Regulatory Advisory for Fintech Companies in Lithuania

AT A GLANCE

Regulatory advisory covers the full lifecycle of a fintech licence — from selecting the correct regulatory pathway through to application submission, Bank of Lithuania review management, and ongoing post-licence supervisory compliance.
Lithuania is the leading EU fintech licensing jurisdiction — but an accessible regulator does not mean an uncomplicated one. Preparation, completeness, and credibility determine how quickly an application moves through the review process.
We provide regulatory advisory across all major Lithuanian fintech licence types: EMI, PI, MiCA CASP, investment firm, VASP, and crowdfunding.
Our regulatory advisory team has direct experience managing Bank of Lithuania licence applications — including pre-application meetings, query responses, and post-approval condition management.
Regulatory advisory is available as a standalone engagement or as part of a full-service fintech setup covering company registration, compliance, legal, and accounting.

Regulatory advisory means guiding a fintech company through the Lithuanian and EU regulatory landscape — determining the correct licence for the business model, preparing the application package, managing the Bank of Lithuania review process, and maintaining compliance with licence conditions after authorisation is granted. We advise companies at every stage: pre-application strategy, full application preparation and submission, responding to Bank of Lithuania queries during review, and ongoing post-licence regulatory compliance. Our advisory is grounded in direct experience with the Bank of Lithuania’s process — not applied from general EU regulatory knowledge.

What Regulatory Advisory Covers

Regulatory advisory is not a single service — it is a continuous engagement that evolves as the company moves through different stages of its regulatory lifecycle. For a new fintech company, advisory begins before any documents are drafted: with the question of which licence is the right one for the intended business model. That initial question has a material impact on timeline, capital requirements, governance structure, and the entire application process. Getting it wrong at the start costs months.

For a company already in the application process, regulatory advisory means managing the relationship with the Bank of Lithuania: responding to information requests accurately and promptly, coordinating between the legal, compliance, and accounting teams to ensure consistency across all submitted documents, and maintaining momentum through a review process that involves multiple Bank of Lithuania departments assessing different aspects of the application simultaneously.

For a licensed entity, regulatory advisory shifts to post-licence compliance management: monitoring licence conditions, advising on the regulatory impact of business changes, preparing periodic submissions, and ensuring the company is ready for supervisory examination. Regulatory advisory at this stage is the difference between a company that is technically licensed and one that operates its licence confidently.

Licence Selection: Choosing the Right Regulatory Pathway

The first and most important regulatory advisory decision is which licence to apply for. Lithuanian fintech regulation covers multiple frameworks — each with different capital requirements, governance obligations, permitted activities, and application timelines. Choosing the wrong one — either too narrow for the intended activities or unnecessarily broad — creates problems that are expensive to correct after the application is submitted.

EMI vs. Payment Institution: the most common decision

The Electronic Money Institution (EMI) licence and the Payment Institution (PI) licence are the two most frequently applied-for licences in Lithuania. The key distinction is whether the company will issue electronic money — that is, store monetary value on behalf of clients in e-wallets, prepaid accounts, or stored-value instruments. If yes, an EMI licence is required. If the company processes payments without storing value, a PI licence may be sufficient. The practical implication is capital: an EMI requires a minimum of €350,000 in initial own funds, while a standard PI requires €125,000 (or €250,000 for acquiring). Many companies that could technically operate under a PI licence choose the EMI because the broader permission set is more commercially flexible as the business scales.

MiCA CASP authorisation

The EU Markets in Crypto-Assets Regulation (MiCA) took full effect in December 2024 and replaced the VASP registration framework for crypto-asset service providers operating in the EU. Under MiCA, a company providing crypto exchange, custody, brokerage, or portfolio management services to EU clients must be authorised by a national competent authority — in Lithuania, the Bank of Lithuania. The capital requirement under MiCA depends on the specific services provided: €50,000 for advisory, €125,000 for execution, and €150,000 for custody. MiCA authorisation also requires a white paper, specific governance provisions, and mandatory client disclosures. We advise on MiCA classification and prepare the full application package.

Investment firm licence under MiFID II

A company providing investment services — forex trading, CFD execution, investment advice, or portfolio management — requires an investment firm licence under MiFID II. Lithuania issues these through the Bank of Lithuania. The capital requirements range from €75,000 to €750,000 depending on the scope of services. Investment firm applications are more complex than EMI or PI applications — they require a more detailed business plan, a broader governance framework, and demonstrated expertise in investment services compliance. We prepare investment firm applications for companies entering the Lithuanian market from non-EU jurisdictions where equivalent authorisation may not be available.

