EMI licence in Lithuania or Latvia: how the two compare

Lithuania or Latvia: which one we recommend

On paper the two licences are almost identical, because both countries transpose the same EU directives. The real difference is the market each supervisor has built. Lithuania is one of the EU’s largest e-money hubs, with one of the highest numbers of licensed EMIs in the Union and a supervisor that has seen almost every business model. Latvia is the newer option: Latvijas Banka has set out to attract fintech licensing, and in our experience it is more open to new businesses and new models.

Whichever you choose, the regulator expects a real business in the country: a local company with a board, and operations at least partly run from there. A licence held from abroad with nobody on the ground does not get through either review.

Lithuania and Latvia side by side

The key facts for a full EMI licence, from the two laws and the supervisors’ own pages:

EMI licence in Lithuania and Latvia compared

Factor	Lithuania	Latvia
Supervisor	Bank of Lithuania	Latvijas Banka
Law	Law on Electronic Money and Electronic Money Institutions	Law on Payment Services and Electronic Money
Initial capital (legal minimum)	€350,000	€350,000
Capital to plan for in practice	About €700,000	About €700,000
Ongoing own funds	2% of average outstanding e-money (the Bank may set it up to 20% lower or higher)	2% of average outstanding e-money (Latvijas Banka may raise it by up to 20%)
Completeness check	5 business days	15 working days
Legal decision deadline	3 months from a complete application	3 months from a complete application
Realistic project timeline	6 to 12 months	6 to 12 months
Application fee	€1,463 state levy	€5,000
Yearly supervision fee	A share of e-money and payment income, rate set each year	€7,000 plus up to 1.4% of gross revenue, capped at €100,000
Small EMI route	Restricted licence: up to €900,000 e-money, Lithuania only	Registered EMI: up to €2 million e-money, Latvia only
Payment system access	CENTROlink (SEPA)	EKS, direct participation
Application language	Lithuanian or English	English accepted in practice; official forms in Latvian

State fees and capital are set by law and paid to the regulator or held by the company; they are not part of MAXCORP’s fees.

Before you file: how each supervisor works with applicants

The Bank of Lithuania runs a Newcomer Programme for fintech companies planning to apply, and publishes detailed guidance on preparing for licensing. Its recommendations are demanding: it expects a country manager permanently resident in Lithuania and communication in Lithuanian alongside English. Applications can be filed in Lithuanian or English.

Latvijas Banka offers a free pre-application meeting, an Innovation Hub that answers questions in Latvian and English, and a regulatory sandbox. Applicants with only innovative services pay a reduced fee. The law expects the board and the legal address in Latvia and the business at least partly linked to Latvia.

The 3-month deadline in both laws only starts once the file is complete, and questions from the supervisor can extend it. In our experience, the time goes into preparation: policies, the business plan, the AML framework and the people. Realistically, plan for 6 to 12 months from start to licence in either country. Capital needs the same realism: €350,000 is the legal minimum, but the supervisor checks that your capital also covers the losses in your business plan for the first years, so most projects need about twice that. Our EMI licence in Latvia page sets out the Latvian route step by step.

What Latvijas Banka asks for

Latvijas Banka publishes its licensing steps in unusual detail, and they show where applications slow down. A few points we pass on to every client:

Applicants that offer only an innovative payment service pay a reduced examination fee of €450 and €1,000 a year in supervision fees for the first three years.

Starting small: the restricted and registered EMI

Both countries allow a lighter route for businesses that stay small and local:

Neither can be passported. They make sense to test a product locally; if you plan to serve clients across the EU from day one, apply for the full licence.

Reaching the payment rails and safeguarding

An EMI needs a way to send and receive euro payments without depending entirely on a partner bank. This is where the two countries differ most in practice:

Direct access to the eurosystem’s TARGET services has been open to non-bank payment institutions across the EU since 6 October 2025, so that no longer separates the two.

Client money must be safeguarded in both countries, in a segregated account at a credit institution, in low-risk assets, or covered by insurance or a guarantee. Note that euro area central banks, including both of these, do not offer safeguarding accounts to payment and e-money institutions, so you need a commercial bank partner for this from the start.

How MAXCORP helps you choose and apply

MAXCORP prepares EMI applications in both countries: the business plan and financial forecasts, the AML and safeguarding frameworks, the governance and the people, and the full file for the supervisor. We start with a written assessment of which country and which route (full or small EMI) fits your business model, your clients and your timeline.

See the EMI licence in Lithuania, the EMI licence in Latvia and our overview of the EMI licence across the EU.