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Get an EMI license in Lithuania
Legalaes offers turnkey company formation and ready-made solutions.
Why obtain an EMI license in Lithuania
An electronic money institution license in Lithuania is frequently considered by companies building payment accounts, e-wallets, card programs, merchant services, remittance products, or cross-border payment flows. It is particularly appropriate for payment businesses planning to operate across the European Economic Area (EEA).
Lithuania remains one of the main EU jurisdictions for EMI licensing. For a payment business, a Lithuania EMI license represents more than a formal authorization. It gives a company a regulated European base, access to the passporting framework, and a jurisdiction with a mature market of electronic money and payment institutions. This is useful beyond the licensing stage, as it ensures a variety of options when a company needs banking services, payment partners, technology providers, and commercial counterparties.
Legalaes explains how EMI licensing works, when this route may be suitable, and what should be prepared before filing an EMI application in Lithuania. We also explain how Legalaes supports clients through structuring, documentation, regulator coordination, and launch preparation.
Regulations governing the 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 authorizations and supervises licensed institutions.
Before issuing a Lithuania fintech license, the Bank of Lithuania looks closely at the applicant’s readiness and capacity to operate as a regulated financial institution. It reviews the company’s ownership structure, management team, capital position, practices regarding safeguarding of client funds, Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) controls, Information and Communications Technology (ICT) arrangements, outsourcing setup, and the specific payment services that will be offered under the license.
In Lithuania, the strength of the application file matters from the beginning. The regulator expects it to elaborate on the product, customer journey, fund movement, local team, and provider setup in a way that matches the business plan and program of operations.
The Lithuanian EMI regime is built on national law and the EU framework for payment services and electronic money. The Second Payment Services Directive (PSD2), the Second Electronic Money Directive (EMD2), AML/CTF, safeguarding, ICT, outsourcing and operational resilience expectations should therefore be considered when preparing the application and why you should consider working with an EMI license consultant in Lithuania once you have decided to proceed with your fintech license application.
Licensing requirements:
- The applicant must have a minimum of 350,000 euros in their initial share capital to apply for an EMI license in Lithuania.
- 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: A Lithuania EMI license applicant is required to develop and implement anti-money laundering and countering terrorist financing (AML/CTF) programs, including customer due diligence/know your customer (CDD/KYC), 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 resilience.
- Application Package:EMI companies’ licensing application packages usually include:
- 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: With EEA passporting, an EMI license in Lithuania can authorize an Electronic Money Institution (EMI) to operate throughout the EEA.
Ongoing compliance:
An EMI with a license in Lithuania must keep operating in line with the business model presented and approved 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 authorized services are provided should remain consistent with the file submitted to the Bank of Lithuania.
The institution has to monitor its own funds, protect customer funds, submit regulatory reports, and actively follow stated procedures for AML/CTF, sanctions, ICT, complaints handling, and internal control 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 remain assigned to responsible persons. 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-authorization changes should be reviewed before they are made. This may include changes to ownership, management, authorized 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 updated its expectations for electronic money and payment institutions, especially on internal controls, governance, and the protection of customer funds. A new applicant must build these recent changes into their file from the start, ensuring that it highlights how the EMI will operate, who is responsible for compliance, and how customer funds will be protected. An EMI license consultant in Lithuania can help with that.
The payment infrastructure is also part of the current discussion. Starting on 6 October 2025, electronic money and payment institutions providing payment services gained direct access to the Eurosystem Trans-European Automated Real-time Gross settlement Express Transfer (TARGET) payment system, except for T2S securities settlement. For EMIs that depend on euro payments, CENTROlink, Single Euro Payments Area (SEPA) connectivity, and possible TARGET access should be considered at the structuring stage.
Legalaes follows these developments when assessing Lithuanian EMI license projects, especially where the model depends on payment infrastructure, safeguarding, banking partners, or cross-border flows.
Get expert legal guidance on your licensing application.
Types of EMI licenses in Lithuania
Lithuania offers different authorization 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 the company’s need for EEA passporting.
Here are the primary types of EMI licenses available in Lithuania:
| License type | Scope |
|---|---|
| Electronic Money Institution licence | A Full EMI license in Lithuania allows an institution to issue electronic money and provide authorized 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 authorized by the Bank of Lithuania. |
| Small Electronic Money Institution license | The Small EMI license 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 operate only in Lithuania. This route may be relevant if the business does not need full EEA market access or a broader EMI structure from launch. |
| Payment Institution licence | A Payment Institution (PI) Lithuania fintech license 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 | The Small Payment Institution authorization 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 and full PI authorization. |
Key differences between a full and small EMI License in Lithuania
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.
