EMI License in Lithuania

Market participants who have the right to issue electronic money are e-money institutions regulated by the Bank of Lithuania. Payments can be made with electronic money that is stored on electronic devices and issued by an electronic money institution. Besides transferring money (directly and credit), making payments, and obtaining cash withdrawals, an e-money institution can also make money transfers.

E-money institutions can operate throughout the European Union if they are licensed to conduct unlimited activities.

An EMI can hold its clients’ funds, while a money institution cannot. This is the primary difference between the two.

The Electronic Money Institution’s largest market share holders:


The main stages of application for an EMI licence in Lithuania

  • Bank of Lithuania’s Supervisory Service receives the application for EMI license. Within five working days, the Oversight Service checks whether all necessary documents have been submitted and accepts the application if there are no deficiencies.
  • EMI will issue the license within three months of receiving the license application and attached documents.
  • A license is granted or refused. A Bank of Lithuania Board of Directors analyses the documents after they have been evaluated.

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

EMI in Lithuania

COST and Stages OF EMI Licence IN LITHUANIA 


4,500 EUR
  • Analysis of the company’s business model and planned services
  • Company structure analysis
  • Analysis of the personality of UBOs, their countries of residence
  • Analysis of the project financing model
  • 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


7,500 EUR

Preparation of documents required for applying for EMI, meeting with representatives of the Bank of Lithuania

  • Preparation of the initial application for an EMI licence Lithuania
  • Support when filling out the initial application form
  • Assistance in the preparation of documents describing the structure of the company
  • Assistance in developing a business plan that meets the requirements Bank of Lithuania
  • Analysis of the project platform/website, a guide to its presentation
  • Assistance in opening an account for the subsequent payment of the authorized capital of the company
  • Communication with the regulator at the application stage,
  • Organization of a meeting with representatives of the Bank of Lithuania


12,500 EUR

Application for an EMI license, preparation of financial and accounting documentation

  • 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.
  • Customer payment data monitoring, tracking, and restriction procedures.
  • 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.
  • To adequately protect electronic money holders and/or payment service users from identified risks, including fraud and unauthorized access to confidential information and personal data, security policies should include an assessment of risks associated with activities carried out, as well as security controls and risk mitigation measures.
  • In addition to branches, agents, individuals or legal entities that will distribute and redeem electronic money for the company issuing electronic money, the structure of the company will be described. Alternatively, the company will outsource the performance of operational functions to third parties.
  • Licensing fee confirmation document.
  • Funds are available for equity (from 350,000 euros).
  • Insurance contract for professional compensation;
  • 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.
  • Electronic money institutions must provide proof that their average outstanding balance is less than 900 thousand. Over the past 12 months, the payment institution has performed an average of 3 million payments.
  • The company’s operational risks are assessed through a questionnaire.
Ready-made company with acquired EMI license in Lithuania 1,200,000 EUR

Authorization process

As part of its authorization process for EMI, the Bank of Lithuania is open and begins long before an application is submitted. In order to help define the financial services that are to be licensed, our company encourages all applicants who are interested in obtaining an EMI license to contact the Company in Lithuania UAB as soon as possible. As a result, we are able to communicate with our clients in greater detail about the authorization process, the requirements of the Bank of Lithuania, and all other factors that may affect the authorization process.

First meeting with the Bank of Lithuania

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.

A number of issues will be discussed at the preliminary meeting by the Bank of Lithuania, including:

  • Company information
  • What is the country of origin of the owners/beneficiaries of the company
  • An application’s status (platform ready, staff recruited)
  • Independent businesses and subsidiaries of groups of companies can apply
  • Conducting business is the responsibility of these individuals
  • Modelling the financing of the project
  • Product/service details, target markets, pricing policies, and regulatory actions in relation to the products/services
  • Funds remitted by EMI
  • Approximately how many employees are expected

During the first meeting with representatives of the Bank of Lithuania, this information must be provided in the form of a presentation. To ensure adequate preparation for the initial request, Company in Lithuania UAB recommends providing all of the above information in advance.

Electronic Money Institution (EMI) application fee

Before applying for an EMI license in Lithuania a duty of 1,463 euros must be paid in the account of the State Tax Inspection.

Basic Requirements for Electronic Money Institution

It is important for the company to prepare all the requirements when applying for the license to become an Electronic Money Institution, as Bank of Lithuania requires detailed data to be provided even before the initial circulation of the electronic money. The following points should be considered in assessing the applicant company:

  • EMI activities and their supervision are regulated by legal acts; all correct data required by legal acts and additional data requested must be included in the documents submitted.
  • In order for electronic money institutions to operate legally, all documents submitted must comply with the requirements of applicable legal acts.
  • A minimum statutory capital requirement of 350,000 euros must be met by EMI according to the law on electronic money and institutions for electronic money.
  • In order to ensure the reliability and prudent management of the payment institution, ensure that it has a good reputation, and make sure the project is financially viable, it must be appropriate and appropriate that EMI and its shareholders or beneficiaries own a significant share in the charter capital and / or the right to vote.
  • E-money institutions must be headed by people with impeccable business reputations, qualified and experienced enough to properly perform their duties, and possess an impeccable professional reputation.
  • A prospective payment institution must be ready to provide financial services at the time the application is submitted, while the business plan provided must correspond to the founders’ (shareholders or beneficiaries) ability to implement it.

