EU Payments Gateway · Bank of Lithuania Regulated

EMI License in Lithuania: Bank of Lithuania E-Money Institution Licensing & EU Passporting

Issue e-money, open IBAN payment accounts and move funds across the SEPA network under a single Bank of Lithuania authorization that passports to all 30 EEA member states. Licensium manages your entire journey — corporate structuring, the EMI license application, AML/CFT compliance and CENTROlink connectivity — as one fixed-fee, fully managed engagement.

Get Your Quote View Requirements
€350,000+ Minimum own funds requirement
6–9 months Average authorization timeline
Bank of Lithuania Single EMI & payments regulator
30 EEA states Passported market access
CENTROlink Direct SEPA settlement access

Regulatory briefing

A Full E-Money Institution License With a Direct Line Into SEPA

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An Electronic Money Institution (EMI) license authorizes a company to issue electronic money, hold customer funds in safeguarded payment accounts, issue IBANs, and provide the full suite of payment services — transfers, direct debits, card issuing and acquiring — without needing a full banking license. In Lithuania, EMIs are licensed and supervised by the Bank of Lithuania under the Law on Electronic Money and Electronic Money Institutions, which transposes the EU's Second Electronic Money Directive (2009/110/EC), alongside the Law on Payments transposing the revised Payment Services Directive (PSD2, 2015/2366).

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What sets Lithuania apart from other EU e-money hubs is CENTROlink — the Bank of Lithuania's own payment system, which gives licensed EMIs and Payment Institutions direct access to SEPA credit transfers and SEPA instant payments without needing a correspondent bank as an intermediary. Very few central banks in the EU offer non-bank fintechs this kind of direct settlement infrastructure, and it materially reduces both the cost and the counterparty risk of running a payments business.

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Once granted, a Lithuanian EMI license passports under the EU's single market rules to all 30 EEA member states through a simple notification procedure, giving a single authorization genuine pan-European reach. The Bank of Lithuania has built a reputation over the past decade as one of the EU's most structured, English-friendly and fintech-literate regulators, running a dedicated Fintech Division and a supervised sandbox (the Newcomer Programme) specifically to help first-time applicants navigate the process.

Services Covered by a Lithuanian EMI License

  • Issuing electronic money and maintaining e-money accounts for customers
  • Opening multi-currency IBAN payment accounts for individuals and businesses
  • Executing SEPA credit transfers and SEPA instant payments via CENTROlink
  • Issuing and acquiring debit/credit card payments
  • Cross-border money remittance and FX conversion services
  • Direct debits and standing order payment execution
  • Distribution through agents and outsourced payment initiation partners

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Jurisdiction Advantage

Why Lithuania Is the EU's Leading EMI Licensing Hub

Lithuania built its reputation as an EU fintech hub deliberately, over roughly a decade of licensing reforms and dedicated regulatory infrastructure. Licensium structures your Lithuanian EMI to capture every one of these fundamentals:

Direct SEPA Access via CENTROlink

Licensed EMIs can connect directly to CENTROlink, the Bank of Lithuania's own payment system, settling SEPA transfers without relying on a correspondent bank — a rare structural advantage among EU regulators.

Full EU/EEA Passporting

A single Bank of Lithuania authorization passports under EU law to all 30 EEA member states through simple notification, giving genuine single-market reach from one license.

A Dedicated, Fintech-Literate Regulator

The Bank of Lithuania runs a specialist Fintech Division and a structured Newcomer Programme sandbox purpose-built to guide first-time EMI applicants through documentation and interviews.

English-Friendly Process

Application forms, regulatory guidance and day-to-day correspondence with the Bank of Lithuania are readily available and conducted in English, materially easing the process for international founders.

A Flat, Competitive Corporate Tax Rate

Lithuanian companies are taxed at a flat 15% corporate income tax rate, with a reduced 5% rate available for qualifying small companies — among the more competitive standard rates in the EU.

A Deep, Experienced Fintech Services Ecosystem

A decade of licensing EMIs and Payment Institutions has built a mature bench of local law firms, MLROs, IT auditors and safeguarding banks that already know how to work with payments clients.

