Founded 1998
Licensed provider specialising in
fintech licensing and compliance
An electronic money institution licence from the Bank of Lithuania to issue e-money and run payment accounts.Choose the full licence for the EU/EEA or the restricted licence for Lithuania-only start-ups with no minimum capital.
Overview
Electronic money institutions in Lithuania are authorised by the Bank of Lithuania under the Law on Electronic Money and Electronic Money Institutions. Besides e-money, an EMI may provide the payment services listed in the Law on Payments, such as money transfers and issuing or acquiring payment instruments. The application is filed online with the Bank of Lithuania, in English or Lithuanian.
Hold client money as e-money in payment accounts and redeem it, next to transfers, cards and acquiring
Start with a restricted licence in Lithuania and move to the full licence and EU passport as you grow
The Bank of Lithuania invites applicants to talk early, before the application is filed
File online in English or Lithuanian; the completeness check takes up to 5 business days
A full EMI licence reaches other EU Member States after a notification, without a second licence
Applicants have direct access to the Bank of Lithuania specialists who assess their documents
The Bank of Lithuania asks for detailed information at the application stage, because an EMI must be ready to operate safely on the day it is licensed. We prepare the application on its forms, set up the Lithuanian company (UAB) with its capital and governance, and plan safeguarding and AML before you file. Licence, company and compliance come from one team.
Coverage
The two Lithuanian licences suit different stages. A start-up can test its product under the restricted licence, while a firm with EU-wide plans applies for the full licence from the start. These are the set-ups we see most often.
You need: to launch an e-money product in one market first, without tying up €350,000 of initial capital.
Lithuania gives you: a restricted licence valid in Lithuania with a shorter document set, and a path to the full licence as you grow.
You need: to serve clients in several EU countries from one licensed base, with accounts, transfers and cards.
Lithuania gives you: a licensed base run from Vilnius for e-money and payment services, extended to other Member States by notification.
You need: to issue payment cards to users and accept card payments for merchants.
Lithuania gives you: issuing and acquiring of payment instruments as payment services under the same EMI licence.
You need: a regulated EU subsidiary for an existing payments business based outside the EU.
Lithuania gives you: a Lithuanian EMI held by the group, with shareholders assessed for repute and financial soundness.
Lithuania combines an open, early-contact approach from its central bank with a licence designed for start-ups. The restricted licence lets a new firm begin without the full capital, and the full licence opens the EU market by notification.
The Bank of Lithuania asks applicants to contact it as early as possible, explains its expectations, reports on progress and gives direct access to its assessors.
The restricted EMI licence has no minimum initial capital and no shareholder assessment. It is limited to Lithuania and to an average of €900,000 outstanding e‑money.
The Bank of Lithuania scrutinises what you plan to do. Applying only for the services you need means fewer documents and a faster assessment.
With the full licence, a Lithuanian EMI can issue e-money and provide payment services in other EU Member States after a notification procedure.
Comparison
The Bank of Lithuania issues a full EMI licence with EU passporting, and an EMI licence to engage in restricted activities, created to help start-ups enter the Lithuanian market. A restricted EMI that outgrows its limit applies for the full licence. If your model needs payment services but no e-money, compare the Payment Institution licence.
| Factor | Full EMI licence | Restricted EMI licence |
|---|---|---|
| Minimum initial capital | €350,000 | None |
| Average outstanding e-money | Unlimited | Up to €900,000 a month (6‑month average) |
| Where it is valid | Lithuania and the EU/EEA by notification | Lithuania only |
| Application documents | Full set (Annex 1) | Shorter set (Annex 3) |
| Shareholder fit and proper assessment | Yes | No |
| State levy for the licence | €1,463 | €1,235 |
As published by the Bank of Lithuania. A restricted EMI that exceeds the e-money limit must apply for the full licence within 30 days.
Pricing
Our EMI packages for a Lithuanian licence, from first opinion to a working institution. Start with Gold to settle the licence type and budget. Platinum is the complete Bank of Lithuania application up to filing. Custom also staffs and equips the EMI in Vilnius and keeps compliance running once it is licensed.
Gold
€10,000fixed fee
A written legal opinion on your model under the Lithuanian e-money and payments laws: full or restricted licence, capital and own funds, safeguarding and a plan for the Bank of Lithuania application.
Platinum
From €80,000
We prepare the Lithuanian application with the documents the Bank of Lithuania lists for your licence type, from the operating plan and internal control rules to the early meetings and the filing.
Custom
From €150,000
The Lithuanian application plus the operation behind it: the heads and key functions, the office in Vilnius, safeguarding and operational banking, and compliance support after the licence.
* Indicative prices, excluding VAT and subject to final confirmation; Platinum and Custom are quoted for your scope. Not included: the €350,000 initial capital for a full licence, registering the Lithuanian company, and the state levy for the licence (€1,463, or €1,235 for a restricted licence), paid to the State Tax Inspectorate before the application.
Timeline
Plan for 6 to 12 months from first preparation to the licence. The Bank of Lithuania usually asks for more information during its assessment, and each request restarts its review term, so a well-prepared file and early contact are what keep a project on time.
Shape the application with the Bank of Lithuania before you file.
Business model, licence type, operating plan, the company and its heads, capital, safeguarding, internal control and AML, discussed with the Bank of Lithuania as early as possible.
