Obtain a license for electronic money in Lithuania

Electronic money is playing an increasingly important role in the modern financial world, and its regulation is now a key focus in the fintech industry. Under EU law, Lithuania has established clear rules for Electronic Money Institutions (EMIs), aimed at creating a transparent and secure environment for both financial service providers and their customers. To operate legally in this space, businesses must obtain the appropriate license.
A licensed EMI can legally accept and hold client funds, issue and redeem electronic money, and provide payment acquiring services. In other words, an EMI license allows companies to fully participate in today’s financial ecosystem and offer a wide range of services.
Types of EMI licenses in Lithuania
Lithuania offers two types of licenses for electronic money activities:
- Full EMI License
- Limited Activity License
The Limited Activity License was introduced to encourage investment and support small businesses. Unlike the full license, it does not require a minimum share capital, but it is valid only within Lithuania. This makes it a suitable option for startups or smaller companies focusing on the local market.
How to Get an EMI License in Lithuania
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Application submission to the Bank of LithuaniaYou’ll need to submit all required documents within five business days. These go through a formal review. It’s crucial to ensure the application is complete and meets all regulatory requirements—any errors or missing information can result in delays or rejection.
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Review and assessmentIf the documents are in order, the license is typically granted within three months (or two months for a limited license). The regulator will carefully assess your company’s financial health, compliance policies, and business model. If there are any issues, the Bank of Lithuania will issue comments and allow you to revise and resubmit your materials.
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Approval or rejectionIf approved, you’ll receive your license and can begin operations. If rejected, you’ll need to address the regulator’s concerns and reapply. Companies should be prepared for back-and-forth communication with the regulator during this process.
Who can apply for EMI license in Liuthania
To qualify for a full EMI license, your company must meet these basic criteria:
- Be registered as an AB (public limited company) or UAB (private limited company) in Lithuania
- Maintain a physical office in Lithuania
- Have a minimum share capital of €350,000
Appoint directors and managers who are experienced, qualified, and of good reputation
The Bank of Lithuania will conduct thorough background checks on your leadership team, which may include interviews and reviews of previous employment and legal history.
Other requirements include:
- A realistic and well-supported business plan
- A risk management system to monitor and mitigate financial, operational, and compliance risks
- Internal governance and control systems, including IT infrastructure, accounting processes, and data protection mechanisms
These measures ensure transparency, compliance, and customer protection.
Documents required to apply for EMI license in Liuthania
To apply for an EMI license in Lithuania, you’ll need to submit the following:
- Company Articles of Association
- Detailed business plan (including services and target markets)
- Proof of initial capital
- Client fund protection procedures
- Internal control and compliance policies
- Description of how sensitive payment data will be stored, monitored, and protected
- Other supporting documents as required
Every document must be carefully prepared to meet regulatory standards. Attention to detail is key.
How we can help
At Law&Trust, we specialize in helping financial companies obtain EMI licenses across Europe. Our lawyers guide you through the entire process—from preparing your documents to communicating with the regulator. With our expertise, you can avoid costly mistakes and significantly speed up the licensing timeline.