Lithuania electronic money institution licence

The statutory decision period is three months from a complete application; plan for four to six months after submission.

The EU base most often chosen by e-money issuers that want low fees, a defined timetable and direct access to the central bank’s payment system from day one.

Before anything is drafted we advise on whether this is the right authorisation for the business, or whether another route would serve it better.

Passporting

EU and EEA

Seven steps from scoping to a passported licence. Regulator periods are as published; preparation times are our planning figures.

1. Choose the licence and model the floatDecide between the full and the restricted licence by projecting average outstanding e-money against the €900,000 monthly limit, and set the capital plan. Time: 1 to 2 weeks.
2. Speak to the Bank of Lithuania earlyThe Bank encourages applicants to contact it before filing, through its Newcomer Programme. Bring the product, the flow of funds and the safeguarding model. Time: 2 to 4 weeks to arrange and hold the meeting.
3. Build the Annex 1 document setThe application form and the documents in Annex 1 to the Rules on the Licensing of Electronic Money and Payment Institutions (Annex 3 for a restricted licence), including the e-money issuance procedure, governance, risk and internal control. Time: 6 to 8 weeks.
4. Open the safeguarding account and pay the levySecure the account that will hold customer funds and pay the €1,463 state levy (€1,235 restricted) to the State Tax Inspectorate. Time: in parallel with step 3.
5. File and pass the completeness checkThe Bank of Lithuania checks the file for formal deficiencies and accepts it if there are none. Time: 5 business days.
6. Answer the assessment commentsDeficiencies are common and each round of comments extends the assessment. The three-month period runs from a proper application, or from the date the additional documents arrive. Time: 3 months by statute; 2 months for a restricted licence.
7. Board decision, CENTROlink and passportingThe Board of the Bank of Lithuania grants or refuses the licence. Then apply for CENTROlink access and notify the Member States you will serve. Time: passport notifications are forwarded to host authorities within 1 month.

Electronic money (e-money) is monetary value stored electronically, issued when the customer pays in funds and accepted as payment by people other than the issuer. In practice it is the balance in a digital wallet, the value loaded on a prepaid card, or the funds sitting in an account with an IBAN (international bank account number) that the customer spends by card or transfer. A Lithuanian EMI may issue all of these and provide every payment service on the same licence, so one authorisation covers wallets, card programmes, payouts and Banking-as-a-Service (BaaS) programmes for other brands.

The licence comes with product rules that apply from the first euro issued, under the second E-Money Directive (EMD2) as transposed by the Law on Electronic Money and Electronic Money Institutions:

• Issue at par. E-money is issued at the value of the funds received, without delay.
• Redeem at par, at any time. The holder can ask for the balance back at any moment. A redemption fee is allowed only if the contract states it and only in three cases: redemption before the contract ends, early termination of a fixed-term contract, or redemption more than one year after the contract ends.
• No interest. An EMI may not pay interest, or any other benefit linked to how long the holder keeps the balance.
• Distributors, not issuing agents. An EMI may distribute and redeem e-money through distributors acting on its behalf, but it may not issue e-money through agents. Agents may be used for payment services under the PSD2 agent rules.

A business that only moves money and never holds a balance for the customer does not need an EMI. A Lithuanian payment institution licence costs less capital and suits acquiring, remittance and payment initiation models.

The Bank of Lithuania lists the acts that govern EMI licensing:

• Laws. The Law on Electronic Money and Electronic Money Institutions and the Law on Payments
• Licensing. Resolution No 238 on granting authorisations to electronic money and payment institutions, and Resolution No 58, the general regulations on submitting and examining applications
• People. Resolution No 03-181, guidelines on assessing members of the management body and key function holders
• Controls and capital. Resolution No 247 on internal control, risk management and protection of received funds, and Resolution No 03-83 on calculating initial capital and own funds
• Owners. Resolution No 03-138, rules for notifying the acquisition and disposal of a qualifying holding

Lithuania offers a restricted-activities EMI licence for issuers starting small. The restricted route removes the capital requirement and the shareholder fitness test, at the price of staying in Lithuania.

