Electronic money institution licence for non-limited activity (Lithuania)

At a glance

What it lets you do

• Issuing electronic money
• Issuing e-money tokens
• Cash placement on a payment account
• Cash withdrawal from a payment account
• Execution of payment transactions
• Execution of payment transactions covered by a credit line
• Issuing payment instruments and acquiring payment transactions
• Money remittance
• Payment initiation services
• Account information services

• Issuing electronic money. Issuing monetary value stored electronically against funds received, redeemable at par and accepted by third parties as payment.
• Issuing e-money tokens. Offering to the public, or seeking admission to trading of, a token that references the value of a single official currency.
• Cash placement on a payment account. Services enabling cash to be placed on a payment account, and the operations required to run that account.
• Cash withdrawal from a payment account. Services enabling cash to be withdrawn from a payment account, and the operations required to run that account.
• Execution of payment transactions. Executing direct debits, card payments and credit transfers, including standing orders, from a payment account.
• Execution of payment transactions covered by a credit line. Executing payment transactions where the funds are covered by a credit line granted to the user, within the limits PSD2 allows.
• Issuing payment instruments and acquiring payment transactions. Issuing cards or other payment instruments to payers, and acquiring card and other payment transactions for merchants.
• Money remittance. Receiving funds from a payer solely to transfer them to a payee or another provider, without opening payment accounts.
• Payment initiation services. Initiating a payment order at the user's request from an account held with another provider, as in open banking.
• Account information services. Providing consolidated online information on one or more payment accounts the user holds with other providers.

Where it is valid

Requirements

Minimum capital: 350000²

Ongoing own funds: Ongoing own funds must at all times equal or exceed the higher of initial capital (EUR 350,000) or regulatory capital calculated under Method D (at least 2% of average outstanding electronic money) plus PSD2 capital requirements (Method A, B, or C) for payment services unrelated to electronic money issuance.³

Who is assessed: The Bank of Lithuania assesses fitness and propriety of board members, executive heads (CEO), key function holders (Head of Compliance, MLRO/AML Officer, Head of Internal Audit), as well as direct and indirect qualifying shareholders holding 10% or more of capital or voting rights, and ultimate beneficial owners (UBOs) acting in concert.²

Substance and people

• The institution must maintain its registered office in Lithuania and actually conduct the business of electronic money issuance within Lithuania.²
• A full EMI must establish a three-tier governance framework comprising a general meeting of shareholders, a board (collegial body), and a single-person head (CEO).²
• Board members, executive managers, and key function holders (Compliance Officer, AML/CFT Officer / MLRO) must demonstrate good repute, appropriate qualifications, and professional experience, subject to prior regulatory non-objection (30 working days review).²
• Customer funds received for e-money issuance must be segregated from corporate funds no later than by the end of the next business day and held in designated safeguarding accounts at a central bank (Bank of Lithuania or Eurosystem central bank) or an authorized EU credit institution, or covered by an insurance guarantee.²
• Institutions must implement comprehensive operational risk management, ICT business continuity, and incident reporting arrangements compliant with the Digital Operational Resilience Act (Regulation (EU) 2022/2554), including controls on critical outsourcing.²
• Annual financial statements must undergo statutory audit by an independent certified auditor, including specific reporting verifying separate accounting and internal control mechanisms for safeguarding client funds.²

Conditions to keep the licence

• The institution must commence licensed electronic money issuance activities within 12 months of licence grant; failure to do so provides statutory grounds for licence revocation.⁵
• If an electronic money institution ceases its licensed activities for more than 6 consecutive months, the Bank of Lithuania may initiate formal withdrawal of the licence.⁵
• Funds received from electronic money holders must be strictly segregated from corporate funds, deposited in designated safeguarding accounts at a central bank or qualifying credit institution, and are legally immune from claims by the institution's creditors in insolvency.²
• Electronic money institutions are strictly prohibited from granting interest, returns, or any monetary benefit linked to the duration or amount of funds held by e-money holders.²
• EMIs must submit periodic financial statements, own funds and capital adequacy calculations, safeguarding audit reports, and operational risk metrics to the Bank of Lithuania.²

Cost

How long it takes

Statutory: 3 months from receipt of a complete application². Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.

Buying a company that already holds it

The licence cannot be assigned or transferred to another legal entity. Under the Law on Electronic Money, the licence belongs exclusively to the corporate entity to which it was issued. Licence transfers can only occur through a corporate acquisition (share deal) where the entity changes ownership following Bank of Lithuania qualifying holding assessment. An asset sale or business transfer requires the acquiring entity to apply for its own separate EMI licence.²

Prior notification with an objection period. Acquiring or increasing a direct or indirect qualifying holding reaching or crossing 10%, 20%, 30%, or 50% of capital or voting rights, or becoming a controlling parent of an EMI, requires prior written notification to the Bank of Lithuania. The regulator assesses acquirer reputation, financial soundness, executive fitness, and AML/CFT risk within a statutory assessment period of 60 working days (interruptible once by up to 20 working days for supplementary information, or 30 working days for non-EU acquirers) under Law on Banks Arts 24-25 (applied via EMI Law Art. 17). Failure to notify or proceeding over objection divests all voting rights.⁶

Ready-made companies holding this licence: see verified positions.

Laws behind it

• Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions: Directive 2009/110/EC
• Directive (EU) 2015/2366 on payment services in the internal market: Directive (EU) 2015/2366
• Digital Operational Resilience Act: Regulation (EU) 2022/2554
• Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114