Lithuania EMI Licence: Bank of Lithuania Requirements, Capital, Fees and Timeline

Who a Lithuanian EMI licence suits

The licence suits firms that need an EU base for stored-value products and want a regulator that works in English. The Bank of Lithuania accepts applications and documents in Lithuanian or English.

It is a common route for UK firms. A UK EMI authorised by the FCA cannot serve EEA customers on its UK licence, so it needs an EU subsidiary with its own licence. Under PSD2 an authorisation can only be granted to a legal person established in an EU state, so the Lithuanian company must be a real operating entity, not a branch of the UK firm.

The sector is large and mature. At the end of 2024 Lithuania had 76 licensed EMIs and 43 payment institutions, which together earned EUR 622 million from licensed activities and handled EUR 152 billion of payment transactions.

Standard licence or restricted licence

The restricted licence is designed for start-ups and new entrants. It has no minimum capital, no own funds requirement and no fit and proper test for shareholders, and the Bank of Lithuania must decide within 2 months. The trade-off is scope: it is valid only in Lithuania, and average outstanding e-money must not exceed EUR 900,000 a month over the preceding 6 months.

A restricted EMI that passes the EUR 900,000 limit must apply for a standard licence within 30 days of finding out. A firm with a cross-border plan should usually apply for the standard licence from the start, because moving up means a second full application.

Initial capital and own funds

A standard EMI must hold EUR 350,000 of initial capital at authorisation. After that it must hold own funds, meaning its loss-absorbing capital, of at least the higher of EUR 350,000 and the amount produced by the calculation methods.

For e-money the method is Method D: 2 per cent of average outstanding e-money. For payment services not linked to e-money, the EMI uses Method A (10 per cent of the prior year's fixed overheads), Method B (a sliding scale on monthly payment volume) or Method C (a scale on income). The two figures are added together.

The Bank of Lithuania treats capital as a live supervisory issue. At the end of 2024 every institution met its own funds requirement, but eight were close to the threshold. The Bank said that operating near the limit is not sustainable and that firms should set their target ratio as high as possible.

Safeguarding customer funds

Funds received in exchange for e-money must be safeguarded. Under EU law, funds still held at the end of the business day after receipt must be placed in a separate account at a credit institution or invested in secure, liquid, low-risk assets. Funds received by card or another payment instrument must be safeguarded no later than 5 business days after the e-money is issued.

Lithuania allows the separate account to be held at a Lithuanian or EU credit institution, at the Bank of Lithuania or at another EU central bank. The alternative is an insurance policy, guarantee or surety bond covering the same amount.

Firms use all three options. At the end of 2024 Lithuanian EMIs and payment institutions held EUR 671 million of customer funds with central banks, EUR 1.2 billion with credit institutions and EUR 742 million in safe, liquid assets.

Substance: people, office and decision-making in Lithuania

• - Registered office in Lithuania. The Bank refuses a licence where there is none
• - Head office in Lithuania and at least part of the e-money business carried on there, as EU law requires
• - Heads of the institution of good repute with the qualifications and experience their roles need, assessed under the Bank's fit and proper guidelines
• - Qualifying shareholders traced to individuals and assessed for repute and financial soundness
• - A named person accountable for anti-money laundering compliance, with the authority and time to do the job
• - Risk management, compliance and internal audit functions that are separate from the commercial side
• - Accounting and management information that the board in Lithuania actually uses to run the business

The Bank of Lithuania's supervisory stance, 2024 to 2026

The Bank of Lithuania licenses many firms, but it also removes them. In 2024 it issued 3 new licences, revoked 9, carried out 15 targeted inspections, imposed 19 sanctions and sent 91 notices asking firms to improve practices. Its focus areas were anti-money laundering, know-your-customer checks, fraud risk, own funds, safeguarding and internal control.

On 3 March 2026 it revoked the licence of PAYTEND EUROPE, UAB, an EMI. It found serious and systematic failures: alerts not analysed promptly, no suspicious transaction reports despite warning signs, weak internal controls, incorrect information given to the regulator about a high-risk customer and late filing of audited 2024 accounts.

Its inspection plan for 2026, published on 23 January 2026, lists about 20 inspections and visits: 6 routine and up to 15 non-routine. Up to 10 non-routine inspections cover anti-money laundering, at least one covers fraud prevention, and up to 4 are aimed at EMIs and payment institutions. The message for applicants is clear: the licence is the start of supervision, not the end of scrutiny.

