We structure your authorization as an electronic money institution with the Bank of Lithuania, the EU’s largest fintech hub: regulatory fit, a UAB company, capital, safeguarding of funds and access to CENTROlink (SEPA), AML/CFT, governance, DORA and an EU passport to the entire European Economic Area.
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Six building blocks that make up a solid, defensible application to the Bank of Lithuania to operate as an electronic money institution and passport across the EU.
Before applying, we confirm which type fits your model: a full EMI (with a passport), a restricted EMI (no minimum capital, but Lithuania only) or a payment institution. That decision determines capital, scope and timelines.
We prepare the application in English: program of operations, policies, fit and proper assessment of directors, business model and responses to requests for information. The statutory period is 3 months from a complete application.
Incorporation of the Lithuanian company (UAB), fit and proper directors, a real office and staff in Lithuania, and key functions (compliance, MLRO). The Bank of Lithuania requires genuine substance, not paper structures.
Issuance and redemption flow, segregated accounts and access to CENTROlink, the Bank of Lithuania’s payment system, which gives direct reach to SEPA without relying on a correspondent bank from day one.
Risk assessment, onboarding, monitoring, screening and reporting. Lithuania keeps a strong focus on anti-money laundering and requires a fit and proper officer (MLRO) and real operational evidence.
Digital operational resilience framework (DORA, mandatory since January 2025) and passport notification to operate in the 30 EEA countries, including Spain, under the free provision of services or through a branch.
Lithuania has the largest number of electronic money institutions in the Union. This is no accident: an English-language process, an accessible regulator, SEPA access via CENTROlink and a mature fintech ecosystem.
“The Bank of Lithuania handles applications in English, with a completeness check within a few days and a statutory period of 3 months (2 for a restricted EMI). The clock starts when the application is genuinely complete.”
“CENTROlink, the central bank’s payment system, allows Lithuanian EMIs to operate in SEPA without relying on a correspondent bank from the outset. It is one of the country’s major practical advantages.”
“There is a support program for newcomers and a regulatory sandbox, which make early dialogue with the supervisor easier and reduce surprises during the review.”
“A mature ecosystem of providers, safeguarding banks, BIN sponsors and compliance talent makes setting up real operations faster than in less specialized jurisdictions.”
The Bank of Lithuania is accessible, but demanding. Most roadblocks do not come from the rules but from inconsistent applications, insufficient substance or poorly designed safeguarding.
Paper substance: registering a UAB is not enough. Without an office, effective management and real staff in Lithuania (including the MLRO), the supervisor halts the application. It is the most common reason for rejection.
The 3-month clock is misleading: the statutory period only runs from a complete application. An incomplete or inconsistent dossier triggers new rounds of requests for information and stretches the actual process to 6–12 months.
Poorly planned safeguarding and CENTROlink: without a safeguarding account and a payments access strategy, the license does not translate into real operations and partners will not integrate.
Minimum initial capital for a full EMI, plus ongoing own funds of at least 2% of average outstanding electronic money.
The restricted license requires no minimum capital, but it only operates within Lithuania and does not allow an EU passport: it is for validating, not for scaling.
Issuing electronic money without a prior license is a serious infringement. Operations must wait for authorization from the Bank of Lithuania.
Before incorporating the UAB, it is worth validating the regulatory fit (full EMI, restricted EMI or payment institution) and comparing Lithuania with Malta, Ireland or Spain based on your model, your timelines and your tax position.
The minimum initial capital for a full EMI is €350,000, the same as in the rest of the EU (it derives from the EMD2 directive). In addition, the institution must maintain ongoing own funds of at least 2% of average outstanding electronic money.
A restricted EMI requires no minimum capital, but in return it may only operate within Lithuania and without an EU passport.
The statutory decision period is 3 months from the submission of a complete application (2 months for a restricted EMI). The Bank of Lithuania first runs a completeness check within a few business days.
In practice, including preparation, the full process usually takes 6 to 12 months, depending on the complexity of the model and the quality of the application.
The state fee for the application is approximately €1,463 for a full EMI and €1,235 for a restricted EMI. That is only the supervisor’s fee.
The real cost of the project also includes the capital, the fees for preparing the application and the local structure: a UAB company, director, MLRO, office, technology and safeguarding banking.
CENTROlink is the Bank of Lithuania’s payment system that allows authorized institutions (EMIs and payment institutions) to access SEPA directly, without relying on a correspondent bank from day one.
It is one of the major practical advantages of getting licensed in Lithuania: it speeds up the launch of payment operations and your own IBANs.
