Lithuania

Lithuania Payment Institution Licence: Bank of Lithuania Requirements, Capital, Fees and Timeline

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Lithuania payment institution licence: EUR 20,000 to 125,000 capital, EUR 898 state fee, restricted licence, safeguarding, timelines and EEA passporting.

EUR 20,000 to 125,000 capitalEUR 898 state fee3-month statutory clock
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Key dates for 2025 to 2027

17 January 2025PassedDORA, the EU digital operational resilience regulation, starts to apply to payment institutions and EMIs, including ICT risk, incident reporting and outsourcing rules.
24 March 2025PassedThe Bank of Lithuania reports 2024 results: 9 EMI and payment institution licences revoked and 19 sanctions imposed.
27 November 2025PassedParliament and Council negotiators agree PSD3 and the Payment Services Regulation, which will replace PSD2 and the E-Money Directive.
23 January 2026PassedThe Bank of Lithuania publishes its 2026 inspection plan, focused on anti-money laundering and fraud prevention.
17 April 2026PassedThe final PSD3 compromise text goes to EU ambassadors, raising payment institution capital to EUR 40,000 for remittance and EUR 150,000 for account and transaction services.
9 April 2027UpcomingEMIs and payment institutions in euro area states, including Lithuania and the Netherlands, must be able to send and receive instant euro credit transfers.
10 July 2027UpcomingThe EU Anti-Money Laundering Regulation (EU) 2024/1624 starts to apply directly to EMIs and payment institutions across the EU.

The short answer

A Lithuanian payment institution (PI) licence is granted by the Bank of Lithuania. It lets a company provide payment services such as running payment accounts, executing transfers, issuing cards, acquiring card payments for merchants, money remittance, payment initiation and account information. It does not allow the firm to hold stored value that customers spend later; that needs an electronic money institution (EMI) licence. A standard licence can be passported to every other EEA state, which is why UK firms that lost EU access on 31 December 2020 use it.

Initial capital is EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only and EUR 125,000 for the other services. The state fee is EUR 898, or EUR 693 for a licence limited to account information services. A restricted licence for new entrants costs EUR 682, needs no minimum capital, is valid only in Lithuania and is capped at an average of EUR 3 million of payment transactions a month.

The Bank of Lithuania checks a file for completeness within 5 business days and decides within 3 months of a complete application, or 2 months for a restricted licence. If it asks for more documents, the period runs from when they arrive. The EU's PSD3 reform would raise the floors: the final compromise text sets EUR 40,000 for money remittance and EUR 150,000 for account and transaction services.

Key facts at a glance

RegulatorBank of Lithuania (Lietuvos bankas)
Licence typesStandard payment institution licence; licence limited to account information services; licence for restricted activity (Lithuania only)
Who needs itCompanies providing payment services from Lithuania without issuing e-money
Local entityA Lithuanian company. EU law requires the head office in the same state as the registered office, with part of the payment business carried on there
Initial capitalEUR 20,000 money remittance only; EUR 50,000 payment initiation only; EUR 125,000 for cash, account, transfer, card issuing and acquiring services. None for restricted or account information only licences
Ongoing own fundsThe higher of initial capital and the result of Method A, B or C
Professional indemnity insuranceRequired for payment initiation and account information services
Restricted licence limitAverage monthly payment transactions over the last 12 months no more than EUR 3 million, including agents the institution answers for
State feeEUR 898 standard; EUR 682 restricted; EUR 693 account information services only
Completeness check5 business days
Statutory decision period3 months from a complete application; 2 months for a restricted licence
Application languageLithuanian or English
Annual supervision costA contribution set each year as a percentage of the prior year's payment services income (0.585 per cent in the 2023 rate table)
PassportingStandard licence only, by notification to the Bank of Lithuania

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What is the Lithuania Payment Institution Licence?

A Lithuanian payment institution licence authorises a company to provide the payment services listed in the Law on Payments. These include placing and withdrawing cash on a payment account, executing payment transactions including transfers, direct debits and card payments, issuing payment instruments, acquiring payment transactions for merchants, money remittance, payment initiation and account information.

The licence is granted by the Board of the Bank of Lithuania, which supervises the institution's capital, safeguarding of client funds, governance and anti-money laundering controls. A standard licence can be used in other EEA states through passporting.

There are three versions. The standard licence covers the full list of services and carries the passport. A licence limited to account information services has no capital requirement but needs professional indemnity insurance. The restricted licence is a lighter, Lithuania-only licence for new entrants with a monthly volume cap.

Who needs a Lithuania Payment Institution Licence?