The float is the pool of customer money held against e-money in issue. It belongs to the holders, and EMD2 requires it to be protected from the EMI’s own creditors in one of two ways: kept separate and placed in a segregated account with a credit institution or central bank, or invested in secure, low-risk assets; or covered by an insurance policy or a guarantee from an insurer or bank outside the group. Funds received by card or other payment instrument must be safeguarded once they reach the EMI, and in any event no later than five business days after the e-money is issued.

Lithuanian EMIs hold the float in all three places, and the Bank of Lithuania publishes the totals. At the end of 2024, customer funds held at central banks fell 26%, from €912 million to €671 million; funds held at credit institutions rose about two and a half times, from €488.3 million to €1.2 billion; and €742 million was invested in safe, liquid assets, 36% more than in 2023.

Since 9 April 2025 payment systems operated by central banks no longer offer accounts for safeguarding customer funds, so a Lithuanian EMI safeguards with a credit institution, in secure low-risk assets, or by insurance or a guarantee, and needs that arrangement in place before launch.

• Location. A company with its registered office and head office in Lithuania; the absence of a Lithuanian office is a statutory ground for refusal.
• Shareholders. Holders of qualifying holdings must support sound and prudent management, have a sufficiently good reputation and be financially sound. This test does not apply to a restricted licence.
• Managers. The heads of the EMI must be of good repute and have the qualifications and experience for their duties.
• Operating plan. The plan must match the founders’ ability to deliver it, and the EMI must be ready to operate safely and soundly from the day of authorisation.
• Governance. A detailed procedure for managing e-money issuance, an organisational structure with clear lines of responsibility, risk identification and monitoring, management information and internal control systems, administrative controls and an accounting system.

Annex 1 to the licensing rules follows the information the E-Money and Payment Services Directives require:

Programme of operations

The services envisaged

Business plan

A forecast budget for the first three financial years

Evidence of initial capital

Capital held at the required level

Safeguarding measures

How customer funds are protected

Governance and internal control

Administrative, risk management and accounting procedures

Incident and complaints procedure

Security incidents and security-related complaints, with incident reporting

Sensitive payment data

How access is filed, monitored, tracked and restricted

Business continuity

Critical operations, contingency plans and testing

Statistical data principles

How performance, transaction and fraud data are collected

Security policy

Risk assessment and security controls

Anti-money laundering internal controls

How the money laundering obligations are met

Structural organisation

Agents, branches, the checks on them at least annually, outsourcing and payment system participation

Qualifying holders, directors and auditors

Identity, holdings and evidence of suitability, repute and experience

Legal status and head office

Articles of association and the head office address

Regulator charges, capital and the role and audit requirements that drive first-year cost. Professional fees are excluded.

Regulator application fee

€1,463 state levy€1,235 for a restricted licence; paid to the State Tax Inspectorate before filing

Initial capital

€350,000None for a restricted licence; own funds then follow Method D

Annual supervisory fee

Contribution set each yearFixed by Bank of Lithuania Board resolution for each year; for 2025, Resolution No 03-115 of 14 October 2024

Audit and safeguarding audit

Annual statutory auditInternal control and an internal audit function are part of the governance the Bank assesses; the auditor’s fee is not set by the regulator

Required roles

Heads of good reputeManagers with the qualifications and experience for their duties, internal control and audit functions, and a designated officer for anti-money laundering (AML) compliance

Insurance or bond

Only as a safeguarding methodAn insurance policy or guarantee may replace segregation; professional indemnity insurance applies only to payment initiation and account information services

CENTROlink is the retail payment system run by the Bank of Lithuania. It gives licensed EMIs and payment institutions access to the Single Euro Payments Area (SEPA) for credit transfers, direct debits and instant payments, linked to RT1 and TIPS. Lithuanian-licensed EMIs and PIs are migrating in scheduled windows from addressable BIC holders to direct participants, which requires compliance with Article 35a of PSD2. At the end of 2024 the system had 21 direct participants and 117 addressable BIC holders, and processed 294.6 million payments that year, 176.8 million of them instant. Lithuanian applicants complete a self-assessment form after authorisation to join.