VASP registration — transitional pathway to MiCA

Before MiCA, Lithuanian crypto businesses registered as Virtual Asset Service Providers (VASPs) with the Financial Crime Investigation Service (FNTT). Companies registered as VASPs before the MiCA transition period are entitled to a transitional pathway to full MiCA CASP authorisation — provided they apply within the transition window. We manage both the VASP registration for new entrants who need to begin operations before their full MiCA application is approved, and the transitional pathway for existing VASPs seeking full MiCA authorisation.

Licence	Permitted Activities	Min. Capital	Approx. Application Timeline
EMI Licence	E-money issuance, payment services, e-wallets	€350,000	10–14 months total
Payment Institution	Payment processing, money transfer, acquiring	€125,000–€250,000	8–12 months total
MiCA CASP Authorisation	Crypto exchange, custody, brokerage, advisory	€50,000–€150,000	8–14 months total
Investment Firm (MiFID II)	Forex, CFD, investment advice, portfolio management	€75,000–€750,000	12–18 months total
ECSP Licence	Crowdfunding for business	€50,000	8–12 months total
VASP Registration	Crypto exchange and custody (pre-MiCA / transitional)	None	4–8 weeks

The Bank of Lithuania Application Process

The Bank of Lithuania’s licence application process follows a defined sequence. Understanding each stage — and the specific risks at each — is the foundation of effective regulatory advisory. The single most impactful variable in application timeline is preparation quality: a complete, consistent, and credible application moves through the process significantly faster than one that requires supplementary information.

Pre-application consultationBefore submitting a formal application, we schedule a pre-application meeting with the Bank of Lithuania. This is an open discussion about the business model, intended licence type, and any specific aspects of the application that require clarification. The Bank of Lithuania uses these meetings to identify potential issues early and to give applicants guidance on how to present their business model. We prepare a detailed briefing document for the meeting, structure the agenda, and manage the follow-up documentation. Pre-application meetings are available to all prospective licence applicants and are strongly recommended — they prevent surprises during the formal review.

Application package preparationThe formal application package for an EMI, PI, or MiCA licence involves approximately 20–30 documents covering: the business plan, the capital adequacy model, the governance structure, the AML/KYC compliance programme, the internal control framework, the outsourcing register, the IT infrastructure description, the remuneration policy, the business continuity plan, and the fit-and-proper documentation for each key function holder. We coordinate the preparation of the complete package across legal, compliance, and accounting disciplines — ensuring all documents are internally consistent and presented in the format the Bank of Lithuania expects.

Application submissionThe application is submitted electronically through the Bank of Lithuania’s supervisory portal. We manage the submission, confirm receipt, and retain a complete copy of everything submitted. The Bank of Lithuania then conducts an initial completeness check — typically within 15 business days — to confirm that all required documents are present. If the application passes the completeness check, it enters the substantive review phase. If any documents are missing or incomplete, the regulator returns the application at this stage rather than during review.

Bank of Lithuania review — substantive assessmentThe substantive review is conducted simultaneously by multiple Bank of Lithuania departments: licensing, supervision, AML, IT, and legal. Each department assesses its area of the application in parallel. The statutory review period is 3 months from acceptance of a complete application, but in practice the review involves a dialogue — the Bank of Lithuania sends queries during the review period, and each query must be answered completely and promptly. Slow or incomplete responses to queries are the single most common cause of extended review timelines. We manage all Bank of Lithuania correspondence throughout the review and coordinate the query responses across our legal, compliance, and technical teams.

Fit-and-proper interviewsDuring the review, the Bank of Lithuania typically interviews key function holders — the CEO, compliance officer, and MLRO — to assess their suitability for their roles. These interviews can be conducted in person at the Bank of Lithuania’s premises in Vilnius or remotely. We prepare each candidate for their interview: briefing them on the Bank of Lithuania’s assessment criteria, conducting mock interview sessions, and advising on how to present their background and qualifications effectively. Poorly prepared interviews are a significant source of delay and negative fit-and-proper outcomes.

Licence granted — conditions and post-authorisationWhen the Bank of Lithuania grants the licence, it is typically accompanied by conditions — specific requirements the company must satisfy within a defined timeframe. These may include capital top-up requirements, governance enhancements, specific compliance programme updates, or technology requirements. We review the licence conditions, map each one to an operational obligation, and prepare a condition fulfilment plan. Failure to satisfy conditions within the prescribed timeframe is a reportable non-compliance event.