Any company providing payment services by way of business from Lithuania that does not issue e-money, and any non-EU payments business that needs an EU-licensed entity to serve EEA customers.

  • - UK payment institutions that need an EU entity after losing passporting on 31 December 2020
  • - Merchant acquirers and payment facilitators serving EEA merchants
  • - Money remittance businesses sending funds into or out of the EU
  • - Open banking providers offering payment initiation or account information services
  • - Platforms and marketplaces that collect and pay out funds for third parties
  • - Lithuanian start-ups testing a payment product under the restricted licence

The most common mistake is choosing a payment institution licence for a product that holds customer balances. If a customer pre-loads value and spends it later with other businesses, that is e-money and needs an EMI licence with EUR 350,000 capital. The second is assuming the restricted licence is a cheap route into the EU. It is valid only in Lithuania and is capped at an average of EUR 3 million of payment transactions a month. The third is assuming a Lithuanian licence can be operated from abroad. EU law requires the head office to be in Lithuania with part of the payment business carried on there, and the Bank of Lithuania assesses who actually runs the business.

Who a Lithuanian payment institution licence suits

The licence suits firms that execute payments for customers without holding stored value: acquirers, remittance businesses, payment processors and open banking providers. The Bank of Lithuania accepts applications in Lithuanian or English.

For UK firms, it replaces the passport lost on 31 December 2020. Under PSD2 an authorisation can only be granted to a legal person established in an EU state, so the UK group sets up a Lithuanian subsidiary with its own management and capital.

Lithuania has an established payments sector. At the end of 2024 there were 43 licensed payment institutions and 76 EMIs. Thirteen institutions provided payment initiation services, and four of them initiated more than 10 million transactions in 2024.

Which services, and how much capital

Capital follows the services. A firm offering only money remittance needs EUR 20,000. A firm offering only payment initiation needs EUR 50,000. Any of the account, cash, transfer, credit line, card issuing or acquiring services needs EUR 125,000. A firm applying for several services holds the larger amount.

OptionInitial capitalState feeWhere validKey limit
Standard licence: money remittance onlyEUR 20,000EUR 898Lithuania and EEA by passportNone
Standard licence: payment initiation onlyEUR 50,000EUR 898Lithuania and EEA by passportProfessional indemnity insurance required
Standard licence: account, transfer, card issuing or acquiring servicesEUR 125,000EUR 898Lithuania and EEA by passportNone
Account information services onlyNoneEUR 693Lithuania and EEA by passportProfessional indemnity insurance required
Restricted licenceNoneEUR 682Lithuania onlyEUR 3 million average monthly payment transactions

The restricted licence

The restricted licence is a sandbox-based licence for new market entrants. It has no minimum capital, no own funds requirement and no fit and proper test for shareholders. The Bank of Lithuania decides within 2 months, and additional documents extend that by 2 months.

It covers only part of the services list (points 1 to 5 of Article 5 of the Law on Payments, according to the Bank's authorisation page) and is valid only in Lithuania. The average monthly value of payment transactions over the last 12 months, including agents the institution answers for, must not exceed EUR 3 million. Where there is no trading history, the business plan projections are used. A firm that plans to serve other EEA states should apply for the standard licence from the start.

Own funds after authorisation

Once trading, own funds must be at least the higher of the initial capital and the figure from the calculation method. Method A is 10 per cent of the previous year's fixed overheads. Method B applies a sliding scale to monthly payment volume: 4 per cent of the first EUR 5 million, then lower rates on higher slices, multiplied by a scaling factor. Method C applies a scale to income.

Institutions with a restricted licence or an account information only licence are not subject to these capital requirements. The Bank of Lithuania monitors own funds through quarterly reports and has warned institutions against operating close to the threshold.

Safeguarding client funds

Funds received from payment service users for the execution of payment transactions must not be mixed with the institution's own funds. Under PSD2, funds still held at the end of the business day after receipt must be deposited in a separate account at a credit institution or invested in secure, liquid, low-risk assets, and protected from other creditors in insolvency.

In Lithuania the separate account can be at a Lithuanian or EU credit institution, at the Bank of Lithuania or at another EU central bank. Insurance, a guarantee or a surety bond for the same amount is the alternative.

Substance in Lithuania

  • - Lithuanian company with its head office in Lithuania and part of the payment business carried on there
  • - Heads of the institution of good repute with the qualifications and experience needed, assessed under the Bank's fit and proper guidelines
  • - Qualifying shareholders traced to individuals and assessed, except under the restricted licence
  • - A named person accountable for anti-money laundering compliance, with real authority
  • - Compliance, risk and internal audit separated from the commercial functions
  • - Board and management meetings, records and decisions held in Lithuania

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

In 2024 the Bank revoked 9 EMI and payment institution licences, issued 3 new ones, carried out 15 targeted inspections and imposed 19 sanctions. It focused on anti-money laundering, know-your-customer checks, fraud risk, own funds, safeguarding and internal control.

