lead does not establish that the entire Cypriot investment industry is losing business, nor does it show that every Lithuanian provider is more efficient than every competitor based elsewhere.

What the figures do establish is that jurisdiction-level totals can be dominated by a small number of exceptionally large providers. Two Lithuanian firms generated a combined client base larger than that of 78 firms from Cyprus. This makes the distribution capabilities of individual platforms central to understanding national market rankings.

For businesses, the implication is that scale and location should not be confused. A jurisdiction can host many regulated providers, while another can achieve a higher cross-border client total through only a handful of firms. The number of firms matters, but the reach of those firms matters more when the metric is customer volume.

Complaints Require Context as the Client Base Expands

The two Lithuanian firms received 2,251 complaints in 2025, an increase of 44% from the previous year. Because their reported client base grew much faster, this represented approximately 46 complaints per 100,000 clients—below the European average of 71.

At first glance, that ratio may appear encouraging. But ESMA cautioned against treating the lower relative figure as evidence of better customer outcomes.

One important limitation is timing. If many clients joined during the second half of 2025, they may not have been customers long enough for complaints to emerge within the reporting period. A rapidly expanding client base can therefore reduce the complaint rate per customer even if the underlying quality of service has not improved.

The report also excludes domestic and branch business, and the same person may be counted by more than one provider. The totals should therefore be understood as measures of reported cross-border activity, not a complete count of unique individuals using every investment service in Europe.

For regulators, firms and customers, the distinction between scale and outcomes is essential. A low complaint rate relative to a fast-growing customer base does not settle questions about product suitability, service quality or investor protection. Those issues require evidence beyond the number of complaints divided by the number of clients.

The Competitive Pressure on Smaller Investment Firms

The concentration figures have practical implications for firms that want to grow across Europe.

A smaller provider cannot necessarily match the distribution reach of a large digital platform by entering more countries or increasing marketing expenditure alone. It needs a sustainable way to acquire customers, provide a service they value and retain them without allowing costs to overwhelm revenue.

For some firms, this may mean focusing on a narrower customer segment or a product offering that differs meaningfully from the execution-led services dominating the market. For others, it may mean improving the customer experience, simplifying onboarding or investing in technology that reduces friction.

The ESMA report does not establish which strategy will work best for any particular firm. But the concentration data makes one point difficult to ignore: being present in the market is not the same as capturing a meaningful share of it.

Smaller businesses should also avoid treating the Lithuanian result as a simple template for expansion. The two firms' customer totals reflect a particular combination of providers, services and cross-border activity. Without detailed company-level disclosures, it is not possible to determine exactly how much of their growth came from existing customers, new market entry, product launches or other factors.

A more useful lesson is to measure the ability to reach and retain customers, not just the number of countries in which a company is authorised to operate.

The Next Reporting Cycle Will Clarify the Growth Story

The 2025 figures establish Lithuania as Europe's leading home jurisdiction for reported cross-border retail investment clients. Its two reporting firms served 4.9 million customers, compared with 4.2 million for Cyprus, while the wider market remained heavily concentrated among a small group of providers.

The data also points to a business model built largely around execution services and broad digital distribution. At the same time, complaint figures show why rapid customer growth needs to be assessed carefully rather than automatically interpreted as improved performance.

Important questions remain unanswered. ESMA's published totals do not reveal the exact customer split between the two Lithuanian firms, and the available information does not establish how much of the increase resulted from the established provider's expansion versus the contribution of the newer entrant.

The next reporting cycle should help clarify whether Lithuania's latest increase represents continued expansion by the established market leader, a meaningful contribution from the new entrant, or both.

For Europe's investment industry, the larger lesson is already visible. Cross-border competition is increasingly shaped by platforms that can combine regulatory access with scalable distribution. A firm's home jurisdiction still matters, but its ability to reach customers across borders can matter far more. The challenge for every competitor is to turn that reach into a durable business without losing sight of the quality of the customer relationship.

Digital Investment Platforms Capture 31% of Europe’s Cross-Border Retail Clients

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