Electronic Money Institution (EMI) License in Lithuania

The e-money institution is a market participant licensed by the Bank of Lithuania who has the right to issue electronic money. Electronic money is a prepaid monetary value issued by an electronic money institution and stored on electronic devices that can be used for payment. An e-money institution may also make money transfers (both direct and credit), make payments, and provide cash deposit and withdrawal services.

An e-money institution licensed to unlimited activities can operate throughout the EU.

The main difference between the Electronic Money Institution and the Payment Institution is that EMI can hold the funds of its clients while the money institutions cannot.

Companies with the largest market share licensed by the Electronic Money Institution



Authorization process

The approach of the Bank of Lithuania to the authorization process for EMI is open and starts long before the application is submitted. Our company advises all applicants who are interested in obtaining an EMI license to contact the Company in Lithuania UAB as soon as possible so that we can discuss your project and help define the financial services to be licensed. This allows us to explain in more detail the authorization process to the client, the requirements of the Bank of Lithuania, and all other aspects that may affect the authorization process.

The main stages of application for an EMI license in Lithuania can be distinguished as follows:

  • Application for the EMI license to the Supervisory Service of the Bank of Lithuania. The Oversight Service verifies, within five working days, whether all the necessary documents have been provided and, if there are no deficiencies, accepts the application.
  • Evaluation of the EMI license application and attached documents: if there is no defect in the submitted documents, EMI will issue the license within three months.
  • License or refusal to grant a license. Upon completion of the evaluation of the submitted documents, the Board of the Bank of Lithuania analyses the submitted documents.

The Supervision Service consolidates the information and decides whether to issue a licence or to refuse to issue one.

First meeting with the Bank of Lithuania

The Bank of Lithuania, bearing in mind that the legal acts regulating the EMI licence application process may not always be understood by the representatives of the applicant company,  We recommend that the EMI license applicants apply to the Bank of Lithuania at an early stage and Company in Lithuania UAB will be glad to help you in this. Representatives of the Bank of Lithuania will provide more detailed information on the authorization process and requirements for the applicant companies.

The purpose of the initial meeting with the representatives of the Bank of Lithuania is to answer all questions of interest that may arise during the preparation of the application, To find out what financial services are to be provided under the project and to determine the type of licence the company is required to apply for. At least two specialists of the Supervisory Service of the Bank of Lithuania are usually present at such meetings, but technical specialists capable of evaluating the platform/website of the applicant company may also be required.

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

  • Details of applicant company
  • Who are the owners/beneficiaries of the company and what their country of origin is
  • Stage of application (platform ready, staff recruited)
  • Whether the applicant is an independent company or a subsidiary of a group of companies
  • Persons responsible for doing business
  • Financing model
  • Detailed information on products/services, target markets, price policies and related regulatory actions
  • Remittances from EMI funding sources
  • Projected number of staff

This information must be provided in the form of a presentation/business plan before the first meeting with representatives of the Bank of Lithuania. Company in Lithuania UAB recommends that all of the above information be provided in advance to be able, if necessary, to supplement it or make necessary adjustments for the initial request.

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

Taking into account that when applying for the Electronic Money Institution license, the company must be prepared to meet all the requirements, as Institution of electronic money, Bank of Lithuania requires that detailed data be provided already at the time of initial circulation. Nevertheless, in assessing the applicant company, we would like to draw attention to the following points:

    • Conformity of the documents submitted: the documents submitted must comply with the requirements of the legal acts regulating EMI activities and their supervision; all correct data established by legal acts or requested additional data must be provided.
  • The documents submitted must comply with the requirements of legal acts regulating the activities of electronic money institutions; all truthful data established by legal acts must be provided.
  • Compliance with the minimum statutory capital requirements for EMI: In accordance with the provisions of the Republic of Lithuania Law on Electronic Money and Institutions for Electronic Money, EMI must have paid the statutory capital of not less than 350,000 euros.
  • The suitability and appropriateness of EMI and its shareholders or beneficiaries, having a significant stake in the charter capital of the payment institution and / or the right to vote, to be able to ensure the reliable and prudent management of the payment institution, have a good reputation and ensure the financial viability of the project.
  • Suitability and integrity of the heads of the e-money institution: the heads of the money institution must have an impeccable business reputation and possess the qualifications and experience necessary for the proper performance of their duties.
  • The business plan provided must correspond to the capacity of the EMI founders (shareholders or beneficiaries) to implement it, while the prospective payment institution must be ready to provide financial services at the time of the application.

It should be noted that, in view of the need to ensure the prudent and prudent management of EMI, EMI should have a detailed e-money management procedure appropriate to the scale and complexity of EMI’s activities. The company should also have a document describing its structure – with a division of labour and clearly defined liability, a customer identification system, a risk monitoring document, The rules of internal control of the company, including the accounting system.

Evaluation of submissions

The process of providing primary documents includes their verification and evaluation by specialists of the Supervisory Service of the Bank of Lithuania. They provide a common view and conclusions on authorization. The following processes are also performed during the evaluation period:

  • Regular communication and meetings with the applicant firm (if necessary)
  • Comments from the Oversight Service to the effect that the institution of the electronic money is obliged to remedy the identified deficiencies

The duration of the examination of the documents depends on the amount of services that the applicant company plans to provide. If an application for an electronic money license is not requested for all services that can be provided under the license and fewer documents are provided, they can be evaluated more quickly.

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

Currently 178 companies have successfully obtained a license from the Electronic Money Institution in Lithuania

Company in Lithuania UAB can help your company obtain a financial license 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.