Home › Blog › EU licensing

How to Become a Specialised Bank in Lithuania: 2026 Bank Licence Guide

Published 11 December 2019 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a bank licence in Lithuania is
  2. Specialised bank and full bank licences
  3. Services a specialised bank can provide
  4. Who a specialised bank suits
  5. Specialised bank or EMI
  6. Capital and prudential requirements
  7. Shareholders and management
  8. Internal arrangements the Bank of Lithuania assesses
  9. The licensing process
  10. Application documents
  11. Timeline and costs
  12. Deposit guarantee, payment systems and passporting
  13. Supervision after authorisation
  14. Frequently asked questions
Key takeaways
  • Lithuania offers two bank licences: a full bank licence with minimum capital of EUR 5 million and a specialised bank licence with minimum capital of EUR 1 million.
  • A specialised bank can take deposits, lend, provide payment services and issue e-money, but cannot provide investment services; its permitted activities are listed in Article 4(5) of the Law on Banks.
  • The Bank of Lithuania and the European Central Bank (ECB) assess applications jointly, and the licence is granted by the ECB on the Bank of Lithuania's proposal.
  • The Law on Banks requires a decision within 6 months of receiving the application, and in any case within 12 months; the Bank of Lithuania describes the process as taking roughly a year.
  • The state levy is EUR 4,157, paid to the State Tax Inspectorate before applying, and at least one head of administration must speak Lithuanian.
  • Deposits at a Lithuanian bank, including a specialised bank, are covered by the deposit guarantee scheme up to EUR 100,000 per depositor.

What a bank licence in Lithuania is

A bank is a credit institution: the only type of company allowed to take deposits and other repayable funds from the public and lend them on its own account. Any firm that wants to hold customer deposits in Lithuania, rather than safeguarded e-money or payment funds, needs a banking licence.

Lithuania is in the euro area, so bank licensing sits within the Single Supervisory Mechanism (SSM), the system of joint banking supervision by the ECB and national authorities. The Bank of Lithuania receives and assesses the application with the ECB, and the ECB grants the licence on the Bank of Lithuania's proposal under Regulation (EU) No 1024/2013 and the SSM Framework Regulation (Regulation (EU) No 468/2014). Providing banking services without a licence is prohibited.

Lithuanian law has allowed specialised banks since 2017. The licence was designed as a lower-capital entry point for new banks, particularly digital banks and lenders, and several of Lithuania's current banks started with it.

Specialised bank and full bank licences

Both licences follow the same authorisation process, requirements and supervision. The difference is the range of services and the minimum capital.

PointSpecialised bankFull bank
Minimum initial capitalEUR 1 millionEUR 5 million
Deposits and lendingYesYes
Payment services and e-moneyYesYes
Investment servicesNoYes
Permitted activitiesListed exhaustively in Law on Banks, Article 4(5)All financial services unless restricted by law
Licence granted byECB, on the Bank of Lithuania's proposalECB, on the Bank of Lithuania's proposal
State levyEUR 4,157EUR 4,157

The Bank of Lithuania notes that the capital requirement may be higher than the minimum, depending on the bank's planned activities. A specialised bank can later apply to change its licence into a full banking licence; the ECB did this for Revolut in December 2021, three years after it received a specialised bank licence.

Services a specialised bank can provide

The permitted activities of a specialised bank are set out exhaustively in Article 4(5) of the Law on Banks. They cover the core of retail and business banking:

  • Taking deposits and other repayable funds.
  • Lending, including mortgage lending.
  • Financial leasing.
  • Payment services.
  • Issuing and administering payment instruments such as travellers' cheques and bills of exchange.
  • Financial guarantees and sureties.
  • Financial intermediation as an agent.
  • Money management.
  • Creditworthiness assessment.
  • Safe deposit box rental.
  • Cash currency exchange.
  • Issuing electronic money.

Investment services, such as brokerage, portfolio management and safekeeping of financial instruments, are excluded. A bank that plans to offer investment products needs a full licence.

Who a specialised bank suits

  • Digital banks that want to hold insured customer deposits and lend from their own balance sheet.
  • Consumer, SME and buy-now-pay-later lenders that want deposit funding instead of wholesale or investor funding.
  • Electronic money institutions that have reached scale and want to keep customer balances as deposits and earn interest margin.
  • Groups outside the EU that want a regulated euro-area bank able to serve customers across the European Economic Area.

A firm that only needs to hold and move customer funds, without lending them, will usually reach the market faster with an EMI or payment institution licence. The firm's guide to the Lithuanian EMI licence and guide to the Lithuanian payment institution licence cover those routes.