MiCA and Crypto Regulatory Advisory

The EU’s Markets in Crypto-Assets Regulation represents the most significant change to the European crypto regulatory landscape since the asset class emerged. For Lithuanian crypto businesses, MiCA creates both a compliance obligation and a commercial opportunity — an EU-wide operating licence accessible through a single Lithuanian authorisation. We provide specialist MiCA advisory covering classification, application preparation, and ongoing compliance.

MiCA classification — what type of CASP are you

MiCA defines crypto-asset services across multiple categories, each with different capital requirements and operational obligations. A company that operates a crypto exchange (buying and selling crypto assets against fiat or other crypto assets) is classified differently from one that provides custody, portfolio management, or investment advice in crypto assets. Many crypto businesses provide multiple services — which means multiple MiCA classifications apply simultaneously. We assess the full scope of a company’s activities and confirm the correct MiCA classification profile before any application work begins.

The MiCA white paper

MiCA requires most crypto-asset service providers to publish a white paper before offering services to EU clients. The white paper is both a marketing and legal document — it must contain specific mandatory disclosures about the crypto assets or services offered, the risks involved, the company’s governance and financial position, and the rights of token holders or service users. The white paper must be filed with the Bank of Lithuania before publication. We prepare MiCA-compliant white papers and manage the Bank of Lithuania filing process.

VASP to MiCA transition

Lithuanian companies registered as VASPs before the MiCA transition window have a defined pathway to full MiCA authorisation. The transitional period allows existing VASPs to continue operating while they prepare and submit their MiCA application. Companies that miss the transition window lose their right to operate under the VASP framework and must obtain full MiCA authorisation before resuming services. We manage the complete VASP-to-MiCA transition — assessing readiness, preparing the full MiCA application, and managing the Bank of Lithuania review process.

MiCA transitional timeline

The MiCA transitional period for existing VASPs runs until July 2026 in most EU member states, subject to national implementation timelines. Companies that fail to submit a MiCA application within the transitional window must cease crypto-asset service provision until authorisation is obtained. We advise existing VASP-registered Lithuanian companies on their transitional deadline and begin MiCA application preparation at least 12 months before the deadline to allow adequate time for the review process.

Post-Licence Regulatory Advisory

Receiving a licence is not the end of the regulatory relationship — it is the beginning of a supervised operational existence. Post-licence regulatory advisory covers the ongoing obligations that keep a licensed entity in good standing with the Bank of Lithuania throughout its operating life.

Licence Condition ManagementMost licences are issued with conditions — specific requirements the company must satisfy within defined timeframes. Conditions range from capital top-up obligations and governance enhancements to IT system requirements and compliance programme updates. We map each licence condition to an operational action, confirm the responsible person, and track fulfilment against the required timeline. Non-fulfilment of licence conditions is reported to the Bank of Lithuania and can result in supervisory action.

Licence condition register — mapping each condition to an operational obligation and a fulfilment deadline
Condition fulfilment tracking — monthly progress reporting against each open condition
Bank of Lithuania condition fulfilment notification — confirming completion and providing evidence to the regulator
Condition waiver applications — where a condition needs to be modified or extended, managing the application to the Bank of Lithuania

Material Change NotificationsAny material change to a licensed entity’s business model, ownership structure, key personnel, or operational setup must be notified to the Bank of Lithuania — either before the change takes effect (for changes requiring prior approval) or within a specified timeframe after. Common notification triggers include: changes in qualifying ownership, appointment or departure of key function holders, outsourcing of critical functions, significant changes to the business plan, and certain technology infrastructure changes. We identify notification triggers, prepare the notification package, and manage the Bank of Lithuania’s assessment of the notified change.

Notification trigger assessment — identifying which business changes require Bank of Lithuania notification
Prior approval applications — for changes that cannot be implemented before Bank of Lithuania approval
Post-change notifications — for changes that can be implemented with notification after the fact
Qualifying holding notifications — for ownership changes above the 10%, 20%, 33%, and 50% thresholds
Key function holder changes — fit-and-proper notification for new or departing key personnel

EU PassportingAn EMI, PI, or MiCA-authorised entity licensed in Lithuania can provide services in other EU member states under the EU passporting framework — without obtaining a separate licence in each country. Passporting requires a formal notification to the Bank of Lithuania, which then notifies the host country’s regulator. We prepare and submit passporting notifications for companies expanding their services across the EU, advise on which activities are covered under the Lithuanian licence in each jurisdiction, and manage any queries from host country regulators.