Yes. Although the UAB (Lithuanian limited liability company) can be incorporated remotely, the Bank of Lithuania requires real substance: effective management in the country, a physical office and sufficient local staff, including the compliance and anti-money laundering officers (MLRO).
A structure that exists only on paper is the most common reason applications get blocked.
Yes. An EMI authorized in Lithuania can operate in the 30 countries of the European Economic Area through the EU passport, by notifying the Bank of Lithuania, which forwards the notification to the host supervisor (for example, the Bank of Spain). The passport can be exercised under the free provision of services or through a branch.
A full EMI requires €350,000 in capital, but it operates across the EU with a passport. A restricted EMI (specialized) requires no minimum capital, but it is limited to Lithuania, with caps of €900,000 in average outstanding electronic money and €3,000,000 in monthly payments, and it cannot passport.
A restricted EMI is useful for validating the product; scaling requires converting into a full EMI later.
Yes. An EMI can issue IBANs, wallets and prepaid cards within its authorized scope, and under MiCA it can also issue e-money tokens (EMTs), subject to additional reserve and governance requirements. It does not take deposits or grant credit like a bank.
A UAB (uždaroji akcinė bendrovė) is the Lithuanian private limited liability company and the usual corporate form for an EMI. It can be set up quickly, in many cases remotely, although the license then requires real substance in the country.
There is a market for already licensed Lithuanian EMIs (with a passport and, sometimes, CENTROlink access). Buying one speeds up go-to-market, but it requires rigorous due diligence (regulatory history, compliance and hidden liabilities) and approval of the change of control by the Bank of Lithuania.
Lithuania stands out for its ecosystem, safeguarding banks, CENTROlink and a fast process. Malta offers a full imputation tax system and a track record in payments and crypto. We cover this in detail in our comparison of European jurisdictions.
The Bank of Lithuania looks for effective local management and suitable directors (fit & proper) with demonstrable experience. The Compliance Officer and the MLRO are key roles and must be able to genuinely perform their functions from Lithuania.
Periodic reporting to the Bank of Lithuania, operational AML/KYC, DORA compliance, audit, record keeping (10 years) and maintaining safeguarding and own funds. The license is the start of supervised operations, not the end.
Yes, the concept is similar to that of an electronic money institution under the simplified regime. We explain it in our pages on the simplified electronic money institution and the EMI license in Spain.
Lithuania offers two routes. The choice depends on whether you need an EU passport from the start or prefer to validate the product within the country with lower capital requirements.
The supervisor’s fee is the smaller item; most of the cost lies in the capital, the local structure and preparing the application.
We first settle the regulatory fit and the right license type, and we coordinate the local side in Lithuania so that the application reaches the supervisor complete.
| Item | Full EMI | Restricted EMI (specialized) |
|---|---|---|
| Minimum capital | €350,000 | No minimum capital |
| Geographic scope | Entire EU / EEA | Lithuania only |
| EU passport | Yes | No |
| Average e-money limit | No specific limit | ≤ €900,000 |
| Monthly payments limit | No specific limit | ≤ €3,000,000 / month |
| Statutory decision period | 3 months | 2 months |
| Best for | Scaling in Europe with a passport | Validating a product within Lithuania |
Indicative figures. The €350,000 capital derives from the EMD2 directive and is common to the whole EU; fees, limits and timelines are set and updated by the Bank of Lithuania, so they should be checked case by case. This page is for information only and does not constitute legal advice.
It is not just a formality: it means building a coherent Lithuanian institution that can be supervised from day one. Local substance and safeguarding are the decisions that most shape the outcome.
Choose between a full EMI, a restricted EMI or a payment institution depending on whether you need a passport. Capital, scope and timelines in Lithuania depend on that decision.
A real office, effective management and local staff (compliance, MLRO). Without credible substance in Lithuania, the Bank of Lithuania halts the application.
The safeguarding account and the SEPA access strategy (CENTROlink) must be planned up front, not as an afterthought. Without them, the license does not translate into operations.
Not sure Lithuania is your best option? Compare options in our EMI license in Europe guide or review the EMI license in Spain.
An effective EMI license in Lithuania is a sequence of coherent decisions (UAB company, substance, safeguarding and CENTROlink, AML/KYC and passport) that you demonstrate with a clear audit trail. Here is the real path.
1) UABIncorporation of the UAB and setting up real substance: office, effective management and local staff. This is the foundation on which the Bank of Lithuania assesses everything else.
