EMI License in Lithuania
Last Update: 24.03.2026
Lithuania is one of the largest EMI authorization hubs in the European Union by number of licensed institutions, with more than 80 electronic money institutions supervised by the Bank of Lithuania (EBA Register, 2025). An EMI license in Lithuania is issued by the Bank of Lithuania (Lietuvos bankas) under Directive 2009/110/EC (EMD2) and the national Law on Electronic Money and Electronic Money Institutions.
The minimum initial capital requirement for an unrestricted EMI license is €350,000. The official application fee is €1,463. In practice, the total authorization process takes between 6 and 12 months, while the statutory regulatory review period is up to 3 months after a complete application is submitted.
Once authorized, a Lithuanian EMI may passport its services across all 30 EU/EEA states. Licensed institutions may also obtain direct access to SEPA via the Bank of Lithuania’s CENTROLINK infrastructure.
Quick Facts — EMI License in Lithuania
| Parameter | Value |
|---|---|
| Minimum initial capital | €350,000 (unrestricted) |
| Application fee | €1,463 |
| Annual supervisory fee | variable (based on supervisory methodology) |
| Realistic total timeline | 6–12 months |
| Statutory review period | up to 3 months (after completeness confirmation) |
| Passporting | Yes — 30 EU/EEA states (unrestricted only) |
| Regulator | Bank of Lithuania (Lietuvos bankas) |
| Legal form | UAB or AB |
| Physical office | Required |
| Direct SEPA access | Available via CENTROLINK |
| Resident director | Not required |
| Min. board size | 3 members + CEO |
| Local employees | At least 4 in Lithuania |
| MiCA stablecoin issuance | Permitted — Article 48, Regulation (EU) 2023/1114 |
What Is an EMI License in Lithuania?
EMI license in Lithuania is a profitable tool, increasing the prospects of your business’s growth and development. Gofaizen&Sherle specialists provide a full company set up with all the necessary infrastructure, and support at every stage and the result is a Lithuanian EMI license.
Every company engaged in issuing electronic currency in Lithuania must obtain an EMI license to legally operate in this jurisdiction. Having a license will allow offline/online payments, providing sub-accounts within a bank account, creating electronic wallets, providing individual IBANs, and transferring money to foreign accounts.
Holders of a Lithuanian license are allowed to provide the above services in the European Economic Area (EEA) without having to obtain an additional license in another EEA state. This license is passported for these activities, which allows you to work in other states. In addition, an entrepreneur may obtain a limited EMI license and provide its services only in Lithuania. In this case, certain restrictions may apply to the company’s turnover.
What Makes Lithuania a Leading EMI Jurisdiction?
Lithuania has developed a reputation for regulatory accessibility combined with EU passporting capability. The Bank of Lithuania operates as a single supervisory authority, and the authorization framework is aligned with EMD2 and PSD2 requirements.
The jurisdiction is frequently selected by fintech groups seeking EU market access, direct participation in SEPA infrastructure through CENTROLINK, and a regulator experienced in supervising electronic money institutions operating cross-border.
Lithuanian law distinguishes between unrestricted and restricted EMI licenses, allowing founders to select a structure depending on their operational scope and capital readiness.
Capabilities of Lithuanian EMI license compared to classic banks
| Payment Service Provider (PSP) | Electronic Money Institution (EMI) | Specialized Bank | Bank | |
|---|---|---|---|---|
| Payment services/money remittance (In and Out) | ✔ | ✔ | ✔ | ✔ |
| Fiat currency exchange | ✔ | ✔ | ✔ | ✔ |
| Issuance of E-money (opening multicurrency accounts, e-wallets) | — | ✔ | ✔ | ✔ |
| Lending to businesses and individual | — | not permitted under EMD2 | ✔ | ✔ |
| Deposits to businesses and individuals | — | — | ✔ | ✔ |
| Investment services, clearing, securities emissions | — | — | — | ✔ |
| EU Passporting to provide services in all EU countries | ✔ | ✔ | ✔ | ✔ |
| Payments System by Central Bank (for EUR settlement in SEPA area) | ✔ | ✔ | ✔ | ✔ |
What Are the Advantages of a Lithuanian EMI License?
