EMI license in
Lithuania
Lithuania remains one of the main EU jurisdictions for EMI licensing, particularly for payment businesses planning to operate across the EEA. It is frequently considered by companies building payment accounts, e-wallets, card programmes, merchant services, remittance products or cross-border payment flows.
For a payment business, the Lithuanian EMI route can provide more than formal
authorisation. It can give the company a regulated European base, access to the passporting framework and a jurisdiction with a developed market around electronic money and payment institutions. This can be useful not only at the licensing stage, but also when approaching banks, payment partners, technology providers and commercial counterparties.
This page explains how EMI licensing works in Lithuania, when this route may be suitable, what should be prepared before an application is filed and how Legalaes supports clients through structuring, documentation, regulator coordination and launch preparation.
Regulations for EMI license in Lithuania
Electronic Money Institutions in Lithuania are licensed and supervised by the Bank of Lithuania, Lietuvos bankas. It is the authority that reviews EMI applications, grants authorisations and continues supervising licensed institutions once they start operating.
The Bank of Lithuania looks closely at whether the applicant is ready to operate as a regulated financial institution. This includes the ownership structure, management team, capital position, safeguarding of client funds, AML/CTF controls, ICT arrangements, outsourcing setup and the services that will be offered under the license.
For Lithuania, the strength of the file matters from the beginning. The regulator will expect the application to explain the product, customer journey, fund movement, local team and provider setup in a way that matches the business plan and programme of operations.
The Lithuanian EMI regime is built on national law and the EU framework for payment services and electronic money. PSD2, EMD2, AML/CTF, safeguarding, ICT, outsourcing and operational resilience expectations should therefore be considered when preparing the application.
Licensing requirements:
- The applicant must have a minimum of 350,000 euros in their initial share capital to apply for an EMI license.
- Shareholders, ultimate beneficial owners (UBOs), board members and other decision makers must be cleared through a “fit and proper” assessment, with complete transparency regarding ownership interests as well as sufficient relevant experience.
- AML / CTF Compliance Program: An applicant is required to develop and implement anti-money laundering and countering terrorist financing (AML/CTF) programs; these include customer due diligence/know your customer (KYC/CDD), transactional monitoring, reporting mechanisms and internal compliance control.
- Governance & Internal Control: The Bank of Lithuania requires applicants to outline and detail governance frameworks, risk management processes, safekeeping methods and internal operating control that would support the operation of the applicant’s intended service.
- ICT & Security Requirements: Applicants are required to provide evidence of suitable Information Technology (IT) systems, security controls, outsourced systems oversight and operational resiliency.
- Application Package: Applicant’s application packages usually includes:
- Business Plan
- Operational Plan
- Forecasted Financial Plans
- AML/CTF policies
- Safekeeping Framework
- Governance Policy
- ICT & Security documentation
- Ownership documents and “Fit and Proper” files
- Product specific assessments (for example, wallet solutions are reviewed separately from card programs)
- Regulatory Review Process: The regulatory review focuses on whether the company can sustainably operate financially based on realistic forecasting, and if it has sufficient operational funding.
- EU Passporting Rights: After being licensed in one member state within the European Economic Area (EEA), an Electronic Money Institution (EMI) is allowed to operate throughout the EEA via EU passporting rights for the services covered by the EMI license.
Ongoing compliance:
After the licence is granted, the Lithuanian EMI has to keep operating in line with the business model accepted during licensing. The application file cannot be separated from the real business once the company starts operating. How the EMI is managed, how controls are applied and how the authorised services are provided should remain consistent with the file submitted to the Bank of Lithuania.
The institution will need to monitor its own funds, protect customer funds, submit regulatory reports and keep AML/CTF, sanctions, ICT, complaints handling and internal control procedures active in day-to-day operations.
The local team and key functions should also remain in place after approval. Management, compliance, risk, finance, ICT/security and operational duties need to stay assigned to responsible people. If some functions are supported by group companies or external service providers, the EMI should still be able to show who is responsible for each part of the setup.
Post-authorisation changes should be reviewed before they are made. This may include changes to ownership, management, authorised services, safeguarding arrangements, outsourcing, passporting plans or the operating model. Depending on the change, the Bank of Lithuania may need to be notified before or around implementation.
