Lithuanian Electronic Money Institution License
Major fintech players like "Revolut" and "Paysera" obtained their licenses here, attesting to
Lithuania’s reputable regulatory environment.
ADVANTAGES
Fast Licensing Process
Regulatory review can be as quicker than other EU regulators, with an open dialogue approach by the Bank of Lithuania to streamline applications.
Fintech-Friendly Environment
Lithuania’s regulator is known for fintech support – over 100 EMI/Payment licenses issued, making it a top EU jurisdiction post-Brexit.
EU Passporting
A Lithuanian EMI license grants access to provide e-money services across the entire European Economic Area (EEA) without additional licenses
Optional “Restricted” License
Startups can begin with a restricted EMI license (no initial capital required) operating within Lithuania only , then upgrade to a full license for EU expansion.
WHY LITHUANIA?
Lithuania offers a clear and transparent legal framework for e-money institutions, grounded in EU directives. The Bank of Lithuania (central bank) actively encourages early consultation with applicants, helping new entrants understand licensing expectations . This collaborative approach results in a smoother process and clarity on requirements.
REQUIREMENTS
Applicants must meet several important requirements to secure an EMI license in Lithuania
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Local Incorporation
The entity must be a Lithuanian company (UAB) with its registered office in Lithuania. A physical office is required (a mere empty room or virtual office won’t suffice), as the regulator may inspect premises. At least part of the EMI’s operations should be in Lithuania (e.g. some staff or infrastructure).
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Initial Capital
A minimum paid-up capital of €350,000 is required for an unrestricted EMI license. This must be deposited and proven in the application. The capital provides a buffer for operational risks and must be maintained throughout the business. (For a restricted EMI license limited to Lithuania, no minimum capital is required, but monthly outstanding e-money is capped at €900,000 until a full license is obtained.)
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Fit and Proper Management
Directors and key executives must have solid experience in finance or payments and a clean reputation. The Bank of Lithuania scrutinises CVs to ensure the management is qualified to run an EMI. At least one management board member typically should be based in Lithuania or readily available. Additionally, shareholders (owners) with qualifying holdings must be transparent, financially sound, and of good repute. Background checks (police clearance, etc.) will be conducted.
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Correct Documentation
Detailed internal documentation is the cornerstone of the application. This includes: an extensive Business Plan with 3-year financial projections, an Organisational Structure chart, descriptions of the IT systems and security measures, risk management policies, internal control procedures, and a full Anti-Money Laundering (AML) / Know-Your-Customer policy set. Plans for safeguarding client funds (e.g. using a segregated account or insurance) are required. The documentation must fully comply with Lithuanian laws and European Banking Authority guidelines. The regulator will closely review these to ensure the EMI is prepared to operate in a safe and sound manner from day one.
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Auditor and Insurance
The EMI must appoint an independent external auditor (for annual financial audits) and often is expected to have professional indemnity insurance (especially if providing certain payment services). Commitment or contracts for these should be in place by licensing.
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Safeguarding Measures
As customer funds will be received, the EMI must demonstrate how it will safeguard e-money funds as per law – usually by holding them in a ring-fenced account with an EU credit institution or obtaining insurance/guarantee. Documentation of agreements or policies on fund safeguarding must be provided.
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Program of Operations
The application requires a comprehensive program of operations describing all planned services and how they will be delivered. This includes details on the target market, onboarding process, transaction flow, and any agents or distributors to be used. If any critical function is outsourced (e.g. IT platform, cloud hosting, compliance services), the EMI must provide contracts and ensure outsourcing meets regulatory requirements (e.g. cloud providers like AWS/Google are considered third-party providers and must fulfil certain conditions).
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In summary, Lithuania expects a turn-key readiness at the time of application – the company should be essentially ready to launch, pending only the licence approval. Preparations often take a few months to ensure all pieces (capital, staff, office, policies) are in order.
PROCEDURE
Obtaining an EMI license in Lithuania involves a structured process with clear stages:
Preparation & Pre-application
It’s advised to engage with the Bank of Lithuania early. Typically, an initial meeting or call is held to discuss the business model and licensing scope. The applicant should incorporate a Lithuanian company (UAB) and gather required documentation (corporate documents, policies, etc.). A business plan and financial forecasts are crucial, demonstrating a viable model and compliance readiness.
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Submission of Application
The formal application (with all annexes) is submitted to the Bank of Lithuania. Within 5 business days, regulators check if all documents are present; if yes, the application is formally accepted for review. A licensing fee payment proof (to the tax authority) must accompany the application.
