Founded 1998
Licensed provider specialising in
fintech licensing and compliance
A specialised bank is a fully regulated EU credit institution that can take deposits, lend and run payments.Lithuania sets its initial capital at €1 million, against €5 million for a full bank, with the same supervision.
Overview
Lithuania’s Law on Banks created the specialised bank as a bank that may provide only a defined list of services. It is a credit institution like any other bank: the Bank of Lithuania assesses the application, the European Central Bank takes the licence decision, and every other requirement and the supervision are the same as for a full bank.
Take deposits from the public, a right reserved for credit institutions, plus lending and payments
Initial capital of at least €1 million, a fifth of the €5 million a full Lithuanian bank needs
Add e-money issuance, guarantees, leasing and cash services from the same licence
Provide the services in your licence in other EU/EEA countries by notification
A licence without a time limit, which can later be amended to a full bank licence
An optional ex-ante assessment with the Bank of Lithuania before you file the application
A bank licence is the most demanding authorisation in financial services: the business plan, capital, governance, risk management and the people behind the bank are all assessed in detail by two supervisors. We prepare the application with you, set up the Lithuanian company and its governance, and build the compliance framework a bank needs. Licence, company and compliance come from one team.
Coverage
A specialised bank suits businesses that need to hold client deposits or fund lending from deposits, but do not need investment services. These are typical models for a Lithuanian specialised bank.
You need: to collect deposits from the public and fund consumer or business lending from them.
Lithuania gives you: deposit-taking and lending, including mortgages and leasing, from a credit institution with €1 million initial capital.
You need: to offer interest-bearing accounts and credit, which an EMI or payment institution cannot provide.
Lithuania gives you: deposits and lending on top of payment services and e-money issuance, under one banking licence.
You need: to lend to businesses and issue guarantees and sureties for their trade.
Lithuania gives you: lending, sureties and guarantees, and payment services for business clients from a supervised EU bank.
You need: an EU-licensed credit institution for a banking or fintech group based outside the EU.
Lithuania gives you: a Lithuanian bank with EU passporting for its licensed services, and a path to a full bank licence.
The specialised bank lowers the entry capital for a deposit-taking institution without lowering the standard of supervision. For a focused business model, it is a realistic route to an EU banking licence.
At least €1 million in initial capital instead of €5 million for a full bank, using the lower threshold the EU banking directive allows for some credit institutions.
The Bank of Lithuania offers an ex-ante assessment before the application and lists the specialised bank licence in its Newcomer Programme.
The decision is due within 6 months of the application, or of any additional documents requested, and never later than 12 months.
Once the bank holds €5 million and is ready for all services, the supervisor amends its licence to that of a full bank.
Comparison
The specialised bank sits between an electronic money institution and a full bank. It can take deposits and lend, which an EMI cannot, but it may not provide investment services, which a full bank can. The authorisation process and supervision are the same as for a full bank.
| Factor | Specialised bank | Full bank | EMI |
|---|---|---|---|
| Minimum initial capital | €1 million | €5 million | €350,000 |
| Deposits from the public | Yes | Yes | No |
| Lending and leasing | Yes | Yes | Limited, linked to payments |
| Payment services and e-money | Yes | Yes | Yes |
| Investment services | No | Yes | No |
| Licence decided by | ECB | ECB | Bank of Lithuania |
Based on the Law on Banks and the Bank of Lithuania’s guidance. The supervisor may require more capital than the minimum depending on the planned activities.
Pricing
Three packages for a Lithuanian specialised bank, quoted for your model. Gold tests whether a bank licence fits your plans, Platinum prepares and files the application, and Custom builds the bank around it.
Gold
Price on request
A written assessment of your model against the Law on Banks: specialised or full bank, capital plan, governance and a roadmap for the application and the ex‑ante assessment.
Platinum
Price on request
The full application to the Bank of Lithuania: the three-year business plan, governance, risk and capital documents, and the ex-ante assessment, prepared and filed.
Custom
Price on request
The application plus the bank behind it: the Lithuanian company, management and key functions, compliance team and support through to operations.
* Prices on request, quoted for your model and scope. Prices exclude VAT. Not included: the initial capital (at least €1 million), the state levy for the licence (€4,157 as published by the Bank of Lithuania), registering the Lithuanian company, and the supervisory fees of the Bank of Lithuania and the ECB.
Process
Step 1
We test your model, capital and governance against the Law on Banks and prepare the optional ex-ante assessment with the Bank of Lithuania.
Step 2
We set up the Lithuanian company with its supervisory board, board and head of administration, and plan the initial capital.
Step 3
We prepare the application with the business plan, risk and capital documents and the shareholder and management files, and file it.
Step 4
The Bank of Lithuania assesses the file with the ECB, which decides. We support the bank’s compliance and EU notifications once licensed.
Requirements
A specialised bank meets the same standards as any EU bank. The Bank of Lithuania and the ECB assess the capital, the people, the owners and the organisation before a licence is granted.
Initial capital of at least €1 million, made up of common equity items under the EU Capital Requirements Regulation. The supervisor may require more for the planned activities.
The bank is an AB or UAB with its registered office in Lithuania, with a supervisory board, a board and a head of administration.
A specialised bank may provide only the services listed in the Law on Banks, including:
Investment services are not allowed; they need a full bank licence.
The documents are set by the Law on Banks and the Bank of Lithuania’s bank licensing rules, including:
FAQ
A bank under the Lithuanian Law on Banks that may provide only a defined list of services, such as deposits, lending, payment services and e-money. It is a full credit institution, supervised like any other bank, but it may not provide investment services.
Initial capital of at least €1 million, against €5 million for a full bank. The supervisor may require more depending on the planned activities, and the EU prudential rules of the CRR apply in full.
The application is filed with the Bank of Lithuania, which assesses it together with the European Central Bank. The Bank of Lithuania proposes the decision and the ECB adopts it, as for every bank licence in the euro area.
The law gives 6 months from the application, or from any additional documents requested, and never more than 12 months. Preparing a complete bank application takes several months before that, and an optional ex-ante assessment with the Bank of Lithuania helps avoid delays.
Yes. Taking deposits from the public is reserved for credit institutions, and a specialised bank is one. Deposits are protected by the Lithuanian deposit insurance scheme up to €100,000 per depositor.
It may provide only the services listed in the Law on Banks. Investment services are not allowed; a bank that wants to offer them needs a full bank licence.
Yes. When the bank shows that it has at least €5 million in initial capital and is ready to provide all banking services, the supervisor amends its licence to a full bank licence.
Yes, for the services in its licence. The bank notifies the Bank of Lithuania, which forwards the notification to the host supervisor: within one month for cross-border services and within three months for a branch.
A Lithuanian public or private limited company (AB or UAB) with its registered office in Lithuania, a supervisory board, a board and a head of administration. We can set up the Lithuanian company for the application.
The members of the management body and the heads, who need the supervisor’s permission and are assessed against the ECB fit and proper guide, and the shareholders with qualifying holdings, who must be suitable and financially sound.
The Bank of Lithuania publishes a state levy of €4,157 for a bank licence. The bank also pays supervisory fees once licensed. Our packages are in the pricing section.
Yes: AML team outsourcing, compliance officer roles, regulatory reporting and DORA support for ICT risk. See our compliance services.
Contact
Tell us about your banking model, and receive a tailored proposal with the steps and a budget for a Lithuanian specialised bank.
With your consent, we use cookies for analytics and to measure our ads. Cookie Policy
Estonia
Latvia
Lithuania
Finland
Sweden
Norway
Poland
Czech Republic
Switzerland
Malta
Cyprus
Canada