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Business Services for Fintech Companies in Lithuania

AT A GLANCE

  1. Lithuania has issued more EMI and payment institution licences than most other EU member states — making it the most accessible regulated fintech jurisdiction in the EU.
  2. A Lithuanian fintech company needs more than a registration certificate — it requires an AML/KYC framework, a compliance officer, capital adequacy planning, and governance that satisfies the Bank of Lithuania.
  3. We provide seven service areas for fintech companies: accounting, legal, compliance, compliance documentation drafting, recruitment, outsourcing, and regulatory advisory.
  4. MiCA regulation took full effect in December 2024, establishing Lithuania as one of the primary EU jurisdictions for crypto-asset service provider authorisation.
  5. Our fintech team works across the full spectrum of Lithuanian and EU regulatory frameworks — EMI, PI, MiCA, VASP, investment firm, and crowdfunding licences.

Lithuania is the leading EU jurisdiction for fintech licensing — accessible, well-regulated, and actively open to payment companies, EMIs, crypto businesses, and forex operators. Establishing a fintech company here requires company registration, AML/KYC compliance documentation, regulatory advisory on the applicable licence, and ongoing accounting and legal support calibrated to the obligations of a licensed entity. We cover all seven service areas under one engagement — from initial structure design through to licence approval and post-licence operations. Our fintech team has direct experience across EMI, PI, MiCA, VASP, and investment firm regulatory frameworks.

Why Lithuania Is the Leading EU Fintech Jurisdiction

Lithuania’s position as the EU’s primary fintech licensing destination is not the result of marketing — it is the outcome of deliberate regulatory infrastructure built over a decade. The Bank of Lithuania has invested in making its licensing process faster, more transparent, and more accessible than most comparable EU regulators, while maintaining the compliance standards required for EU-wide passporting rights.

EMI and payment institution licensing

Lithuania has developed an established financial technology sector, particularly in electronic money and payment services. The Bank of Lithuania authorises and supervises Electronic Money Institutions (EMIs) and Payment Institutions (PIs) under Lithuanian and EU legislation. Licensing applications are assessed individually against requirements concerning initial capital, governance, management suitability, safeguarding of client funds, operational infrastructure and regulatory compliance. The duration of authorisation depends on the completeness and complexity of the application. Claims about Lithuania’s ranking by number of licences or comparative licensing speed should be supported by current regulatory statistics. An EMI licence issued by the Bank of Lithuania carries full EU passporting rights under the Electronic Money Directive (EMD2) and the Payment Services Directive (PSD2), allowing the licensed entity to offer services across all 27 EU member states under a single authorisation.

MiCA and crypto licensing

Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA) established a harmonised EU regulatory framework for crypto-assets and crypto-asset service providers. Its provisions concerning CASPs have generally applied since 30 December 2024. Lithuania’s transitional period for previously registered Virtual Asset Service Providers (VASPs) ended on 31 December 2025. Since 1 January 2026, national VASP registration no longer provides sufficient authorisation to offer regulated crypto-asset services. Businesses must generally obtain CASP authorisation from the Bank of Lithuania or qualify for an applicable exemption or notification procedure, including Article 60 of MiCA for certain authorised financial institutions. The Financial Crime Investigation Service (FNTT) performs relevant AML/CFT functions within its statutory competence.

CENTROlink and SEPA infrastructure

CENTROlink is a payment infrastructure operated by the Bank of Lithuania that provides eligible payment service providers licensed in the European Economic Area with access to major SEPA payment schemes. Electronic Money Institutions and Payment Institutions may apply to participate, subject to the applicable eligibility, technical, operational and compliance requirements. Access is not granted automatically upon obtaining a financial licence. CENTROlink may reduce dependence on commercial payment intermediaries, but it does not eliminate the need for appropriate arrangements to safeguard customer funds or guarantee unrestricted access to central bank settlement services.

Talent, cost, and operational environment

Vilnius has a growing fintech talent pool — compliance officers, AML analysts, software engineers, and financial professionals with experience in regulated entities. The cost of establishing operations in Lithuania is competitive relative to Western European fintech hubs. The country’s digital infrastructure ranks among the best in the EU, and English is widely used in the corporate and professional services environment. For companies that need to demonstrate genuine operational presence to the regulator — as most licensed entities do — Lithuania is both credible and practical.

