Under Article 16(2) of the Law, the technical condition of a vehicle in traffic must be ensured by its owner or user and by the driver; therefore, even when a Level 2 automated driving system is used, responsibility remains with the human driver.
Although the recognition in Lithuania, as of May 2026, of the type approval for “Tesla FSD” opened the door to Level 2 automated driving, legal responsibility for control of the vehicle remains firmly with the driver. The key point is that Lithuanian legal regulation of automated driving systems does not create new subjects of liability; the general provisions of the Law on Road Traffic Safety (the Law) apply. The more precise question that will have to be addressed when using such a system is whether its use satisfies the requirements that only a technically roadworthy vehicle meeting the prescribed technical requirements may participate in traffic (Article 16(1) of the Law), and whether the driver performs the supervisory duties assigned to him or her at all times (Articles 12 and 8). The operating conditions of such systems are also determined by reference to EU legal acts, because Article 5 includes both international treaties and European Union legal acts among the sources governing traffic safety; it is against that legal framework that the recognition of the temporary type approval issued by the Netherlands is assessed.
The structure of the Law permits the lawful use of Level 2 systems only where two groups of conditions are satisfied: technical and behavioural. Under Article 16, the technical condition of a vehicle in traffic must be ensured by its owner or user and by the driver (Article 16(2)), while the installation of devices that interfere with speed measurement or record such measurement is prohibited (Article 16(4)); this also limits any software modifications that could disable speed-control mechanisms. The driver’s duties are set out in Article 12: a road user must know the Law and be familiar with the Road Traffic Rules (Article 12(2)), and must take all precautionary measures and avoid endangering others (Article 12(5)). A similar duty to take all necessary measures to avoid harmful consequences is repeated in Article 8(3). This means that even while an active driving system is operating, the driver must continuously monitor traffic and take over control where necessary, because the Law does not recognise “reliance on the system” as a substitute for precautionary conduct. State competence is set out in Article 6: traffic safety is ensured, among other things, by adopting regulatory legal acts (Article 6(1)(3)) and by addressing the implementation of scientific and technological innovations in the transport sector (Article 6(1)(5)). The latter provision is the direct legal basis for the actions of the Ministry of Transport and Communications and the Lithuanian Transport Safety Administration in relation to recognition of type approval. The statement by the Vice-Minister of Transport and Communications that the effectiveness of technologies depends on infrastructure, control measures and driver behaviour is consistent with Article 6(1)(8), concerning state supervision of compliance with legal acts; this confirms that, even when innovations are recognised, enforcement control remains in the hands of the State. The sources provided contain no case law on automated driving systems, so issues concerning the allocation of liability in specific cases must for the time being be resolved by applying the general provisions of the Law without guidance from judicial practice.
For drivers, the practical conclusion is straightforward: if a traffic accident occurs while using “FSD” or an analogous Level 2 system, liability will be assessed under Article 12(5) and Article 8(3)(4), namely whether the driver, rather than the system, took all necessary measures in the event of danger. For vehicle owners or users, it is important that Article 16(2) assigns responsibility for ensuring the technical condition of the vehicle specifically to them and to the driver; accordingly, the software status of the system and its compliance with the conditions of type approval will remain within their area of responsibility. For manufacturers and importers, including BMW, Ford, Hyundai, Mercedes-Benz and others, the recognised Dutch approval creates a pathway, but authorisation of each other system will still depend on the regulatory procedures under Article 6(1)(3) and (5), that is, on decisions of the Ministry of Transport and Communications and the institution authorised by it. The Government’s action point in this area is already visible: by Resolution No. 538 of 8 July 2026, the Government approved in principle draft amendment No. XVP-667(2) to Article 11 of the Law, so the next procedure to monitor is the consideration of that draft in the Seimas and the course of its adoption or further refinement.
Under Article 15(1) of the Law on International Sanctions, a legal person is subject to a fine of 50 to 100 per cent of the value of the subject matter of the breach for violating sanctions, and, where that value exceeds EUR 100,000, up to 5 per cent of total annual income.
Article 123-1(1) of the Criminal Code provides for a fine or imprisonment for up to five years for a sanctions breach that causes substantial harm, while paragraph 3 permits a legal person to be held liable as well.
The licence issued by the U.S. Department of the Treasury, allowing Russian diesel to reach global markets until April 2027, relaxes restrictions within the U.S. legal framework, but would not affect the sanctions regime applied by the European Union and Lithuania; the sources contain no indication that the prohibitions have been lifted at EU level. For Lithuanian entities, this means that any participation in the supply, transportation or financing chain for Russian diesel would continue to be assessed as a breach of international sanctions, notwithstanding the fact that the U.S. market accepts this fuel. The precise legal assessment turns on two sets of rules: Articles 13 and 13-1 of the Law on International Sanctions of the Republic of Lithuania define what constitutes a breach, including the import, export, transit and transport of goods and the provision of related services, while the level of liability is determined by Article 15 of the same law, Article 515 of the Code of Administrative Offences, and Article 123-1 of the Criminal Code where the breach causes substantial harm.