In March 2026 it revoked the licence of PAYTEND EUROPE, UAB, an EMI, for serious anti-money laundering failures, including unanalysed alerts and unfiled suspicious transaction reports. Its 2026 inspection plan, published on 23 January 2026, lists about 20 inspections and visits, with up to 10 non-routine anti-money laundering inspections and at least one on fraud prevention.

Passporting to other EEA states

A standard licence holder notifies the Bank of Lithuania of each state, service, branch and agent. The Bank sends the information to the host regulator within 1 month of receiving it in full. The host regulator has 1 month to respond, and the Bank communicates its decision within 3 months of the notification.

Restricted licences cannot be passported. Under PSD2 the passporting rules do not apply to institutions registered under the small institution exemption.

Ongoing reporting and obligations

  • - Quarterly financial and activity reports within 20 calendar days of quarter end, including safeguarding and, for unrestricted licences, initial capital and own funds
  • - Quarterly and annual anti-money laundering reports, the annual one by 1 March
  • - Annual financial statements approved by shareholders, with the auditor's report
  • - Operational and security risk report at least once a year
  • - Notice of important outsourcing at least 1 month before signing
  • - Notice of new services within 30 days of starting them
  • - DORA rules on ICT risk, incidents and ICT outsourcing, which apply to payment institutions from 17 January 2025
  • - From 9 April 2027, euro instant payment capability for payment institutions in euro area states

PSD3: what changes for Lithuanian payment institutions

Parliament and Council negotiators agreed PSD3 and the Payment Services Regulation on 27 November 2025. The final compromise text went to EU ambassadors on 17 April 2026.

Under that text, initial capital rises to EUR 40,000 for money remittance only and EUR 150,000 for the account, transfer, card issuing and acquiring services, with EUR 50,000 for payment initiation. Where a firm provides more than one of payment initiation, the account and transaction services and e-money issuance, the amounts are added together.

Existing payment institutions may continue for up to 27 months after PSD3 enters into force. They must give the Bank of Lithuania the information needed to confirm compliance, or face suspension until they do. Capital planning for a new licence should allow for the higher PSD3 figures.

Pre-application checklist

  • - Flow-of-funds diagram mapped to each payment service in the Law on Payments
  • - Written confirmation that the product does not issue e-money
  • - Choice of standard, account information only or restricted licence
  • - Lithuanian company with registered office and real head office in Lithuania
  • - Heads identified with CVs and fit and proper documents
  • - Qualifying shareholders traced to individuals, with source of funds evidence
  • - Initial capital for the chosen services, plus a PSD3 buffer
  • - Three-year forecast showing own funds under the expected method
  • - Safeguarding method chosen and provider approached
  • - Professional indemnity insurance quote for payment initiation or account information services
  • - Anti-money laundering risk assessment and procedures matched to corridors and customers
  • - IT, security, business continuity and outsourcing documents meeting DORA
  • - List of EEA states for passport notifications
  • - State fee paid to the State Tax Inspectorate

Lithuania vs Netherlands vs Ireland vs Malta vs UK: payment institution licence compared

PSD2 sets the same capital floors across the EU. Fees, levies, lighter routes and substance expectations differ.

PointLithuaniaNetherlandsIrelandMaltaUnited Kingdom
RegulatorBank of LithuaniaDe Nederlandsche Bank (DNB); AFM for conductCentral Bank of IrelandMalta Financial Services Authority (MFSA)Financial Conduct Authority (FCA)
Initial capitalEUR 20,000, EUR 50,000 or EUR 125,000 by service (none for restricted or account information only)EUR 20,000, EUR 50,000 or EUR 125,000 by serviceEUR 20,000, EUR 50,000 or EUR 125,000 by serviceEUR 20,000, EUR 50,000 or EUR 125,000 by serviceEUR 20,000, EUR 50,000 or EUR 125,000 by service
Regulator application feeEUR 898 (EUR 682 restricted; EUR 693 account information only)EUR 10,400No application feeEUR 10,000 for payment servicesGBP 2,820 or GBP 5,640
Annual supervision feePercentage of prior-year payment services income, set yearly (0.585 per cent for 2023)DNB levy from EUR 8,250 plus a variable part; AFM levy EUR 1,535 to EUR 9,536 (2026)Minimum levy EUR 6,625 plus a variable levy (2026 regulations)EUR 25,000 plus a variable part capped at EUR 250,000FCA periodic fees, which vary by firm
Statutory decision period3 months from a complete file (2 months restricted)3 months from a complete file3 months from a complete file3 months from a complete file (EU rule)3 months for a complete application
Lighter routeRestricted licence: no capital, EUR 3 million monthly average, Lithuania onlyNot covered in this comparisonNo small payment institution regimeNot covered in this comparisonSmall payment institution registration, EUR 3 million monthly average
Local substanceRegistered office and head office in Lithuania; heads assessed for repute, qualifications and experienceAt least two day-to-day policymakers working from the NetherlandsBoard and senior roles need Central Bank pre-approval (PCF roles); interviews possibleHead office in Malta (EU rule)Head office in the UK
Application languageLithuanian or EnglishNot stated by DNB; application notes published in EnglishEnglishEnglishEnglish
EEA passportYes (not the restricted licence)YesYesYesNo

