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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.

OpenLicensed under the Law on Payment Institutions; PSD3/PSR still awaiting final adoption

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.

  1. HartsizScoping and gap analysis2–4 weeks
  2. YouCompany set-up, hires, capital and application pack6–14 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
  3. 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.

Tell us about your business.

We come back with the licensing options that fit your business model and what it takes to get there. A founder reads every message.

Contact us