EMI license in Lithuania

✦

Before applying for an EMI license, the applicant must be incorporated as a Lithuanian legal entity with the Register of Legal Entities of the Republic of Lithuania, administered by the State Enterprise Centre of Registers (VĮ Registrų centras).

For licensing purposes, the recommended default legal form is the UAB (Uždaroji akcinė bendrovė) — a private limited liability company, functionally equivalent to an international LLC, and one of the forms explicitly accepted for EMI licensing (the license source also permits AB, the public limited company form, for larger-scale operations). Other legal forms are available in Lithuania (see the Basic company reference) but are generally not suited to licensed financial activity.

A registered office in Lithuania is required for the company. For banking relationships, Swedbank Lithuania and SEB Bank Lithuania are established banks operating in the jurisdiction.

Lithuania has positioned itself as one of the EU's leading jurisdictions for electronic money institutions, combining a large existing EMI community with direct central-bank infrastructure access. Key features of the regime:

• Regulator: the Bank of Lithuania (Lietuvos bankas) is the licensing and supervisory authority for EMIs.
• Legal basis: Directive 2009/110/EC (EMD2), implemented through Lithuania's national Law on Electronic Money and Electronic Money Institutions.
• Minimum initial capital: EUR 350,000 for an unrestricted EMI license.
• Application fee: EUR 1,463.
• Regulatory review: up to 3 months for the Bank of Lithuania to review a complete application; the realistic total timeline to licensing (including preparation) is typically 6–12 months.
• Legal form: UAB or AB.
• Governance: a board of at least 3 members plus a CEO; at least 4 employees must be based in Lithuania. A resident director is not required.
• EU/EEA passporting: an unrestricted Lithuanian EMI license allows passporting of services across 30 EU/EEA states.
• SEPA access: licensed EMIs can obtain direct SEPA access via the Bank of Lithuania's CENTROLINK infrastructure, rather than relying solely on correspondent banking relationships.
• Stablecoin/MiCA activity: EMIs may issue MiCA-covered stablecoins (e-money tokens) under Article 48 of Regulation (EU) 2023/1114.
• AML/CTF supervision: ongoing compliance is monitored by the Financial Crimes Investigation Service (FCIS/FNTT), Lithuania's AML/CTF enforcement authority for regulated entities.

The Bank of Lithuania requires an EMI to maintain a board of at least 3 members plus a CEO, and at least 4 employees based in Lithuania. A resident director is not required.

Lithuania is one of the largest hubs in the EU for electronic money institutions, hosting more than 80 licensed EMIs on the EBA register. An EMI license issued by the Bank of Lithuania allows a company to issue electronic money, provide payment services, obtain direct SEPA access, and passport its services across the EU/EEA under a single authorisation. This page outlines the route from company formation through to obtaining an EMI license in Lithuania.

✦

The license-specific stages (4–5) have a statutory review period of up to 3 months, with a realistic total timeline (including preparation and follow-up) of 6–12 months; this estimate does not include the timeline for Stage 1 (company registration), which is not confirmed in available sources.

✦

✦

Discover company formation and licensing opportunities across leading international jurisdictions.

✦

• Bank of Lithuania