- Relatively fast and simple procedure for obtaining an EMI license.
- Customers can obtain a personal IBAN.
- Possibility of SWIFT transfers.
- Remote opening of payment accounts for individuals and legal entities.
- The company can issue Visa or MasterCard payment cards.
- The company can transfer payments with global banks in different currencies.
- The company can make its own payment decisions and open accounts. In addition, correspondent accounts around the world.
- Providing services for cash deposit or withdrawal and all transactions necessary for payment account operation.
- An extremely attractive tax system with relatively low taxes ranks 6th in the international ranking of Tax competitiveness.
- The duration of the license is not limited to time.
- Passporting the license to other EU countries.
- All documents can be submitted in English. In addition, the jurisdiction of Lithuania complies with EU norms and therefore does not require in-depth research.
- Ability to conduct customer checks remotely as part of KYC procedures, through video link, digital signature, or electronic copies of documentation.
- Virtually no fines in the first year of the institution.
Stages of EMI License in Lithuania acquisition
Step 1: Pre-Application Consultation with the Bank of Lithuania
Result: Initial meeting with the Bank of Lithuania is successfully conducted; The approval to proceed with licensing is received from the Bank of Lithuania.
Gofaizen & Sherle conducts preliminary analysis of the client prepares for the initial meeting with the Bank of Lithuania, which includes:
- Analysis of the documents that client have on hands,
- Preparation of materials for the meeting with the Bank of Lithuania,
- Preparation for initial meeting with representatives of the Bank of Lithuania,
- Representing the client on the initial meeting with the bank of Lithuania.
Step 2: Company Incorporation and Documentation Preparation
Result: Basic documents have been prepared; there is a complete understanding of the project; preliminary approval from the Central Bank of Lithuania obtained.
Gofaizen & Sherle After the successful meeting with Bank of Lithuania conducts pre-licensing process which includes the following:
- General consulting regarding the EMI licensing process,
- Initial assessment for infrastructure require,
- Preparation of (a) Business plan (b) Program of Operations (c) preliminary Financial Forecasts,
- Shareholders and Group Companies Due Diligence,
- Local Company Formation and assistance with Bank account opening for share capital contribution,
- Human resource (at least 4 employees shall be in Lithuania) -assistance in essential staff recruitment process; drafting employment agreements,
- Premises search (HQ should be based in Lithuania).
Step 3: Application Submission and Regulatory Review
Result: All the necessary documents are drafted, application submitted; license granted.
Gofaizen & Sherle carry out assistance for licensing process according to the following steps:
Preparation of legal, financial and IT documents (non-exhaustive list):
- Description of the Management Structure.
- Compliance documentation (AML/KYC/KYT etc.).
- Financial documentation and forecasts.
- Operational Risk Procedures.
- IT Procedures.
Application for the license
- Submission of the application for the license.
- Representation and guiding through the entire licensing process.
- Payment of the state fees.
Step 4: Infrastructure and Operational Setup
Result: All the necessary arrangements for the project are completed; EMI license holder fully operative.
The stage is necessary for the license holder to be fully operative and be capable of initiating activity. Deliverables include the following:
- Setup of IT Systems -mediation in finding an IT system supplier and/ or facilitation of IT; system development to meet EMI License requirements.
- Compliance –consulting and training of employees on KYC process, AML and terrorist financing check tools according to the specs of the project.
- Banking Partner –to meet the requirements on clients’ funds segregation, provide FX and/or cross-border transfers, and other financial services.
