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Obtaining a banking license in Lithuania

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Obtaining a Banking License in Lithuania

Banking License in Lithuania

Obtaining a banking license in Lithuania provides access to the European Union markets and enables business expansion. The country has long established itself as a favorable jurisdiction for setting up banks and financial institutions, largely due to its flexible regulatory policies and advanced financial technologies. A banking license grants access to the EU Single Market, covering more than 450 million consumers, which significantly expands growth opportunities and facilitates investor attraction.

A banking license provides access not only to the domestic market but also to all EU member states under Directive 2013/36/EU, placing Lithuania in a strategically important position for banks seeking to expand their presence across Europe.

Contents

Advantages of Obtaining a Banking License in Lithuania

Lithuania, with its high level of digitalization and active adoption of modern technologies in banking and payment systems, creates conditions conducive to the development of innovative financial initiatives.

In addition, entrepreneurs gain access to the following opportunities:

  1. Providing banking services to clients in multiple currencies.

  2. Precious metals custody option.

  3. Acceptance of deposits from individuals.

  4. Expansion of business activities as the company grows.

  5. Opening bank branches in EU countries.

Holding a banking license ensures client security of deposits and reliability of partnerships.

Furthermore, Lithuania offers financial institutions one of the lowest tax rates in Europe. The country also maintains one of the most transparent business systems in the region, making it particularly attractive for long-term growth in the banking sector.

Types of Banking Licenses in Lithuania

  • Full Banking License
    This license grants financial institutions a wide range of opportunities. It is suitable for organizations intending to offer traditional banking services, such as deposit-taking, lending, securities transactions, and asset management. Banks holding this license enjoy flexibility in service provision and investment operations.

  • Specialized Banking License
    This license is designed for institutions aiming to focus on specific types of banking activities. Compared to a full license, it is more accessible and intended for companies operating within particular segments of the financial market.

Requirements for Obtaining a Banking License in Lithuania

Full Banking License

  • Bank executives and staff must demonstrate proven experience in the financial sector.

  • A registered office in Lithuania is mandatory. Minimum share capital: EUR 5,000,000.

  • Founders and shareholders must possess impeccable reputation and financial soundness.

Specialized Banking License

  • Minimum share capital: EUR 1,000,000.

  • Management must comply with regulatory standards, though requirements regarding experience and qualifications may be less strict compared to the full license.

  • Supervision is conducted by the Bank of Lithuania, although prudential reporting obligations may be simplified.

  • Such banks must comply with AML regulations and ensure financial stability.

  • Additionally, Lithuanian legislation obliges banks to safeguard client funds through segregation, i.e., client funds must be held separately from the bank’s own funds — either in segregated accounts or in accounts with other EU-member banks.

  • Violation of these requirements may result in sanctions, including fines or license revocation.

Required documents

  1. License application.

  2. Incorporation documents of the legal entity (articles of association, memorandum of association, etc.).

  3. Documents verifying the identity and qualifications of executives and key employees.

  4. Business plan.

  5. Documents confirming the origin of funds from founders and shareholders.

  6. Information on ownership and governance structure.

  7. Proof of compliance with minimum capital requirements.

  8. Statements confirming no sanctions or restrictions in other jurisdictions.

  9. Copies of incorporation documents and other required papers, notarized or apostilled if issued outside Lithuania.

The licensing decision is made in accordance with the Law on Banks of the Republic of Lithuania, based on Regulation (EU) No. 468/2014

The Process of Obtaining a Banking License in Lithuania

  1. Preliminary assessment
    The regulator conducts a preliminary assessment of compliance
  2. Application submission to the Bank of Lithuania
    To expedite the process, professional assistance in document preparation is recommended. Law&Trust specialists, experienced in preparing banking license applications, can optimize this stage. Consultations are available by phone or through the website.
  3. Decision-making
    Average processing time is 6 months from the date of application submission.

The Bank of Lithuania reviews the application within 5 working days for completeness and compliance. If discrepancies are found, the applicant is given an opportunity to rectify them.

Our Services for Obtaining a Banking License in Lithuania

Law&Trust International provides comprehensive legal support in obtaining banking, EMI, and PI licenses in Lithuania. Our experts in European regulatory frameworks guide clients through all licensing stages with minimized risks and optimized timelines.

  1. Consultation on license type selection

    Analysis of the business model and recommendation of the most suitable option (Bank / EMI / PI), including comparison of requirements and costs.

  2. Due Diligence of founders and beneficiaries

    Assessment of compliance with reputation requirements set by the Bank of Lithuania.

  3. Business plan development

    Preparation of a long-term plan in line with ECB standards, including financial models and capital flow forecasts.

F.A.Q.

Technically possible, but extremely difficult. The Bank of Lithuania requires “substantial presence,” which includes not only a registered address but also real operational activity in the country. Foreign founders must at least lease office premises and hire local staff (3–5 employees minimum). The only exception applies to EU bank branches, which may rely on the “passporting” principle.

Following Brexit, UK companies lost their right to a simplified procedure and are now treated as third-country applicants. They must establish a new legal entity in the EU, contribute the full minimum share capital (no less than EUR 5 million), and undergo enhanced beneficiary checks. Processing time has increased from 12 to 18–24 months, with particular scrutiny on links to offshore jurisdictions.

Beyond standard PCI DSS and PSD2 requirements, the Bank of Lithuania pays special attention to:

  • Availability of a backup center outside Lithuania (within the EU).

  • Real-time transaction monitoring systems.

  • DDoS protection of at least 100 Gbps capacity.

  • 95% of IT systems must be hosted within the EU.

  • Cloud solutions require a special EuroCloud audit.

Key reasons for rejection include insufficient segregation of client funds (particularly concerning stablecoins). Weak AML policies for anonymous transactions. Absence of clear crypto-to-fiat conversion mechanisms. In the last 3 years, only 2 crypto projects obtained EMI licenses, both with restrictions on servicing Lithuanian residents.

In addition to standard reasons (incomplete documentation), delays may be caused by ECB seasonal audits (April–May, October–November). Need for consultations with other EU regulators (if foreign founders are involved). Changes in shareholder structure during review. In 2023, the average processing period increased from 12 to 16 months.

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