Electronic Money Institution (EMI) license in Lithuania

Lithuania is one of the most attractive EU jurisdictions for obtaining an EMI license, thanks to its clear regulatory framework and supportive supervision by the Bank of Lithuania. We guide clients through every stage: from company incorporation to safeguarding account setup and regulatory communication. Our goal is to cut through bureaucracy and help your fintech business launch across the EU faster.

• Lithuania is recognised as an EU leader in EMI licensing.
• The country offers two regimes: Authorised EMI and Small EMI.
• The process involves assessment, documentation, submission, and final approval.
• The costs of licensing depend on the capital size and selected services.
• The key benefits include fast timelines and access to the EU market.

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Regulations for EMI license in Lithuania

Electronic Money Institutions in Lithuania are regulated by the Law on Electronic Money Institutions, the Law on Payments, and the Law on Prevention of Money Laundering and Terrorist Financing. The regulator is the Bank of Lithuania. It issues both standard EMI licenses and restricted-activity licenses for those with smaller scale operations. The regulatory requirements cover capital, own funds, safeguarding customer funds, governance, internal controls, and AML/CTF compliance.

• The minimum share capital for a full EMI is €350,000.
• Restricted-activity EMIs do not need the initial capital requirement and may only operate within Lithuania under limits on average outstanding e-money and payment operations.
• Own funds requirement for full EMIs is at least 2 % of the average outstanding electronic money, or the minimum initial capital if that is higher.
• The Bank of Lithuania requires that management and persons with significant control pass fit-and-proper tests.
• Applicants must submit a detailed business plan, programme of operations, risk management framework, safeguarding measures, and descriptions of internal procedures and IT infrastructure.
• Processing time for a full EMI licence is generally 3 months after receipt of complete documentation; processing for restricted-activity EMI may be faster.

Types of EMI licenses in Lithuania

Lithuania has a single framework for electronic money institutions, but the Bank of Lithuania distinguishes between two levels of licensing: the full (unrestricted) EMI license and the restricted EMI license. This dual approach allows firms to choose the regime that best fits their business model, from large-scale operations to smaller startups testing the market.

Full (Unrestricted) EMI license

The full EMI license is designed for companies aiming at large-scale or cross-border operations. It enables the issuance of e-money without limits, provides access to payment services throughout the EU under passporting rights, and allows firms to work with banks and partners as fully authorised financial institutions. The key requirement is sufficient capital and robust safeguarding arrangements.

• Minimum initial capital requirement is €350,000.
• The license is valid across the entire European Union.
• Unlimited issuance of electronic money is permitted.
• Provision of related payment services is allowed.
• Compliance with safeguarding and AML rules is mandatory.

Restricted EMI license

The restricted EMI license is intended for companies operating on a smaller scale or just entering the market. It does not require initial share capital but is limited to activities within Lithuania, with a cap on the average volume of issued e-money. This option is suitable for startups that want to test their products locally before moving to full authorisation.

• No minimum share capital is required.
• The license is valid only within Lithuania.
• The average outstanding e-money may not exceed €900,000.
• Exceeding thresholds requires upgrading to a full EMI license.
• AML/CTF and internal control obligations must still be met.

Services you can provide with an EMI license

An EMI license in Lithuania grants companies the right to provide a broad range of services related to e-money issuance and payment solutions. This status enhances client and partner trust and provides access to the European financial market.

• The company may issue electronic money and manage e-wallets.
• It is authorised to execute both domestic and international transfers.
• The firm may issue and service payment cards.
• Payment services for online stores and digital platforms are permitted.
• Client funds can be safeguarded in compliance with regulations.
• The company may offer additional payment instruments, including direct debits and credit transfers.

Requirements to obtain an EMI license in Lithuania

To obtain an EMI license in Lithuania, a firm must meet a comprehensive set of regulatory requirements covering capital, safeguarding, governance, management, and risk frameworks. The Bank of Lithuania conducts a thorough review of submitted documents, management qualifications, and operational readiness. Below are the main requirements.

Capital and own funds requirements

A company applying for a full (unrestricted) EMI license must hold a minimum initial capital of €350,000. Ongoing own funds must be at least 2 % of the average outstanding electronic money or the minimum initial capital, whichever is higher. For the restricted EMI regime, no initial capital is required, but operational limits on outstanding e-money and transaction volumes apply.