Lithuania fintech by numbers
Lithuania has an established fintech sector covering electronic money institutions, payment institutions, investment firms and authorised crypto-asset service providers · The number of licensed institutions changes over time and should be verified against current supervisory registers · Pre-application consultations with the Bank of Lithuania are available and recommended · Eligible EEA-licensed payment service providers may apply for CENTROlink participation, subject to the applicable requirements · The MiCA CASP authorisation framework has applied since 30 December 2024 · Lithuania’s former VASP transitional regime ended on 31 December 2025 · AML/CFT supervision is carried out by the competent Lithuanian authorities according to their statutory responsibilities.

Regulated Licences Available in Lithuania

Different fintech activities require different licences. The table below maps the most common fintech business models to the applicable Lithuanian regulatory framework. We advise on the correct licence category as the first step of every regulatory advisory engagement.

Business Activity Licence / Registration Authority Min. Capital
Issuing e-money, e-wallets EMI Licence Bank of Lithuania €350,000
Payment processing, acquiring and other regulated payment services Payment Institution Licence Bank of Lithuania EUR 20,000, EUR 50,000 or EUR 125,000, depending on the services authorised. Money remittance generally requires EUR 20,000; payment initiation services generally require EUR 50,000; and acquiring of payment transactions and other payment services within the relevant statutory categories generally require EUR 125,000. Additional ongoing own funds and insurance requirements may apply.
Crypto exchange, custody, brokerage MiCA CASP Authorisation Bank of Lithuania €50,000–€150,000
Forex, CFD, investment services Investment Firm Licence (MiFID II) Bank of Lithuania €75,000–€750,000
Crowdfunding platform European Crowdfunding Service Provider (ECSP) Authorisation under Regulation (EU) 2020/1503 Bank of Lithuania Prudential safeguards equal to at least the higher of EUR 25,000 or one quarter of the preceding year’s fixed overheads, calculated in accordance with Article 11 of the Regulation. Safeguards may be maintained through qualifying own funds, insurance or comparable guarantees, or a permitted combination.
Crypto-asset services previously covered by the Lithuanian VASP registration regime CASP Authorisation under Regulation (EU) 2023/1114 (MiCA) Bank of Lithuania EUR 50,000, EUR 125,000 or EUR 150,000 in permanent minimum capital requirements, depending on the authorised services, together with the applicable ongoing prudential safeguards. National VASP registration no longer provides authorisation to offer regulated crypto-asset services as of 1 January 2026.
Consumer credit and peer-to-peer lending Registration in the applicable public list maintained by the Bank of Lithuania, subject to the specific requirements of Lithuanian consumer credit legislation Bank of Lithuania Capital and prudential requirements depend on the type of lending activity and the applicable regulatory framework. A universal EUR 1,000,000 minimum capital requirement does not apply to every consumer credit provider or P2P lending platform. Deposit-taking credit institutions and specialised banks are subject to separate licensing and capital requirements.

The licence categories above are simplified descriptions. Exact scope depends on the specific services offered and business model. A payment company also holding client funds may need an EMI rather than a PI licence. A crypto business offering staking may be treated differently from one offering exchange services only. We assess the correct category in the initial regulatory advisory consultation before any application work begins.

Our Services for Fintech Companies

Fintech companies in Lithuania have more complex service requirements than standard commercial businesses — spanning accounting, legal, compliance, documentation, staffing, and regulatory engagement simultaneously. We provide all seven service areas under one engagement, with a team that understands both the Lithuanian regulatory environment and the practical realities of building a licensed fintech business.

Accounting Services for Fintech

Accounting for a licensed fintech entity goes beyond standard bookkeeping. Regulatory capital requirements must be monitored monthly. Client fund segregation must be reflected correctly in the accounts. Transactions in multiple currencies — including crypto assets — require specialist treatment. We provide fintech-specific accounting on a fixed monthly retainer, with reporting calibrated to both standard Lithuanian obligations and the additional requirements of a Bank of Lithuania-regulated entity.

  • Monthly bookkeeping under Lithuanian accounting standards — including multi-currency and crypto transactions
  • Regulatory capital monitoring — monthly confirmation that minimum capital requirements are maintained
  • Client fund segregation accounting — separate tracking of client funds in safeguarding accounts
  • VAT returns — including complex VAT treatment of financial and payment services
  • Payroll and SoDra declarations for Lithuanian compliance and operations staff
  • Annual financial statements for both JAR filing and Bank of Lithuania regulatory reporting
  • Intragroup transaction accounting and transfer pricing documentation
  • Crypto asset accounting — fair value measurement and VMI-compliant reporting
Legal Services for Fintech

Legal work for a licensed fintech company spans corporate law, contract law, employment law, and regulatory law at the same time. The legal documentation required — terms of service, data processing agreements, payment processing contracts, employment agreements for regulated roles — must satisfy both standard Lithuanian commercial law and the additional requirements imposed by the Bank of Lithuania as conditions of the licence. We prepare and maintain the full legal documentation framework for fintech companies.