Step 5: Maintenance and add-ons. Ongoing after license acquisition by request
This stage is necessary to support and maintain the structure and includes:
- Accounting services,
- Auditing,
- Opening of safeguarding accounts,
- Connection to SWIFT payment scheme,
- Agreement for the issuing own brand MasterCard cards,
- BIC/SWIFT and LEI codes acquisition,
- Reporting to Central Bank on the regularly basis,
- Applying for activity in other jurisdictions (incl. passporting),
- Consulting on the arising issues from Central Bank.
Total realistic timeline: 6–12 months.
What Types of EMI Licenses Are Available in Lithuania?
| Parameter | Unrestricted EMI | Restricted EMI |
|---|---|---|
| Geographic scope | EU/EEA (30 states) | Lithuania only |
| Minimum capital | €350,000 | Not required |
| Average e-money cap | No cap | €900,000/month |
| Passporting | Yes | No |
| MiCA e-money token issuance | Yes (subject to MiCA compliance) | Limited |
| Statutory review | Up to 3 months | 2 months |
How Much Does an EMI License in Lithuania Cost?
The total cost of obtaining an EMI license in Lithuania depends on the license type and business structure. Below is an indicative breakdown of the main cost components.
| Cost Component | Estimated Amount |
|---|---|
| Minimum initial capital (unrestricted EMI) | €350,000 |
| State application fee | €1,463 |
| Annual supervisory fee | Variable (based on supervisory methodology) |
| Company incorporation | €2,000–5,000 |
| Legal and compliance preparation | €20,000–50,000+ |
| Office and infrastructure setup | Variable |
| IT systems and AML implementation | Variable |
| Audit and ongoing reporting | Recurring annual expense |
| Total estimated budget | ∼€430,000–600,000+ |
EMI License in Lithuania and MiCA: Issuing E-Money Tokens
Under Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), only credit institutions and authorized electronic money institutions may issue e-money tokens (EMTs) within the European Union.
A Lithuanian EMI license therefore provides the regulatory status required to act as an issuer of e-money tokens, subject to compliance with MiCA requirements. These include preparation of a crypto-asset white paper, capital and reserve obligations, safeguarding of funds, and ongoing disclosure requirements.
Issuing an EMT under MiCA does not occur automatically upon obtaining an EMI license. Separate compliance steps and regulatory notifications are required. However, Lithuania’s experience in supervising electronic money institutions and its access to CENTROLINK infrastructure position it as a practical jurisdiction for fintech projects combining traditional e-money services with tokenized payment models.
EMI License vs. Payment Institution (PI) License in Lithuania
The Lithuanian financial ecosystem has two key types of licenses for electronic payment market participants: Payment Institution (PI) and Electronic Money Institution (EMI) licenses issued by the Bank of Lithuania:
Lithuania EMI license:
- Authorizes the creation and management of electronic money.
- Allows long-term storage of customers’ funds in electronic wallets.
- Funds can be used at any time to make payments or purchases.
- Subject to strict regulatory standards to ensure the security and stability of funds storage.
- Includes the functionality of the PI license and extends its capabilities with the issuance of electronic money.
Lithuania PI license:
- Focuses on processing payment transactions between parties.
- Requires prompt transfer of funds from payment accounts on the next business day after receipt of a payment order.
- Does not provide for long-term storage of client funds on accounts.
- Violation of rules on speed of funds transfer may result in sanctions, up to and including revocation of license.
- It is intended for companies providing direct payment services without the function of issuing electronic money.
The choice between EMI and PI licenses depends on the company’s business model and the expected volume of services. EMI is suitable for organizations wishing to offer their customers comprehensive electronic financial management solutions, including storage and reusability of funds. PI is aimed at companies specializing in payment services and money transfers, with a focus on fast and efficient transaction processing.