Regulatory Checklist

Expert Structuring: We Build a Compliant Lithuanian EMI File From Day One

Because an EMI license hinges on demonstrable own funds, robust governance and a credible AML/CFT program, Licensium designs, drafts and stress-tests your entire corporate and compliance structure before we ever file with the Bank of Lithuania:

Corporate & Governance Setup

  • Incorporation of a Lithuanian UAB (private limited company) with Articles of Association drafted for EMI licensing
  • Appointment of at least one Lithuania/EEA-resident manager and a designated Money Laundering Reporting Officer (MLRO)
  • Fit-and-proper documentation for all shareholders, directors and key function holders
  • Beneficial ownership disclosure filed with the Lithuanian Centre of Registers

Own Funds & Safeguarding

  • Demonstration of the €350,000 minimum initial own funds required for a full EMI license
  • Design of a compliant safeguarding structure — segregated client-fund accounts or an insurance/guarantee arrangement — keeping customer balances legally separate from operating capital
  • Capital adequacy calculation methodology aligned with Bank of Lithuania requirements
  • Business plan and three-year financial projections supporting the license application

Bank of Lithuania Licensing Application

  • Preparation and submission of the full EMI license application under the Law on Electronic Money and Electronic Money Institutions
  • IT systems and security policy documentation, including outsourcing and business continuity plans
  • Ongoing correspondence management through the Bank of Lithuania's review and clarification rounds to license grant
  • Coordination with the Newcomer Programme sandbox track where applicable

AML/CFT Compliance Program

  • Custom AML/CFT policy manual aligned with Lithuanian AML law and FATF standards
  • Business-wide and customer risk assessments tailored to your payment product and customer base
  • KYC/KYB onboarding workflows, transaction monitoring rules and suspicious activity reporting procedures
  • Staff training program and independent AML audit scheduling

CENTROlink & Payment Infrastructure Onboarding

  • Technical and legal coordination to connect your licensed entity to CENTROlink for direct SEPA settlement
  • Selection and onboarding of a safeguarding bank for client-fund segregation
  • Card scheme and processor introductions for card-issuing or acquiring use cases
  • Ongoing regulatory reporting, annual license renewal and Bank of Lithuania policy-update monitoring

Step-by-Step

Our Proven Turnkey Methodology: From Onboarding to Active License

We run a fully managed process end to end, so your team stays focused on the product while we carry every administrative and regulatory step through to completion:

Feasibility & Structuring

1–2 weeks

We assess your payment product against EMI vs. smaller PI licensing thresholds and design a lean corporate and compliance structure suited to the Bank of Lithuania's expectations.

Turnkey Local Incorporation

2–3 weeks

We register your Lithuanian UAB, appoint a resident manager and MLRO, and complete beneficial-ownership filings with the Centre of Registers.

Own Funds & AML Dossier Preparation

4–6 weeks

Our compliance team drafts your AML/CFT policy manual, safeguarding structure and business plan tailored to Bank of Lithuania EMI requirements.

Bank of Lithuania License Filing

4–5 months

We submit your complete license application and manage every round of Bank of Lithuania correspondence, interviews and clarification requests through to grant.

CENTROlink & Safeguarding Onboarding

4–6 weeks

We coordinate your direct CENTROlink connection for SEPA settlement and onboard a compliant safeguarding bank for client-fund segregation.

Launch & Ongoing Compliance

Ongoing

We manage your EEA passporting notifications, annual filings and AML/CFT reviews, and monitor Bank of Lithuania policy developments on your behalf.

Budgeting

Transparent Pricing: Turnkey Licensing with Zero Surprises

We work on a fixed, milestone-based professional fee model so you can budget your Lithuanian EMI setup with total confidence. Below is a realistic breakdown of the costs involved, in EUR thousands:

Each slice represents the average estimated budget allocation (€ thousands) with full range detail on hover/tap.

Budget ItemEst. Range (EUR)Frequency
Bank of Lithuania application & regulatory fees
One-off — official EMI license application and processing fees
 €6k – €12k One-off
Legal & turnkey preparation fees
One-off professional fees — structuring, corporate setup, document drafting and filing
 €20k – €38k One-off
Minimum own funds (held as capital, not a fee)
Regulatory capital requirement — remains a company asset, not a spent cost
 €350k – €350k One-off
Registered office, resident manager & MLRO
Annual — physical registered office, resident manager and Money Laundering Reporting Officer
 €18k – €32k Annual
Annual supervisory fee
Annual — ongoing Bank of Lithuania supervisory fee
 €8k – €16k Annual
AML/KYC & transaction-monitoring software
Annual — KYC/KYB onboarding and transaction-monitoring integration
 €12k – €24k Annual
Ongoing legal & regulatory retainer
Annual — ongoing reporting, license renewal and regulatory-update management
 €14k – €24k Annual

Swipe sideways on mobile to see the full breakdown.

