Company in Lithuania UAB – Practice areas – Financial Licenses in Lithuania – Payment Institution License in Lithuania

Payment Institution License in Lithuania

Payment Institution License in Lithuania The best solution for financial service providers providing payment transactions and money transfers is a licensed payment institution or payment service provider (PSP) in Lithuania.

In accordance with the Law on Payments, a payment agency cannot hold the client’s funds longer than necessary for the payment transaction; therefore, it is not sufficient to have a license from the payment institution in order to be able to store funds on a payment card or other technical instrument, such as an electronic wallet – the License of the electronic money institution (EMI) or the bank license is required in these circumstances.

The Republic of Lithuania Law on Payments describes the full list of payment services that can be provided by payment institutions licensed by Lithuania.

Payment institution licensees are allowed to provide the following services:

Services for depositing cash in a payment account
Services for withdrawing cash
Payment transactions are executed
Execution of debits directly
Credit transfers are executed
Performing credit-backed payment transactions
The use of a credit or debit card for payment transactions
Transfers of funds
Payment Initiation Service (PSD2)
Account Information Service (PSD2)

Payment institution license in Lithuania

Cost and Stages of Payment Institution License in Lithuania

STAGE 1 – Preliminary analysis of the project

4,500 EUR

Legal analysis of the company’s business model and planned services
Company structure analysis
Calculation of total budget calculation (together with the salaries for the employees and any additional costs for the office).
Identification of requirements for the company’s personnel and their qualifications
Identification and approval of the requirements of the Bank of Lithuania for filing an application

STAGE 2 – Organization of the meeting with the Bank of Lithuania (together with the document and project preparation)

Organization of a meeting with representatives of the Bank of Lithuania
Assistance in the preparation of documents describing the structure of the company
Analysis of the project platform/website, a guide to its presentation
Preparation of the application for a PSP licence in Lithuania
Support when filling out the application form
Assistance in developing a business plan that meets the requirements Bank of Lithuania

STAGE 3 – License application

Documentation of company policies for AML, KYC, and cybersecurity of client assets.
A financial plan for the next three years will be prepared, along with a profit and loss statement and cash flow statement.
Documentation for the company’s operational processes and procedures (internal policies, risk assessment policies, internal audit process, operational plan, accounting procedures).
The preparation of required documents, assistance with filling out the application.
Representatives of a company must sign this document to confirm their right to do so.
In compliance with Lithuanian legislation, a document describing internal control mechanisms for preventing money laundering and terrorist financing.
Incidences and complaints that relate to safety, as well as procedures for monitoring, handling, and investigating them.
Detailed description of the business continuity processes, procedures for testing the adequacy and effectiveness of such plans, and a statement of operations of exceptional importance.
Statistical data collection and notification of suspicious transactions are described in terms of the principles and definitions applicable to this process.
Licensing fee confirmation document.
Documentary proof that client funds are stored in a client account.
The company structure is described in detail.
Detailed CVs of company owners and key executives.
Agreement regarding the office of the company.

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Lithuanian PSP/PI license for sale

Company in Lithuania UAB has extensive experience in establishing companies with financial licenses. Our primary goal is to make the process as efficient and timely as possible. We value our clients’ time and we found various ready-made Payment Institution licensed solutions to save your time. Below you will find valid offers with different fees, date of establishment, shared capital, employee count, and experience. Contact our team to find the best solution for your project and be operative in just 4 weeks.

Capital requirement for a payment institution

When the payment institution only provides money transfer services, not less than 20,000 euros is required.
A minimum of 50,000 euros is required if only payment initiating services are being offered by the payment institution.
Payment institutions must provide the following services with a minimum of €125,000:

Cash deposits, as well as all transactions associated with a payment account, are available through these services.
The payment account can be used to withdraw cash and to conduct all transaction requirements.
Transfers of cash to the Payment Account as part of payment transactions.
A payment transaction for which the user has a credit line.
Payment instrument issuance and/or transaction purchase.