Safeguarding of client funds

EMIs must safeguard customer funds either by holding them in a segregated account with a credit institution in Lithuania or the EU, or by investing them in safe, liquid, low-risk assets. Alternatively, insurance, a guarantee, or comparable commitment from a credit or insurance institution can be used. The Bank of Lithuania requires reconciliation of safeguarded funds, transparent procedures, and regular reporting to ensure compliance.

Fit & Proper governance, management and key personnel

Directors, board members, and persons with significant control must meet fit and proper standards, including integrity, financial soundness, and sufficient professional experience in payment services or e-money operations. The Bank of Lithuania requires a transparent governance structure with clearly defined responsibilities for compliance, risk management, and oversight. Applicants must also implement internal control systems, audit functions, incident response procedures, and oversight of third parties, such as agents or service providers.

Business plan, programme of operations and risk management

An EMI application must include a detailed 3-year business plan with financial forecasts, growth strategies, and stress scenarios. The programme of operations should describe transaction flows, IT systems, data protection measures, and safeguarding arrangements. Risk management systems must cover operational risks, cybersecurity, business continuity, and incident handling procedures.

Physical presence, legal form and corporate governance

The company must be incorporated in Lithuania as a legal entity (such as UAB) and have a registered office in the country. Its Articles of Association and corporate documents must comply with Lithuanian laws governing EMIs and payment institutions. Shareholders, especially those with qualifying holdings, must be disclosed, and their integrity, financial background, and source of funds verified.

Roadmap to obtain a payment license in Lithuania

The process of obtaining an EMI license in Lithuania consists of several stages that require careful preparation and close cooperation with the Bank of Lithuania. The licensing timeline is usually between 3 and 6 months if the application is complete and well-prepared. Actual timing depends on the quality of documentation, regulator’s additional requests, and the complexity of the business model.

Step 1. Incorporation and initial setup

The first step is incorporating a company in Lithuania (commonly as a UAB) and defining the shareholder and director structure. A registered office and local legal address must be established to comply with regulatory requirements. It is also advisable to engage with a bank early to arrange for a safeguarding account.

• Incorporation of the company as UAB.
• Appointment of shareholders and directors.
• Establishment of a registered office in Lithuania.
• Initial engagement with a bank for safeguarding.

Step 2. Preparation of documentation

The second stage involves preparing the documentation package, including a business plan, programme of operations, IT systems description, and internal procedures. AML/CTF policies, risk management framework, and safeguarding arrangements must also be included. The quality and completeness of the submission directly influence the speed of approval by the Bank of Lithuania.

• Drafting a three-year business plan.
• Preparing the programme of operations.
• Developing AML/CTF and risk management policies.
• Providing safeguarding and IT systems documentation.

Step 3. Submission to the Bank of Lithuania

Once documentation is ready, the application is filed with the Bank of Lithuania for review. The regulator assesses the business model, conducts fit & proper checks for directors and shareholders, and evaluates safeguarding mechanisms. Additional information may be requested, and timely responses are essential.

• Filing the application with the Bank of Lithuania.
• Regulator’s review of documents and company structure.
• Fit & proper assessment of directors and shareholders.
• Responding to regulator’s inquiries within deadlines.

Step 4. Decision and post-authorisation setup

The final stage is the licensing decision and post-authorisation compliance setup. The company must open its safeguarding account, implement internal policies, and commence operations in line with the license. Ongoing obligations include reporting and readiness for supervision by the Bank of Lithuania.

• Receiving the license from the Bank of Lithuania.
• Opening a safeguarding account with a bank.
• Setting up internal controls and reporting procedures.
• Preparing for inspections and supervisory oversight.

Advantages of EMI license in Lithuania

Obtaining an EMI license in Lithuania provides companies with significant opportunities across the European market. The jurisdiction is known for fast application processing, strong support for fintech, and strict yet transparent supervision.

• The license enables access to the EU market through passporting.
• The licensing process is efficient and relatively fast.
• Supervision by the Bank of Lithuania builds client and partner trust.
• The regulatory environment supports fintech innovation.
• Lithuania is among the leading EMI licensing hubs in the EU.
• Safeguarding standards ensure strong protection of customer funds.

Ready to move forward? Ask a question to a compliance expert

Don’t delay your fintech launch – apply for an EMI license in Lithuania and gain access to the EU market. Our expert team will assist you at every step: from company incorporation and documentation to authorisation and compliance setup.