Passporting strategy — assessing which EU member states require passporting notifications for the intended activities
Outbound passporting notification — submission to the Bank of Lithuania for each target jurisdiction
Host country regulatory requirements — advising on any additional local requirements beyond the passporting notification
Ongoing passporting maintenance — managing updates and withdrawals as the company’s EU market presence evolves

Supervisory Examination PreparationThe Bank of Lithuania conducts periodic on-site and off-site examinations of licensed entities, covering prudential oversight, AML compliance, governance, and operational resilience. An examination is not a formality — findings can result in conditions, fines, or in serious cases, licence suspension. We prepare licensed entities for supervisory examinations by conducting a pre-examination review across all areas the regulator is likely to assess, organising documentation, and preparing key personnel for examiner interviews.

Pre-examination readiness review — comprehensive assessment across prudential, AML, governance, and operational areas
Document organisation and gap remediation — ensuring all required records are complete and accessible
Key personnel interview preparation — coaching the CEO, compliance officer, and MLRO for examiner meetings
Mock examination exercise — simulated examination to identify remaining gaps under examination conditions
Post-examination finding response — drafting responses and preparing remediation plans for any examination findings

Regulatory Change MonitoringThe EU regulatory landscape for fintech is in a period of sustained legislative activity — MiCA, DORA, PSD3, the AML Package, and the revised PSR are all at various stages of implementation and are reshaping the operating environment for licensed entities. We monitor all relevant EU and Lithuanian regulatory developments, assess their practical impact on each client’s licence and operations, and advise on the actions required to remain compliant as the regulatory landscape evolves.

Monthly regulatory update — summary of EU and Lithuanian regulatory developments relevant to the client’s licence
Impact assessment — practical analysis of how each new requirement affects the client’s current operations
Implementation planning — advising on the timeline and actions needed to comply with incoming regulations
EBA and ECB guideline monitoring — tracking supervisory expectations beyond formal legislation
DORA compliance monitoring — tracking Digital Operational Resilience Act obligations for licensed entities

Regulatory Advisory Pricing

Regulatory advisory is priced on a mixed basis: fixed fees for defined project deliverables and on request for ongoing advisory retainers and complex multi-stage engagements whose scope cannot be determined in advance of an initial consultation.

Service	Price
Initial regulatory strategy consultation Licence selection, application timeline, and readiness assessment — credited toward engagement fee if you proceed	€2,500
Regulatory pathway assessment — written report Written analysis of the correct licence type, capital requirements, and application timeline for your specific business model	€900
Pre-application meeting preparation Briefing document, agenda, and follow-up documentation management for Bank of Lithuania pre-application meeting	€1,800
EMI licence application — full preparation and management Complete application package preparation, submission, and Bank of Lithuania liaison throughout review	On request
PI licence application — full preparation and management Complete application package preparation, submission, and Bank of Lithuania liaison throughout review	On request
MiCA CASP authorisation — full preparation and management Complete MiCA application including white paper, governance docs, and Bank of Lithuania review management	On request
Investment firm (MiFID II) — full preparation and management Complete application package; more complex than EMI/PI — scope confirmed after initial assessment	On request
MiCA transitional pathway (VASP to CASP) For existing VASP-registered companies — assessment plus full MiCA application preparation	On request
Business plan drafting (regulatory format) Bank of Lithuania-format business plan covering strategy, financials, and risk framework	€1,800
Capital adequacy model preparation Own funds calculation and capital adequacy demonstration for the application	€900
Query response drafting (per Bank of Lithuania query set) Depends on complexity and number of questions — quoted per query set	€900
Fit-and-proper interview preparation (per candidate) Mock interview, briefing document, and presentation coaching	€1,350
MiCA white paper preparation MiCA-mandatory white paper including all required disclosures and Bank of Lithuania filing	€3,000
Licence condition management — monthly retainer Based on number of open conditions and complexity of fulfilment obligations	On request
Material change notification package Depends on type and complexity of the change; quoted individually	€500–€1,200
EU passporting notification (per jurisdiction) Single outbound passporting notification to Bank of Lithuania for one EU member state	€700
Pre-examination readiness review Full pre-examination assessment covering prudential, AML, governance, and operational areas	€2,000
Post-examination response and remediation plan Based on number and severity of examination findings	On request
Ongoing regulatory advisory retainer Monthly retainer for post-licence regulatory monitoring, change management, and Bank of Lithuania liaison	On request

Full application engagement — how we price it

A full licence application engagement — from pre-application preparation through to licence grant — is quoted as a fixed project fee after our initial regulatory pathway assessment. The project fee covers the complete application package, Bank of Lithuania correspondence throughout the review, query responses, and fit-and-proper preparation for key function holders. We quote this as a single fixed fee rather than billing by the hour, so you know the total cost of the engagement before we begin. Contact us to arrange an initial assessment call.

