An electronic money institution is a company licensed to issue electronic money: a stored monetary value that a customer pays for in advance, holds on an account, card or wallet, and spends with third parties. A Lithuanian EMI may also provide the payment services listed in Article 5 of the Law on Payments, such as payment accounts, transfers, card issuing and acquiring.
The Bank of Lithuania licenses and supervises EMIs. Only credit institutions, EMIs and a small number of other bodies may issue e-money in Lithuania. A full licence allows the EMI to operate in every European Economic Area state after a notification procedure, which is why Lithuania has become one of the EU's main centres for e-money and payment firms.
The Bank of Lithuania offers two EMI licences. The full licence is the route for any firm that will serve customers outside Lithuania or expects significant volumes. The restricted-activities licence is designed for start-ups testing a product in Lithuania first.
| Point | Full EMI licence | Restricted-activities EMI licence |
|---|---|---|
| Minimum initial capital | EUR 350,000 | None |
| State levy | EUR 1,463 | EUR 1,235 |
| Where it applies | Lithuania and, after notification, the EEA | Lithuania only |
| Volume limit | None | EUR 900,000 average outstanding e-money a month over the preceding 6 months |
| Statutory decision period | 3 months | 2 months |
| Documents | Annex 1 to the licensing rules | Annex 3 to the licensing rules |
A restricted EMI that exceeds the volume limit must apply for a full licence within 30 days. Firms that only move funds without holding stored balances should consider a payment institution licence instead, set out in the firm's guide to the Lithuanian payment institution licence.
An EMI cannot take deposits or pay interest on e-money balances. Remote onboarding with electronic identity verification is permitted, provided it meets the anti-money laundering rules.
The Bank of Lithuania expects an EMI to be fully ready to operate on the day it is licensed, so the application must show the complete business, not a plan to build it later.
A full EMI must hold initial capital of at least EUR 350,000. After licensing, own funds must also cover the requirement calculated under Resolution No 03-83, which for e-money is 2% of average outstanding e-money. The business plan should fund at least three years of operation above these minimums, sized to the forecast.
Anyone with a qualifying holding must be of sufficient reputation and financially sound, and must support sound management of the EMI. The source of the capital must be documented.
Directors and key function holders must be of good repute with the qualifications and experience for their roles, assessed under Resolution No 03-181. The registered office and head office must be in Lithuania. The Bank of Lithuania looks for real substance: a chief executive and senior managers who run the business from Vilnius or elsewhere in Lithuania, a local MLRO, and compliance, risk management and internal audit functions in place.
A Lithuanian EMI must protect the funds received for e-money, either by holding them in a separate account at a credit institution or investing them in secure, low-risk assets, or by covering them with an insurance policy or a guarantee. Under the EU E-Money Directive the funds must be safeguarded no later than five business days after the e-money is issued.
The Bank of Lithuania states that customer funds cannot be held in central bank payment systems for safeguarding purposes. A Lithuanian EMI therefore needs a safeguarding account with a commercial credit institution, or an insurance or guarantee arrangement, before it launches. The firm's safeguarding and client assets service sources these accounts and designs the reconciliation.
CENTROlink is the payment system operated by the Bank of Lithuania. It gives licensed EEA payment service providers, including EMIs and payment institutions, direct access to SEPA Credit Transfer, SEPA Instant Credit Transfer and SEPA Direct Debit Core through one integration, together with Verification of Payee and a proxy lookup service.
A Lithuanian EMI applies to CENTROlink separately after licensing. It completes a self-assessment and submits a compliance report, and an audit report may also be required. CENTROlink provides payment access only; it does not hold safeguarded funds.
| Document | What it shows |
|---|---|
| Application form and company details | The applicant and the services requested |
| Programme of operations | The e-money and payment services, customers and markets |
| Business plan | Three-year forecasts and own funds calculations |
| Organisational structure | Functions, reporting lines, agents, distributors and outsourcing |
| Evidence of initial capital | EUR 350,000 paid up, with its source |
| Safeguarding measures | How customer funds are protected and reconciled |
| Governance and internal control | Risk management, compliance and internal audit |
| Incident and complaints procedures | Security incidents and customer complaints |
| Sensitive payment data and continuity | Data protection and business continuity arrangements |
| Statistical data principles | How performance, transaction and fraud data is collected |
| Security policy | Security risk assessment and controls |
| Anti-money laundering internal controls | Risk assessment, due diligence, monitoring and reporting |
| Auditor, directors and shareholders | Identity and fitness and propriety evidence |
The Bank of Lithuania checks within 5 business days whether all required documents are present. Once the file is accepted, it must decide within 3 months of receiving proper and sufficiently informative documents, or 2 months for a restricted licence. Where it asks for more information, the period runs from the date the additional documents are provided, and the Bank of Lithuania notes that it usually issues comments.
| Stage | Typical duration | Basis |
|---|---|---|
| Completeness check | 5 business days | Bank of Lithuania |
| Statutory decision period | 3 months (2 for restricted) | Bank of Lithuania |
| Submission to licence | 6 to 8 months | Firm's planning figure, including comments |
A narrower scope of services means less information to assess and a faster review, so the application should request only the services the product needs.
The Bank of Lithuania has raised its supervisory expectations of EMIs since 2023, with on-site inspections, fines and licence revocations where anti-money laundering, safeguarding or governance controls fell short of the law. Earlier descriptions of Lithuania as a jurisdiction with a light first year of supervision no longer reflect its approach.
Ongoing obligations across the EU are covered in the firm's briefing on e-money compliance in Europe.
Under the Markets in Crypto-Assets Regulation (MiCA), a Lithuanian EMI may issue e-money tokens, which are stablecoins referencing a single official currency, after notifying a crypto-asset white paper to the Bank of Lithuania. Custody or exchange of crypto-assets is a separate MiCA service, explained in the firm's guide to MiCA CASP authorisation in Lithuania.
The proposed PSD3 and Payment Services Regulation would bring EMIs into the payment institution framework. The Council and Parliament reached political agreement in late 2025; at the date of review the texts had not been formally adopted or published in the Official Journal. Existing EMIs are expected to receive a transition period once they are.
The firm's Lithuania EMI licence service prepares the full application and manages the Bank of Lithuania review through to licensing.
EUR 350,000 for a full EMI licence. A restricted-activities licence has no minimum capital requirement but is limited to Lithuania.
The state levy is EUR 1,463 for a full EMI licence and EUR 1,235 for a restricted-activities licence, paid to the State Tax Inspectorate before applying.
The Bank of Lithuania must decide within 3 months of receiving proper documents, or 2 months for a restricted licence. The firm plans 6 to 8 months from submission, including comments.
The head office must be in Lithuania and the Bank of Lithuania expects the business to be run there. In practice the chief executive, MLRO and key control functions are based in Lithuania.
A full EMI licence can be passported to every EEA state after notification through the Bank of Lithuania. A restricted licence is valid only in Lithuania.
Yes. Lithuanian EMIs can apply to join CENTROlink for SEPA credit transfers, SEPA Instant and direct debits, subject to its participation requirements.
No. The Bank of Lithuania states that customer funds cannot be held in central bank payment systems for safeguarding, so a commercial safeguarding account or insurance is needed.
Buckingham Capital Consulting has obtained e-money authorisations for firms including Dzing Finance, Hryze and Own Solutions since 2013, and prepares Lithuanian EMI applications to the Bank of Lithuania's published requirements. The firm builds the capital plan, safeguarding and anti-money laundering frameworks alongside the application, and arranges the safeguarding and operating accounts the EMI needs to launch.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.
This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.