Payment institution license application process

Payment institutions are required to apply for a license before submitting an application to the Bank of Lithuania. Please contact Company in Lithuania UAB as soon as possible if you are interested in obtaining a license from a payment institution so that we can help you define the financial services you should be licensed for. In this way, our clients gain a better understanding of the licensing process, the requirements of the Bank of Lithuania, as well as all other important aspects related to licensing.
Applicants go through the following stages:

A license application was submitted to the Bank of Lithuania’s Supervisory Service. If no deficiencies exist, the Oversight Service accepts the application if all the necessary documents are provided within five working days.
A license will be issued within three months if the application and attached documents do not contain any defects.
Granting or refusing a license. Bank of Lithuania’s Board analyses the submitted documents after they have been evaluated.

Upon reviewing the information, the Supervision Service decides whether to issue a licence or not.

Period for submitting license applications for payment institutions

According to the Law on Payments of the Republic of Lithuania, payment agencies that provide only account information services must process license applications within three months of receiving complete documentation.
We met for the first time with a representative of the Lithuanian Bank
In view of the fact that the representatives of the applicant company may not always be able to understand the legal acts governing the EMI licence application process, the Bank of Lithuania recommends that applicants for an EMI license apply to the Bank of Lithuania as soon as possible, and Company in Lithuania UAB will be happy to assist. Companies wishing to apply for authorization will receive more detailed information from representatives of the Bank of Lithuania.
In order to determine the type of license that is required for the project and to find out what financial services are to be provided under the project, the company must first meet with representatives of the Bank of Lithuania in order to answer all questions of interest that may arise during the application preparation. In such meetings, at least two representatives from the Bank of Lithuania’s Supervisory Service usually attend, but it may be necessary to bring in technical specialists who can evaluate the applicant’s platform or website.
Following are some topics the Bank of Lithuania plans to discuss during the preliminary meeting:

Company information
Payout institution’s shareholder, beneficiary, and investor data, by country of residence
Legal entity data related to the applicant
Ownership information of the company
Company’s business plan
Describe the project’s stage
The application will include detailed information about the products/services, target markets, pricing policies, and related regulations
The payment institution’s sources of financing
Personnel numbers expected

Before the first meeting with the Bank of Lithuania, the above information must be presented.

Licence fees of the money institution

To apply for a license of a payment agency, you must pay 898 euros to the State Tax Inspectorate’s account.

Basic claims on the payment institution

As an active payment institution, The Bank of Lithuania requires detailed data to be provided already at the time of initial circulation, since the establishment of a payment institution must meet all the requirements laid down at the time of approval. Nevertheless, the following points should be taken into consideration when assessing the applicant company:

Documents submitted to payment organizations must comply with the legal acts regulating their activities; truthful information set forth in legal acts must be submitted.
The payment institution must comply with its statutory capital requirements: Taking into account the services provided, the minimum capital payable by the payment institution must be at least 20,000, 50,000, or 125,000 euros, according to the Law on Payment Institutions of the Republic of Lithuania. Payment organizations must not make payments exceeding €3,000,000 per month.
Having a significant stake in the payment institution’s authorized capital and / or the right to vote, making sure the payment institution and its shareholders or beneficiaries are suitable and appropriate. It is important to have a good reputation, ensure financial viability of the project, and ensure reliable and prudent management.
Director qualification and experience: the directors must be able to carry out their duties with the required qualifications and experience, as well as an impeccable business reputation.
It is important that the business planning provided by the prospective payment institution corresponds to the capacity of the institution’s founders (shareholders or beneficiaries) to implement it.

A payment institution’s activities must be insured.
The company applying for a licence must also provide a detailed business plan that reflects the activities of the payment institution, in order to ensure the sound and prudent management of the payment institution. In addition, it is crucial that the company has a document describing its structure, such as divisions of labour and clear roles and responsibilities, a customer identification system, a risk monitoring document, as well as rules of internal control.

Comparison of PSP and EMI licenses

	PSP	EMI
Services for depositing cash in a payment account
Services for depositing cash in a payment account
Services for withdrawing cash
Payment transactions are executed
Execution of debits directly
Transfers of funds
Payment initiation
Account Information Service
The use of a credit or debit card for payment transactions
Electronic money issuance
Holding customer funds

Evaluation of submissions

Primary documents are verified and evaluated by Bank of Lithuania Supervisory Service specialists as part of the provision process. Their conclusions on authorization are based on a common understanding. During the evaluation process, the following processes are carried out:

The applicant firm should be kept in regular communication and be able to meet (if necessary).
Payment institutions are responsible for rectifying deficiencies identified by the Oversight Service.