  • Terms of service and user agreements — compliant with PSD2, EMD2, MiCA, GDPR, and Lithuanian consumer protection law
  • Data processing agreements — for fintech companies processing client personal data at scale
  • Payment processing and acquiring agreements — for companies operating payment infrastructure
  • Employment contracts for regulated roles — compliance officers, MLROs, data protection officers
  • Shareholder agreements and corporate governance — aligned with Bank of Lithuania governance expectations
  • Cross-border passporting notifications and compliance documentation — assisting authorised financial institutions with the applicable regulatory notification procedures for providing permitted services in other EU/EEA Member States. Passporting rights depend on the institution's licence type and scope of authorisation. Restricted EMI and PI licences do not provide the same cross-border passporting rights as full authorisations. A separate contractual passporting agreement is not generally required to obtain the statutory right to provide authorised services across the EU/EEA.
  • Licence condition compliance documentation — internal policies required as conditions of authorisation
  • Regulatory correspondence support — drafting and reviewing communications with the Bank of Lithuania
Compliance Services for Fintech

AML/KYC compliance is a legal obligation under the Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing, which implements the EU Anti-Money Laundering Directives. For licensed entities, the Bank of Lithuania actively supervises compliance frameworks and conducts on-site inspections. A framework that is incomplete, undocumented, or inconsistently applied is a material risk to the licence. We design, implement, and maintain AML/KYC compliance frameworks from pre-licence stage through to ongoing regulatory supervision.

  • AML/KYC policy drafting — comprehensive internal policy compliant with Lithuanian law and FATF standards
  • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures and workflows
  • Business-wide ML/TF risk assessment and customer risk scoring methodology
  • MLRO (Money Laundering Reporting Officer) function — outsourced or advisory
  • Transaction monitoring framework — typologies, alert thresholds, escalation procedures
  • STR (Suspicious Transaction Report) filing procedures and FNTT reporting
  • Compliance testing and gap analysis against current Bank of Lithuania expectations
  • Supervisory examination preparation — supporting companies ahead of Bank of Lithuania reviews
MLRO requirement for licensed entities

Every Lithuanian fintech company subject to AML obligations must designate a Money Laundering Reporting Officer (MLRO) — a named individual responsible for receiving internal suspicious activity reports and filing STRs with the FNTT. The MLRO must be adequately qualified, given sufficient authority, and supported by documented procedures. We provide outsourced MLRO services for licensed entities that do not yet have this function in-house.

Compliance Documentation Drafting

A licensed fintech company is not compliant simply because it has an AML policy — it is compliant when all of its operational procedures, internal controls, and staff-facing documents are correctly drafted, consistently applied, and regularly reviewed. The Bank of Lithuania's supervisory examinations assess documentation quality directly. Gaps between a company's stated policies and its actual documented procedures are one of the most common findings in regulatory examinations. We draft the complete suite of compliance documentation required for a licensed Lithuanian fintech entity.

  • AML/CFT Compliance Programme — the master document defining the company's full anti-money laundering framework
  • Customer Acceptance Policy — defining which customers are accepted, rejected, or subject to enhanced scrutiny
  • KYC Onboarding Procedures — step-by-step documented procedures for individual and corporate client onboarding
  • Enhanced Due Diligence (EDD) Procedures — for PEPs, high-risk jurisdictions, and complex ownership structures
  • Transaction Monitoring Procedures — alert handling, investigation workflow, and escalation to the MLRO
  • Sanctions Screening Procedures — screening against EU, UN, OFAC, and other applicable sanctions lists
  • Internal STR Reporting Procedures — how staff report suspicions internally before the MLRO files externally
  • Compliance Training Programme — staff AML/KYC training materials and training records framework
  • Data Retention and Record-Keeping Policy — aligned with AML retention obligations (minimum 5 years)
  • Outsourcing Policy — governing third-party service arrangements in accordance with EBA guidelines
  • Business Continuity and ICT Risk Policy — for companies subject to DORA (Digital Operational Resilience Act)
  • Annual Compliance Review Template — structured internal review of the compliance programme effectiveness
Documentation vs. policy

There is a meaningful distinction between having an AML policy and having a fully documented compliance programme. An AML policy states what the company does in principle. Compliance documentation provides the step-by-step procedures that staff actually follow — the KYC checklist an analyst uses when onboarding a client, the decision tree a transaction monitoring officer uses when an alert fires, the escalation flowchart the MLRO uses when deciding whether to file an STR. The Bank of Lithuania's examiners review both. We draft both.