Recent developments:
In 2025, the Bank of Lithuania refreshed its expectations for electronic money and payment institutions, especially on internal controls, governance and protection of customer funds. For a new applicant, this means these points should be built into the file from the start. The regulator should be able to see how the EMI will operate, who is responsible for compliance and how customer funds will be protected.
Payment infrastructure is also part of the current discussion. From 6 October 2025, electronic money and payment institutions providing payment services gained direct access to the Eurosystem TARGET payment system, except for T2S securities settlement. For EMI projects that depend on euro payments, CENTROlink, SEPA connectivity and possible TARGET access should be considered at the structuring stage.
Legalaes follows these developments when assessing Lithuanian EMI projects, especially where the model depends on payment infrastructure, safeguarding, banking partners or cross-border flows.
Types of EMI licensing in Lithuania
Lithuania offers different authorisation routes depending on whether the business needs to issue electronic money, provide payment services only, or operate under a narrower domestic scope. The correct route should be selected based on the product, customer fund flow, target markets and whether the company needs EEA passporting.
In Lithuania, the licensing of Electronic Money Institutions (EMIs) is structured to cater to different business models and operational scopes. Here are the primary types of EMI licenses available in Lithuania:
| License type | Scope |
|---|---|
| Electronic Money Institution licence | Full EMI license in Lithuania allows the institution to issue electronic money and provide authorised payment services. This route can support e-wallet balances, payment accounts, card-related services, SEPA payments, merchant services, money remittance and other payment services included in the approved scope. A full EMI may operate across the EU through the passporting framework, subject to the services authorised by the Bank of Lithuania |
| Small Electronic Money Institution license | Small EMI authorisation in Lithuania is designed for smaller-scale activity. It is subject to limits on average outstanding electronic money and/or payment transaction turnover, and the institution may only operate in Lithuania. This route may be relevant where the business does not need full EEA market access or a broader EMI structure from launch. |
| Payment Institution licence | A PI licence in Lithuania allows the company to provide payment services without issuing electronic money. This route may fit models focused on payment processing, merchant acquiring, account services, money remittance, payment initiation or account information services, where stored-value or e-money issuance is not required. |
| Small Payment Institution license | Small PI authorisation in Lithuania is used for narrower payment service models operating within Lithuania and subject to applicable activity limits. It can be relevant for smaller domestic payment models that do not require EEA passporting or full PI authorisation. |
Key Differences Between Full and Small EMI Licenses
Capital Requirements
- Full EMI License: Requires a minimum initial capital of EUR 350,000.
- Small EMI License: The capital requirement is significantly lower, reflecting the reduced scale of operations.
Scope of Services
- Full EMI License: Can provide a comprehensive range of payment and electronic money services.
- Small EMI License: Limited to issuing electronic money and providing certain payment services up to specified thresholds.
Operational Restrictions
- Full EMI License: No specific restrictions on the volume of transactions or the value of electronic money issued.
- Small EMI License: Subject to limits on the total value of electronic money issued and the volume of transactions.
Regulatory Oversight
Both types of EMI licenses are regulated by the Bank of Lithuania, which ensures that institutions comply with relevant EU directives, such as the Second Electronic Money Directive (EMD2) and the Payment Services Directive (PSD2). This regulatory framework aims to ensure the security and stability of the financial system while fostering innovation and competition in the fintech sector.
By choosing the appropriate type of Lithuania EMI license, companies can align their regulatory obligations with their business models and strategic goals, enabling them to effectively serve their target markets.
Services Allowed Under an EMI Licence in Lithuania:
The service scope is approved by the Bank of Lithuania through the programme of operations and should reflect the actual product, customer flow and payment setup.
