Electronic money institution licence in Lithuania
The Bank of Lithuania licenses electronic money institutions and gives applicants direct access to its specialists during the process. Lithuania built a large EMI sector and the regulator has since tightened supervision, so a light-touch application no longer works. Expect close scrutiny of the business plan, AML controls and the people running the firm locally.
Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them
Regulator · Bank of Lithuania (Lietuvos bankas) ↗
Key facts
- Minimum initial capital
- €350,000EMD-Art-4as of 2026-10-08Source ↗
- Statutory assessment period
- 3 months from submission of complete and sufficiently informative documents; the clock restarts when the Bank of Lithuania asks for moreas of 2026-10-08Source ↗
- Passporting
- A full EMI licence allows e-money and payment services in other EU/EEA states after notificationas of 2026-10-08Source ↗
- EU reform status (PSD3/PSR)
- Negotiated text approved by the European Parliament ECON committee on 5 May 2026; plenary indicatively scheduled for 14 December 2026as of 2026-10-08Source ↗
Realistic timeline
Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.
- HartsizScoping and gap analysis2–4 weeks
- YouCompany set-up, hires, capital and application pack8–16 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
- RegulatorBank of Lithuania review, questions and decision16–52 weeksOutside our control; each request for more information restarts the statutory clock
Estimated end to end: 6–17 months. Not a guarantee.
What the regulator expects to see
- Lithuanian company with head office in Lithuania and part of the business carried on there
- Management and key function holders with real presence, competence and time for the role
- AML/CFT officer and framework under the Lithuanian AML law
- Safeguarding arrangements for e-money holders' funds
- ICT risk-management framework under DORA
Questions we get
Is Lithuania still the fast route to an EU EMI licence?
The legal deadline is 3 months, but it runs from a complete file and restarts with every request for more information. Applicants with thin local teams or weak AML frameworks should expect long question rounds or refusal.
Can we buy an existing Lithuanian EMI instead?
Acquiring a qualifying holding needs prior approval from the Bank of Lithuania, and the buyer is assessed much like a new applicant. It can save time but is not a shortcut.