Depending on the amount of services the applicant company plans to provide, the examination of the documents will take a certain amount of time. Applicants for a license of a payment agency can be evaluated more quickly if fewer documents are provided and applications are not submitted for all services that can be provided by the agency.

Currently, 311 companies have successfully obtained the Payment Institution in Lithuania license

Company in Lithuania UAB can help your company obtain a financial license in Lithuania, necessary for providing Payment institution services, and is ready to accompany your company at all stages of application. Contact us and ask your questions today.

Types of PI Licences in Lithuania

Depending on your resources and scope of intended activities, you can effectively choose one of the payment institution (PI) licences offered by the Bank of Lithuania.
Whether you’re a startup looking for reasonable market entry conditions, or a more mature company preparing to offer your payment services to the entire European continent, the Lithuanian regulator has a solution for you.

The Bank of Lithuania offers two types of PI licences:

Regular Payment Institution Licence
Payment Institution Limited Activity Licence

The Regular Payment Institution Licence is suitable and more accessible to established financial companies that are capable of meeting and continuously
maintaining initial capital requirements varying from 20,000 EUR to 125,000 EUR. Compared to other EU countries, this range is very competitive. The licence allows
its holders to provide a broad range of payment services in Lithuania and the EU, a single market with a vast and diverse customer base.

The Payment Institution Limited Activity Licence has been designed for Lithuanian and foreign startups with fewer resources. It’s based on a sandbox principle which means that the licence provides financial startups with access to a controlled environment where they can test new payment products, services, or business models with reduced regulatory constraints.

The main difference between a payment institution engaged in restricted activities and a regular payment institution is that the payment institution engaged in restricted activities isn’t subject to the minimum initial capital requirement. However, the Payment Institution Limited Activity Licence is valid solely in Lithuania and allows its licensees to provide only the payment services specified in Article 5(1- 5) of the Law on Payments.

Advantages of the Lithuanian PI Licence

Lithuania has established itself as a fintech-friendly hub, promoting innovation within the financial services sector. The regulatory framework is supportive of fintech startups, which makes it an ideal location for businesses focused on digital payments and financial technology. The Bank of Lithuania has recognised the importance of keeping pace with the rapidly evolving fintech industry and is always willing to work closely with innovative businesses. It offers a supportive and agile regulatory framework, where innovation is encouraged by allowing for experimentation and exploration while effectively protecting customers. Moreover, you can expect to join such fintech initiatives as clusters where fintech businesses, investors, and other stakeholders come together to collaborate and share resources.

The Bank of Lithuania has streamlined the application process for payment institution licences, which leads to quicker approval and entry into the market, compared to some other EU countries with lengthier regulatory procedures. If your application is successful, you can obtain a Lithuanian licence within three months. This early entry can help you capture market share and establish a strong foothold before your competitors. Shorter licensing times also translate into lower costs associated with the application process, including legal and compliance costs, application fees, and ongoing expenses while waiting for the licence.

If you succeed in obtaining the Regular Payment Institution Licence, the passporting principle will enable you to offer your products and services in other EU member
countries, provided that you notify the Bank of Lithuania and the appropriate authorities of those countries. Needless to say, obtaining a single licence in Lithuania can be more cost-effective than applying for separate licences in every country of operations. This means that you can invest more in the expansion and cross-border operations, and significantly accelerate your business growth.

Lithuania is also part of the Single Euro Payments Area (SEPA), an initiative that enables easy cross-border euro payments and enhances the convenience of providing payment services to EU customers. Customers across SEPA countries benefit from fast, low-cost, and standardised euro payments. For Lithuanian PI licence holders, this contributes to an improved customer experience, and in turn, allows them to grow and maintain their customer base. It’s also worth noting that Lithuania has an appealing taxation environment, featuring one of the EU's most favourable Corporate Income Tax rates at 15%. This allows payment institutions to retain a more significant share of their profits for reinvestment, business expansion, and day-to-day operational costs. The Ministry of Finance aligns itself with a growth-friendly tax policy that includes a range of significant tax incentives available to eligible businesses. The incentives include a triple-deduction of R&D costs and the Innovation Box where taxable profit from inventions created through R&D activities is taxed at a reduced 5% tax rate.