- Issuance of electronic money and maintenance of e-wallet or stored-value balances
- Payment account services, including pay-ins, withdrawals and account-based functionality
- SEPA payments, card-based payments, direct debits and standing orders
- Issuing or acquiring of payment instruments, including payment cards
- Money remittance, merchant services, pay-ins and payouts
- Currency conversion linked to the provision of payment services
- Payment initiation or account information services, where included in the authorised scope
Overview of requirements to obtain an EMI license in Lithuania
Main requirements:
- Lithuanian company structure suitable for EMI authorisation
- Clear shareholder and UBO structure
- Source-of-funds materials for initial capital
- Route-based initial capital: EUR 350,000 for EMI; EUR 20,000 to EUR 125,000 for PI
- Management board and senior team with relevant financial services experience
- Local Lithuanian team, usually with at least three responsible persons
- Fit-and-proper files for managers, shareholders and key persons
- Business plan and programme of operations
- Three-year financial forecasts
- Safeguarding model for client funds
- AML/CTF, sanctions and governance framework
- ICT/security, outsourcing and business continuity setup
- Lithuanian operational presence for supervision and record access
Additional requirements:
- Payment infrastructure planning, including SEPA, cards, acquiring, safeguarding, banking or payment partners where relevant
- Outsourcing controls for ICT, processing, compliance, customer operations or group support
- Extra structuring for merchant acquiring, crypto exposure, higher-risk payment flows or
- Complex group arrangements
Estimated time frames
Company formation
1-2 weeks
Documents preparation
6-12 weeks
Regulatory review and clarifications
3-6 months
*The timeline also depends on the workload of BoL and any clarifications and queries that BoL may request in relation to the application.
Legal services for obtaining EMI license in Lithuania
Basic Package
25,000 EUR initial set up
- Turnkey company formation
- Legal address for 1 year
- Corporate documents
- Due diligence for shareholders and key directors
- Overview of the business plan
- Overview of financial forecasts
- Overview of an organizational structure
- Analysis of the internal documents
- Applying for the license
Registration of the EMI / PI licensed company under the minimum regulatory requirements
Additional services on request
- Preparation of individual business plan
- Preparation of required documents for the licensing
- Accounting services
- Assistance in opening bank account, including segregated and safeguard accounts
- Connection with SEPA system
- Connection with SWIFT
- Connection with card issuance programme
- Apostilled corporate documents
- Introduction to confirmed software provider
- Legal support
Ready-Made solution
available on request
- Registered company
- Legal address for 1 year
- No debts, no liabilities – clean company
- Active license
- Corporate documents
- Assistance with transfer of ownership
Jegor Kupratsevits
Head of Fintech
Detailed Requirements for EMI licensing in Lithuania
List of required documents
- 1. Application and corporate documents
- Application form, Lithuanian company documents, articles of association, ownership structure, UBO information, shareholder documents and qualifying holding materials where relevant.
- 2.Management and fit-and-proper materials
- CVs, qualification documents, reputation declarations, non-criminal record certificates where required, and suitability files for board members, managers and key persons.
- 3.Business model and financial documents
- Business plan, programme of operations, description of services, target markets, customer journey, transaction flows, three-year forecasts and capital planning assumptions.
- 4.Safeguarding and client funds documents
- Safeguarding policy, client fund flow description, segregation and reconciliation procedures, safeguarding account information and
settlement logic.
- Safeguarding policy, client fund flow description, segregation and reconciliation procedures, safeguarding account information and
- 5.AML/CTF and internal control documents
- AML/CTF risk assessment, customer due diligence procedures, sanctions screening, transaction monitoring, suspicious activity reporting and compliance review materials.
- 6. ICT, security and outsourcing documents
- ICT architecture, cloud and data hosting information, cybersecurity controls, incident response, business continuity, outsourcing register and provider due diligence.
- 7. Governance and operational policies
- Organisational structure, allocation of responsibilities, risk management, complaints handling, recordkeeping, internal reporting and audit arrangements where required.
Share Capital and Government Fees
- Minimum Share Capital: EUR 350,000 for a full EMI licence. For PI authorisation, the required capital depends on the payment services requested and may be EUR 20,000, EUR 50,000 or EUR 125,000.
- Government Fees: The application fee for an EMI or PI licence in Lithuania is EUR 1,463. The amount should be checked again before filing against the applicable Lithuanian fee schedule.
- Capital adequacy: The capital position should support the business plan, projected costs, transaction volumes, operating risks and first years of implementation. In some projects, capital above the legal minimum may be advisable.
Bank account requirements
- Safeguarding account: Used to keep client funds separate from the company’s own funds. The application should explain how customer funds are received, segregated, reconciled and protected.
- Operational account: Used for company expenses, payroll, taxes, provider payments and other ordinary business costs. This account should be separate from safeguarded client funds.
- Payment and settlement accounts: Used for payment flows connected to the services offered by the EMI. Depending on the model, this may include SEPA payments, card settlement, merchant payouts, remittance flows or other payment infrastructure arrangements.