Get guidance on which license to apply for.
Regulatory Oversight
Both the full and small EMI licenses in Lithuania are regulated by the Bank of Lithuania, which ensures that institutions comply with relevant EU directives, such as the EMD2 and 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 License in Lithuania:
The service scope is approved by the Bank of Lithuania through the program 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 authorized scope
Overview of requirements to obtain an EMI license in Lithuania
Main requirements:
- Lithuanian company structure suitable for EMI authorization
- Clear shareholder and Ultimate Beneficial Owner (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 program 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
- 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 the BoL and any clarifications and queries that the 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 the 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 an individual business plan
- Preparation of the documents required for licensing
- Accounting services
- Assistance in opening a bank account, including segregated and safeguard accounts
- Connection with the SEPA system
- Connection with SWIFT
- Connection with a card issuance program
- Apostilled corporate documents
- Introduction to confirmed software providers
- Legal support
Ready-Made solution
This service is available on request
- Registered company
- No debts, no liabilities – clean company
- Active license
- Assistance with transfer of ownership
Jegor Kupratsevits
Head of Fintech
Jegor Kupratsevits is the Head of Fintech at Legalaes, leading the firm’s advisory across fintech, crypto, and financial services projects. He oversees regulatory compliance, licensing strategies, and cross-border structuring, supporting clients in navigating complex legal and operational environments.
With a background in banking, finance, and international business structures, Jegor focuses on delivering practical, compliant, and scalable solutions for fintech companies. His role combines regulatory expertise with commercial understanding, ensuring that client operations are aligned with both legal requirements and business objectives.
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, program 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.
- 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
- Organizational 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 license in Lithuania. For PI authorization, 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 license 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 the first year of implementation. In some projects, a 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
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, a 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 local executive available 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 an EMI with a license in Lithuania, this role is usually expected to have a credible local connection or availability.
- 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 on 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 sufficiently independent 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: Data Protection Officer (DPO) may be required where the company’s data-processing activity triggers General Data Protection Regulation (GDPR) requirements. Even where a formal DPO is not required, data protection responsibility should still be assigned.
Additional Obligations Under the Regulations
- After authorization, 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, authorized 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 your business model and define which roles should be local, internal, outsourced, or part-time.
Roadmap for obtaining an EMI license in Lithuania
For a more detailed roadmap of the project and commercial offer, get in touch with our EMI professional.
Jegor Kupratsevits
Head of Fintech
Jegor Kupratsevits is the Head of Fintech at Legalaes, leading the firm’s advisory across fintech, crypto, and financial services projects. He oversees regulatory compliance, licensing strategies, and cross-border structuring, supporting clients in navigating complex legal and operational environments.
With a background in banking, finance, and international business structures, Jegor focuses on delivering practical, compliant, and scalable solutions for fintech companies. His role combines regulatory expertise with commercial understanding, ensuring that client operations are aligned with both legal requirements and business objectives.
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 the payment institution license or restricted authorization, may 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 the first screening of shareholders, directors, UBOs, and key persons. The local management and compliance setup should 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 Program or another introductory route. The discussion is normally used to present the model, check whether the expected authorization 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
In this stage, the Bank of Lithuania goes through the application in detail. It may comment 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 license approval, 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’s supervision and must operate within the scope set out in the license issued.
scope set out in the granted licence.
Our EMI license consultant in Lithuania can provide support throughout the entire process.
Detailed Time Frames to Obtain an EMI License in Lithuania
A Lithuanian EMI licensing project will usually take somewhere between 6 and 14 months, starting from the first structuring work and ending with the licensing decision. The shorter timeline is likely if the ownership file, management team, source-of-funds materials, and main licensing documents are complete and well-prepared. If the payment flows are complicated, the documents are unclear, or the Bank of Lithuania has to send several rounds of questions, the timeline is likely to 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 program 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 Program or introductory regulator contact
- Presentation of the proposed EMI model
- Discussion of the intended authorization 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’s questions
By ensuring thorough preparation and proactive communication with the regulator, applicants can streamline the process and potentially reduce the time required to obtain an EMI license in Lithuania.
Get expert help on obtaining your Lithuania EMI license.
