Payment institution licence in Lithuania
The Bank of Lithuania licenses payment institutions under PSD2 as implemented in the Law on Payment Institutions. Applicants can choose a full licence, which can be passported, or a restricted-activity licence valid only in Lithuania. Supervision has tightened, so expect detailed questions on AML, safeguarding and local management.
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
- €20,000 (money remittance only), €50,000 (payment initiation) or €125,000 (services 1 to 5 of PSD2 Annex I)PSD2-Art-7as of 2026-10-08Source ↗
- Statutory assessment period
- 3 months from submission of complete and sufficiently informative documents (2 months for a restricted-activity licence); the period is extended when more information is requestedas of 2026-10-08Source ↗
- Head office
- A payment institution must have its head office in the same Member State as its registered office and carry out at least part of its payment services business therePSD2-Art-11(3)as 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 pack6–14 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
- RegulatorBank of Lithuania review, questions and decision12–40 weeksOutside our control; requests for more information extend the statutory period
Estimated end to end: 5–13 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 client funds
- ICT risk-management framework under DORA
Questions we get
What is a restricted-activity payment institution licence?
A licence for smaller operations with a shorter 2-month assessment period. It is valid only in Lithuania and cannot be passported to other EU states.
Does the Bank of Lithuania really decide within 3 months?
The 3 months run from a complete file. In practice the Bank of Lithuania usually sends comments asking for more information, which extends the period.