Business premises requirements
- The applicant should have a Lithuanian operating setup that supports management, record access, staff presence and communication with the Bank of Lithuania.
- The premises setup should match the scale of the institution. For some projects, this may be a lean office or shared workspace. For larger EMI models, stronger local presence may be expected.
Personnel Requirements
- Management board: The institution should have a management board with at least three members. Board members should collectively show relevant experience in payments, e-money, compliance, finance, risk, technology or operations.
- Local management presence: At least part of the management and control setup should be based in Lithuania. The structure should include responsible local persons who can support decision-making, regulatory communication and day-to-day oversight.
- CEO or local executive director: The company should have a responsible executive person available in Lithuania for operational management and communication with the Bank of Lithuania. Lithuanian language capability may be important where the role involves local administration, staff coordination or regulator-facing communication.
- AML/CTF compliance officer: The AML/CTF compliance function should be covered by a responsible person with sufficient experience. For a Lithuanian EMI project, this role is usually expected to have a credible local connection or availability in Lithuania.
- Risk and internal control: Risk management and internal control responsibilities should be clearly assigned. The function should match the services, transaction profile, outsourcing model and expected scale of the institution.
- ICT and security officer: ICT/security responsibility may be internal or outsourced, but the institution should have clear oversight of system security, access controls, incident handling, outsourcing and operational resilience.
- Internal audit: Internal audit may be internal or outsourced, depending on the structure. The function should be independent enough to review compliance, governance and operational controls.
- Finance and reporting: Accounting, regulatory reporting, own funds monitoring and financial control responsibilities should be clearly allocated.
- Data protection responsibility: A DPO may be required where the company’s data-processing activity triggers GDPR requirements. Even where a formal DPO is not required, data protection responsibility should still be assigned.
Additional Obligations Under the Regulations
- After authorisation, the EMI must maintain the same regulatory standard presented in the application. This includes own funds monitoring, safeguarding, AML/CTF controls, ICT/security, outsourcing oversight, reporting and internal governance.
- Material changes to ownership, management, key personnel, authorised services, outsourcing, safeguarding or passporting plans may need to be notified to the Bank of Lithuania.
Not sure how many people your Lithuanian EMI structure needs? Legalaes can review the model and define which roles should be local, internal, outsourced or part-time.
By meeting these requirements and submitting the necessary documents, applicants can demonstrate their readiness and compliance with regulatory standards, facilitating the approval process for obtaining an EMI license in Lithuania.
Roadmap of the project
For more detailed road map of the project and commercial offer – get in touch with our Forex professional.
Jegor Kupratsevits
Head of Fintech
Model assessment
The project begins with a review of the planned services, customer journey, transaction flows and target markets. At this stage, the EMI route is tested against the business model, and alternatives such as PI or restricted authorisation may also be considered if the company does not need full electronic money issuance from the outset.
Lithuanian setup
After the route is confirmed, the Lithuanian structure is prepared. This includes company formation, legal address, corporate documents, ownership setup and first screening of shareholders, directors, UBOs and key persons. The local management and compliance setup should also be planned early, as it will influence both the application file and regulator comfort.
Application build-out
The licensing file is then developed around the actual product. This usually includes the business plan, programme of operations, three-year forecasts, ownership materials, fit-and-proper files, safeguarding model, AML/CTF framework, ICT/security materials, outsourcing documents and governance policies. The file should present one coherent operating structure, not a set of disconnected policies.
Optional Bank of Lithuania engagement
Early communication with the Bank of Lithuania can be useful before the application is filed. This may take place through the Newcomer Programme or another introductory route. The discussion is normally used to present the model, check whether the expected authorisation route is suitable, and identify points that may need improvement before submission. This phase is optional, but it can add value where the project includes several payment services, card infrastructure, outsourcing or cross-border flows.
Launch readiness planning
Licensing work should run together with planning for the actual launch. During this stage, the project should review safeguarding arrangements, operational banking, SEPA or other payment infrastructure, software providers, accounting, reporting processes and internal workflows. The Bank of Lithuania will expect the services described in the application to be deliverable in practice, not only described in policy documents.
