EMI licence in LithuaniaOverview
The Bank of Lithuania is the single regulator for banks, payment institutions and EMIs in Lithuania. EMIs are licensed under the Law on Electronic Money and Electronic Money Institutions, which transposes EMD2, and may also provide the payment services set out in the Law on Payments. Licensing follows Bank of Lithuania resolutions on the licensing of EMIs and PIs and on the general authorisation procedure, the latter updated in September 2025. At the end of 2024, 76 EMIs and 43 payment institutions held Lithuanian licences, processing payment transactions worth EUR 152 billion that year.
Two licence classes are available. The standard EMI licence permits e-money issuance and payment services across the EEA through passporting, with initial capital of at least EUR 350,000 and ongoing own funds of at least 2% of average outstanding e-money. The licence for restricted activities is aimed at early-stage firms: it is valid only in Lithuania, carries no own funds requirement, and is capped at EUR 900,000 average monthly outstanding e-money over six months (and EUR 3 million in average monthly payment transactions where payment services are offered). If the cap is exceeded, the firm must apply for a standard licence within 30 days.
One practical advantage of Lithuania is access to CENTROlink, the Bank of Lithuania's payment system, which allows licensed EMIs to reach SEPA payments without depending entirely on a correspondent bank. That access is only as reliable as the institution's compliance, however. In recent years the Bank of Lithuania has prioritised AML, KYC and fraud controls, own funds headroom and customer fund safeguarding; in 2024 alone it carried out 15 targeted inspections, imposed 19 sanctions and issued 91 practice improvement notices, and it has warned institutions operating close to their capital minimum.
Applicants should also plan for change. The EU's PSD3 package will fold EMIs into a single payment institution licence, and existing Lithuanian EMIs will need to be re-authorised during the transition period. The Bank of Lithuania's 2026 consultative programme covers DORA implementation, AML/CTF, payment services, licensing and third-party risk, which indicates where supervisory attention will sit in the coming years.
Key benefits
- Transparent, published licensing procedure with access to central bank specialists during the process
- Restricted licence route for start-ups, with no minimum own funds while volumes remain modest
- EEA-wide passporting from a standard licence
- Direct access to CENTROlink for SEPA payments, subject to the system's participation criteria
- Deep local pool of payments, compliance and engineering talent built around the fintech sector
- Low state application fees compared with most EU jurisdictions
Requirements
- Lithuanian company with registered office and head office in Lithuania
- Initial capital of at least EUR 350,000 for a standard licence, with documented lawful origin
- Own funds of at least 2% of average outstanding e-money, plus method A, B or C for other payment services
- Managers of good repute with the qualifications and experience to run an EMI
- Qualifying shareholders who are reputable and financially sound (not assessed for restricted-licence applicants)
- Documented e-money issuance procedures, organisational structure, internal control and accounting systems
- Safeguarding through a segregated account at a credit institution or central bank, secure low-risk assets, or insurance or guarantee
- AML/CTF programme under the Lithuanian AML/CTF Law, including risk assessment, KYC, monitoring and reporting
- ICT and security risk management aligned with DORA, plus professional indemnity insurance for AIS or PIS
- A realistic business plan showing the firm can operate safely from the date of authorisation
Licence options & capital
Standard EMI licence
EUR 350,000 initial capital
Full e-money issuance and payment services, passportable throughout the EEA. Three-month statutory review from a complete application.
EMI licence for restricted activities
No minimum own funds; EUR 900,000 e-money cap
Lithuania-only licence for start-ups, with a two-month statutory review. Moving to cross-border activity requires a standard licence and then passport notifications.
Licence extension
Existing Lithuanian EMIs may apply to add payment services, such as cash withdrawals or issuing payment instruments, as their model develops.
Step-by-step process
- 1
Early consultation
The Bank of Lithuania encourages contact before filing to discuss the business model and which services require authorisation.
- 2
Company and capital
A Lithuanian UAB is incorporated, initial capital is paid in and evidenced, and key personnel are appointed.
- 3
Application and state fee
The state fee is paid and the application, prepared under the Bank's licensing rules, is filed. Completeness is checked within five business days.
- 4
Assessment
The Bank reviews the file and usually issues information requests; the statutory period restarts from receipt of the additional documents.
- 5
Board decision
The Board of the Bank of Lithuania grants or refuses the licence, and the institution is entered in the public register.
- 6
Launch and passporting
Safeguarding accounts, payment system access and EEA passport notifications are completed before services begin.
Typical documents
- Application form and confirmation of state fee payment
- Articles of association and incorporation documents
- Business plan with programme of operations and financial forecasts
- Evidence of initial capital and source of funds
- Questionnaires and supporting documents for managers and qualifying shareholders
- Organisational structure and governance arrangements
- Internal control, risk management and safeguarding procedures
- AML/CTF and sanctions policies with business-wide risk assessment
- ICT security, incident management and business continuity policies
- Outsourcing arrangements and agent or distributor details, where relevant
How Legal Wealth helps
Legal Wealth helps clients decide whether a standard or restricted Lithuanian licence fits their stage, and then builds an application that anticipates the Bank of Lithuania's focus on capital adequacy, safeguarding and AML. We coordinate incorporation, capital evidence, local management and outsourcing, prepare the policies and business plan, manage regulator correspondence discreetly, and plan for post-licence obligations and PSD3 re-authorisation. Contact info@legalwealthglobal.com to discuss your project in confidence.
Enquire with Legal WealthFrequently asked questions
How long does a Lithuanian EMI licence take?
The statutory period is three months for a standard licence and two months for a restricted licence, counted from a complete application. Because the Bank usually requests additional information and the period restarts from receipt, most projects take considerably longer in practice.
Can a restricted EMI operate in other EU countries?
No. The restricted licence is valid only in Lithuania. To serve other EEA markets, the firm must first obtain a standard licence and then notify each target state.
What does the state fee cost?
The Bank of Lithuania lists the state fee as EUR 1,463 for a standard EMI licence and EUR 1,235 for a restricted licence, paid before applying. Professional, audit and capital costs are separate and significantly higher.
Do I need local management?
Yes. The head office must be in Lithuania and the Bank expects management and key control functions to be run from there with genuine decision-making authority.
Can a Lithuanian EMI access SEPA directly?
Licensed EMIs may apply to participate in CENTROlink, the Bank of Lithuania's payment system, which provides access to SEPA payments. Participation has its own technical and compliance requirements.
What happens under PSD3?
EMD2 will be repealed and e-money issuance will become a service within the payment institution licence. Existing Lithuanian EMIs will need to apply for authorisation under the new regime within the transition period set by the final texts.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
