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EMI license in Lithuania

Lithuania

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,…

Gilded relief map and metallic skyline silhouette of Lithuania on a navy base, studio-lit still life
Jurisdiction Lithuania
License type EMI license
Regulator Bank of Lithuania (BoL)

Requirements

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.

Get Your EMI License in Lithuania

Bank of Lithuania (BoL)

Primary licensing and supervisory authority for CASP (crypto-asset service provider) authorization under MiCA, previously for VASP registration under the legacy regime, and for EMI (electronic money institution) licensing under EMD2/national law; conducts completeness review and evaluation/decision stages for CASP applications; grants EMI licenses enabling SEPA access via CENTROLINK and EU/EEA passporting https://www.lb.lt

Overview

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.

Licensing Process

Engraved gold medallion of official documents with the Lithuania skyline

Step 1

Incorporate the Lithuanian company (recommended form: UAB) with the Register of Legal Entities and open a corporate bank account (e.g. with Swedbank or SEB).

Engraved gold medallion of a document being filed with the Lithuania skyline

Step 2

Build out governance and substance: appoint a board of at least 3 members plus a CEO, and put in place at least 4 Lithuania-based employees.

Engraved gold medallion of an ornate certificate with the Lithuania skyline

Step 3

Fund the company to meet the EUR 350,000 minimum initial capital requirement for an unrestricted EMI license.

Engraved gold medallion of an appointment ledger with the Lithuania skyline

Step 4

Prepare and submit the EMI license application to the Bank of Lithuania, paying the EUR 1,463 application fee.

Engraved gold medallion of a bank ledger with the Lithuania skyline

Step 5

Undergo the Bank of Lithuania's regulatory review (statutory period up to 3 months for a complete application).

Step 6

Upon approval, connect to SEPA via CENTROLINK and, if desired, exercise EU/EEA passporting rights across up to 30 member states.

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.

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Frequently Asked Questions

Which regulator issues the EMI license in Lithuania?

The Bank of Lithuania (Lietuvos bankas) is the competent authority for licensing and supervising electronic money institutions.

What is the minimum capital required?

EUR 350,000 for an unrestricted EMI license.

How long does the licensing process take?

The Bank of Lithuania's statutory review period is up to 3 months for a complete application, but the realistic total timeline, including preparation, is typically 6–12 months.

Which legal form should the company take?

A UAB (private limited liability company) is the recommended default; an AB (public limited company) is also accepted under the EMI regime.

Does the company need a resident director?

No, a resident director is not required, though the board must have at least 3 members plus a CEO, and at least 4 employees must be based in Lithuania.

Can a Lithuanian EMI operate across the EU?

Yes, an unrestricted EMI license allows passporting of services into 30 EU/EEA states.

Can the EMI get direct SEPA access?

Yes, via the Bank of Lithuania's CENTROLINK infrastructure, giving direct SEPA connectivity rather than relying only on correspondent banks.

Can a Lithuanian EMI issue stablecoins?

Yes, MiCA-covered stablecoin (e-money token) issuance is permitted under Article 48 of Regulation (EU) 2023/1114.

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Official Sources

Official Sources