2) ApplicationProgram of operations, policies, governance and technology, with no contradictions. The completeness check starts the 3-month statutory clock.
3) SafeguardingSegregated accounts at an EEA credit institution and a CENTROlink access strategy to operate in SEPA. This is what turns the license into real operations.
4) Passport + complianceAfter authorization, passport notification to target markets (including Spain) and ongoing compliance: AML/KYC, DORA, reporting and audit. Inspections review evidence, not intentions.
Quick decisionFull EMI: €350,000 in capital and a passport to the 30 EEA countries.
Restricted EMI: no minimum capital, Lithuania only, with volume caps and no passport.
Payment institution: if you do not issue electronic money (transfers, payments, remittances).
A UAB incorporated with effective management, an office and real staff in Lithuania.
Articles of association, office lease, organization chart and local employment contracts.
A business model in English, consistent with clients, channels, technology and partners.
Detailed business description, 3-year projections and third-party agreements.
Issuance and redemption flow, segregated accounts and a SEPA access plan.
Safeguarding policy, bank agreements and CENTROlink application/plan.
Risk assessment, onboarding, monitoring and an operational MLRO in Lithuania.
AML/CFT manual, KYC files, alert log and appointment of the MLRO.
Fit and proper directors, internal control and an ICT resilience framework (DORA).
Fit and proper questionnaires, ICT risk map and incident register.
Spot them before you submit the application to the Bank of Lithuania.
If you are structuring an EMI license in Lithuania, these terms come up in the application, in your dealings with the Bank of Lithuania and in day-to-day operations.
An institution authorized to issue electronic money (wallets, prepaid cards, balances) and provide payment services. Minimum capital of €350,000 for a full license.
Lithuanian private limited liability company, the usual corporate form for an EMI. Quick to incorporate, but the license then requires real substance.
The Bank of Lithuania’s payment system, which gives authorized institutions direct access to SEPA without relying on a correspondent bank from the outset.
A license type with no minimum capital, limited to Lithuania, with caps of €900,000 in average e-money and €3,000,000 in monthly payments. It does not allow an EU passport.
The officer responsible for anti-money laundering. Must be fit and proper and able to perform the role effectively from Lithuania, with evidence of their activity.
Lithuania’s central bank and financial supervisor. It authorizes and supervises EMIs and payment institutions, with an English-language process and a newcomer program.
The obligation to protect client funds through segregated accounts at an EEA credit institution or an equivalent insurance policy or guarantee.
The right to operate in the 30 EEA countries with the Lithuanian license, after notifying the Bank of Lithuania, under the free provision of services or through a branch.
EU regulation applicable since January 2025: ICT risk management, continuity, incident reporting and oversight of critical providers.
Download the guide covering the full process: full vs restricted EMI, capital and own funds, local substance, CENTROlink, the Bank of Lithuania’s real timelines and the EU passport.
Tell us about your project and we will explain how to structure your EMI license in Lithuania (or whether another jurisdiction suits you better) with the shortest possible processing time.
Electronic money institutions in Lithuania are authorized and supervised by the Bank of Lithuania (Lietuvos bankas) within the harmonized EU framework: Directive 2009/110/EC (EMD2) for electronic money and Directive (EU) 2015/2366 (PSD2) for payment services, both transposed into Lithuanian law. That is why the minimum capital and core obligations are the same as in the rest of the EU, while the language of the process, the timelines and the operational tools are what make Lithuania the Union’s largest fintech hub.
A full EMI requires €350,000 in initial capital and ongoing own funds of at least 2% of average outstanding electronic money. A restricted EMI requires no minimum capital, in exchange for operating only in Lithuania and without a passport, with caps of €900,000 in average e-money and €3,000,000 in monthly payments.
The statutory decision period is 3 months from a complete application (2 months for a restricted EMI), preceded by a completeness check. The state fee is around €1,463 (full) and €1,235 (restricted). The real process, including preparation, usually takes between 6 and 12 months.
A distinctive advantage of Lithuania is CENTROlink, the Bank of Lithuania’s payment system, which gives authorized institutions direct access to the SEPA area without relying on a correspondent bank from the outset. This speeds up the launch of their own IBANs and payments.
Since January 2025, the DORA Regulation has been mandatory (ICT risk management, continuity, incidents and critical providers). On top of that come periodic reporting to the Bank of Lithuania, the AML/CFT framework with its MLRO, record keeping and maintaining safeguarding and own funds.
Key legislation, linked to the official text:
Legislation and links reviewed in .