PI Regulations in Lithuania

Lithuanian payment institutions operate within a robust but agile framework, enforced by the Bank of Lithuania. It consists of national and EU regulations that primarily focus on ensuring prudent operations, customer protection, and unhindered growth. While navigating this framework is relatively easy, and you’ll receive plenty of support from the national institutions and from within the industry itself, we strongly recommend consulting with our legal team who can analyse your unique situation and ensure that your initial steps towards the launch of your payment institution don’t cause unwanted legal implications.

The main Lithuanian legislation and regulations governing the operations and licensing of PIs in Lithuania:

Republic of Lithuania Law on Financial Institutions
Republic of Lithuania Law on Payment Institutions
Republic of Lithuania Law on Payments
Republic of Lithuania Law on Companies
Republic of Lithuania Law on Banks
Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing
Resolution No 03-83 of the Board of the Bank of Lithuania of 24 May 2018 on the approval of the regulations for the calculation of initial capital and own
funds of electronic money institutions and payment institutions and the forms of the report on the calculation of initial capital and own funds of electronic money institutions (payment institutions)

The following EU regulations, inter alia, are also applicable:

The Payment Services Directive 2 (PSD2)
The Sixth Anti-Money Laundering Directive (AMLD6)
General Data Protection Regulation (GDPR)
Market Abuse Regulation (MAR)

Choosing Between a New PI Licence and a Ready-Made Company with a PI Licence in Lithuania

When launching a payment institution in Lithuania, one of the fundamental decisions that you must make is whether to apply for a new PI licence or to consider the acquisition of a ready-made company with an already existing PI licence. Each path has its own advantages and drawbacks, and the choice can significantly impact the launch and operations of your payment institution in Lithuania and beyond. Whichever way you choose, we have legal experts specialising in both, licensing and acquisition of a payment institution.

First, consider the following aspects of obtaining a new PI licence in Lithuania:

Obtaining a new PI licence allows you to build your payment institution from the ground up in accordance with your vision, as you’ll have complete control over its structure, policies, and operations
By building your payment institution from the ground up with robust regulatory compliance in mind, you can ensure a strong foundation in this crucial aspect which will prevent you from unwanted legal implications
New payment institutions don't carry the legacy issues or liabilities that can be associated with existing companies
The process of securing a new PI licence can be more time-consuming and resource-intensive as it involves detailed regulatory investigation, extensive
documentation, and a period of waiting for approval

Then, take into account the main aspects of buying a ready-made company with a PI licence in Lithuania:

Once the company is acquired, you can enter the market almost immediately and you can hit the ground running by launching your operations and serving customers without the wait associated with a new licence application
Ready-made payment institutions usually come with existing operational infrastructure, such as client relationships, systems, and processes which can save a lot of time and resources
Such companies can also offer opportunities for mergers and expansion strategies, allowing you to consolidate or diversify your presence in the market
Acquiring an existing company with a PI licence can be expensive, as you’ll need to cover the purchase price, due diligence costs, and potential liabilities

Key Requirements for PI Licence Applicants in Lithuania

To be able to apply for a Lithuanian PI licence, you first have to establish a local company that meets initial capital requirements and has a local registered office.

We can help you to choose the most suitable and permissible legal form, such as a Private Limited Liability Company (UAB), and design a corporate structure that
matches your business goals. It only takes up to a week to register a new company in Lithuania, provided that your documents are duly prepared and correctly
submitted. This means that you can move on to the licence application process almost in no time.

We also want to emphasise the importance of having all necessary internal processes in place and thorough documentation. They will make your company prepared to provide financial services in a safe and sound manner at the time of authorisation which is a legal prerequisite. Among everything else, you’ll have to establish sound anti-money laundering and counter-financing of terrorism (AML/CFT) procedures, including customer due diligence, risk assessment, and internal controls to prevent illegal activities within your payment institution.

Another essential requirement is your consent to due diligence and background checks which company owners, shareholders, and key personnel must undergo. The
Bank of Lithuania conducts them rigorously to assess every applicant’s integrity, professional qualifications and experience, and the actual availability of the
required capital and resources to launch and maintain a payment institution and fulfill its financial obligations. You must be willing to cooperate with the authority
and disclose any information that’s required to assess your suitability to run a payment institution.

