Authorised Electronic Money Institution (EMI) in Lithuania
Lithuania’s Authorised Electronic Money Institution (EMI) licence, issued by the Bank of Lithuania (Lietuvos Bankas), enables firms to issue electronic money, hold client funds, and provide a full range of payment services across the EEA via passporting. Direct access to CENTROlink — the Bank of Lithuania’s real-time SEPA Instant infrastructure — is a practical advantage that sets Lithuanian EMIs apart from most other EU payment jurisdictions.
Requirements for a full AEMI: €350,000 initial capital, UAB or AB legal form, at least one Lithuanian-resident board member, and a real compliance operation in-country. The Bank of Lithuania applies a statutory 3-month review once the file is complete. From 2026, the corporate income tax rate is 17%, with a reduced rate for smaller entities.
A restricted AEMI is also available — without initial capital requirements, but limited to Lithuania only, with no EEA passporting.
This page covers Lithuanian EMI entities currently available for transfer, with a full breakdown of both licence structures, capital thresholds, and what the acquisition process involves.
Our team handles both paths — ready-made EMI acquisition and new licence application — covering compliance staffing, Bank of Lithuania filings, and CENTROlink onboarding.
Our Available Lithuania EMI Licenses for Sale
Lithuanian EMI With CENTROlink, Four Safeguarding Banks and BaaS Platform for Sale #1
A licensed Lithuanian Electronic Money Institution incorporated in 2019, combining payment infrastructure, banking integrations, and local operational substance. The company offers a clean regulatory history, multiple safeguarding relationships, and Banking-as-a-Service capabilities for buyers seeking an established European payments platform.
• Licensed Lithuanian EMI incorporated in 2019
• Direct CENTROlink connectivity for SEPA payment access
• Four safeguarding banking partners established
• BaaS software infrastructure and existing banking integrations included
• Five employees currently in place, with local Lithuanian director available to remain
• Clean regulatory history with no fines, sanctions, or supervisory findings
• Dormant operational structure with minimal legacy activity
• Share capital of EUR 400,000 stated separately from the sale price
Full regulatory, technical, financial, and due diligence materials shared after NDA.
Lithuanian EMI With CENTROlink Connectivity and BaaS Infrastructure for Sale #2
A licensed Lithuanian Electronic Money Institution incorporated in 2019, offering established payment infrastructure, local substance, and a clean regulatory history. The company combines CENTROlink connectivity, safeguarding relationships, and Banking-as-a-Service capabilities within a dormant operational structure.
• Licensed Lithuanian EMI incorporated in 2019
• Direct CENTROlink connectivity in place
• Two safeguarding banking partners established
• BaaS software infrastructure included in the transaction
• Four employees currently engaged, with local Lithuanian director available to remain
• Clean regulatory history with no fines, sanctions, or supervisory remarks
• Dormant operational structure with no significant legacy activity
• Share capital of EUR 400,000 stated separately from the sale price
Full regulatory, technical, financial, and due diligence materials shared after NDA.
Lithuanian EMI With Direct CENTROlink Access, SWIFT Connectivity and EUR 700,000 Capital for Sale #3
A fully authorised Lithuanian Electronic Money Institution offering immediate access to the European payments market through EEA passporting, direct central bank connectivity, and established banking infrastructure. The institution combines a modern technology stack, local substance, and a clean regulatory history with significant regulatory capital already maintained on the balance sheet.
• Full EMI licence authorised by the Bank of Lithuania and passported across the EEA
• Direct CENTROlink participation with own EUR IBAN generation capabilities
• SWIFT connectivity through an established banking partner
• Core banking platform with internet banking, AML transaction monitoring, and risk management systems
• Approximately EUR 700,000 of regulatory capital and liquidity reserves included in the transaction
• Approved local management, board, MLRO, compliance, and audit functions available to support transition
Full regulatory, financial, technical, and due diligence materials shared after NDA.
Active Lithuanian EMI With 29-Country Passporting and CENTROlink Access for Sale #4
An active Lithuanian EMI with passporting across 29 countries and direct participation in CENTROlink. The company has operational and safeguarding banking relationships in Lithuania and Poland, a small existing money-remittance customer base, and a clean seller-disclosed regulatory history.
• Lithuanian EMI with passporting across 29 countries
• Permissions include money remittance, payment instrument issuance, acquiring, and currency exchange services
• Direct CENTROlink participation with SCT, SCT Inst, and SDD functionality
• Operational and safeguarding banking relationships in Lithuania and Poland
• Existing team includes director, CIO, and MLRO, with continuity potentially available
• Share capital stated at EUR 430,000, separate from the sale price
Full regulatory, financial, client, and due diligence materials shared after NDA.