Submission and completeness check
Once the application file is complete, it is submitted to the Bank of Lithuania with the required forms, supporting documents and application fee. The first review focuses on whether the submitted package contains enough information for assessment. If documents are missing, unclear or inconsistent, the applicant may need to correct the file before it moves to detailed evaluation.
Detailed evaluation and comments
This is the stage where the Bank of Lithuania goes through the application in detail. Comments may be raised on ownership, management, capital, safeguarding measures, AML/CTF framework, ICT setup, outsourcing arrangements, financial forecasts and the operating structure described in the file. The applicant may need to revise documents, clarify assumptions, answer follow-up questions or attend meetings with the people who will oversee the licensed institution.
Approval and go-live
After approval of the licence, the project leaves the regulatory review stage and enters launch preparation. The remaining setup items are then completed before the EMI starts serving clients. This usually includes final banking and safeguarding arrangements, provider onboarding, payment infrastructure activation, reporting access and internal testing. Once the EMI is live, it remains under Bank of Lithuania supervision and must operate within the
scope set out in the granted licence.
Detailed Time Frames to Obtain a EMI License in Lithuania
A Lithuanian EMI licensing project will usually take somewhere between six and fourteen months, starting from the first structuring work and ending with the licensing decision. The process is more likely to stay near the faster end of the range where the ownership file, management team, source-of-funds materials and main licensing documents are already in good shape. If the payment flows are complicated, the documents are unclear or the Bank of Lithuania has to send several rounds of questions, the timeline can easily become longer.
1. Structuring and document collection
Time Frame: 2-4 weeks
- EMI route confirmation
- Review of planned services and target markets
- Collection of shareholder, UBO and management documents
- Initial review of capital, local team and Lithuanian setup
- Confirmation of the documentation plan
2. Company setup and licensing file preparation
Time Frame: 6-12 weeks
- Lithuanian company formation
- Preparation of business plan and programme of operations
- Preparation of three-year financial forecasts
- AML/CTF, safeguarding, ICT/security and governance documentation
- Fit-and-proper and ownership file preparation
- Review of outsourcing and provider arrangements
3. Optional Bank of Lithuania discussion
Time Frame: 1-4 weeks, where used
- Newcomer Programme or introductory regulator contact
- Presentation of the proposed EMI model
- Discussion of the intended authorisation route
- Identification of points to improve before filing
- Updates to the file following preliminary comments
4. Filing and completeness check
Time Frame: several business days to several weeks
- Final review of the application package
- Submission of the EMI application to the Bank of Lithuania
- Payment of the application fee
- Completeness check by the regulator
- Correction of missing or unclear items, if requested
5. Regulatory assessment and clarifications
Time Frame: usually up to 3 months after completeness, longer if comments continue
- Review of business plan, ownership, capital and management
- Assessment of safeguarding, AML/CTF, ICT/security and outsourcing
- Written questions from the Bank of Lithuania
- Preparation of responses and updated documents
- Meetings or interviews with key persons, where requested
6. Decision and launch readiness
Time Frame: usually up to 3 months after completeness, longer if comments continue
- Receipt of the regulatory decision
- Entry into the relevant public register
- Finalisation of banking and safeguarding arrangements
- Payment infrastructure and provider onboarding
- Reporting setup, internal testing and go-live preparation
Factors Influencing the Time Frame
- Quality and consistency of the initial licensing file
- Readiness of shareholder, management and source-of-funds materials
- Speed and quality of responses to Bank of Lithuania questions
By ensuring thorough preparation and proactive communication with the regulator, applicants can help streamline the process and potentially reduce the time required to obtain an EMI license in Lithuania.
Advantages of the EMI license in Lithuania
Obtaining an Electronic Money Institution (EMI) license in Lithuania offers several strategic and operational advantages for fintech companies. Here are the key benefits:
01
Large EMI and PI Market in the EU
Lithuania has one of the largest electronic money and payment institution markets in Europe by number of authorised institutions. This gives the jurisdiction a stronger regulatory and professional ecosystem around EMI licensing, compliance, payment operations and post-authorisation supervision.
02
EEA Market Access Through Passporting
A Lithuanian EMI licence can support the provision of approved services across the EEA through the EU passporting framework. This allows the company to scale from one EU authorisation instead of applying for separate licences in each target member state, provided the services remain within the scope approved by the Bank of Lithuania.