Under Article 2(5) of the Law on International Sanctions, international sanctions are the body of restrictions established by EU legal acts and UN decisions, applicable in Lithuania either directly or through the procedure laid down by law; a unilateral U.S. decision does not alter that definition. Article 13-1(4) prohibits the import, export, sale, purchase, transfer, transit or carriage of goods, as well as the provision of brokering, technical assistance and other related services, where such conduct is prohibited in the implementation of sanctions; paragraph 5 prohibits the provision of financial services or the conduct of financial activities. Article 7(1) of the Law declares transactions whose performance is contrary to sanctions to be null and void, while paragraph 3 requires transactions concluded before the imposition of sanctions to be terminated or suspended without delay. The scope of liability depends on the subject and recurrence:
For Lithuanian and EU logistics, port, trading and financial companies, the practical conclusion is that the U.S. licence does not provide a legal basis to participate in the Russian diesel supply chain: the transaction would be null and void under Article 7, and could expose the entity to a fine of up to 5 per cent of annual income, confiscation of assets, an administrative fine for the manager, or criminal proceedings carrying imprisonment for up to five years. Given the large volumes involved — the report refers to 300,000 tonnes now, a further 500,000 tonnes in November and 1 million tonnes later — funds associated with any such quantity would likely exceed the EUR 100,000 threshold, which under Article 15(1)(3) triggers the highest fine bracket. The political context, including the U.S. midterm elections and new U.S. sanctions under the act named after Graham, indicates that sanctions regimes may diverge across jurisdictions, requiring companies to assess each jurisdiction’s regime separately. Monitoring point: it is worth tracking whether EU institutions respond to the U.S. licence, valid until April 2027, with any decision of their own on sanctions alignment; the sources provided do not identify any such decision or timeframe.
Under Article 13(10) of the Law on the Approval of the 2026-2028 Budget, the Ministry of Justice may use Norwegian Financial Mechanism funds only after the Minister of Finance determines the allocation of management and control system functions and the national coordination institution confirms in writing that the expenditure is justified.
Prison modernisation here raises not a criminal-law issue but a budget-law issue: the use of EUR 36 million from the Norwegian Financial Mechanism depends on whether the conditions set out in Article 13(10) of the Law of the Republic of Lithuania on the Approval of the 2026-2028 Budget have been met before the agreement is signed. Under that provision, the Ministry of Justice has no right to use these funds until the Minister of Finance, having signed the Memorandum of Understanding on the Implementation of the 2021-2028 Norwegian Financial Mechanism, determines the allocation of management and control system functions, and the national coordination institution confirms in writing that the expenditure is justified. The more precise question is whether the agreement for the Justice programme planned for December can be signed on time if these procedural preconditions have not yet been completed. Article 27(1) of the Law on the Budget Structure is also applicable; it provides that international financial assistance funds are to be used only for assistance programmes and projects, while the flexibility for carrying forward unused appropriations is regulated by Article 28(1)(2).
The Ministry of Justice is the manager of appropriations, while, under Article 4 of the Law on the Penal Enforcement System, penal enforcement activities are carried out by the Lithuanian Prison Service and the Lithuanian Probation Service; institutions are established and reorganised by the Government on the proposal of the Minister of Justice. The practical obligations arising from the sources are as follows:
Historical practice confirms the model: under the 2009-2014 Norwegian Financial Mechanism programme LT14, “Correctional Services, Including Non-Custodial Sanctions,” EUR 9,058,824 was allocated, and the programme objective, to reduce overcrowding and improve the conditions of vulnerable groups of convicted persons, was implemented through agreements signed in 2014, including the project “Application of Electronic Monitoring Measures to Conditionally Released Convicted Persons” (2014 Government Activity Report). This shows that the deployment of electronic monitoring measures, also envisaged in the current news item, is a continuation, and that administration is carried out through the CPMA together with the Ministry of Justice.
If the agreement is signed in December without written confirmation from the national coordination institution that the expenditure is justified, the expenditure becomes legally justified only from the moment of confirmation, creating a risk that it will not qualify as eligible expenditure. Because of Article 28(1)(2), unused assistance funds may be carried forward between budget years without the 30% restriction, meaning that the 2030-2031 deadline is procedurally achievable even across several budget cycles. Progress on the construction component depends on the permits already obtained for the reconstruction of Vilnius Prison; the news item does not indicate such readiness for the Kaunas Prison projects.
Under Article 250-3(1) of the Criminal Code, a threat to blow up a synagogue, where there are sufficient grounds to believe that the threat may be carried out, is punishable by imprisonment for up to five years, and a legal person may also be held liable for this offence.
