Where to Launch a FinTech Startup: Comparing Lithuania, France, and Malta

1. The same EU framework, different supervisory experience

Payment and e-money activities are shaped by EU legislation, including PSD2 and the E-Money Directive, but applications are assessed by national competent authorities. The regulator will still examine the proposed entity's governance, local management, risk controls, outsourcing, capital, safeguarding and financial projections in the context of its jurisdiction.

Founders should therefore separate three questions: what permission is required, where the company should be authorised, and where the business will genuinely operate. A passport can support cross-border expansion after authorisation; it does not remove the need for a credible home-state operating base.

Important: This is a strategic comparison, not a regulator ranking. Capital is not a budget: legal, staffing, technology, audit, safeguarding, insurance, reporting and local operations may be substantially higher than the statutory minimum.

2. Capital requirements: minimum is not the same as adequate

Under the EU framework, the starting capital reference depends on the services. PI applicants commonly encounter €20,000, €50,000 or €125,000 thresholds, while an EMI generally has a €350,000 initial-capital requirement. The business must also demonstrate ongoing own funds, liquidity and a financial plan that can cover fixed overheads and stress scenarios.

The final financial model should add salaries, rent, professional advisers, technology, safeguarding, audit, insurance, compliance monitoring, customer support and a realistic time-to-revenue. An applicant that presents only the statutory minimum may signal that it has not understood the cost of operating under supervision.

3. How the three regulators may feel to a startup team

4. A practical decision matrix

1. Choose the customer market: identify where customers, merchants, investors and banking partners will actually be located.
2. Choose the service: decide whether the model needs PI, EMI, agent, distributor, account-information or another permission.
3. Test substance: name the directors, MLRO, compliance lead, risk owner, technology owner and customer-support team for each country.
4. Price the full runway: model at least the pre-revenue period, capital, fixed costs, outsourcing, audit, insurance and regulatory change budget.
5. Challenge banking: ask whether the expected customer geographies, merchants, crypto exposure, chargebacks and transaction volumes are acceptable to the target partners.

5. Banking, AML and local talent can decide the outcome

A jurisdiction can look attractive on paper but become expensive if the business cannot recruit a capable MLRO, obtain a bank account, secure safeguarding partners or explain its customer-risk profile. Founders should review banking and payment setup together with the AML/KYC framework, not after authorisation.

For a French project, language and market familiarity may be important. For Lithuania or Malta, the ability to maintain experienced local decision-makers and compliance resources is equally important. The regulator's attitude toward startups is best understood as proportionate supervision: authorities may support innovation, but they cannot approve an under-resourced control environment simply because the product is new.

Conclusion: choose the base you can defend for five years

Lithuania, France and Malta each offer a credible route for the right FinTech business. The best choice is the one that matches the customer market, capital, founders, local management, AML risk, technology and banking plan. Incorporation speed should be a secondary metric.

Licensium can prepare a jurisdiction comparison, assess EMI and PI licensing scope, build the evidence plan and coordinate a confidential market-entry review.