FINANCIAL LICENSE (EMI) IN LITHUANIA
The Lithuanian license continues to hold a leading position among fintech jurisdictions in the European Union. By obtaining an Electronic Money Institution (EMI) license in Lithuania, a company gets the opportunity to operate in more than 25 EU countries, making this jurisdiction one of the most attractive for scaling a business.
Lithuania's key advantage is its loyalty to crypto services and a relatively short license period of about half a year. It is not surprising that giants like Wise, who saw in Lithuania not only stability but also the potential for rapid growth, began their journey here.
The Bank of Lithuania (Lietuvos bankas) is responsible for issuing and supervising EMI licenses. Legally regulated by the Law on Electronic Money Institutions and relevant acts on payment services.
A company with an EMI license in Lithuania allows:
- issuance and redemption of electronic money storage of customer funds in accounts (payment accounts);
- provision of various payment services: transfers, payments, issuance of payment instruments, possibly cards, etc.
- to operate in all EU countries (EU passporting), if it has an unrestricted license.
BASIC REQUIREMENTS AND LIMITATIONS
Authorized capital / own funds:
- minimum €350,000 for a full EMI license.
- There is also a “restricted activities” option for a small EMI with no minimum capital requirement but with restrictions on turnover or average e-money debt.
Leadership and integrity:
- Owners, managers, beneficial owners (UBO) must be “fit and proper” — with appropriate reputation, experience.
- Minimum 3 board members and CEO, mandatory key positions (AML/Compliance, information security, etc.).
Documents, business plan, operational plan:
- business model financial forecasts,
- AML/KYC policies
- internal controls
- risk management
- IT/security.
Deadlines:
- the application is first reviewed for formal defects (5 business days to check for completeness).
- if everything is fine - a full EMI license - about 3 months. for a restricted license - about 2 months.
Supervisory and operational responsibilities:
- annual supervision
- reporting internal audits
- protection of client funds (segregation)
- AML/CFT compliance.
Restrictions / “restricted EMI”:
- “Restricted activities EMI” has the following restrictions:
- Only valid within Lithuania;
- Limitations on average outstanding e-money or payment volumes.
- No or lower initial capital requirements
ADVANTAGES
Prestigious EU jurisdiction
Fast processing of applications (compared to other EU countries)
Passporting по Євросоюзу
Active support for fintech startups
Transparency and clear requirements
Quite a fast and transparent process of obtaining
Company in Lithuania UAB
Moderate license costs compared to some other jurisdictions
Ability to use the license throughout the EU (passporting) if there is an “unrestricted” license
Well-developed financial tecnologies ecosystem, support for startups.
The procedure for obtaining an EMI (Electronic Money Institution) financial license in Lithuania, under the supervision of the Bank of Lithuania (Lietuvos Bankas).
Determining the type of license
First, you need to determine what kind of license you want to obtain:
- Full EMI license (Unrestricted): full license for operation throughout the EU; passporting - yes.
- Small / Restricted EMI license: for the domestic market of Lithuania, with a limited volume of operations; passporting - no.
Company Registration in Lithuania
- A UAB (Private Limited Company) is created - an analogue of an LLC.
- Minimum authorized capital: €350,000 (for full EMI).
- A local director, legal address, office and bank account in the EU are required.
- You can use e-Residency to register and manage a company.
Preparation of a package of documents for the Bank of Lithuania
The application must be very detailed. The package includes:
- General information: company data, managers, shareholders, ownership structure and corporate scheme
- Business plan (business model, target markets, types of services, financial forecasts for at least 3 years, risk analysis)
- Internal policies (AML/CFT policy, KYC policy, risk management, internal control, description of IT infrastructure and data security, client funds protection policy)
- Management qualifications (CV, diplomas, fit and proper test), declarations of financial reliability and absence of criminal records)
Submitting an application to the Bank of Lithuania
- After submission, the Bank of Lithuania checks whether the package of documents is complete (5 days).
- If everything is in order, the formal consideration begins.
Application review by the regulator
Process duration:
Restricted — ≈ 2–3 months
Full (unrestricted) — ≈ 3–6 months
Stages of consideration:
- Verification of documents and ownership structure
- Analysis of business model and financial stability
- Assessment of management competencies (“fit & proper test”)
- Verification of AML / KYC policies
- Additional inquiries or interviews as needed
Obtaining an EMI license
After approval:
- Your company is included in the EMI register of Lithuania
- You can start operating
- For a full EMI license — passporting to all EU countries is possible
Post-license obligations
- Regular reporting to the Bank of Lithuania (quarterly/annually)
- Maintaining segregated client accounts
- Annual audit
- Continuous compliance with AML/KYC policies
- Updating business plan and risk procedures
WHAT IS PASSPORTING
Passporting is a key concept in European Union (EU) financial regulation that opens up great opportunities for companies licensed in one EU country.
Passporting is the right of a financial institution licensed in one European Union or EEA country (e.g. Malta, Estonia, Lithuania, Poland) to provide its services in other EU countries without the need to obtain a new license in each of them.
Passporting is like a "European financial passport": get a license in one EU country and you can legally work in all 27 countries without new permits.
Advantages of passporting
- No need to obtain a license in each EU country
- Reduction of costs and time to enter new markets
- Single compliance center and regulator
- Transparency and customer trust across the ES
Types of passporting
- Freedom to provide services (FPS): activity in other EU countries without a branch (via the internet or remotely)
- Freedom of establishment (FoE): opening a representative office or branch in another EU country
How it works: ️
- The company obtains, for example, an EMI license in Lithuania (issued by the Bank of Lithuania).
- Then it submits a notification to the regulator (MFSA, KNF, FI, etc.) about its intention to provide services in other EU countries.
- The regulator sends a notification to the relevant supervisory authorities of other countries.
- After 1–2 months, the company can legally operate in these countries - open accounts, issue electronic money, make payments, advertise services, etc.
Example:
- If an EMI company has a license in Estonia, it can, through passporting: Offer e-wallets to customers in Germany, France, Spain, etc.;
- Operate under the same brand in all EU countries;
- Not open a new company or obtain a local license.
What services can be “passported” :
- Issuance of electronic money (e-money)
- Provision of payment services (transfers, wallets, cards)
- Currency exchange, FX services
- Maintenance of payment accounts
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