~2 to 4months
Bank of Lithuania: The Bank of Lithuania encourages applicants to contact it early to discuss which services need a licence.
What to prepare
Build the file around how the EMI will operate.
The application is checked for formal deficiencies.
The state levy is paid first. The application is filed electronically through the Bank of Lithuania portal, e-signed, in Lithuanian or English; the Bank then checks that nothing is missing.
5business days
Bank of Lithuania: The completeness review takes up to 5 business days.
What must be complete
The documents follow the Bank of Lithuania licensing rules.
Several specialists assess the file; the Board decides.
Assessment of the operating plan, capital, heads and shareholders, internal control and risk management, with comments and meetings where needed. The Board of the Bank of Lithuania takes the decision.
~4 to 7months
In practice: The review term restarts with each request for additional documents, so most applications take longer than the legal minimum.
What is assessed
Whether the EMI can provide its services safely and soundly.
Licence granted, operations start, notifications filed.
Start operating in Lithuania with safeguarding and AML controls in place and, with a full licence, notify the Member States where you will provide services.
~6 to 12months total
Passporting note: The Bank of Lithuania forwards a complete notification to the host authority within one month. A restricted licence cannot be passported.
What to maintain
A licensed EMI is supervised on its day‑to‑day operation.
* Indicative end-to-end duration. The statutory terms run from a complete application; requests for additional information restart them, so the quality of the file decides the real pace.
Process
Step 1
We review your business model, the services that need a licence and your markets, and decide between the full and the restricted EMI licence.
Step 2
We register your Lithuanian company (UAB), appoint its heads, and arrange the initial capital where the full licence requires it.
Step 3
We meet the Bank of Lithuania early, pay the state levy, and file the application with the documents its rules list for your licence type.
Step 4
After the Board of the Bank of Lithuania decides, we support safeguarding, AML compliance and the notifications to provide services in other Member States.
Requirements
The Bank of Lithuania expects an EMI to be ready to operate on the day of authorisation. It therefore asks for detailed information with the application and assesses the people, the capital, the plan and the controls.
A full EMI needs initial capital of at least €350,000. A restricted EMI has no minimum initial capital requirement.
The EMI is a Lithuanian UAB or AB with its head office in Lithuania, and the e-money business must be run from Lithuania. Its heads must be of good repute and have the qualifications and experience for their duties. For a full licence, qualifying shareholders must also be:
The application form and documents are set by the Bank of Lithuania licensing rules (Annex 1 for the full licence, Annex 3 for the restricted licence). The EMI needs:
Client funds are never mixed with the EMI’s own money. Funds still held after the next business day go to a separate account at an EU credit institution or the Bank of Lithuania, into secure liquid assets, or are covered by insurance or a guarantee.
FAQ
The Bank of Lithuania. Its specialists assess the application, and the Board of the Bank of Lithuania decides whether to issue the licence.
The Law on Electronic Money and Electronic Money Institutions, the Law on Payments for the payment services an EMI may provide, and the Lithuanian law on the prevention of money laundering and terrorist financing. The Bank of Lithuania licensing rules set the application forms.
The full licence requires €350,000 initial capital and can be used in other EU Member States after a notification. The restricted licence has no minimum initial capital, is valid only in Lithuania, and is limited to an average of €900,000 outstanding e‑money a month.
Count on about 6 to 12 months in total, including preparation. The Bank of Lithuania checks completeness within 5 business days, but during the assessment it usually asks for more information, and each request restarts its review term. A complete, consistent file is the best way to keep the timeline.
A state levy of €1,463 for the full licence or €1,235 for the restricted licence, paid to the State Tax Inspectorate before the application. Our packages are listed in the pricing section.
When the average outstanding e-money exceeds €900,000 a month, the institution must apply to the Bank of Lithuania for the full EMI licence within 30 days.
Yes. Besides issuing e-money, an EMI may provide the payment services of the Law on Payments, for example money transfers and issuing or acquiring payment instruments.
With the full licence, yes. The EMI notifies the Bank of Lithuania before it starts in another Member State, directly or through a branch or distributors, and the Bank forwards the notification to the host authority within one month of receiving all information. The restricted licence is valid in Lithuania only.
Electronically, through the Bank of Lithuania licensing portal, with e-signed documents in Lithuanian or English. Documents in other languages need a translation, and foreign documents usually an apostille or legalisation.
Client funds may not be mixed with the EMI’s own funds. Funds still held at the end of the next business day must sit in a separate account at an EU credit institution, the Bank of Lithuania or another EU central bank, or in secure liquid assets, or be covered by an insurance policy or a guarantee.
The EMI must be a Lithuanian private or public limited company (UAB or AB) with its head office in Lithuania, and the Bank of Lithuania expects the e-money business to be run from there. You can apply for a company being established or an existing one. We can set up the Lithuanian company (UAB) and arrange its governance and capital for the application.
Your EMI does, and we can carry part of the load: an outsourced MLRO or compliance officer, an AML team for onboarding and monitoring, help with reports to the Bank of Lithuania and DORA for ICT risk. All compliance services.
Contact
Tell us about your project and receive a tailored proposal with indicative timelines and a budget from our legal and compliance team.
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