Recruitment Services for Fintech

A Lithuanian fintech licence requires a demonstrably qualified team. The Bank of Lithuania assesses the fitness and propriety of key function holders — directors, the compliance officer, the MLRO, the risk manager, and any other persons responsible for regulated activities. Beyond the regulatory requirement, a fintech operation needs staff who understand compliance, payments infrastructure, and financial services. We support fintech companies in identifying, assessing, and onboarding the key personnel needed to satisfy both the regulator and operational requirements.

  • Compliance officer and MLRO sourcing — candidates with Bank of Lithuania-approved qualification profiles
  • Risk manager and internal audit function sourcing for licensed entities
  • AML analyst and KYC specialist recruitment for companies building in-house compliance teams
  • Technical staff sourcing — payments engineers, backend developers, and infrastructure specialists
  • Employment contract drafting for regulated roles — compliant with the Labour Code and licence conditions
  • Fit and proper assessment support — preparing key function holders for Bank of Lithuania suitability review
  • Employer registration and payroll setup for companies making their first Lithuanian hires
Outsourcing Services for Fintech

Not every fintech company needs a full in-house team from day one. Outsourcing key functions — CFO, compliance officer, legal counsel, and MLRO — allows companies to access qualified professionals at a fraction of the cost of full-time employment, while meeting the Bank of Lithuania's requirements for demonstrated expertise in regulated roles. We provide outsourced function services specifically designed for licensed and pre-licence fintech entities.

  • Outsourced CFO — monthly financial oversight, management reporting, investor relations support
  • Outsourced Compliance Officer — ongoing compliance programme management, policy maintenance, staff training
  • Outsourced MLRO — STR assessment and FNTT filing, SAR management, internal reporting oversight
  • Outsourced Legal Counsel — ongoing advisory on licence conditions, regulatory changes, and contracts
  • Virtual DPO (Data Protection Officer) — GDPR compliance programme management
  • Regulatory reporting support — periodic Bank of Lithuania submissions and supervisory correspondence
  • Board advisory services — preparing management for Bank of Lithuania governance assessments
Outsourcing and the Bank of Lithuania

Lithuanian financial institutions may outsource certain operational and compliance functions where permitted under the regulatory framework applicable to their licence and business model. Outsourcing arrangements must comply with relevant Lithuanian legislation, applicable EBA guidelines and, where relevant, Regulation (EU) 2022/2554 on digital operational resilience (DORA). Outsourcing must not impair the institution's internal controls, effective supervision or ability to meet regulatory obligations. The institution retains ultimate responsibility for outsourced activities. The outsourcing of compliance or AML reporting functions must be assessed individually, taking into account the institution's governance arrangements, applicable independence requirements, personnel suitability and the specific responsibilities that cannot be transferred to an external provider.

Regulatory Advisory

Regulatory advisory covers the strategic and technical guidance needed to navigate the Lithuanian and EU regulatory landscape — from selecting the right licence through to preparing and submitting the application, managing the Bank of Lithuania review process, and maintaining compliance with ongoing supervisory expectations after the licence is granted. We provide regulatory advisory at every stage of the fintech regulatory lifecycle.

  • Licence selection and strategy — assessing the applicable regulatory framework and most efficient path to authorisation
  • Pre-application consultation — preparing for and attending Bank of Lithuania pre-application meetings
  • Licence application preparation — complete package: business plan, capital adequacy model, governance documents, AML policy
  • Application submission and Bank of Lithuania liaison — managing the review and responding to regulator queries
  • MiCA CASP authorisation — full application support for crypto-asset service providers under MiCA Regulation
  • MiCA CASP authorisation for existing and newly established crypto-asset businesses — regulatory gap analysis, assessment of the proposed crypto-asset services, preparation of the authorisation application and supporting governance, prudential, AML/CFT and operational documentation. Lithuania's former VASP transitional regime ended on 31 December 2025, and VASP registration no longer provides authorisation to conduct regulated crypto-asset services.
  • Ongoing regulatory compliance programme — maintaining licence conditions and preparing for supervisory examinations
  • Regulatory change monitoring — tracking EU and Lithuanian regulatory developments affecting licensed entities

The Fintech Company Lifecycle in Lithuania

Building a licensed fintech company in Lithuania follows a defined sequence. Understanding what is required at each stage helps avoid the delays that result from preparing documents in the wrong order or starting the licence application before the foundational elements are in place.