03
CENTROlink and SEPA Access
Lithuania’s payment infrastructure is one of the main practical advantages of the jurisdiction. CENTROlink, operated by the Bank of Lithuania, provides technical access to the Single Euro Payments Area for payment service providers, including electronic money and payment institutions licensed in the EEA. This can support euro payment flows, instant payments, direct debits and settlement models where the institution meets the relevant access requirements.
04
Early Engagement With the Regulator
The Newcomer Programme is one of the practical reasons Lithuania can be attractive for new EMI projects. It allows the applicant to speak with the Bank of Lithuania before preparing the full filing. The discussion can be used to present the model, test whether the intended licensing route is realistic and understand which points may need to be adjusted before submission.
05
Fintech Infrastructure and Specialist Talent
Lithuania’s fintech market has created a support base around EMI and payment institution projects. This can include compliance people, local management candidates, technology vendors, auditors, payment consultants and lawyers with experience in regulated payment businesses and post-licensing work.
06
Efficient EU Operating Base
Lithuania can offer a more cost-efficient operating base than larger Western European financial centres while still remaining inside the EU regulatory framework. This can be relevant when planning local substance, staff, office setup, compliance functions, technology support and first-year operating costs.
By leveraging these advantages, fintech companies can effectively establish and expand their operations in Europe, providing innovative financial services while benefiting from Lithuania’s supportive and dynamic business environment.
Links for legislation related to EMI business in Lithuania
Bank of Lithuania page for EMI authorisation. It is the starting point for checking the application route, filing steps and main documents expected from applicants.
Main Lithuanian law for electronic money institutions. It deals with EMI authorisation, issuance and redemption of electronic money, restricted activity licences, initial capital, safeguarding and supervision.
Lithuanian law on payment services and payment transactions. It should be checked where the EMI model also includes payment accounts, transfers, acquiring, remittance, payment initiation or account information services.
Bank of Lithuania resolution on the authorisation process for electronic money and payment institutions. This source is important when preparing the formal filing package.
Rules on internal control, risk management and protection of funds received by electronic money and payment institutions. This source is important for governance, safeguarding and operating model preparation
Bank of Lithuania guidelines for assessing management bodies and key function holders of supervised financial market participants. These should be considered when preparing fit- and-proper files and board or key person materials.
EU directive for payment services. It is relevant for payment institutions, payment services, payment initiation, account information services, transparency and security requirements.
EU directive for electronic money institutions. It sets the EU-level basis for electronic money issuance, initial capital and the taking up and pursuit of EMI activity.
Bank of Lithuania page for companies considering regulated financial activity in Lithuania. It can be used for early contact with the regulator before the application is filed.
These descriptions provide a quick overview of each act’s main purpose and its role in the regulatory landscape for obtaining EMI license in Lithuania.
Taxation of EMI Companies in Lithuania
The tax position of a Lithuanian EMI should be checked together with the company’s operating model, revenue streams, local staffing and shareholder structure.
- Corporate Income Tax: Lithuania’s standard corporate income tax rate is 17%. A reduced regime may apply to smaller companies that meet the relevant conditions, but this is usually less relevant for a fully licensed EMI with regulatory capital, local staff and operating substance.
- Dividend Withholding Tax: Dividends and other income from distributed profits are generally subject to 17% tax in Lithuania. Where profits are paid to a foreign shareholder, the final treatment depends on the recipient, the applicable tax treaty, EU Parent-Subsidiary Directive conditions and whether an exemption can be used.
- VAT on EMI Services: Lithuania’s standard VAT rate is 21%. Many core financial services may be VAT exempt, but an EMI should not assume that every type of fee receives the same treatment. Technology fees, platform fees, software-related charges and other ancillary services should be checked separately.
- Payroll and Local Staff: A Lithuanian EMI should plan payroll costs from the beginning if local management, compliance, finance, operations or ICT staff will be employed in Lithuania. Employment income is subject to progressive personal income tax, with main rates of 20%, 25% and 32% depending on income level. Employee-side social security and health insurance contributions are generally 19.5% up to the applicable annual ceiling. Employer contributions are usually lower, but the final cost depends on the contract type and applicable thresholds. The payroll position should be checked against salary level, pension participation, contract type and the final staffing model.