Comparison of EMI and PI Licenses in Lithuania
| Feature | EMI License | Payment Institution (PI) |
|---|---|---|
| Issue electronic money | Yes | No |
| Hold client funds long-term | Yes (e-wallets, stored value accounts) | No (funds must be transferred without long-term storage) |
| Initial capital | €350,000 | €20,000–€125,000 (depending on services) |
| Regulatory framework | Directive 2009/110/EC (EMD2) + PSD2 | Directive (EU) 2015/2366 (PSD2) |
| EU passporting | Yes | Yes |
| MiCA e-money token (EMT) issuance | Yes (Article 48, Regulation (EU) 2023/1114) | No |
What Documents Are Required for an EMI License Application?
- Charter of the payment institution;
- Corporate documents;
- Company requisites;
- Detailed business plan;
- Action program and activity structure;
- Proof of minimum share capital;
- Bank account;
- Founders’ passports and certificate of registration;
- A detailed description of the generally accepted measures to protect and regulate clients’ funds;
- Local office lease agreement;
- Criminal records of all beneficiaries;
- Description of the use of internal management controls, including administrative procedures, risk management procedures, and accounting procedures;
- Description of the internal management control mechanism for the performance of duties to prevent money laundering and terrorist financing;
- Description of company policies: customer funds protection measures, risk and accounting controls, AML, organizational structures, and branches;
- Confirmation that shareholder equity does not fall below a specified minimum;
- Description of the organizational structure, including the use of branches and agents, as well as plans to outsource and participate in payment systems for the distribution and redemption of electronic money;
- Information on persons with qualifying equity interests, their assets and rights, and proof of their suitability to properly manage the institution;
- Identification of management and proof of their reputation and compliance with legal requirements;
- Information on the audit services provided by the audit firm or independent auditor.
- €350,000 minimum initial capital required for an unrestricted EMI license under Directive 2009/110/EC (EMD2).
- Proof of origin and receipt of finances.
- Opening of a local office.
- Opening of a Lithuanian bank account.
- Availability of AML officer.
- Management board of at least 3 members plus a separately appointed CEO.
- At least 4 employees based in Lithuania.
- Own funds must at all times equal at least 2% of average outstanding electronic money, or €350,000, whichever is higher (Article 5, EMD2).
- No minimum capital requirement for restricted EMI license.
- Impeccable reputation of the company’s beneficiaries.
- A director or manager must have higher education in law or economics, management or business administration, and have an impeccable reputation, competence, and practical experience as the head of the institution.
- There must be at least one individual among the shareholders, Lithuanian residency is not required. The main requirement is the age over 18 and impeccable business reputation.
How Is the EMI Sector Regulated in Lithuania?
Lithuania attracts fintech companies with its innovative and business-friendly regulations developed by the Bank of Lithuania. The regulator’s mission is to maintain the stability and soundness of the national financial system, which is important for the management of EMI (electronic money institutions) licenses. The Bank actively cooperates with the European Central Bank and participates in shaping the monetary policy of the Eurozone, which directly affects EMI regulation.
Lithuania, as a member of the European Union, has integrated into its regulatory framework several key EU directives affecting the financial sector and data protection:
The Electronic Money Directive (EMD), or Directive 2009/110/EC regulates the activities of electronic money institutions, establishing rules for the issuance and circulation of electronic money in the European Union. The Directive aims to encourage the development and use of electronic money while ensuring its safety and security. It sets requirements for the capitalization, management, and supervision of institutions, which contributes to increasing consumer confidence and the efficiency of payment systems.
The Second Payment Services Directive (PSD2), or Directive (EU) 2015/2366 broadens and deepens the regulation of payment services in the EU, introducing new rules to improve and integrate the market for payment services in Europe. The Directive aims to increase competition includes requirements for payment transparency and security, and introduces the concept of open banking, allowing third parties access to customers’ banking data with their consent.
The EU Anti-Money Laundering Directives (AMLD) comprise several successive regulations aimed at preventing the use of the EU financial system for money laundering and terrorist financing. The directives require financial institutions to conduct thorough customer due diligence, monitor transactions, and report suspicious activity.
