EMI License in Lithuania

EMI License in Lithuania

Lithuania has become one of the most prominent fintech hubs in the European Union, particularly for companies seeking authorization as Electronic Money Institutions. More than eighty EMIs currently operate under the supervision of the Bank of Lithuania (Lietuvos bankas), making the country one of the most active licensing jurisdictions in Europe.

An EMI license in Lithuania is issued by the Bank of Lithuania in accordance with Directive 2009/110/EC (Electronic Money Directive – EMD2) and the national Law on Electronic Money and Electronic Money Institutions.

This authorization allows companies to issue electronic money, operate digital wallets, and provide payment services throughout the European Economic Area through EU passporting.

The minimum initial capital required for a full EMI authorization is €350,000, while the official state application fee is €1,463. In practice, the entire authorization process typically takes 6–12 months, although the formal regulatory review period after submission of a complete application may take up to three months.

Once authorized, an EMI in Lithuania may expand services across all EU and EEA member states. Licensed institutions may also obtain direct access to SEPA infrastructure through the Bank of Lithuania’s CENTROLINK platform, which significantly simplifies payment operations in euro.

Bergerslegal provides legal and regulatory support for obtaining an EMI license in Lithuania, including preparation of the application package, development of compliance frameworks, and assistance during the licensing process with the Bank of Lithuania.

Quick Facts — EMI License in Lithuania

What Is an EMI License in Lithuania

An Electronic Money Institution license authorizes a company to issue electronic money and provide a broad range of payment services within the European Union.

Electronic money represents a digitally stored monetary value issued in exchange for funds and accepted as a means of payment by third parties.

Companies holding an EMI license may provide services such as:

• issuing electronic money
• operating digital wallets and payment accounts
• enabling online and offline payments
• providing individual IBAN accounts
• facilitating cross-border transfers
• processing payments for individuals and businesses
• issuing payment cards through international schemes such as Visa or Mastercard

Lithuanian EMIs may operate throughout the EU and EEA using the passporting mechanism, meaning additional licensing in other member states is not required.

Lithuanian legislation also allows the issuance of a restricted EMI license, under which activities may be limited to Lithuania and certain operational thresholds may apply.

Why Lithuania Is a Leading EMI Jurisdiction

Lithuania has established itself as one of the most accessible fintech jurisdictions in the European Union.

The Bank of Lithuania acts as a centralized financial regulator responsible for licensing and supervision of electronic money institutions.

Several factors contribute to Lithuania’s popularity among fintech companies.

Experienced regulator

The Bank of Lithuania has significant experience supervising fintech companies operating internationally.

Access to SEPA infrastructure

Licensed institutions may connect directly to SEPA through the CENTROLINK payment system, enabling efficient euro settlement.

EU passporting

Lithuanian EMIs may provide services across all EU and EEA states without obtaining additional national licenses.

Balanced regulatory environment

Lithuania combines strong regulatory standards with relatively accessible licensing procedures compared with many other EU jurisdictions.

Fintech-friendly ecosystem

The country actively promotes financial innovation and maintains a supportive regulatory dialogue with fintech companies.

Capabilities of an EMI License Compared to Other Financial Institutions

Advantages of an EMI License in Lithuania

Obtaining an EMI license in Lithuania offers a number of strategic advantages for fintech businesses.

Access to the European financial market

A licensed EMI may provide services throughout the European Economic Area through passporting rights.

Direct participation in SEPA

Through the Bank of Lithuania’s CENTROLINK system, EMIs may gain direct access to SEPA payment infrastructure.

Ability to issue electronic money

EMIs may create electronic wallets, manage stored customer funds, and provide payment accounts with IBAN numbers.

Support for global payment networks

Licensed institutions may integrate with international card schemes such as Visa and Mastercard.

Flexible operational models

Companies may open payment accounts remotely for individuals and businesses.

Remote KYC capabilities

Customer verification may be performed using digital identification tools such as video verification and electronic signatures.

Unlimited license validity

Once granted, the EMI license remains valid indefinitely provided regulatory obligations are met.