Passporting to other EEA states

A standard licence lets the EMI serve other EEA states either directly across borders or through a branch or agents. It must first notify the Bank of Lithuania with the states, services and any branch or agent details.

Under the PSD2 procedure the Bank of Lithuania sends the information to the host regulator within 1 month of receiving everything. The host regulator has 1 month to respond, including any money laundering concerns about agents or branches. The Bank of Lithuania then has 3 months from receipt of the notification to communicate its decision.

• - Choose between cross-border services and a branch for each state
• - List agents and distributors, with their own fit and proper checks
• - Check host-state consumer, language and complaints rules before launch
• - Plan for host-state anti-money laundering contact point rules where agents or distributors are used

Ongoing reporting and obligations

• - Quarterly reports within 20 calendar days of quarter end: balance sheet, profit and loss, changes in equity, performance indicators, safeguarding of funds, and initial capital and own funds
• - Quarterly anti-money laundering reports, and an annual anti-money laundering report by 1 March of the following year
• - Annual financial statements approved by shareholders, with the auditor's report, within 3 days of the general meeting, which must be held within 3 months of year end
• - An operational and security risk report at least once a year
• - Notice of outsourcing of important operational functions at least 1 month before the contract is signed
• - Notice of major changes to safeguarding arrangements, of new services within 30 days of starting them, and of bank account closures or restrictions within 5 calendar days
• - DORA rules on ICT risk, incident reporting and ICT outsourcing, which apply to EMIs from 17 January 2025

Payment system access through CENTROlink

The Bank of Lithuania runs CENTROlink, a retail payment system that gives access to SEPA credit transfers, direct debits and instant payments. EMIs and payment institutions licensed in the EEA can take part.

Since August 2024 EMIs and payment institutions that meet Article 35a of PSD2 can become direct participants. Lithuanian-licensed participants must complete a self-assessment and may be asked for an audit report. From 9 April 2027, EMIs and payment institutions in euro area states must be able to send and receive instant euro payments, so payment system access should be planned at application stage.

PSD3: what changes for Lithuanian EMIs

The EU is replacing PSD2 and the E-Money Directive with PSD3 and the Payment Services Regulation. Parliament and Council negotiators agreed the package on 27 November 2025, and the final compromise text went to EU ambassadors on 17 April 2026.

Under that text, e-money issuance becomes a payment service and EMIs become payment institutions. Initial capital for e-money issuance falls to EUR 250,000. The amounts for payment initiation (EUR 50,000), the account and transaction services (EUR 150,000) and e-money issuance are added together where a firm provides more than one of them, so a firm issuing e-money and also executing payment transactions would need EUR 400,000.

Existing EMIs may continue for up to 27 months after PSD3 enters into force. They must give the Bank of Lithuania the information it needs to confirm compliance, or face suspension. A firm applying now should build its file so it can meet the PSD3 conditions without a rewrite.

Issuing e-money tokens under MiCA

Under MiCA, an e-money token, meaning a crypto-asset that tracks one official currency, can only be offered to the public by a credit institution or an EMI. E-money tokens are treated as e-money, so the issuer must meet the EMI rules on capital, safeguarding and redemption at par.

The issuer must notify its regulator at least 40 working days before offering the token and publish a white paper. A Lithuanian EMI can do this through the Bank of Lithuania, which also authorises crypto-asset service providers under MiCA.

Pre-application checklist

• - Written analysis confirming the product issues e-money and listing each payment service needed
• - Decision between the standard and restricted licence, with the EUR 900,000 limit tested against forecasts
• - Lithuanian company incorporated, with a registered office and a real head office in Lithuania
• - Heads of the institution identified, with CVs and fit and proper documents ready
• - Qualifying shareholders traced to individuals, with source of funds and source of wealth evidence
• - EUR 350,000 of initial capital available and a plan to pay it in and evidence it
• - Three-year financial forecast showing own funds above the requirement as e-money grows
• - Safeguarding method chosen and the bank, central bank or insurer approached
• - Business-wide money laundering risk assessment and procedures matched to the product and countries served
• - Governance map: board, risk, compliance, internal audit, with terms of reference
• - IT, security, business continuity and outsourcing documents meeting DORA
• - Payment system and card scheme access plan, including CENTROlink or a correspondent bank
• - List of target EEA states for passport notifications
• - State fee of EUR 1,463 (or EUR 1,235) paid to the State Tax Inspectorate