Unlike Article 145(3) of the Criminal Code, under which liability arises only upon receipt of a victim’s complaint or a prosecutor’s request, a pre-trial investigation under Article 250-3 of the Criminal Code proceeds on the initiative of the State without a private complaint.
Threats to blow up a synagogue and kill Jews in Lithuania should be assessed not as hate speech, but as potential criminal offences under the Criminal Code of the Republic of Lithuania: the threat to cause an explosion falls under Article 250-3(1) of the Criminal Code (threatening to commit a terrorist offence, punishable by imprisonment for up to five years, with legal persons also subject to liability), while the threat to kill Jews falls under Article 145(1) of the Criminal Code (imprisonment for up to two years) or, in the case of systematic intimidation, Article 145(2) of the Criminal Code (terrorisation, punishable by up to four years). The precise legal issue to be determined by pre-trial investigation officers is whether there were “sufficient grounds to believe that the threat could be carried out” (Article 250-3(1)) and whether the threat was addressed to specific individuals or to the community as a group of persons on grounds of religion. In addition, antisemitic comments on social media may constitute an offence under Article 170(2) of the Criminal Code: public contempt or incitement to hatred on grounds of religion, punishable by imprisonment for up to two years. The concern expressed by the Chair of the Lithuanian Jewish Community regarding “voluntary” protection is legally well-founded: under Article 5(1)(1) and (2) of the Law on Police, the protection of human rights and the maintenance of public security are tasks of the police, not of the community.
The competence of law enforcement authorities in this situation:
Realistic scenarios:
The documents concern the amendment of Article 145 of the Criminal Code, criminalising public threats to kill, incitement to kill, or incitement to violence through the mass media. The sponsors argued that the existing regulatory framework contains a gap: a public call to kill or seriously injure a person is not punishable, and the aim is therefore to close that gap, ensure the inevitability of liability, and protect society from extremely dangerous acts. The conclusion of the Legal Department raises issues concerning the principle of expediency, namely whether the intended objectives could be achieved by other means, and assesses the compatibility of the new offence with the Constitution and with the principles of legislative drafting. However, the documents contain no information about the specific sponsors or any connection with the subject of antisemitism, and it is therefore not possible to answer who initiated the regulation in relation to antisemitism.
Under Article 18(4) of the Law on Roads, losses incurred by road users as a result of traffic restrictions applied during repair works are not compensated.
Failure to comply with temporary road signs in the works area carries a fine of EUR 30 to 90 under Article 417(1) of the Code of Administrative Offences.
The repair of Garažų Street in Kaunas is a municipal road capital repair works contract, the performance of which allows the road owner temporarily to restrict traffic and alter public transport routes without any obligation to compensate road users for losses arising as a result. Drivers in the works area are subject to temporary traffic regulation and a fine for failure to comply with road signs under Article 417(1) of the Code of Administrative Offences of the Republic of Lithuania (EUR 30–90), while the contractor UAB Autokausta and the municipality are subject to the contractual and traffic-restriction regime established by the Law on Public Procurement and the Law on Roads. The assessment is based on Articles 18 (traffic restrictions), 2 (the concept of a street as a road) and 16 (financing of road repairs) of the Law on Roads, and Articles 101 and 107 of the Law on Public Procurement (disputes concerning procurement and contract performance).
Under Article 2(3) and 2(5) of the Law on Roads, Garažų Street is a road, that is, an engineering structure whose elements include not only the carriageway, but also bus stop bays, pedestrian and bicycle paths, intersections and technical traffic-control measures. Accordingly, the project works involving stormwater drainage networks, bicycle paths, the public transport interchange and the railway crossing legally constitute parts of the repair of a single road object, rather than separate works. Article 18(1) of the Law on Roads grants the road owner the right, in accordance with the procedure established by the Government, temporarily to restrict or suspend traffic during road repair works; it is precisely on this basis that, from 8 October, six routes are being changed and the “Garažų g. A” stop is no longer operating. Article 18(4) expressly provides that losses incurred by road users as a result of such restrictions are not compensated. Article 16 of the Law on Roads provides that repairs of a road owned by a municipality are financed in accordance with the procedure established by special laws and that, where private persons cover part of the costs, priority may be given to such works.
For drivers in the coming months, the practical risk is administrative: ignoring temporary signs in the works area results in a fine of EUR 30 to 90 under Article 417(1) of the Code of Administrative Offences, and a road sign that differs from road markings takes precedence. Passengers using routes 19, 20, 26, 28, 40 and 57 cannot claim compensation for being diverted via a detour: Article 18(4) of the Law on Roads excludes compensation for such losses. For the contractor, the two-year contractual term means that delay may give rise to the issue of contractual penalties. If any unsuccessful procurement participant suspected procedural infringements, its remedies would be a complaint and an action before the regional court under Article 101 of the Law on Public Procurement, while the limits of damages are determined by Article 107. Monitoring point: the completion date announced by the contractor is the end of 2027, while the maximum contractual term falls in 2028.