Stages of Obtaining an EMI License in Lithuania

The authorization procedure usually involves several stages coordinated with the Bank of Lithuania.

Step 1 — Pre-application consultation

At this stage, the applicant typically holds an introductory meeting with the regulator to discuss the business model and licensing requirements.

Step 2 — Company formation and documentation preparation

This stage includes:

• incorporation of the company in Lithuania
• preparation of the business plan and operational program
• development of financial forecasts
• due diligence on shareholders and management
• recruitment of required staff
• establishment of a local office

Step 3 — Submission of the license application

The complete application package is submitted to the Bank of Lithuania and includes financial, legal, and technical documentation.

Step 4 — Regulatory review

The Bank of Lithuania evaluates the application and may request additional information before granting authorization.

Step 5 — Operational launch

Once the license is issued, the company completes infrastructure setup and prepares for operational activity.

The realistic timeframe for completing all stages is typically six to twelve months.

Types of EMI Licenses Available in Lithuania

Lithuanian law distinguishes between two categories of EMI authorization depending on the scale of operations.

An unrestricted EMI license allows the institution to operate across the European Economic Area and issue electronic money without operational caps.

A restricted EMI license allows operation only within Lithuania and may impose limits on transaction volumes.

Cost of Obtaining an EMI License in Lithuania

The total cost of authorization depends on the project structure, compliance requirements, and infrastructure implementation.

In practice, the overall budget for launching a fully operational EMI in Lithuania usually ranges between €430,000 and €600,000 or more, including capital requirements and operational setup.

EMI License and MiCA Regulation

Under the Markets in Crypto-Assets Regulation (MiCA), only credit institutions and licensed electronic money institutions may issue e-money tokens (EMTs) within the European Union.

An EMI license in Lithuania therefore provides the regulatory status necessary for companies planning to issue stablecoin-type digital assets, provided they comply with MiCA obligations such as:

• preparation of a crypto-asset white paper
• safeguarding of reserves
• capital requirements
• regulatory disclosure obligations

Lithuania’s fintech ecosystem and regulatory experience make it a practical jurisdiction for projects combining traditional electronic money services with tokenized payment models.

EMI License vs Payment Institution License

Lithuania also offers Payment Institution (PI) licenses, which differ from EMI licenses in scope and functionality.

A Payment Institution license is generally suitable for companies that focus solely on processing payments and transferring funds.

An EMI license, by contrast, allows institutions to issue electronic money and maintain stored customer balances within digital wallets.

Documents Required for an EMI License Application

The Bank of Lithuania requires a comprehensive documentation package during the licensing process.

Typical documentation includes:

• company incorporation documents
• articles of association
• detailed business plan
• operational program
• financial forecasts
• proof of minimum share capital
• shareholder and beneficial owner information
• criminal record certificates for key persons
• description of internal governance structure
• AML and KYC policies
• internal risk management procedures
• safeguarding procedures for client funds
• IT systems description
• information about auditors and accounting procedures
• office lease agreement in Lithuania

The regulator evaluates both the financial stability of the project and the professional reputation of the management team.

Regulation of Electronic Money Institutions in Lithuania

Electronic money institutions in Lithuania operate under a comprehensive regulatory framework combining European and national legislation.

Key regulatory instruments include:

• Directive 2009/110/EC (Electronic Money Directive – EMD2)
• Directive (EU) 2015/2366 (Payment Services Directive – PSD2)
• EU Anti-Money Laundering Directives
• General Data Protection Regulation (GDPR)
• Digital Operational Resilience Act (DORA)

Lithuanian national legislation also includes:

• the Law on Electronic Money and Electronic Money Institutions
• the Law on Financial Institutions
• the Law on Payment Institutions
• the Law on Prevention of Money Laundering and Terrorist Financing
• the Law on Legal Protection of Personal Data

These regulatory instruments establish requirements for:

• corporate governance
• capital adequacy
• risk management
• customer protection
• AML compliance
• cybersecurity and operational resilience

The Bank of Lithuania conducts ongoing supervision of licensed institutions and ensures compliance with both EU and national regulations.