- Accounting and Tax Compliance: A Lithuanian EMI should maintain local accounting, annual tax filings, payroll reporting and VAT filings where applicable. Tax, accounting and regulatory reporting should be aligned before authorisation, especially where the company will have local staff, outsourced functions, regulated payment flows or cross-border operations.
By understanding and adhering to these taxation principles, EMI companies in Lithuania can effectively manage their tax obligations while benefiting from the country’s favorable business environment.
FAQ about Crypto license in Lithuania
1. How can I obtain a CASP license in Lithuania?
Our legal experts provide comprehensive guidance throughout the entire licensing process, which includes establishing a UAB company, depositing required share capital, drafting AML/KYC/CFT policies, appointing a local AML compliance officer and director, and submitting the complete application to the Bank of Lithuania.
2. How long does it take to obtain a CASP license in Lithuania?
Typically, obtaining a CASP license takes around 4 to 6 months. The timeline includes company formation, capital deposit, documentation preparation, application submission, and regulatory review by the Bank of Lithuania.
3. What is the required share capital for a CASP license in Lithuania under MiCA regulations?
Under MiCA regulations, minimum share capital requirements vary based on services provided:
<ul>
<li>Basic crypto-asset services: EUR 50,000</li>
<li>Intermediate crypto-asset services: EUR 125,000</li>
<li>Comprehensive crypto-asset services: EUR 150,000</li>
</ul>
4. Is it possible to open a crypto-friendly bank account?
Yes, CASP-licensed companies can open multiple accounts, particularly with European Electronic Money Institutions (EMIs). Our company maintains partnerships with over 15 crypto-friendly EU-based financial institutions, allowing flexible banking options for CASP license holders.
5. What services does the CASP license cover in Lithuania under MiCA regulations?
A CASP license covers:
<ul>
<li>Crypto exchange services (crypto-to-fiat and crypto-to-crypto exchanges)</li>
<li>Custodial wallet services (secure storage and management of crypto assets)</li>
<li>Crypto-asset advisory and related services</li>
<li>Token issuance (including ICOs and other token offerings)</li>
</ul>
6. What are the key regulatory authorities overseeing crypto licenses in Lithuania?
The primary regulatory body is the Bank of Lithuania. The Financial Crime Investigation Service (FCIS) also plays a vital role, enforcing AML/CFT regulations.
7. What documents are required for obtaining a CASP license?
Required documents include:
<ul>
<li>Power of Attorney (notarized and legalized, if applicable)</li>
<li>Comprehensive AML/KYC/CFT policies</li>
<li>CASP Application Form (submitted to the Bank of Lithuania)</li>
<li>Memorandum and Articles of Association (company incorporation documents)</li>
<li>Detailed business plan and organizational structure</li>
</ul>
8. What ongoing compliance obligations do CASPs have?
Ongoing compliance obligations include:
<ul>
<li>Regular reporting to the Bank of Lithuania</li>
<li>Maintenance of AML/KYC/CFT standards</li>
<li>Continuous operational monitoring and annual audits</li>
<li>Regulatory reporting and adherence to MiCA guidelines</li>
</ul>
9. Is a local physical office required for a CASP license?
Yes, CASPs must have a verifiable local office presence. Cost-effective solutions like virtual offices or coworking spaces can fulfill this requirement.
10. What are the tax implications for crypto companies in Lithuania under MiCA?
Lithuania offers a competitive corporate tax rate of 15%, with potential reductions to 5% for eligible small businesses. Crypto transactions are exempt from specific crypto taxes.
11. What are the personnel requirements under MiCA?
CASPs must appoint:
<ul>
<li>At least one qualified local AML Compliance Officer (EU or Lithuanian resident)</li>
<li>Experienced directors with relevant expertise in finance or blockchain technology (EU residency recommended but not mandatory)</li>
</ul>
12. Can foreign nationals or entities apply for a CASP license in Lithuania?
Yes, foreign nationals or entities can apply for a CASP license by appointing local representatives, establishing a Lithuanian entity (UAB), and maintaining a local office presence.
13. How can I ensure a successful application for a CASP license in Lithuania?
Ensure comprehensive documentation, robust compliance frameworks, prompt responses to regulatory queries, and consider professional assistance from legal experts such as Legalaes, experienced in crypto licensing and MiCA regulations.
Each of our projects receives unique and tailored solutions in accordance with the initial objectives and vision of the shareholders.
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