Lithuania EMI License in 2026: The Complete Guide

Why Lithuania dominates the EU EMI league table

Lithuania hosts the largest population of EMI licences per capita in the EU. The Bank of Lithuania (Lietuvos bankas) has licensed more than 90 EMIs since 2017, including Revolut (before its upgrade to a Lithuanian specialised bank), Flywire, Banking Circle, Checkout, Contis, Paysafe and a long tail of neobanks and BaaS providers. The reasons are practical.

Substance expectations have tightened materially since 2022. The days of letter-box Lithuanian EMIs are over: the regulator wants local staff, local management and genuine business ties.

Unrestricted vs restricted EMI: the two tracks

Lithuania operates both tracks under the Law on Electronic Money and Electronic Money Institutions, which transposes EMD2.

A growing number of founders file as restricted EMI first to test product-market fit, then upgrade to unrestricted once the cap becomes binding. The upgrade is significantly less work than a fresh authorisation.

The Bank of Lithuania process step by step

1. Newcomer programme. The Bank of Lithuania offers pre-application meetings to discuss business model, scope, substance and timeline. Mandatory in practice, even if technically optional. Book at least 2 months before your target submission date.
2. Incorporation. Register a Lithuanian UAB (private limited). Open a capital account at a local bank, pay in EUR 350k (or less for restricted). Appoint at least one Lithuanian-resident director, ideally two.
3. File preparation (3 to 4 months). Articles of association, 3-year business plan with stressed scenarios, programme of operations, AML/CFT policy, ICAAP, safeguarding plan, ICT and security documentation (DORA-aligned), outsourcing register, governance framework, fit-and-proper questionnaires.
4. Submission and completeness check (5 business days). Bank of Lithuania has 5 business days to confirm the file is complete. Missing items reset the clock.
5. Substantive assessment (3 months statutory, 6 to 9 months real). RFIs, interviews with management, independent ICT or AML expert reviews if requested.
6. Pre-authorisation conditions. Paid-up capital, safeguarding account live, key hires on board, systems tested. All must be evidenced before the licence is issued.
7. Passporting notification. Once authorised, notify the Bank of Lithuania of every EEA Member State where you want to operate. Services can start 2 to 4 weeks later.

Substance: the filter that catches most applicants

Bank of Lithuania substance expectations in 2026:

• Local directors. At least one executive director resident in Lithuania, present in the office. Two is preferred.
• Local staff. Compliance officer (MLRO), risk manager, head of IT, ideally head of operations, all Lithuanian-based. Outsourced part-time MLROs are no longer accepted.
• Real office. Not a virtual address. Bank of Lithuania checks rental agreements, utility bills and visits the office.
• Decision-making in Lithuania. Board meetings, strategic decisions and material risk calls must happen locally. Video meetings with founders in Dubai are a red flag.
• Documented risk ownership. The head of risk and head of compliance report to the Lithuanian board, not to a group CEO abroad.

Firms that fail substance are either refused or granted with conditions that require substance to be built within 6 months of licence, failing which the licence is revoked. Several 2023 and 2024 authorisations were revoked on exactly this basis.

Taxes, banking partners and operational reality

• Corporate income tax. 17% from 1 January 2026 (up from 16%). A reduced 5% rate applies to small businesses meeting specific conditions. CFC and transfer-pricing rules apply normally.
• VAT. Most EMI services are VAT-exempt under the EU financial-services exemption. Specific services (consulting, IT support for third parties) may fall in scope at 21%.
• Correspondent banking. CENTROlink direct access reduces dependence on commercial correspondent banks. A Tier-1 correspondent (Barclays, ING, BNY) is still useful for GBP, USD and non-EUR rails.
• Safeguarding banks. A handful of Lithuanian and EU banks specialise in EMI safeguarding (SEB, Swedbank, Luminor, OP Corporate Bank). Expect 2 to 6 months to onboard.
• Scheme partners. Visa and Mastercard issuing requires a scheme sponsorship or direct principal membership. Direct principal is rare for Lithuanian EMIs; most use a BIN sponsor.

Supervisory reality after the licence

Bank of Lithuania has invested heavily in supervision capacity and runs one of the more active payment-institution supervisory functions in the EU.

• Quarterly prudential reporting. Own funds, safeguarding, transaction volume, customer numbers, incidents.
• Annual AML supervisory return. Institutional risk assessment, detection rule statistics, SAR filings, remediation actions.
• Onsite inspections. Typical frequency: every 2 to 4 years for a stable EMI, more often for fast-growing or higher-risk firms.
• Major incident reporting. 4-hour initial report, follow-up within 72 hours. DORA-aligned process expected from day one.
• Supervisory fee. Scales with revenue and risk profile; EUR 15k to EUR 80k per year for most EMIs.

PSD3 and what Lithuanian EMIs must prepare for

PSD3 and PSR reached provisional agreement on 27 November 2025. Publication in H1 2026, entry into force 2027. Lithuanian EMIs keep their authorisation and migrate to the unified "payment institution authorised to issue e-money" category.

Operational items to work on in 2026: mandatory IBAN-name check across all rails, APP-fraud liability readiness, safeguarding diversification across at least two credit institutions, tighter substance expectations and refreshed open-banking API performance if the EMI is also an ASPSP.

Ship a Lithuanian EMI product with Crassula

A licence is the legal layer. The product layer is core banking: ledger, IBANs, wallets, cards, SEPA and SEPA Instant through CENTROlink, KYC and AML, safeguarding reconciliation, regulator reporting and a customer-facing app. Crassula delivers it as a white-label core pre-integrated with Lithuanian banking partners.

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