The General Data Protection Regulation (GDPR), which came into force in May 2018, sets strict rules for the processing and protection of personal data in all EU member states. The regulation ensures the rights of citizens to access, correct, and delete their data, and requires organizations to take measures to protect data, including appointing dedicated data protection officers and ensuring an adequate level of security for personal data.
The Lithuanian regulatory framework governing the activities of EMI licensees (electronic money institutions) is a comprehensive set of laws and regulations ensuring effective regulation in the financial services sector. These legislative acts not only contribute to streamlining the activities of EMIs but also create conditions for their stable and secure operation:
- The Law on Electronic Money and Electronic Money Institutions sets standards for the issuance and circulation of electronic money, as well as norms to be followed by institutions carrying out these operations.
- The Law of the Republic of Lithuania on Financial Institutions regulates various aspects of the operation of financial institutions, including management, financial reporting, and capitalization requirements.
- The Law of the Republic of Lithuania on Payment Institutions defines rules concerning the provision of payment services, including requirements for transparency of operations and consumer protection.
- The Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing establishes measures to combat financial crimes, such as customer due diligence and transaction monitoring.
- The Law of the Republic of Lithuania on the Legal Protection of Personal Data ensures the protection of personal data by GDPR standards by regulating the collection, processing, and transfer of data.
- The Rules on Issuing Licenses to Electronic Money Institutions and Payment Institutions describe the procedure for obtaining an EMI license in Lithuania to operate in the field of electronic and payment services, including evaluation criteria and required documentation.
From 17 January 2025, Lithuanian EMIs also fall within the scope of the Digital Operational Resilience Act (DORA, Regulation (EU) 2022/2554), which imposes requirements on ICT risk management, incident reporting, and third-party technology oversight. Compliance with DORA is assessed by the Bank of Lithuania during the authorization process.
How Gofaizen & Sherle Supports EMI License Applications in Lithuania
Gofaizen & Sherle has supported over 800 regulated licensing projects across 50+ jurisdictions, including Electronic Money Institution and Payment Institution authorizations in Lithuania, Malta, Cyprus, and the United Kingdom. The firm’s support for Lithuanian EMI applications covers:
- Pre-application regulatory assessment and jurisdiction selection advisory;
- Legal entity incorporation in Lithuania (UAB/AB structure);
- €350,000 capital structuring and source-of-funds documentation;
- Safeguarding model design and bank partner introduction for segregated accounts;
- Full documentation package preparation: business plan, AML/CTF policy, program of operations, IT architecture, governance framework;
- Key personnel recruitment support: compliance officer, MLRO, board members meeting Bank of Lithuania fitness and propriety requirements;
- CENTROLINK onboarding and SEPA connectivity setup;
- Post-licensing compliance maintenance and AML framework updates;
- MiCA readiness assessment for EMT (stablecoin) issuance.
For companies evaluating Lithuania against Malta, Cyprus, or other EU jurisdictions, Gofaizen & Sherle provides jurisdiction selection analysis based on timeline, operational requirements, and strategic goals. Contact: [email protected] | +372 602 8423
FAQ about the Lithuanian EMI license
What is an EMI license in Lithuania?
A Lithuanian EMI license is a regulatory authorization issued by the Bank of Lithuania allowing a non-bank entity to issue electronic money, safeguard client funds, provide IBAN-based payment accounts, and execute payment transactions. The unrestricted license enables operations across all 30 EU/EEA states via passporting. Lithuania has authorized more than 80 electronic money institutions, making it one of the largest EMI hubs in the EU by number of authorized institutions.
How much does an EMI license in Lithuania cost?
The Bank of Lithuania charges a one-time application fee of €1,463 for a full EMI license (€1,235 for a restricted EMI license). The annual supervisory fee is variable and calculated by the Bank of Lithuania based on the institution’s activity volume and supervisory methodology — it is not a fixed amount. The minimum initial capital requirement is €350,000 for an unrestricted license; no capital is required for a restricted license. Total first-year costs including capital, legal preparation, office setup, and minimum staffing typically range from €430,000 to €600,000+, depending on the scope of operations.