Specialised bank or EMI

PointLithuanian EMILithuanian specialised bank
Minimum initial capitalEUR 350,000EUR 1 million
Customer fundsSafeguarded, not lentDeposits, which the bank may lend
Interest to customersNot permitted on e-moneyPermitted on deposits
Deposit guaranteeNoUp to EUR 100,000 per depositor
Licence granted byBank of LithuaniaECB, on the Bank of Lithuania's proposal
Statutory decision period3 months6 months, at most 12 months
Prudential rulesE-money own funds rulesEU Capital Requirements Regulation
State levyEUR 1,463EUR 4,157

Many founders start with an EMI, prove the model and then apply for a specialised bank licence once deposit funding and lending make commercial sense.

Capital and prudential requirements

Initial capital of EUR 1 million for a specialised bank or EUR 5 million for a full bank must be paid up before the licence is granted. This is the entry minimum. Once licensed, the bank is subject to the EU Capital Requirements Regulation (Regulation (EU) No 575/2013, as amended), which applies on a continuing basis. The CRR was amended by Regulation (EU) 2024/1623, the EU's implementation of the final Basel III standards, which has applied in most respects since 1 January 2025.

RequirementMinimumSource
Common Equity Tier 1 ratio4.5% of risk-weighted assetsCRR, Article 92
Tier 1 ratio6% of risk-weighted assetsCRR, Article 92
Total capital ratio8% of risk-weighted assetsCRR, Article 92
Liquidity coverage ratio100%CRR, Article 412, and Delegated Regulation (EU) 2015/61
Net stable funding ratio100%CRR, Article 428b

On top of these minimums the bank holds the combined capital buffers set under the Capital Requirements Directive (Directive 2013/36/EU) and any additional requirement set by the supervisor after its annual review. In practice a new bank's capital plan needs capital well above the EUR 1 million entry figure to fund its first years of lending growth and losses before it reaches profit.

Shareholders and management

Shareholders

Every holder of a qualifying holding must have an impeccable reputation, be financially sound and show a transparent source of funds. Where there are no qualifying holders, the assessment covers the 20 founders who together hold most of the capital or voting rights.

Management

Board members and senior managers must have an impeccable reputation and the qualifications and experience for their roles. At least one head of administration must speak Lithuanian. The Bank of Lithuania publishes an indicative minimum structure, which it states is guidance rather than a legal requirement.

Role or bodyIndicative minimum
Management boardAt least 3 members, including the Chief Risk Officer and Chief Financial Officer
Supervisory boardAt least 3 members
Head of administration and deputyThe chair of the management board is one of them
Head of internal auditAn independent person is recommended
Chief Technical Officer and Chief Legal OfficerRecommended to sit outside both boards
Audit and risk committeesSupervisory board members
Credit committeeManagement board members may serve

The numbers rise with the bank's complexity, scale and geographic reach. An MLRO and compliance officer are also needed for the anti-money laundering framework.

Internal arrangements the Bank of Lithuania assesses

  • Articles of association and a governance framework with clear lines of responsibility.
  • Risk management covering credit, liquidity, market, operational and concentration risk.
  • A remuneration policy that meets the Capital Requirements Directive.
  • Accounting, management information and internal control systems.
  • IT security and operational resilience under DORA (Regulation (EU) 2022/2554), in force since 17 January 2025.
  • Anti-money laundering and sanctions controls under the Law on the Prevention of Money Laundering and Terrorist Financing.
  • Premises in Lithuania and appropriate insurance.
  • An operating plan that matches the founders' capacity to deliver it, with the bank ready to provide services safely from the day it is licensed.

The DORA requirements for banks are covered in the firm's briefing on digital operational resilience.

The licensing process

  1. Ex-ante evaluation. The applicant studies the rules, holds preliminary meetings with Bank of Lithuania specialists and submits draft documents for an informal review. The ECB may take part. This stage covers the business model and financial capacity, risks and risk management, shareholders and funding, managers, organisation and readiness. It is optional but encouraged.
  2. Submission. The applicant pays the state levy and submits the application. The Bank of Lithuania checks within 5 business days that all required documents are present and, if there are no formal deficiencies, accepts the application.
  3. Joint assessment. The Bank of Lithuania passes the file to the ECB and the two assess it together, issuing joint requests where information is missing.
  4. Decision. The Bank of Lithuania sends its proposal to the ECB, which grants or refuses the licence.
  5. Launch. The bank registers, joins the deposit guarantee scheme, connects to payment systems and begins operating under supervision.

Application documents

The full list is in the Annex to the Rules for Licensing of Bank Activities (Bank of Lithuania Resolution No 03-196 of 22 December 2016), and submissions must also follow Resolution No 58 on applications for authorisation. The file typically covers the following.

