17/10/25
Lithuania’s regulatory framework for Electronic Money Institutions (EMIs) offers a compelling pathway for fintech companies aiming to operate across the European Union. The Bank of Lithuania provides two distinct licensing options-restricted and unrestricted-catering to various business models and operational scopes.
📜 Regulatory Framework and Licensing Process
Under the Republic of Lithuania’s Law on Electronic Money and Payment Institutions, entities seeking an EMI license must submit a comprehensive application to the Bank of Lithuania. This includes detailed documentation as specified in Annexes 1 and 3 of the Rules on the Licensing of Electronic Money and Payment Institutions. The application process is conducted in Lithuanian or English, with foreign documents requiring legalisation or an apostille.
A restricted EMI license permits operations solely within Lithuania, with relaxed requirements regarding own funds and shareholder eligibility. In contrast, an unrestricted EMI license allows for pan-European operations, subject to stricter capital and compliance obligations.
⚖️ Comparative Analysis and Implications
Lithuania’s EMI licensing framework aligns with EU directives, notably the Electronic Money Directive (EMD2), facilitating cross-border service provision within the EU. The dual-licensing approach enables businesses to select a model that aligns with their operational scale and risk appetite. For instance, Payhawk Financial Services UAB, granted an EMI license in July 2023, exemplifies how companies can leverage Lithuania’s regulatory environment to expand their service offerings across multiple EU jurisdictions.
💼 Practical Considerations for Fintech Entities
Entities operating under an EMI license are authorised to issue electronic money and provide a range of payment services, including account management, payment transactions, and issuance of payment instruments. Moreover, the Bank of Lithuania’s proactive approach in guiding applicants through the licensing process ensures a transparent and efficient pathway to authorisation.
✅ Conclusion
Lithuania’s EMI licensing regime presents a strategic advantage for fintech companies seeking to establish a foothold in the European market. With clear regulatory guidelines and a supportive supervisory environment, Lithuania offers a conducive landscape for the growth of electronic money and payment services.
For tailored legal advice and assistance in navigating the EMI licensing process, contact NUR Legal. Our team specialises in financial services regulation and can provide expert guidance to ensure compliance and successful authorisation. Visit us at NUR-Legal.com or contact us directly at info@nur-legal.com
Kätrin Särap