Advantages of the EMI license in Lithuania
Obtaining an Electronic Money Institution 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 authorized institutions. This gives the jurisdiction a stronger regulatory and professional ecosystem around EMI licensing, compliance, payment operations, and post-authorization supervision.
02
EEA Market Access Through Passporting
A Lithuanian EMI license can support the provision of approved services across the EEA through the EU passporting framework. This allows the company to scale from one EU authorization instead of applying for separate licenses in each target member state, provided its 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 Program is one of the practical reasons Lithuania can be attractive to new EMIs. Applicants can speak with the Bank of Lithuania before preparing their full file. They can use this opportunity to present their 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 centers 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 the EMI business in Lithuania
Bank of Lithuania page for EMI authorization. It is the starting point for checking the application routes, filing steps, and the main documents expected from applicants.
Main Lithuanian law for electronic money institutions. It deals with EMI authorization, issuance and redemption of electronic money, restricted activity licenses, 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 planning to engage in regulated financial activities 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 an EMI license in Lithuania.
Navigate the requirements of all applicable legislation with confidence. Seek expert legal support from Legalaes.
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. If the 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 authorization, 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.
Get legal guidance on Lithuania’s tax regime and tax obligations applicable to electronic money and payment institutions.
Frequently asked questions about the Lithuania EMI license
1. What is an EMI license in Lithuania?
An EMI license in Lithuania is a regulatory authorization granted by the Bank of Lithuania. It allows companies to issue electronic money and provide various payment services in Lithuania and, through EU passporting, across the European Economic Area. This license is ideal for businesses managing e-wallets, payment accounts, card programs, and cross-border payment flows.
2. How long does it take to obtain an EMI license in Lithuania?
Obtaining an EMI license in Lithuania typically requires 6-14 months from initial structuring to the final decision. This timeline includes company formation, document preparation, and regulatory review. High-quality applications and proactive communication with the Bank of Lithuania help streamline this process.
The Bank of Lithuania’s detailed evaluation typically lasts three months and commences once the application is deemed complete. However, complex transaction flows, unclear ownership documents, and other issues can extend this period significantly.
3. What is the minimum capital for an EMI license in Lithuania?
The minimum share capital for an EMI license in Lithuania is EUR 350,000. This capital must be fully paid up and its source of funds clearly documented to satisfy the Bank of Lithuania's strict regulatory assessment. Projects with a narrower scope, such as a Payment Institution license, require a lower capital amount.
A payment institution’s minimum share capital ranges between EUR 20,000 to EUR 125,000, depending on the specific payment services requested. A small EMI license also has significantly lower requirements, reflecting its reduced operational scale and domestic limits.
4. What is the difference between a full EMI license and a small EMI license in Lithuania?
A full EMI license in Lithuania provides EU passporting rights and unrestricted transaction volumes. Conversely, a small license limits operations to the Lithuanian market with specific turnover thresholds. While both require Bank of Lithuania oversight, the small license offers a significantly lower initial capital requirement.
- Geographic Scope: A full authorization allows institutions to serve the entire European Economic Area, while small licenses are restricted to domestic activity.
- Operational Ceilings: Small EMIs are subject to strict limits on the average outstanding electronic money and payment transaction turnover.
- Capital Investment: The full license requires a minimum of EUR 350,000 in share capital, whereas the required capital for smaller licenses is significantly lower.
5. Can a Lithuania EMI license be passported across the EEA?
A full EMI license in Lithuania allows institutions to operate throughout the EEA via EU passporting rights. This framework enables businesses to scale across the European market without seeking separate authorizations in each member state. However, small-scale licenses are restricted solely to domestic Lithuanian activities.
Passporting rights apply only to the specific payment services authorized by the Bank of Lithuania in the institution's program of operations. While full licenses provide unrestricted transaction volumes, small EMI authorizations are limited by average outstanding electronic money and transaction turnover thresholds, preventing geographic expansion.
6. What documents are required for an EMI license application in Lithuania?
Obtaining an EMI license in Lithuania requires submitting a detailed business plan, operational programs, and three-year financial forecasts. The application package must also include management fit-and-proper files, AML/CTF policies, and safeguarding frameworks. Furthermore, specific documents regarding ICT security and governance policies are mandatory.
The regulatory file further includes ownership structure materials, UBO information, and reputation declarations for all decision-makers. For specialized services, the Bank of Lithuania reviews product-specific assessments, such as wallet solutions or card programs, separately from the standard program of operations.
Get an EMI license in Lithuania.
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