Active Lithuanian EMI for Sale #5
EEA Passporting, Own Core Banking, Minimal Burn Rate
An active EEA-passported EMI with direct SEPA via CentroLink, a proprietary core banking system, and operational accounts with Wise and Paysera. SWIFT-registered but not transacting via SWIFT for two years. Small part-time team — transition may affect retention. Previous regulatory fine disclosed.
• Direct SEPA via CentroLink, safeguarding with Mano Bankas
• Own core banking: IBAN issuance, KYC, onboarding, SWIFT/SEPA via Inventi
• SWIFT member, Wise and Paysera operational accounts
• Share capital 400k EUR (not included in transaction)
Full financials and due diligence materials shared after NDA.
Active Small Electronic Money Institution in Lithuania for Sale #6
Main Details:
• Licensed Small Electronic Money Institution operating in Lithuania
• IBAN accounts limited to Lithuanian residents
• No EU passporting rights
Payments & Infrastructure:
• Connected to CENTROlink
• Preparing for direct SEPA participation
• Core banking software: Forbis (Lithuania)
Clients & Operations:
• Approximately 65 individual clients
• Around half of the clients are internal company employees
• Client funds safeguarded with two Lithuanian credit institutions
Regulatory & Corporate:
• Share capital of €350,000 (not included in the transaction)
• Previous regulatory fine disclosed
• Sale possible with or without existing clients
• Shareholders available to assist with upgrade to a full EMI licence if required
Additional Information:
• Financial information available upon request after NDA/KYC
Related EU e-money licences available for transfer
Key Takeaways for Authorised Electronic Money Institution (EMI) in Lithuania
- Scope and reach. A full EMI in Lithuania issues/redeems e-money and provides Law on Payments services, with EEA passporting after notification; the restricted EMI is LT-only with scale caps.
- Capital, levy, timeline. Full EMI needs €350,000 capital; the state levy is €1,463 (restricted €1,235) and the statutory review is up to 3 months from a complete file.
- Substance and safeguarding. Expect on-staff compliance and risk roles, documented safeguarding via segregated accounts or secure assets, plus periodic reporting and audits.
- Payments access realities. SEPA runs through CENTROlink, migrating to direct participation in 2026—budget IT work, treasury tooling, and onboarding effort.
- Regulatory horizon and taxes. EMT-linked flows may require payment services permission by 2 March 2026; model CIT 16% for 2025 and plan for 17% from 2026.
- Total cost picture. Beyond the levy, plan for translations and apostille, banking setup, safeguarding accounts, SEPA integration, annual audits, and ongoing compliance.
- How we help. Legasset can sell a ready-made EMI or obtain a new licence, covering entity setup, filings, policies, staffing, CENTROlink planning, and MiCA–payments alignment.
What You Need to Know About EMI in Lithuania
Table of Contents
A Lithuania EMI license lets you issue and redeem e-money and provide Law on Payments services (issuing/acquiring, transfers, remittance) under the Bank of Lithuania. Full EMIs can notify for EEA passporting after authorisation.
Core requirements: €350,000 initial capital, ongoing own funds ≥2% of average outstanding e-money, documented safeguarding, and fit-and-proper governance. A restricted-activity EMI has no initial-capital floor, operates in Lithuania only, and is capped at €900,000 average outstanding e-money and €3,000,000 monthly payment turnover.
Key timelines and fees: completeness check in 5 business days; statutory decision within 3 months from a complete file (2 months for restricted). Pay the state levy €1,463 (EMI) or €1,235 (restricted) to the STI before filing.
Why this matters now: MiCA is fully in effect; CASPs benefit from a transitional regime until 1 July 2026 EU-wide, while Lithuania set 31 December 2025 for local legacy providers. EMI status remains valuable for fiat on/off-ramp flows intersecting with crypto.
Regulator, legal bases, taxes, and what’s changing
Supervisor: the Bank of Lithuania (Supervision Service). Main acts: Law on Electronic Money Institutions and Law on Payments. Prudential guidance confirms €350,000 capital and the 2% own-funds floor for e-money issuance.
Process specifics that competitors often skip: BoL publishes the 5-day completeness check and the 3-month decision clock; both are paused if information is missing. Official fees are listed on the same page. For modelling, the current corporate income tax is 16%.
You can purchase a ready-made EMI in Lithuania for faster continuity or apply for a new EMI license in Lithuania. We support both—mapping activities, structuring governance and safeguarding, preparing filings, and guiding you through supervisory dialogue to go-live. Next, we’ll detail eligibility, capital, safeguarding, and documentation.
Eligibility Requirements for Obtaining Lithuanian EMI License
A Lithuania EMI license is granted to a Lithuanian legal entity. Most applicants form a UAB or AB and apply to the Bank of Lithuania. Full EMIs may passport across the EEA after notification, while restricted EMIs are LT-only.
