Vilnius business district
Home › Licensing › Lithuania › Lithuania EMI licence
Licence guide

Lithuania electronic money institution licence.

The EU base most often chosen by e-money issuers that want low fees, a defined timetable and direct access to the central bank’s payment system from day one.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
Bank of LithuaniaRegulator
€350,000Initial capital
€1,463State levy
4 to 6 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

4 to 6 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for directors, senior managers and an internal auditor, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The licence route, full or restricted, the capital and the state levy are confirmed in writing, with a Newcomer Programme meeting with the Bank of Lithuania arranged before filing.
  2. Application pack. The document set in the licensing rules’ annexes, the governance and internal audit arrangements and the shareholder and manager files so the five-day completeness check passes first time.
  3. Banking. The safeguarding account with a Lithuanian or EU credit institution and the operating accounts are arranged through the firm’s relationships before the decision, alongside the CENTROlink access application.
  4. Regulator engagement. The deficiency and comment rounds are answered through one process with the evidence assembled, until the Board of the Bank of Lithuania takes its decision.

Key people, banking and technology

You will need directors and senior managers with a good reputation and experience, and an internal auditor, with supervision kept separate from management.

Key peopleThe firm introduces candidates for directors, senior managers and an internal auditor from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A Lithuanian EMI issues e-money and provides payment services across the EU and EEA on one licence; Lithuania hosts more EMIs than any other EU state.
  • Initial capital is €350,000; own funds are the higher of that and 2% of average outstanding e-money, adjustable by 20%.
  • The state levy is €1,463; the annual supervisory fee is 0.65% of income from e-money and payment services.
  • Three months from a proper application by statute, with a five-business-day completeness check; two months for a restricted licence.
  • Registered office in Lithuania; the Bank of Lithuania publishes governance principles and its refusal decisions.
  • A restricted licence covers issuers below €900,000 of average outstanding e-money a month, for Lithuania only.

Who needs the licence

A business issuing stored value in Lithuania or, through passporting, across the EU and EEA needs a Bank of Lithuania licence. Lithuania offers the lowest fees and the shortest timeline of the EU regimes, access to the central bank’s payment system for licensed institutions, and a regulator with a dedicated newcomer programme. An EMI may provide every payment service under the same licence.

What the Bank of Lithuania requires

  • Legal form and location. A company with its registered office and head office in Lithuania; the absence of a Lithuanian office is a statutory ground for refusal.
  • Governance. Managers of good repute and experience; supervisory and managerial functions separated; an appointed internal auditor; control functions outside the board; outsourcing clearly contracted, under the Bank of Lithuania’s governance principles.
  • Safeguarding. Segregation in a separate account with a Lithuanian or EU credit institution or central bank, or low-risk assets; or insurance, a guarantee or a surety from an unaffiliated provider.
  • Application pack. The document set in the licensing rules’ annexes, with the state levy paid to the tax inspectorate before filing; a Newcomer Programme meeting with the Bank of Lithuania on request; a five-business-day completeness check; a Board decision.
  • Capital. Initial capital of €350,000 and own funds thereafter equal to the higher of that and 2% of average outstanding e-money, adjustable by 20% at the supervisor’s discretion; unrelated payment services under Methods A, B or C.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own fundsHigher of €350,000 and 2% of average outstanding e-money
AdjustmentUp to 20% either way
Restricted licenceNo initial capital; average outstanding e-money not above €900,000 a month

Safeguarding of funds received by payment instrument applies within five working days of issuance.

Timing

FigureValueSource
Statutory decision period3 months from a proper application; 2 months for a restricted licenceLaw on Electronic Money and Electronic Money Institutions
Regulator’s published figureCompleteness check within 5 business days; the period restarts on supplementary documentsBank of Lithuania authorisation rules
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline4 to 6 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
State levy€1,463Paid to the State Tax Inspectorate before filing; €1,235 for a restricted licence
Annual supervisory fee0.65% of incomeOn annual income from e-money issuance and payment services (2026 rate)
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

Restricted-activity licence

An issuer whose average outstanding e-money stays below €900,000 a month and whose payment transactions stay below €3 million a month may hold a restricted licence, valid in Lithuania only, without initial capital or shareholder fitness tests. A full licence is required within 30 days of exceeding the limits.

Passporting and scope

A Lithuanian EMI’s full licence is valid in other Member States; branches and cross-border services are notified to the Bank of Lithuania. The restricted licence carries no passport.

Why applications are delayed

The Bank of Lithuania publishes its reasons.

  1. Documents that do not comply with the licensing rules or lack required data.
  2. Capital or fitness shortfalls among shareholders and managers; it has refused licences on reputational grounds and published the decisions.
  3. Business plans beyond the founders’ demonstrated capacity.

Banking

An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Lithuania and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does a Bank of Lithuania EMI licence take?

Three months from a proper application by statute, with a five-business-day completeness check and comment rounds that extend the period. The firm plans for four to six months after submission.

Why do so many EMIs choose Lithuania?

Low fees, a defined timeline, a newcomer programme, direct access to the central bank’s payment system for licensed institutions, and passporting across the EU.

What is the restricted licence?

A licence for issuers below €900,000 of average outstanding e-money a month, valid in Lithuania only, without initial capital.

What does supervision cost?

0.65% of annual income from e-money and payment services.

Does the Bank of Lithuania refuse applications?

Yes, and it publishes its decisions, including refusals on reputational grounds. Shareholder and manager fitness is assessed closely.

References

  1. Bank of Lithuania: authorisation of electronic money institutions
  2. Bank of Lithuania: authorisation of payment institutions
  3. Bank of Lithuania: EMI prudential requirements
  4. Bank of Lithuania: PI prudential requirements
  5. Bank of Lithuania: supervisory fee rates
  6. Bank of Lithuania: Newcomer Programme
  7. Law on Electronic Money and Electronic Money Institutions

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.