EU capital follows Article 7 of Directive (EU) 2015/2366. The Netherlands substance rule is taken from DNB's notes for EMIs, which apply the same dual management principle to payment institutions. Fees are as published at 29 October 2026. Professional fees are not included.

Key requirements

Initial capital

EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only and EUR 125,000 for the account, transfer, card issuing and acquiring services. Capital must at all times be no less than the larger applicable amount. None for restricted or account information only licences.

Own funds

After authorisation, own funds must be at least the higher of initial capital and the figure from Method A (10 per cent of prior-year fixed overheads), Method B (a sliding scale on monthly payment volume) or Method C (a scale on income).

Safeguarding

Where the institution receives client funds, it must keep them in a separate account at a Lithuanian or EU credit institution, at the Bank of Lithuania or another EU central bank, or in secure, liquid, low-risk assets. Insurance, a guarantee or a surety bond is the alternative.

Professional indemnity insurance

Payment initiation and account information service providers must hold professional indemnity insurance or a comparable guarantee against their liability.

Heads and shareholders

Heads must be of good repute with the qualifications and experience the role needs. Qualifying shareholders must be able to ensure sound management, have good repute and be financially sound. The shareholder test does not apply to a restricted licence.

Governance and business plan

Adequate governance, risk management, internal control and accounting, and a business plan the founders can realistically carry out.

Anti-money laundering

A risk assessment, customer due diligence, transaction monitoring and suspicious transaction reporting matched to the services, customers and countries served.

What does a Lithuanian payment institution licence cost in year one?

The state fee is low by EU standards. The main costs are capital, local people and compliance systems. Third-party costs are shown as varies where no reliable published figure exists.

ItemAmountNotes
State fee, standard licenceEUR 898Paid to the State Tax Inspectorate before applying
State fee, restricted licenceEUR 682Instead of the standard fee
State fee, account information services onlyEUR 693Instead of the standard fee
Initial capitalEUR 20,000, EUR 50,000 or EUR 125,000By service. None for restricted or account information only licences
Own funds above the minimumVariesMethod A, B or C once trading
Bank of Lithuania annual contributionVariesA percentage of the prior year's payment services income, set each year (0.585 per cent for 2023)
Professional indemnity insuranceVariesPayment initiation and account information services only
Statutory auditVariesAuditor's report filed with the Bank
Safeguarding account, insurance or guaranteeVariesDepends on method and provider
Local staff and office in LithuaniaVariesHeads, anti-money laundering, compliance, risk and finance
Screening and monitoring systemsVariesSized to volumes and corridors
Professional fees for the applicationA fixed fee set out in a written proposalScoped to services and structure

Regulator figures are from the Bank of Lithuania at 29 October 2026.

The application process

1

Service mapping

We map the flow of funds to each payment service in the Law on Payments, confirm the product does not issue e-money and choose between the standard, account information only or restricted licence.

2

Early contact with the Bank of Lithuania

We prepare a short summary of the services and structure so the Bank can raise questions on scope before the file is submitted.

3

Company, people and capital

We help set up the Lithuanian company, select heads who meet the fit and proper test, trace qualifying shareholders and plan the capital for the chosen services.

4

Application file

We draft the business plan, forecasts, safeguarding procedure, anti-money laundering framework, governance and IT documents following Annex 2 (standard), Annex 4 (restricted) or Annex 5 (account information only) to the Bank's licensing rules.

5

Fee, submission and completeness check

The state fee is paid to the State Tax Inspectorate and the file is submitted electronically through the applicant's account. The Bank checks completeness within 5 business days.

