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.
Before submitting an EMI licence application, applicants are encouraged to engage with the Bank of Lithuania to discuss their proposed business model, planned financial services and applicable regulatory requirements. A preliminary meeting may help identify licensing issues and clarify supervisory expectations. However, such a meeting should not be presented as a universal statutory prerequisite for submitting an application. The applicant remains responsible for preparing a complete application and demonstrating compliance with all applicable authorisation requirements. 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.
- Applicants for a full EMI licence must demonstrate that their ownership structure supports sound and prudent management. Persons holding qualifying interests in the applicant must satisfy the applicable suitability requirements, including those concerning good repute, financial soundness and the transparency of the ownership structure. The Bank of Lithuania also assesses the institution’s management, governance arrangements, business plan and capacity to comply with regulatory obligations. The specific shareholder suitability requirements applicable to a restricted EMI licence differ from those applicable to a full EMI licence.
- 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.
Digital Operational Resilience and ICT Risk Management
Electronic Money Institutions in Lithuania must comply with the applicable requirements of Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA), which has applied since 17 January 2025.
The relevant obligations include:
- Establishing an ICT risk management framework appropriate to the institution’s size, activities and risk profile.
- Implementing ICT incident detection, classification, management and regulatory reporting procedures.
- Maintaining business continuity, disaster recovery and operational resilience arrangements.
- Managing ICT third-party service provider risks, including contractual safeguards and the required register of information.
- Conducting digital operational resilience testing in accordance with applicable requirements.
Full and restricted EMIs must assess the DORA provisions applicable to their activities, including any relevant proportionality rules or exemptions. Compliance with DORA forms part of the institution’s ongoing regulatory obligations.
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
Lithuania has an established electronic money institution sector supervised by the Bank of Lithuania. The number of licensed EMIs changes over time as institutions receive, surrender or lose their authorisations. According to the Bank of Lithuania’s supervisory statistics updated on 2 July 2026, Lithuania had 80 supervised electronic money institutions. Applicants and market participants should consult the Bank of Lithuania’s current register for the latest information about authorised institutions.
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.