In addition to such financial requirements as initial capital, you’ll also have to demonstrate that your operations will be financially prudent right from the start of your business. Lithuanian payment institutions are required to segregate customer funds from their own operational funds in order to safeguard customer funds in the event of the institution’s insolvency or financial difficulties. Also, it might be essential to demonstrate the possession of capital buffers as a safeguard against unexpected losses and economic downturns and have effective liquidity management policies to help ensure that the institution can meet its financial obligations in a timely manner.

Requirements for the Buyers of a Ready-Made Company with a Lithuanian PI Licence

To acquire a ready-made company with a PI licence in Lithuania, you’ll first have to verify with the Bank of Lithuania and other relevant regulatory authorities that the proposed acquisition of the ready-made company complies with all legal and regulatory requirements. In some cases, you might even be required to submit a formal application for regulatory approval of the acquisition. This application should usually include detailed information about the buyer, the seller, the transaction terms, and the reasons for the acquisition.

Similarly to applicants for a new PI licence, buyers also have to undergo due diligence and background checks. The Bank of Lithuania conducts a thorough review of every proposed acquisition which includes an assessment of the buyer’s financial stability, reputation, ability to meet regulatory requirements, and the seller’s compliance history. Following this process, the authority may need to approve the change of control which is an essential step in ensuring that the PI licence remains valid and in compliance with regulatory standards.

If the acquisition is approved and goes through, you’ll be obligated to provide notifications to customers of the ready-made company about the change in ownership which will allow you to maintain transparency and ensure a smooth transition. The notification should be provided to customers well in advance of the actual change in ownership, and include details about the acquiring company, any changes in the acquired company's name or branding, and the expected timeline for the transition.

Ongoing Requirements for PI Licensees in Lithuania

Once you’re a proud owner of a fully licensed Lithuanian payment institution, there will be many ongoing requirements for your company to fulfil continuously in order
to ensure uninterrupted compliance with the regulatory standards and the smooth operations of the business. These requirements include a range of areas, including
regulatory reporting, customer protection, and risk management.

The main requirements you have to be aware of are the following:

Maintaining the required capital at all times, and ensuring financial stability and the ability to meet financial obligations
Maintaining detailed records of customer transactions, financial statements, and other documentation
Submitting regular reports to the Bank of Lithuania and other relevant regulatory authorities to ensure transparency of the operations, financial health, and overall compliance with regulatory standards
Maintaining operational resilience by ensuring that the critical operations and services are uninterrupted, even in the face of disruptions or crises
Investing in cybersecurity measures to protect customer data and financial assets
Constantly updating and maintaining the efficiency of internal AML/CFT policies, including staff training

If you think that Lithuania is the right European jurisdiction for your payment institution, our team here at the Company in Lithuania UAB can help you realise your business idea as swiftly as possible. With support from our dedicated legal advisors, business development professionals, and financial accountants, you’ll find
the process of launching a payment institution in Lithuania straightforward, transparent, and effective. Reach out to us today to arrange a tailored consultation,
where we’ll work with you to understand your specific needs and develop a custom-made roadmap for your business success.

FREQUENTLY ASKED QUESTIONS

A licensed payment institution or payment service provider (PSP) in Lithuania is the best option for financial service providers providing payment transactions and money transfers.

The following services can be provided by payment institution licensees:

Providing services for depositing cash in a payment account
A cash withdrawal service
Execution of payments
Debits are directly executed
Transactions involving credit transfers are completed
Transactions backed by credit
Transactions involving credit or debit cards
Bringing funds into a bank account
PSD2 is the Payment Initiation Service
The Account Information Service (PDD2) provides account information to customers

Payment agencies cannot retain client funds longer than necessary for a payment transaction under the Law on Payments; therefore, a license from the payment institution is not sufficient to be able to store funds on a payment card or other technical instrument, such as an electronic wallet – it is necessary to have a license from an electronic money institution (EMI) or from the bank in these circumstances.

Lithuanian payment institutions are licensed to provide the full range of payment services described in the Law on Payments.