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Regulatory Assessment
The Bank of Lithuania’s specialists evaluate the application in depth. By law, the decision must be made within 3 months if all information is sufficient (for restricted EMI, 2 months). In practice, initial submissions often receive comments or requests for additional data. The applicant will be asked to correct deficiencies or provide clarifications – common iterations involve refining the internal procedures, IT security measures, etc. Once the application is deemed complete, the 3-month clock for final decision starts.
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Approval and Licensing
Upon satisfaction, the Board of the Bank of Lithuania issues the EMI licence. The EMI can then commence activity. If the application is rejected (e.g. due to major shortcomings), the decision will detail the reasons and the firm may reapply after addressing issues. Fortunately, Lithuania’s open communication often prevents surprises by resolving issues during the review phase.
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Estimated Timeline
In ideal cases with a thorough initial application, an EMI licence can be obtained from 4 to 9 months. However, realistically many applications take closer to 6 months if multiple rounds of feedback are needed. Preparation is key to expedite the process.
OUR OFFERS
NUR Legal provides an end-to-end service package to streamline the complex EMI licensing process. Our offers include
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For those still evaluating the regulatory landscape, we offer a comprehensive Legal Opinion that assesses answers all of your questions in legal aspect before moving forward.
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For clients ready to proceed, we deliver a full-scope package that includes everything necessary to start your fintech business.
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Full package Licensing
Navigating the EMI licensing process can be challenging. Our team provides end-to-end support to make it seamless
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Consultation on license type and business model fit
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Advice on corporate structure and EU passporting
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Company setup and bank account opening in Lithuania
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Legal address and office registration support
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Business plan and financial forecast drafting
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Preparation of IT, AML, and risk policies
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Help hiring key staff to meet 4-eye principle
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Drafting employment contracts and board resolutions
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Liaison with the Bank of Lithuania as main contact
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Application submission and query handling
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Attendance at meetings and Lithuanian communication
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Fast resolution of regulator comments
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Guidance on speeding up the process
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Post-licensing compliance and reporting support
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Ongoing regulatory advice and compliance monitoring
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And more — complete legal and operational support for EMI licensing success
LEGAL FRAMEWORK
The EU Electronic Money Directive (2009/110/EC), implemented in Lithuania, defines electronic money institutions and their rights across the EU. It ensures a level playing field and strong consumer protection for e-money issuers operating in member states. Lithuanian electronic money institution (EMI) licenses fully comply with the directive’s standards, which enables EU passporting.
The Republic of Lithuania Law on Electronic Money and Electronic Money Institutions is the primary legislation governing EMI activities in Lithuania. It sets out licensing requirements, including the €350,000 capital threshold, safeguarding obligations, and rules for ongoing supervision. The law also distinguishes between unrestricted and restricted EMI licenses, specifying the conditions applicable to each type.
The Republic of Lithuania Law on Payments establishes the payment services that EMIs and payment institutions can provide. It transposes the EU Payment Services Directive (PSD2) into Lithuanian law. An EMI licensed in Lithuania is entitled not only to issue electronic money but also to offer payment services such as money remittance, payment account provision, and card acquiring. This effectively allows EMIs to combine e-money and payment institution permissions under a single license.
The Bank of Lithuania Regulations and Guidelines provide detailed rules, including the “Rules on the Licensing of Electronic Money and Payment Institutions” and various resolutions covering outsourcing, risk management, and safeguarding practices. Applicants are required to comply with these regulations when preparing their internal policies. The Bank of Lithuania also enforces European Banking Authority (EBA) Guidelines on areas such as ICT security and anti-money laundering, ensuring that Lithuanian EMIs adhere to European best practices.
The Supervisory Authority, the Bank of Lithuania, acts as the sole regulator and supervisor for EMIs. It reviews license applications and, after granting a license, monitors compliance through periodic reporting and onsite inspections. The Bank follows an open-door approach and engages proactively with fintech companies, which supports new market entrants. All licensed EMIs are listed in the Bank of Lithuania’s public register, providing transparency for consumers and business partners.
OUR SERVICES
Ready to pursue a Lithuanian EMI license? Contact us for tailored legal guidance and a smooth licensing process in Lithuania.
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At NUR Legal, our services encompass:
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Regulatory Consultation
Assessing the best jurisdiction and license type for your business.​
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Documentation Assistance
Preparing and reviewing all necessary documents.​
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Application Management
Handling the submission and liaison with regulatory bodies.​
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Post-Licensing Support
Ensuring ongoing compliance and addressing any regulatory updates.