Stage Key Activities Typical Timeline Services Involved
Structure design Entity selection, share structure, governance design, licence strategy Week 1–2 Regulatory advisory, legal
Company registration UAB registration, address, bank account, VAT Week 2–4 Corporate, accounting
Pre-licence prep AML policy, compliance docs, business plan, capital plan, key personnel Month 1–3 Compliance, documentation, legal, recruitment, regulatory
Licence application Submission to Bank of Lithuania; responses to queries Month 3–6 Regulatory advisory, legal, compliance
BoL review Regulator assessment, fit-and-proper interviews, additional information Month 6–12 Regulatory advisory, compliance, outsourcing
Licence granted Certificate issued; SEPA/CENTROlink connection; operational launch Month 10–14 All services
Ongoing supervision Periodic reporting, AML monitoring, licence condition compliance, examinations Ongoing Accounting, compliance, documentation, outsourcing, regulatory
Realistic timeline expectations
The Bank of Lithuania’s statutory review period for EMI and PI applications is 3 months from the date a complete application is received. In practice, the total process from initial preparation to licence grant typically takes 10–14 months for well-prepared applications. The most common causes of delay are incomplete applications, governance gaps identified during the review, and fit-and-proper concerns about key function holders. A well-prepared application — with complete documentation, a credible business plan, and qualified key personnel — moves through the process significantly faster than one assembled under time pressure.

AML Compliance: What Lithuanian Fintech Companies Must Have

AML compliance is the area where most fintech licence applications run into problems — either because the framework is incomplete at the time of application, or because it has not been properly maintained after the licence is granted. The Bank of Lithuania and the FNTT both conduct active AML supervision of licensed entities. Here is what a compliant Lithuanian fintech entity must have in place.

Before the licence application

  • A fully drafted AML/CFT Compliance Programme — not a template, but a document tailored to the specific business model and customer base
  • A designated MLRO — named, qualified, and with a documented mandate
  • A business-wide ML/TF risk assessment — identifying the specific money laundering and terrorist financing risks of the company’s activities
  • Customer Acceptance Policy — defining risk appetite for customer categories, PEPs, high-risk jurisdictions
  • KYC and EDD procedures — documented step-by-step onboarding workflows for all customer types the company will serve
  • Transaction monitoring framework — a documented approach to monitoring transactions for suspicious activity

After the licence is granted

  • Annual review of the AML/CFT Compliance Programme — updated to reflect regulatory developments and business changes
  • Ongoing transaction monitoring — active monitoring of customer transactions against established typologies and thresholds
  • STR filing with the FNTT — within the statutory timeframe when suspicious activity is identified
  • AML training for all relevant staff — documented, with training records maintained
  • Regular internal compliance testing — assessing whether documented procedures are being followed in practice
  • Regulatory reporting — periodic submissions to the Bank of Lithuania and FNTT as required by licence conditions
What Bank of Lithuania examiners look for
During AML supervisory examinations, the Bank of Lithuania’s examiners review the written compliance programme, sample customer onboarding files to assess KYC quality, examine transaction monitoring alert records, and interview the MLRO and compliance officer. The most common findings are: insufficient EDD for high-risk customers; transaction monitoring alerts that were closed without adequate investigation; AML policies that do not reflect the company’s actual business model; and MLRO functions held by individuals without demonstrable AML expertise. Our compliance documentation and outsourced MLRO services are designed specifically to address these examination risk areas.

Frequently Asked Questions

Ready to build your Lithuanian fintech company?

Contact us to begin. We will confirm the correct licence for your business model, assess your current state of readiness, and provide a structured engagement plan covering all seven service areas. We work with pre-application companies, companies mid-application, and licensed entities that need ongoing support. Response within 24 business hours.

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Company in Lithuania UAB partners

Company in Lithuania UAB collaborates with a network of trusted partners across legal, financial, accounting, and business consulting sectors. Our strategic partnerships enable us to provide clients with end-to-end solutions for company registration, tax advisory, banking setup, and beyond — all under one roof, right here in Lithuania.

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Company in Lithuania UAB has been recognised as one of Lithuania’s most trusted business services firms. Based on the independent economic data of 2025, we have been awarded the Strongest in Lithuania designation for four consecutive years — a testament to our financial stability, professional credibility, and the trust that our clients place in us.

We contribute to a transparent, well-functioning business environment in the Lithuanian Republic — and we bring that same standard of integrity to every client engagement.

Ready to start your business in Lithuania?Contact our team today for a personalized consultation. We are here to make the process simple, fast and hassle-free.Contact us
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