6

Assessment and decision

We manage information requests and keep answers consistent with the business plan. The Board of the Bank of Lithuania decides whether to grant the licence.

7

Passporting and launch

We prepare passport notifications for target EEA states, safeguarding arrangements and the first reporting cycle.

The Bank of Lithuania must decide within 3 months of a complete application, or 2 months for a restricted licence. If it asks for more documents, the period runs from when they arrive.

How long does a Lithuanian payment institution licence take?

Statutory position: the Bank of Lithuania checks completeness within 5 business days and decides within 3 months of receiving proper documents, or 2 months for a restricted licence. If documents are deficient or more information is requested, the 3 months run from when the extra material is submitted. For a restricted licence, additional documents extend the period by 2 months.

Practical position: deficiencies are common and requests for more information extend the timeline. The files that move quickest are complete on day one, consistent across the business plan, forecasts and anti-money laundering documents, and answered quickly.

StageTime limitWhat drives it
Contact with the Bank before applyingNo fixed periodClarity of services and structure
Pay state fee and submit electronicallyBefore applyingDocuments signed with e-signatures
Completeness check5 business daysMissing documents
Assessment, standard or account information licence3 months from complete documentsInformation requests
Assessment, restricted licence2 months, extended by 2 months if more documents are neededInformation requests
Passport notification1 month to send to host regulator; decision within 3 months of notificationBranch and agent details

Why applications fail, and how we prevent it

Wrong licence for the product

A wallet or stored balance designed under a payment institution licence has to be re-filed as an EMI application. Settle this before drafting.

Services listed loosely

Capital and own funds follow the services applied for. Applying for services the business will not use raises capital; missing a service means a later extension.

Generic anti-money laundering controls

Anti-money laundering is the main focus of the Bank's 2026 inspection plan. Policies that do not match the corridors, merchants or customers served are challenged.

Head office outside Lithuania

A file showing management, compliance and finance run from another country conflicts with the EU head office rule and is challenged.

Practitioner notes on Lithuanian payment institution applications

  • - Map services from the flow of funds, not from the product name. It decides capital, own funds and whether safeguarding applies
  • - Price in PSD3. A firm licensed today at EUR 125,000 will need to show EUR 150,000 under the compromise text
  • - Use the restricted licence only for a genuine Lithuanian pilot. Moving up means a new application
  • - Keep professional indemnity insurance in view for open banking services. It is a licence condition, not an afterthought
  • - Expect anti-money laundering inspections. They dominate the Bank's 2026 plan

How we help

Licence strategy

Service mapping, capital tier, choice of licence version and EEA rollout plan.

Application file

Business plan, forecasts, safeguarding procedure, anti-money laundering framework and governance documents to the Bank of Lithuania's document list.

After authorisation

Passport notifications, quarterly reporting, own funds monitoring and PSD3 readiness.

Regulatory Counsel is a licensing and compliance practice for payment, e-money, crypto, lending, insurance and investment firms, with more than 200 licence and registration engagements across 65+ jurisdictions. We prepare payment institution applications in Lithuania, the Netherlands, Ireland, Malta and the UK. Our fee is a fixed fee set out in a written proposal.

Frequently asked questions

EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only and EUR 125,000 for account, transfer, card issuing or acquiring services. Restricted and account information only licences have no capital requirement. After authorisation, own funds follow Method A, B or C.

A state fee of EUR 898 for a standard licence, EUR 682 for a restricted licence and EUR 693 for a licence limited to account information services, paid to the State Tax Inspectorate before applying.

The Bank checks completeness within 5 business days and decides within 3 months of a complete file, or 2 months for a restricted licence. If it asks for more documents, the period runs from when they arrive.

A Lithuania-only licence for new entrants with no minimum capital and no shareholder fit and proper test. Average monthly payment transactions over 12 months must not exceed EUR 3 million, and it covers only part of the services list.

Yes, if customers hold a balance with you that they can spend later with other businesses. That is e-money. A payment institution licence covers executing payments, not storing value.

A UK group can own one, but the licence is granted to a Lithuanian company with its head office in Lithuania. The UK licence gives no EU access after 31 December 2020.

Yes. The Bank of Lithuania accepts applications and documents in Lithuanian or English.

A standard licence can, by notifying the Bank of Lithuania, which sends the details to the host regulator within 1 month. A restricted licence cannot.

Under the final compromise text, capital rises to EUR 40,000 for money remittance only and EUR 150,000 for account and transaction services, with EUR 50,000 for payment initiation. Existing institutions have up to 27 months after entry into force to show compliance.

Primary sources

The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.

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Harry Khan advises payment, e-money and money transmission firms on licensing and compliance.