How long does it take to get an EMI license in Lithuania?
The Bank of Lithuania’s statutory review period is 3 months from submission of a complete application (2 months for restricted EMI). In practice, the total timeline from project initiation to license issuance is 6 to 12 months, with 3–4 months typically required for preparation and documentation before formal submission.
What is the minimum capital for a Lithuanian EMI license?
An unrestricted EMI license requires €350,000 minimum initial capital under Directive 2009/110/EC (EMD2). A restricted EMI license (Lithuania-only operations) has no minimum capital requirement, but is capped at €900,000 in average outstanding electronic money per month.
What is the difference between a restricted and unrestricted EMI license in Lithuania?
An unrestricted EMI license allows operations across all 30 EU/EEA states via passporting and requires €350,000 minimum capital. A restricted EMI license operates only within Lithuania, has no minimum capital requirement, but cannot exceed €900,000 in average outstanding electronic money per month or €3,000,000 in unrelated payment services. If those thresholds are exceeded, the institution must apply for an unrestricted license within 30 days.
Who regulates EMIs in Lithuania?
The Bank of Lithuania (Lietuvos bankas) is the sole competent authority for EMI authorization and ongoing supervision in Lithuania. It operates under EBA oversight as part of the EU supervisory framework. The Bank of Lithuania is known for its structured, transparent approach to authorization and its active encouragement of pre-application consultations.
Can a non-resident obtain a Lithuanian EMI license?
Yes. Lithuania does not require resident directors or shareholders. The legal entity must be incorporated in Lithuania (UAB or AB), maintain a physical office, and employ at least 4 staff in Lithuania. Non-residents may serve as directors and shareholders subject to fitness and propriety requirements.
What is CENTROLINK and what advantage does it provide?
CENTROLINK is the payment infrastructure operated by the Bank of Lithuania, giving licensed EMIs and payment institutions direct participant status in the SEPA payment area. Lithuanian EMIs can send and receive SEPA Credit Transfer and SEPA Instant payments without requiring a correspondent banking relationship, reducing operational costs and dependency on third-party banks. This infrastructure model is uncommon among EU regulators.
Can a Lithuanian EMI license be used to issue stablecoins?
Yes. Under Article 48 of Regulation (EU) 2023/1114 (MiCA), only an authorized EMI or credit institution may issue electronic money tokens (fiat-backed stablecoins) in the EU. A Lithuanian unrestricted EMI license satisfies this requirement. The EMT issuer must also comply with MiCA-specific reserve asset, redemption, and white paper obligations in addition to standard EMI requirements.
What documents are required for a Lithuanian EMI license application?
The application file must include: certificate of incorporation and articles of association, business plan with 3-year financial projections, program of operations, AML/CTF policy and risk assessment, governance structure and CVs of directors and key personnel, evidence of €350,000 initial capital and its source, safeguarding account arrangements, IT architecture documentation, and outsourcing agreements. Incomplete documentation is the primary cause of review delays.
What taxes apply to EMIs in Lithuania?
Lithuania applies a standard corporate income tax (CIT) rate of 17% from 1 January 2026 (increased from 16%). Small companies with annual revenue below €300,000 benefit from a reduced rate of 7% (increased from 6%) – as applicable under Lithuanian corporate tax law. Newly established small companies benefit from a 0% CIT rate for the first two years of operation. There is no withholding tax on dividends paid to EU companies meeting the participation exemption conditions under the EU Parent-Subsidiary Directive.
Does a Lithuanian EMI license require an annual audit?
Yes. Authorized EMIs are subject to annual external audit requirements. The audit firm must be independent and meet the requirements of the Lithuanian Law on Financial Institutions. Auditors review financial statements, safeguarding compliance, and AML system effectiveness. Annual audit costs typically range from €8,000 to €20,000 depending on the institution’s size and complexity.
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