Digital Payments & Fintech · Lithuania
EMI license in Lithuania: e-money institution (EMI) requirements (2026)
Lithuania shaded by its digital payments & fintech status
Fintech and digital payments in Lithuania: licensing regime.
FrameworkLaw on Payments (Mokėjimų įstatymas), Law on Electronic Money Institutions (Elektroninių pinigų įstaigų įstatymas); Bank of Lithuania (Lietuvos bankas) as competent authority; PSD2 (Directive 2015/2366) fully transposed; EU PSD3/Payment Services Regulation provisionally agreed November 2025, national applicability targeted Q2-Q3 2028
Lithuania operates one of the EU's most comprehensive fintech licensing regimes, with the Bank of Lithuania supervising 100+ licensed payment institutions (PIs) and electronic money institutions (EMIs) under a clear statutory framework derived from PSD2 and national implementing laws. The country hosts 248 active fintech companies processing over €166 billion in payments annually, and is the EU's largest PI/EMI licensing hub per capita. The EU PSD3 Directive and Payment Services Regulation, provisionally agreed in November 2025, will further consolidate this regime with applicability expected by 2027-2028.
How to get an EMI license in Lithuania
To provide electronic-money or payment services in Lithuania you need authorisation as an Electronic Money Institution (EMI), supervised by the Bank of Lithuania, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Bank of Lithuania
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Lithuania covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
How to get an EMI license in Lithuania: step by step
- 1Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
- 2Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
- 3Deposit and evidence the €350,000 initial capital.
- 4Submit the application to the national competent authority.
- 5The authority has three months from a complete application to grant or refuse.
- 6On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Lithuania
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
After authorisation: ongoing obligations in Lithuania
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
EMI license in Lithuania: FAQ
Yes. To provide electronic-money or payment services in Lithuania you need authorisation as an Electronic Money Institution (EMI), supervised by the Bank of Lithuania, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
The Bank of Lithuania.
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Key points
The Bank of Lithuania grants two main licence categories: Payment Institution (PI) and Electronic Money Institution (EMI, full or restricted). A full EMI requires minimum initial capital of €350,000; applications must be assessed within 3 months. Over 100 PIs have been authorised since 2016, making Lithuania the largest PI hub in the EU per capita. The entire process is conducted in English.
CENTROlink, operated by the Bank of Lithuania, provides direct SEPA access to all licensed PSPs across the EEA. Lithuania leads the euro area in instant payments, instant credit transfers represent 55% of all CENTROlink transactions, and Lithuanian providers account for 64% of euro-area interbank credit transfers. SEPA Request to Pay (SRTP) messaging was introduced in H2 2025.
PSD2 was transposed in Lithuania in 2018, mandating bank APIs for account information and payment initiation services; as of 2024 the register includes 24 bank APIs and 150+ registered TPPs. PSD3 and the Payment Services Regulation (PSR) reached provisional agreement on 27 November 2025; PSD3 requires national transposition within 18 months of entry into force, with full applicability targeted for Q2-Q3 2028.
From 17 January 2025, all Lithuanian EMIs and PIs fall within scope of the EU Digital Operational Resilience Act (DORA, Regulation (EU) 2022/2554), imposing mandatory ICT risk-management frameworks, major-incident reporting obligations, and third-party technology-provider oversight requirements.
BNPL products in Lithuania are governed by EU Directive 2023/2225 (CCD2), which explicitly brings deferred-payment and BNPL arrangements within the consumer credit licensing and disclosure framework; member states were required to transpose CCD2 by 20 November 2025. No standalone Lithuania-specific BNPL statute exists beyond CCD2 transposition.
Lithuania's EMI/PI sector generated €622 million in licensed-activity income in 2024 (up 25% year-on-year), processing €152 billion in transactions (up 33%). The Bank of Lithuania runs a Regulatory Sandbox and a 'Newcomer Programme' offering pre-application consultations in English, supporting 248 active fintech companies and nearly 8,000 sector professionals.
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