Client asset cybersecurity and AML policies are documented in the company’s policies.
In addition to profit and loss statements and cash flow statements, a financial plan for the next three years will be developed.
Processes and procedures for the company’s operational activities (internal policies, risk assessment policies, internal audit procedures, operational plan, accounting procedures, etc.).
Assisting with the application process, preparing required documents.
Signing this document confirms the right to act of the representatives of the company.
An internal control document for preventing money laundering and terrorist financing that complies with Lithuanian legislation.
Monitoring, handling, and investigating incidents and complaints related to safety.
Descriptions of processes and procedures for testing the adequacy and effectiveness of business continuity plans, as well as statements of operations of exceptional importance.
The principles and definitions applicable to the collection of statistical data and notification of suspicious transactions are described.
Confirmation of licensing fees.
Client account documentation proving client funds are in the account.
In this section, we describe in detail how the company is structured.
Key executives’ and company owners’ CVs.
Company office agreement.

There is a minimum requirement of 20,000 euros for payment institutions that only offer money transfer services.
The payment institution must have 50,000 euros in capital if it only offers payment initiating services.
There is a minimum requirement of €125,000 for the following payment services provided by payment institutions:

This service allows for cash deposits as well as all transactions associated with a payment account.
You can withdraw cash and conduct all transactions through the payment account.
As part of payment transactions, cash is transferred to the Payment Account.
Using credit to make a payment.
Either the issuance of payment instruments or the purchase of transactions.

The following stages are followed by applicants:

An application for a license was submitted to the supervisory service of the Bank of Lithuania. If all the necessary documents are provided within five working days, the Oversight Service accepts the application if no deficiencies exist.
Upon receiving an application and its supporting documents that are free of errors, a license will be issued within three months.
Whether a license should be granted or refused. After evaluating the submitted documents, the Bank of Lithuania’s Board analyzes them.

A license is issued or denied by the Supervision Service after reviewing the information.

Lithuanian law requires payment agencies that provide only account information services to process license applications within three months of receiving complete documentation.

During the preliminary meeting, the Bank of Lithuania plans to discuss the following topics:

A brief description of the company
The shareholders, beneficiaries, and investors of a payout institution, grouped by country of residence
Data about a legal entity associated with the applicant
An overview of the company’s ownership
A business plan for the company
The stage of the project should be described
In addition to details about the products and services, target markets, pricing policies, and related regulations, the application will provide information about the target markets.
Financing sources for payment institutions
Expected number of employees

It is necessary to present the above information to the Bank of Lithuania before the first meeting.

The State Tax Inspectorate requires 898 euros as a fee for a license application for a payment agency.

Since the establishment of a payment institution must meet all the requirements laid down at the time of approval, the Bank of Lithuania requires detailed data already at the time of initial circulation. While evaluating an applicant company, it is important to keep the following points in mind:

Submitted documents must comply with the legal acts governing payment organizations; truthful information must be included.
It is the responsibility of the payment institution to comply with its statutory capital requirements. Based on the services provided, the payment institution must have a minimum capital requirement of at least 20,000, 50,000, or 125,000 euros, according to the Lithuanian Law on Payment Institutions. Monthly payments cannot exceed €3,000,000 for payment organizations.
Assuring the payment institution and its shareholders or beneficiaries are suitable and appropriate by having a significant stake in the institution’s authorized capital and/or the right to vote. To ensure the success of a project, a good reputation, and reliable and prudent management are necessary.
A director’s qualifications and experience, as well as their impeccable reputation in business, must be necessary for them to fulfill their duties.
In order for a prospective payment institution to be successful, its business plan must meet the needs of its founders (shareholders or beneficiaries).

In order to ensure the sound and prudent management of a payment institution, companies applying for a license must also provide a detailed business plan. The company should also have a document describing its structure, such as divisions of labor and clear roles and responsibilities, a system for identifying customers, a document for monitoring risk, and rules for internal control.

A Bank of Lithuania Supervisory Service specialist verifies and evaluates primary documents as part of the provision process. A common understanding underlies their conclusions about authorization. A number of processes are conducted during the evaluation process, including:

Regular communication and meetings (if necessary) should be maintained with the applicant firm.
It is the responsibility of payment institutions to rectify deficiencies identified by the Oversight Service.

An applicant’s company will require a certain amount of time to examine the documents depending on what services it plans to offer. It is better to provide fewer documents and not submit applications for every service that the payment agency can provide if you are applying for a license.

The Lithuanian Payment Institution license has been granted to 311 companies so far.

Milana Scherbakova

Licensing Services Manager

+370 661 75988
[email protected]

Contact me