Lithuania Specialised Bank License in 2026: The Complete Guide

The fintech-friendly banking licence that exists only in Lithuania

The Lithuanian Specialised Bank licence is a unique CRD-compatible credit-institution authorisation available only through the Bank of Lithuania. Initial capital is EUR 1 million, five times less than the CRD minimum of EUR 5 million that applies elsewhere in the EU. Twelve specialised banks have been licensed since the regime opened in 2017, including Revolut Bank before its upgrade to a full bank, PayRay, SME Bank, European Merchant Bank, Mano Bank and others.

A specialised bank is a full credit institution under CRD and CRR, gets the full banking EU passport, and is covered by the Lithuanian deposit-guarantee scheme up to EUR 100,000 per depositor. The trade-off is a scope restriction: specialised banks cannot provide investment advisory, securities brokerage, investment fund management, custody of financial instruments or most derivative-related services.

In practice the regime is ideal for digital banks, challenger banks, SME-lending banks, trade-finance banks, white-label BaaS providers and neobanks that want to upgrade from EMI without going straight to a full CRD licence.

Capital, own funds and prudential reality

The EUR 1 million floor is just the entry ticket. Real capital at launch is driven by the business model, risk-weighted assets and supervisory assessment.

• Initial capital. EUR 1 million paid up in cash, in the licensed entity's name, in a Lithuanian credit institution.
• Ongoing own funds. CRR Pillar 1 RWA times 8% minimum, 4.5% CET1, 6% Tier 1, plus 2.5% conservation buffer, countercyclical and systemic buffers if applicable.
• SREP add-on. Pillar 2 requirement (P2R) and guidance (P2G). Bank of Lithuania typically adds 1.5-3% to the headline ratio for new specialised banks.
• CRR3 / Basel 3.5 output floor. Applies from 1 January 2025. Specialised banks mostly use standardised credit-risk approaches, so the output floor bites less than at IRB-modelled banks.
• Liquidity. LCR 100% minimum, NSFR 100% minimum. ILAAP expected from day one.
• MREL. Most specialised banks sit below the resolution-required MREL threshold, but a funding-plan roadmap is required in the authorisation file.

Realistic launch CET1 for a credible specialised bank: EUR 5 million to EUR 25 million depending on expected balance-sheet growth. EUR 1 million is enough for the licence but not enough to run a bank for more than 6 to 12 months.

The authorisation process: Bank of Lithuania plus ECB

Every new specialised bank goes through the same two-step process that applies to full banks in the Eurozone. Bank of Lithuania leads the substantive review; the ECB takes the final decision under the SSM Regulation.

1. Phase 1 - Pre-application (3 to 6 months). Bank of Lithuania's newcomer programme is mandatory in practice. Multiple meetings cover business model, capital plan, governance, ICAAP, ILAAP, and ICT. This phase is where 30 to 40% of applications are quietly discontinued before formal filing.
2. Phase 2 - Application preparation (4 to 6 months). Full authorisation file (typically 1,500 to 3,000 pages). Business plan with 5-year projections, ICAAP, ILAAP, recovery plan, governance, remuneration, risk framework, AML/CFT, ICT and DORA, internal audit charter, IFRS 9 model, outsourcing register, fit-and-proper files.
3. Phase 3 - Completeness check (5 business days). Bank of Lithuania confirms the file is complete. Missing items reset the clock.
4. Phase 4 - Substantive assessment (6 months statutory, 9 to 12 months real). RFIs, interviews with management, ICAAP/ILAAP challenge, cyber and AML deep-dives.
5. Phase 5 - ECB decision (2 to 4 months). Bank of Lithuania submits the draft decision to the ECB. ECB issues the final decision.
6. Phase 6 - Conditions precedent (1 to 3 months). Paid-up capital, key hires on board, systems tested, DGS contribution paid. Licence issued.

Total end-to-end: 12 to 24 months for a credible, well-prepared file. Less-prepared files run longer and sometimes withdraw mid-process.

The state fee for a specialised bank licence is EUR 50,683, paid once on submission. Supervisory fees apply post-licence, scaled to size.

Governance, substance and fit-and-proper

Bank of Lithuania plus ECB fit-and-proper standards are demanding and non-negotiable.

• Management body. At least 5 board members with collective suitability in banking, risk, finance, technology and compliance. Minimum 2 executive directors, typically 3 to 4 non-executive directors including independents.
• Key function holders. CEO, CFO, CRO, CCO (Head of Compliance / MLRO), Head of Internal Audit. All subject to detailed fit-and-proper review. First-time banking hires are commonly rejected at CRO level.
• Local substance. Head office in Lithuania, executive management resident in Lithuania, critical functions (risk, compliance, operations, IT) located in Lithuania. "Brass plate" banks do not pass ECB review.
• Qualifying shareholders. Every 10%+ shareholder fit-and-proper tested. Private-equity or VC fund chains are unpacked to UBO.
• Remuneration. CRD bonus cap (100% fixed, 200% with shareholder vote), deferred variable pay, malus and clawback, gender-neutral policy.
• Three lines of defence. Independent risk, compliance and internal audit. Outsourced arrangements are allowed but must not impair local oversight.

Upgrade path: specialised bank to full bank

Revolut Bank is the best-known example. Licensed as a specialised bank in 2018, upgraded to full CRD bank in 2021 after the scope and scale of the business outgrew the specialised-bank perimeter. The upgrade path is structured.

1. Scope delta analysis. Identify activities that need the full-bank licence (investment services, custody, fund management, portfolio management).
2. Capital uplift. CET1 boost to EUR 5 million+ initial plus higher SREP run-rate capital.
3. Governance uplift. Additional board committees, higher-seniority CRO and CFO, investment-services expertise on the board.
4. File supplement. Focused on the incremental scope and supporting capital, rather than a full re-application. Bank of Lithuania and ECB treat the existing specialised-bank file as the base.
5. Timeline. 12 to 18 months for a well-prepared upgrade, significantly faster than a full de-novo banking authorisation.

Operating a specialised bank: supervision, reporting, costs

• JST supervision. Bank of Lithuania-led joint supervisory team, with ECB participation depending on classification (less-significant vs significant).
• COREP and FINREP. Quarterly and monthly supervisory data reports. AnaCredit granular credit data.
• SREP cycle. Annual review; produces P2R, P2G, supervisory score, action plan.
• Recovery plan. Annual update. Simpler than a full bank's plan but mandatory.
• AML supervision. Bank of Lithuania plus FCIS (Financial Crimes Investigation Service). Increasing AMLA coordination from 2026.
• DGS contribution. Annual risk-based contribution to the Lithuanian deposit-guarantee scheme, scaled to covered deposits.
• Supervisory fee. EUR 100k to EUR 500k per year for most specialised banks.

Specialised banks that reach EUR 30 billion of total assets or are otherwise deemed "significant" come under direct ECB supervision.

Comparison: specialised bank vs EMI vs full bank

Typical decision: EMI for payment products, specialised bank when deposit-plus-lending is the core economics, full bank when investment services or securities custody become part of the offer.

Ship a specialised bank product with Crassula

A licence is the legal layer. Core banking is the product layer: ledger, deposits, lending, cards, payments, treasury, risk, DORA ICT, reporting. Crassula delivers it as a composable core that supports EMI-to-specialised-bank-to-full-bank growth trajectories on the same platform.

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