CENTROlink also offers Verification of Payee, which the Instant Payments Regulation required European payment service providers to introduce by 9 October 2025, and a proxy lookup that initiates SEPA and SEPA Instant payments from the payee’s phone number. To join, an institution completes a self-assessment and reports on its compliance with the participation requirements, with an audit report if the operator requests one. Only EMIs and PIs licensed in the EU or EEA are eligible for direct participation.

A full Lithuanian EMI licence can be used across the EU and EEA through a branch, a distributor of e-money, an agent for payment services, or cross-border services. The EMI notifies the Bank of Lithuania, which sends the notification to the host authority within one month; the host has a further month to respond. A restricted licence carries no passport.

• Assessment contact. During assessment the Bank holds regular communication and, when required, meetings with the applicant’s representatives, and applicants have direct access to its specialists.
• Operational resilience. DORA has applied to e-money institutions since 17 January 2025, with major ICT incidents reported under it instead of under PSD2.
• Owners. Acquisitions and disposals of qualifying holdings are notified under Resolution No 03-138.
• Anti-money laundering. The EU Anti-Money Laundering Regulation applies from 10 July 2027.
• E-money tokens. Under MiCA a Lithuanian EMI may offer an e-money token, a stablecoin referencing one official currency, once it has notified a crypto-asset white paper to the Bank of Lithuania; custody or exchange of other crypto-assets is a separate MiCA licence.

The third Payment Services Directive (PSD3) and the Payment Services Regulation (PSR) will end the EMI as a separate licence. The Council and Parliament reached provisional agreement on 27 November 2025, the agreed text was published on 23 April 2026, and publication in the Official Journal is expected at the end of 2026. EMD2 is repealed and e-money issuance becomes an activity of a payment institution.

• Existing EMIs keep operating under their current licence, but must submit the information for re-authorisation within 27 months of PSD3 entering into force, with up to 30 months where the supervisor could not process a timely filing.
• Funds received for e-money must be safeguarded by the end of the business day after receipt, replacing the five-business-day window.
• The bank holding safeguarded funds must be authorised in a Member State, and firms using segregation must try not to hold all customer funds with a single bank.
• Most of the new rules apply 21 months after entry into force.

An EMI authorised in Lithuania in 2027 will therefore face re-authorisation within its first years. We build the application to the PSD3 standard now, so the re-authorisation file is a refresh rather than a rewrite.

The Council adopted its position on PSD3 on 29 October 2026. See our PSD3 guide for Lithuania for what the change means here and what to prepare.

An EMI needs a safeguarding account for the float, an operating account and settlement accounts in each currency it serves. We open each alongside the application, so you trade from authorisation. See banking and payment processing.

1. Scoping. We confirm the licence route, full or restricted, the capital and the state levy, and arrange a Newcomer Programme meeting with the Bank of Lithuania before filing.
2. Application pack. The document set in the licensing rules’ annexes, the governance and internal audit arrangements and the shareholder and manager files so the five-day completeness check passes first time.
3. Banking. The safeguarding account with a Lithuanian or EU credit institution and the operating accounts, opened alongside the application, together with the CENTROlink access application.
4. Regulator engagement. We answer each deficiency and comment round with the evidence, until the Board of the Bank of Lithuania takes its decision.

You will need directors and senior managers with a good reputation and experience, and an internal auditor, with supervision kept separate from management.

We prepare Lithuania EMI licence applications, file them with the Bank of Lithuania and manage each one to approval, from our offices in London and New York.

Authorisation is the first stage. We can also arrange what the regulator expects to be in place alongside it: the local directors and compliance officer, bank and safeguarding accounts, card issuing and the first year of compliance.

EMI licence consultants