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


The main stages of application for an EMI licence in Lithuania

  • 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.

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
  • Preparation of the company’s constituent documentation, registration of a Lithuanian private limited liability company
  • 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

Preparation of financial and accounting documentation, filing an application and obtaining an EMI license Lithuania

  • Preparation of legal documents of the company (AML, KYC policies, IT solutions for cybersecurity of client assets).
  • Preparation of financial documentation of the company (financial plan for 3 years, profit and loss statement, cash flow statement).
  • Preparation of the company’s operational documentation (internal policies, risk assessment policies, internal audit of the company, operational plan, accounting procedures of the company).
  • Assistance in filling out the application, description of financial services provided, preparation of required documents).
  • A document confirming the right to sign for company representatives.
  • Document of internal control mechanisms established in order to fulfil obligations regarding the prevention of money laundering and terrorist financing in accordance with the legislation of Lithuania.
  • Procedures for monitoring, handling and following up on operational and safety incidents and customer complaints related to safety.
  • Procedures for monitoring, tracking and restricting access to confidential customer payment data.
  • Description of business continuity processes with a clear statement of operations of exceptional importance, effective business continuity plans, procedures for testing and monitoring the adequacy and effectiveness of such plans.
  • Description of the principles and definitions applicable to the collection of statistical data on the results of activities, transactions and notification of the regulator of suspicious transactions.
  • Description of security policies, including a detailed assessment of the risks associated with the activities carried out, security control and risk mitigation measures taken to adequately protect electronic money holders and/or payment service users from identified risks, including fraud and unauthorized use of confidential and personal data.
  • Description of the company’s structure, including the use of branches, agents, individuals or legal entities through which the company issuing electronic money will distribute and redeem electronic money, or third parties to whom the performance of operational functions will be outsourced.
  • A document confirming payment of the state fee for issuing a license.
  • Documentary evidence of the availability of funds for equity (from 350,000 euros).
  • Professional compensation insurance contract;
  • Documentary confirmation of the existence of an account for storing client funds.
  • Detailed description of the company structure.
  • CV of company owners and key officials.
  • Company office agreement.
  • Documents confirming that the average amount of outstanding electronic money of an electronic money institution will not exceed 900 thousand. The average total amount of payment transactions performed by the payment institution over the previous 12 months will not exceed 3 million euros per month.
  • Questionnaire on operational risks of the company’s activities.

EMI in Lithuania

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.

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, 192 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.

Additional Information/BLOG: