Lithuania Payment Institution License in 2026

Why a Lithuanian PI still makes sense in 2026

Lithuania is the largest Payment Institution hub in the EU measured by licences per capita. More than 100 PIs have been authorised by the Bank of Lithuania since 2016, including large B2B acquirers, money-remittance operators, acquiring gateways and BaaS providers. The combination of English-language procedure, the Bank of Lithuania's newcomer programme, published 3-month statutory clock, direct SEPA access through CENTROlink, and reasonable legal cost keeps Lithuania the natural first stop for EU payment projects.

The PI licence authorises the full catalogue of PSD2 Annex I services under Directive (EU) 2015/2366: money transfers and remittance, merchant acquiring, card and non-card payment-instrument issuing, PISP and AISP. The Bank of Lithuania also operates a Small PI regime (no EU passport, reduced file) for sub-scale firms under EUR 3 million monthly average volume.

Capital and own funds for a Lithuanian PI

Initial capital follows PSD2 Article 7, applied without discount by Bank of Lithuania.

Own funds are calculated under PSD2 Methods A, B, C or D. Bank of Lithuania picks the method based on risk profile; Method B is the most common for early-stage acquirers and transfer PSPs. AISP-only firms do not need initial capital but need PII.

Process and state fees

The Bank of Lithuania process is modular and well documented. Expect this sequence:

1. Newcomer programme. Informal meetings to pressure-test business model, scope, substance and capital plan. Strongly advised.
2. Incorporation. Lithuanian UAB, capital account with pay-up, resident director(s), lease of a real office.
3. File preparation (3 to 4 months). Programme of operations, business plan, governance, AML, safeguarding, ICT, outsourcing, fit-and-proper.
4. State fee. EUR 1,463 for a PI licence (full), EUR 1,235 for a Small PI, paid to the State Tax Inspectorate before filing.
5. Submission and completeness check (5 business days).
6. Substantive assessment (3 months statutory). Real time frame 6 to 9 months with RFIs and interviews.
7. Conditions precedent. Safeguarding live, capital paid up, key hires on board, IT systems tested.
8. Passporting notification. Start services in host states 2 to 4 weeks after notification.

The CENTROlink advantage

CENTROlink is the Bank of Lithuania's own payment system, providing direct access to SEPA Credit Transfer, SEPA Instant Credit Transfer, TARGET2 and cross-border SWIFT. Lithuanian PIs and EMIs can join CENTROlink by signing a technical agreement with Bank of Lithuania, bypassing commercial correspondent banks for SEPA rails.

Benefits of CENTROlink membership:

• Lower cost. Fees published and substantially below commercial correspondent rates.
• Lower counterparty risk. Direct Bank of Lithuania membership reduces dependency on a single commercial correspondent.
• SEPA Instant by default. Mandatory EU-wide from 9 October 2025 under Regulation (EU) 2024/886; CENTROlink participants were already live.
• Operational resilience. Diversified settlement reduces the chance of a correspondent-bank outage breaking payments.

CENTROlink is the single biggest practical differentiator of a Lithuanian PI versus a PI in most other EU jurisdictions.

Substance, tax and operational setup

• Local directors. At least one executive director resident in Lithuania, typically two.
• Local staff. MLRO, risk and IT leads resident in Lithuania. Outsourced part-time MLROs no longer accepted.
• Real office. Rental agreement, utilities, desk presence. Bank of Lithuania visits.
• Corporate tax. 17% from 1 January 2026 (up from 16%).
• VAT. Core payment services exempt under the EU financial-services exemption. Ancillary consulting/IT services may be 21%.
• Banking partners. SEB, Swedbank, Luminor, OP Corporate Bank are the usual safeguarding partners. Tier-1 correspondents (Barclays, ING, BNY) often used for GBP/USD.

Small PI: the lighter Lithuanian track

Lithuania operates an Article 32 PSD2 Small PI regime. Under EUR 3 million monthly average transaction volume (rolling 12 months), a Small PI:

• Has no fixed initial-capital requirement.
• Files a lighter governance and AML package.
• Cannot passport to other EEA Member States. Lithuania only.
• Must upgrade to full PI before breaching the EUR 3M cap.

See the small PI and small EMI guide for the full framework.

What to prepare for PSD3

PSD3 and PSR reached provisional agreement on 27 November 2025, with applicability expected mid-to-late 2027. Lithuanian PIs keep their authorisation and migrate to the unified "payment institution authorised to issue e-money" category under PSD3. See the PSD3 and PSR guide for the full roadmap.

Practical work for 2026: deploy IBAN-name check across all rails (already mandatory for SEPA Instant since 9 October 2025), upgrade fraud monitoring for APP-fraud liability, diversify safeguarding across at least two credit institutions, lift open-banking API performance if you are also an ASPSP, and review substance and governance against tighter PSD3 expectations.

Ship a Lithuanian PI product with Crassula

A Lithuanian PI licence is the legal wrapper. The product layer is the core: ledger, IBANs, wallets, SEPA and SEPA Instant through CENTROlink, cards, KYC, safeguarding and supervisor-ready reporting. Crassula delivers it as a white-label core pre-integrated with Lithuanian banking partners and CENTROlink.

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