All figures are indicative estimates for typical 2026 EMI setups and vary by payment product, service scope and the Bank of Lithuania's current fee schedule. The €350,000 own-funds requirement remains company capital and is not a fee paid to any third party. Contact Licensium for a precise, fixed-fee quote tailored to your project.

Benchmarking

Why Lithuania Competes With Europe's Leading EMI Jurisdictions

Founders comparing Lithuania usually shortlist it against other established EU and UK e-money hubs. Here is how Lithuania stacks up against the jurisdictions our clients compare it with most:

JurisdictionRegulatorMin. Own FundsAvg. TimelineEU/EEA PassportingEst. Total Setup Cost
Lithuania flag Lithuania Bank of Lithuania €350,000+ 6–9 months Full passporting + direct CENTROlink SEPA access €70k–120k
Malta flag Malta Malta Financial Services Authority (MFSA) €350,000+ 9–12 months Full EU/EEA passporting €110k–180k
Cyprus flag Cyprus Central Bank of Cyprus €350,000+ 8–10 months Full EU/EEA passporting €90k–140k
United Kingdom flag United Kingdom Financial Conduct Authority (FCA) £350,000+ 6–9 months No EU passporting post-Brexit £80k–130k
Estonia flag Estonia Finantsinspektsioon €350,000+ 7–10 months Full passporting (tightened supervision) €65k–110k

Swipe the table sideways to see every column. Regulator names link to the official authority website.

Figures vary with each regulator's current fee schedule, chosen payment products and the complexity of the applicant's ownership structure.

Average months from application submission to authorisation

Estimated total first-year setup cost, in thousands of euros

Lithuania's core advantage is structural: direct CENTROlink access to SEPA settlement is not replicated by any of its closest EU peers, removing a layer of correspondent-banking cost and counterparty risk that EMIs elsewhere must absorb.

Malta and Cyprus offer comparable EU passporting and a similarly reputable "onshore" profile, but both typically run longer review timelines and higher setup costs than Lithuania for an equivalent EMI scope.

The United Kingdom remains attractive for founders targeting the UK domestic market specifically, but an FCA e-money license no longer passports into the EU/EEA post-Brexit, making it a fundamentally different strategic choice rather than a direct substitute.

Estonia pioneered the EU fintech-licensing wave but has tightened supervision materially since a wave of license revocations in recent years, giving Lithuania a comparative credibility edge with banking partners today.

Common Questions

Frequently Asked Questions

Direct, business-focused answers to the regulatory questions we handle for digital asset founders every day.

What is the difference between an EMI and a Payment Institution license in Lithuania?
An EMI license permits issuing electronic money and holding e-money balances for customers in addition to the full range of payment services. A Payment Institution (PI) license covers payment services only — such as transfers and payment initiation — without the right to issue e-money, and carries a lower minimum capital requirement (from €20,000 to €125,000 depending on services, versus €350,000 for a full EMI).
Does a Lithuanian EMI license really passport to the whole EU/EEA?
Yes. Under EU law, once the Bank of Lithuania grants your EMI license, you can passport into any other EEA member state through a straightforward notification procedure, without needing a separate license in each country.
What is CENTROlink and why does it matter?
CENTROlink is the Bank of Lithuania's own payment settlement system. It gives licensed EMIs and Payment Institutions a direct connection to SEPA credit transfers and SEPA instant payments, removing the need for a correspondent bank intermediary for basic SEPA settlement — a structural advantage very few EU central banks offer non-bank fintechs.
How long does it take to secure an EMI license with Licensium?
Most clients complete incorporation, own-funds/AML dossier preparation and Bank of Lithuania license grant within 6 to 9 months. Company incorporation alone typically takes 2 to 3 weeks.
Is the €350,000 own funds requirement a fee?
No. It is regulatory capital that must be demonstrably available and remains an asset of your company — it is not paid to the Bank of Lithuania or to Licensium. It must simply be maintained at or above the required level on an ongoing basis once licensed.
Do I need a Lithuania-resident director?
The Bank of Lithuania requires at least one manager resident in Lithuania or another EEA state with real operational authority, plus a suitably qualified Money Laundering Reporting Officer. We provide and manage compliant local substance as part of your setup.
What ongoing obligations apply once I am licensed?
Licensed EMIs must maintain their own funds above the regulatory minimum, run an active AML/CFT program, file periodic regulatory returns, undergo independent AML audits, and renew EEA passporting notifications as needed. We manage your compliance calendar so no filing or renewal deadline is missed.

Authoritative Sources & References

This guide is provided for general informational purposes and does not constitute legal advice. Regulations evolve — always confirm current requirements with Licensium or the relevant national regulator directly.

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