DocumentWhat it shows
Business plan and financial forecastsProducts, customers, balance sheet growth, capital and liquidity over at least three years
Capital plan and stress testsCapital and liquidity ratios under base and adverse scenarios
Articles of association and governanceBoards, committees, responsibilities and reporting lines
Shareholder informationOwnership chain, reputation, financial soundness and source of funds
Management fitnessReputation, qualifications and experience of each board member and key function holder
Risk management and internal controlPolicies for each risk type, internal audit and compliance
IT, security and outsourcingSystems, DORA framework and material providers
Anti-money laundering frameworkRisk assessment, customer due diligence, monitoring and reporting
Recovery and exit planningHow the bank would restore its position or wind down in an orderly way

Timeline and costs

Article 9(11) of the Law on Banks requires a decision within 6 months of receiving the application. Where documents are missing or deficient, the 6 months run from receipt of the additional information, and in any case the decision must be taken within 12 months of the application. The Bank of Lithuania describes the authorisation process as taking roughly a year.

StageTypical durationBasis
Ex-ante evaluation and draftingSeveral monthsDepends on the applicant's readiness
Completeness check5 business daysBank of Lithuania
Statutory decision period6 months, at most 12Law on Banks, Article 9(11)
Overall authorisation processRoughly a yearBank of Lithuania

The state levy is EUR 4,157 for a banking licence, including a specialised licence, paid to the State Tax Inspectorate before applying; a further EUR 149 applies if the group must be entered in the public list of financial conglomerate undertakings. The larger costs are the capital itself, the management team, core banking technology, audit and deposit guarantee contributions.

Deposit guarantee, payment systems and passporting

A licensed Lithuanian bank, including a specialised bank, joins the national deposit insurance scheme, which protects each depositor up to EUR 100,000 under the EU Deposit Guarantee Schemes Directive. The bank pays contributions to the scheme based on its covered deposits and risk profile.

Lithuanian banks can join CENTROlink, the Bank of Lithuania's payment system, for SEPA credit transfers, SEPA Instant and direct debits. A licensed bank can also passport its permitted services across the European Economic Area under the Capital Requirements Directive, by branch or cross-border services, after notification through the Bank of Lithuania. The firm's banking and payment processing service arranges the correspondent and scheme relationships a new bank needs.

Supervision after authorisation

  • Day-to-day supervision by the Bank of Lithuania, within the SSM; the ECB remains responsible for licensing and for approving qualifying holdings.
  • Regular prudential and financial reporting on capital, liquidity, large exposures and leverage.
  • An internal assessment of capital and liquidity adequacy each year, reviewed by the supervisor, which may set additional capital requirements.
  • Anti-money laundering supervision and reporting to the Financial Crime Investigation Service.
  • DORA incident reporting, resilience testing and third-party oversight.
  • Recovery planning and resolution planning with the resolution authority.

Buying an existing Lithuanian bank requires approval of the new qualifying holders, decided by the ECB on the Bank of Lithuania's proposal. The Bank of Lithuania recommends an ex-ante assessment before such an acquisition. The firm's transactions and change of control service manages that approval.

Frequently asked questions

What is the minimum capital for a bank in Lithuania?

EUR 5 million for a full bank and EUR 1 million for a specialised bank. The Bank of Lithuania may require more depending on the planned activities.

What can a specialised bank not do?

It cannot provide investment services such as brokerage or portfolio management. Its permitted activities are listed exhaustively in Article 4(5) of the Law on Banks.

Who grants a bank licence in Lithuania?

The ECB grants the licence on the proposal of the Bank of Lithuania, after a joint assessment of the application.

How long does it take to get a bank licence in Lithuania?

The Law on Banks requires a decision within 6 months of the application, and at most 12 months. The Bank of Lithuania describes the process as taking roughly a year.

How much is the state levy for a Lithuanian bank licence?

EUR 4,157, paid to the State Tax Inspectorate before applying, for both full and specialised bank licences.

Are deposits at a Lithuanian specialised bank protected?

Yes. Deposits are covered by the Lithuanian deposit insurance scheme up to EUR 100,000 per depositor.

Can a specialised bank become a full bank?

Yes. The bank can apply to change its licence to a full banking licence, which the ECB grants on the Bank of Lithuania's proposal.

Does a bank's management need to speak Lithuanian?

At least one head of administration must speak Lithuanian. The Bank of Lithuania lists this among its requirements for bank management.

References

  1. Bank of Lithuania: Authorisation of banks
  2. Bank of Lithuania: AB Fjord Bank granted a specialised bank licence
  3. Bank of Lithuania: Banking licence granted to Revolut Bank UAB
  4. Regulation (EU) No 1024/2013 conferring supervisory tasks on the ECB (EUR-Lex)
  5. Regulation (EU) No 575/2013 on prudential requirements for credit institutions (EUR-Lex)
  6. Directive 2013/36/EU on access to the activity of credit institutions (EUR-Lex)
  7. Directive 2014/49/EU on deposit guarantee schemes (EUR-Lex)

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained e-money and payment authorisations for firms including Dzing Finance, Hryze and Nexpay since 2013, and supports founders planning the step from an EMI to a specialised bank licence in Lithuania. The firm prepares the business plan, capital plan, governance and anti-money laundering frameworks for the joint Bank of Lithuania and ECB assessment, and arranges the banking and payment relationships the new bank needs.

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.