A comprehensive e-money management procedure appropriate to EMI’s size and complexity is required in order to ensure the prudent and prudent management of EMI. Additionally, the company should have a structure document, including a division of labour, clearly defined liabilities, a system for identifying customers, a system for monitoring risks, and its internal control rules.

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 regularly communicated with and met with (if necessary)
  • Electronic money institutions are required to remedy the deficiencies identified by the Oversight Service

The length of time it takes to examine the documents depends on how many services the applicant company intends to provide. It is easier to evaluate an electronic money license application if it does not reference all services that can be provided under the license and only a limited number of documents are submitted.

Details of the licensing process are described on the website of the Bank of Lithuania   

Currently, 205 companies have successfully obtained a licence from the Electronic Money Institution in Lithuania

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

EMI License in LithuaniaFintech is a rapidly evolving industry and attracts more and more entrepreneurs. Therefore, online banking has a promising potential. While traditional banking steps aside, businesses such as Wise, Revolut, N26, Paysera, Payoneer, Monese are growing on the market with every second.

Electronic money (e-money) institution (or EMI) is a licensed financial institution which may engage in e-money related services and payment services (as it would be described in details in the next paragraphs).


Areas of activity of an e-money institution:

  • Money transfers
  • Cash depositing and withdrawal
  • Issuing of Electronic Money
  • Issuing of payment instruments
  • Payment Initiation Service (PSD2)
  • Account Information Service (PSD2)

To establish a favourable environment for Lithuanian and foreign startups, a special project for an EMI licence to engage in restricted activities has been implemented with the aim of facilitating access of new market participants to the Lithuanian market and later, after being granted a licence to engage in usual activities, to also the European Economic Area market. The basic difference between an EMI engaged in restricted activities and a traditional EMI is that the EMI engaged in restricted activities is not subject to the minimum initial capital requirement; however, a licence of an electronic money institution to engage in restricted activities is valid solely in the Republic of Lithuania. In order to be granted an EMI licence, it is necessary to hold a capital of EUR 350,000; however, this licence entitles to the provision of the electronic money issuance and redemption, distribution and payment services in other EU Member States as well after carrying out a notification procedure.

Authorisation process

The entire authorisation process for EMIs is done through the Authorities, an application for an authorisation is submitted directly to it. The planning process is discussed in regards well before starting the activity so that the planning process can be discussed in regards. The topics that are discussed are: authorisation process, requirements, expectations, and all other major aspects that may affect the licensing process.

Stages of application:

  • Submission of an application for an EMI licence to the Supervision Service of the Authorities – within 5 business days, reviews whether all necessary documents have been submitted and have no formal deficiencies;
  • Assessment of an application for an EMI License: where the documents submitted have no deficiencies, the licence is issued within the shortest possible 3 month-term.
  • Issuance of a licence: after finishing assessment of submitted documents, the Board of the Authorities analyses summary information submitted by the Supervision Service and takes a decision regarding the issuance of a licence.

Key requirements for an EMI being established or authorised

  • The documents submitted must comply with the requirements of the legal acts regulating EMI activities and their supervision;
  • compliance with the minimum capital requirement for EMIs: according to the provisions of the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions, an EMI must possess a minimum initial capital of no less than EUR 350,000
  • Entities with a qualifying holding in the EMI’s authorised capital must be able to ensure sound and prudent management of the EMI, have sufficiently high repute and be financially sound;
  • The heads of an electronic money institution must be of good repute and possess the qualification and experience necessary to properly perform their duties.
  • The operating plan must correspond to the possibilities of the EMI’s founders to implement it, while the prospective EMI must, at the time of authorisation, be prepared to provide financial services in a safe and sound manner.

Prior to applying for an EMI licence, it is necessary to pay into the account of the State Tax Inspectorate (STI) a state levy for the granting of the EMI licence. The EMI licence to engage in restricted activities is currently subject to a smaller levy.

The own funds requirement is calculated by the Supervision Service based on average outstanding electronic money. The own funds requirement of an EMI designated for issuance of electronic money must account for no less than 2% of average outstanding electronic money.

At this moment, there are 205 EMI Licensed companies operating in Lithuania.

Company in Lithuania UAB can assist you obtain an EMI license, thereby ensuring a smooth start for your business. Contact us for more information.

Milana Scherbakova

Licensing Services Manager

+370 661 75988 [email protected]