Frequently Asked Questions

The total timeline from beginning preparation to receiving the licence certificate is typically 10–14 months for a well-prepared EMI application. This breaks down as follows: 2–3 months for pre-application preparation (company registration, compliance framework, governance documents, business plan); 1–2 months to prepare and submit the formal application; the Bank of Lithuania’s 3-month statutory review period; plus time to respond to queries and satisfy any conditions. The most common cause of delay is incomplete or inconsistent documentation in the initial application. Applications that pass the Bank of Lithuania’s completeness check on the first submission and respond to queries promptly typically receive their licence in under 12 months from preparation start.

No. The Bank of Lithuania requires the licence applicant to be an existing, registered Lithuanian legal entity — typically a UAB. The company must be registered and have a Bank of Lithuania-accepted governance structure before the licence application can be submitted. We manage the company registration and initial setup in parallel with the early stages of MiCA application preparation, so the company is ready to apply as soon as the preparation work is complete. This parallel approach saves 4–6 weeks compared to completing registration first and then beginning application preparation.

A pre-application meeting is an informal consultation with the Bank of Lithuania — it takes place before any formal application is submitted and before any fees are paid. The Bank of Lithuania uses these meetings to understand the business model, identify potential application issues early, and provide guidance on how to present specific aspects of the application. Formal applications are made through the Bank of Lithuania’s supervisory portal, accompanied by the complete documentation package and the application fee. Pre-application meetings are strongly recommended — they prevent the most common application errors and signal to the regulator that the applicant is professional and prepared.

The Bank of Lithuania rarely rejects applications outright — more commonly, it issues a series of information requests and queries that the applicant must resolve during the review period. True rejection — where the Bank of Lithuania formally declines to grant the licence — occurs when there is a fundamental deficiency in the application that cannot be remedied through supplementary information: for example, a capital adequacy that is structurally insufficient, key function holders who fail the fit-and-proper assessment, or a business model that does not qualify for the applied-for licence type. We conduct a thorough pre-application assessment specifically to identify and address any such fundamental issues before the application is submitted.

A Lithuanian EMI licence grants the right to provide e-money and payment services across the EU under the passporting framework — but the right does not activate automatically. To provide services in another EU member state, the licensed entity must submit a passporting notification to the Bank of Lithuania specifying the target country and the services to be provided. The Bank of Lithuania then notifies the host country’s regulator. The process takes a minimum of 3 months. Some activities — for example, opening a physical branch in another country — have additional requirements. We manage the passporting process for companies expanding their EU market coverage.

DORA — the Digital Operational Resilience Act (EU Regulation 2022/2554) — has applied to all EU-licensed financial entities, including Lithuanian EMIs, PIs, investment firms, and MiCA-authorised companies, since January 2025. DORA requires covered entities to have ICT risk management frameworks, ICT incident classification and reporting procedures, digital operational resilience testing programmes, and contractual protections in agreements with critical ICT providers. For licensed Lithuanian fintech companies, DORA compliance is an ongoing regulatory obligation that forms part of the Bank of Lithuania’s supervisory examination scope. We advise on DORA implementation and prepare the required ICT governance documentation as part of our post-licence regulatory advisory.

Yes — and this is often the first question we answer. Not every fintech business model requires a Bank of Lithuania licence. The boundary between a licensed and an unlicensed activity depends on: whether the company handles client funds, whether it issues or redeems e-money, whether it processes payment transactions as a principal, and whether it provides investment services. Some business models — for example, providing software to a licensed payment company, or operating a comparison website — do not require a licence even though they operate in the fintech space. We provide a written regulatory classification opinion (€600) that confirms whether a licence is required, and if so, which one.

Ready to discuss your regulatory pathway?

CContact us to book an initial regulatory strategy consultation. We will assess your business model, confirm the correct licence, review your current state of readiness, and provide a realistic application timeline and cost estimate. We work with companies at every stage — from concept to post-licence supervision.