Payment initiation and account information services in Lithuania
In Lithuania, payment initiation providers need a payment institution licence from the Bank of Lithuania, while account information providers are registered. Neither may hold client funds, but both need professional indemnity insurance. Expect the same scrutiny of management, security and AML as for other payment firms.
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
- Payment initiation (PIS) initial capital
- €50,000, plus professional indemnity insurance or a comparable guaranteePSD2-Art-7(b)as of 2026-10-08Source ↗
- Account information (AIS) capital
- No initial capital; registration instead of authorisation, with professional indemnity insurance or a comparable guaranteePSD2-Art-33as of 2026-10-08Source ↗
- Statutory assessment period (PI licence)
- 3 months from submission of complete and sufficiently informative documents; extended when more information is requestedas 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, insurance and application pack6–12 weeksHartsiz drafts the pack; the client supplies people, insurance and decisions
- RegulatorBank of Lithuania review and decision12–36 weeksOutside our control; requests for more information extend the statutory period
Estimated end to end: 5–12 months. Not a guarantee.
What the regulator expects to see
- Lithuanian company with head office in Lithuania
- Management and key function holders with real presence, competence and time for the role
- Professional indemnity insurance sized under the EBA guidelines
- Strong customer authentication and secure communication with banks' APIs
- ICT risk-management framework under DORA
Questions we get
Can an AIS registration be passported?
Yes. Registered account information service providers can offer their service in other EU/EEA states through the PSD2 notification procedure.
Will PSD3 change this?
The new EU payments package is not yet adopted. Until it applies, PIS and AIS remain under the current PSD2-based rules.
Changes affecting this route
- UpcomingEuropean Union · Fintech & Crypto · medium impact
PSD3 and Payment Services Regulation indicative plenary vote
The European Parliament's procedure file lists 14 December 2026 as the indicative plenary date for the payment services file, after the committee approved the agreed text in May 2026. Adoption would start the countdown to new authorisation, safeguarding and fraud-liability rules for payment and e-money institutions. Indicative plenary dates can move.
Source ↗