Capital and ongoing financial requirements
The full EMI requires €350,000 initial capital. Ongoing own funds must be ≥2% of average outstanding e-money, with method-based calculation. Restricted EMIs have no initial-capital floor but are limited in scale and geography.
Local presence and compliance oversight
The supervisor expects real management, robust governance, and effective safeguarding at authorisation. 2025 updates to Resolution No. 247 tightened expectations on risk culture, internal control, and client-fund protection. Critical functions must be demonstrably under the institution’s control, with outsourcing of important tasks tightly managed.
Required documentation and submission process
Your file includes an application, programme of operations, business plan, governance and risk frameworks, AML/CTF policies, safeguarding methodology, and fit-and-proper evidence for shareholders and managers. The Rules also cover qualifying holdings and notifications. Documents may need translation into Lithuanian or English, and the Bank may require notarisation or apostille for foreign documents.
Approval timelines, official fees, and hidden costs
The Bank checks completeness within 5 business days. Decisions are taken within 3 months from a complete file, or 2 months for restricted EMIs; clocks pause if information is missing. Pay the state levy €1,463 for a full EMI or €1,235 for restricted, to the STI before filing. Budget for audit, reporting, safeguarding accounts, and payment-system onboarding.
Common challenges and how to overcome them
Expect detailed AML scrutiny, safeguarding evidence, and board effectiveness checks. Joining CENTROlink now involves additional readiness, periodic confirmations, and, if requested, an independent audit on payments-law compliance. Plan treasury, liquidity collateral, and documentation early to avoid delays.
This section explains who qualifies, what capital and substance you need, which documents to prepare, and how the approval works—so you can plan a realistic path to authorisation.
Pros & Cons of Acquiring an EMI License in Lithuania
+ EU-wide passporting. A full EMI authorised by the Bank of Lithuania can provide services across the EEA under the Law on Payments, eliminating the need for separate national licences.
+ Defined application timelines. The regulator checks completeness within 5 business days and must decide within 3 months of a complete submission, giving investors realistic planning certainty.
+ Entry flexibility through restricted EMI. Businesses can launch domestically without capital, testing operations in Lithuania before upgrading to the full EMI license Lithuania with €350,000 capital.
+ Transparent and low official costs. The state levy is fixed at €1,463 for a full EMI and €1,235 for restricted, payable to the STI before filing—there are no hidden regulator fees.
+ Direct SEPA access. Licensed EMIs can join CENTROlink, Lithuania’s SEPA gateway, now migrating to direct participation in 2026—reducing dependency on intermediary banks.
+ Stable tax base. The corporate income tax rate is 16% (rising to 17% from 2025), lower than most Western EU states and predictable for budgeting.
– High substance expectations. The Bank requires effective management, compliance, and safeguarding presence in Lithuania—outsourced-only models are rarely approved.
– Restricted EMI operational caps. Local-only scope with limits of €900,000 average e-money and €3,000,000 monthly payment turnover; exceeding these triggers conversion to a full EMI.
– Intensive governance obligations. Resolution No. 247 (2025) raised standards for internal control and client-fund protection, increasing compliance costs for small operators.
– CENTROlink migration complexity. The 2025 shift to direct participation adds new treasury, IT, and reporting duties; firms must upgrade systems to retain SEPA access.
– Crypto-linked activity overlap. With Lithuania’s MiCA transition ending on 31 Dec 2025, EMI–CASP combinations require parallel authorisations to remain compliant.
– Hidden operational costs. Beyond licensing, firms must maintain audited safeguarding accounts, annual reporting, and AML oversight—expenses often exceeding €50,000 yearly.
How to Get an AEMI Licence in Lithuania
You have two paths. Acquire a ready-made EMI (licensed UAB/AB with operations) or apply for a new EMI license in Lithuania from scratch. We manage both—entity registration, compliance structuring, capital planning, filings, regulator Q&A, SEPA access, and post-approval obligations. Steps below apply to both, with notes where they differ.
AEMI License Application Process in Lithuania
- Step 1: Scope the model and pick the route 1-2 weeks
Define services, geographies, and whether you need EEA passporting (full EMI) or LT-only launch (restricted EMI) under the Bank of Lithuania.
Key Documents: activity map, programme-of-operations outline, ownership chart.
Estimated Cost: advisory €3,000–€8,000.
Timeline: 1–2 weeks. - Step 2: Incorporate and set governance 1-2 weeks
Form a Lithuanian UAB/AB; prepare fit-and-proper evidence for management and key functions; align internal control and safeguarding per Resolution No. 247.
Key Documents: incorporation set, IDs/CVs, fit-and-proper forms.
Estimated Cost: company setup €1,000–€2,500; translations/notarisation extra.
Timeline: 1–2 weeks. - Step 3: Capitalise and design safeguarding 1-3 weeks
Deposit €350,000 initial capital (full EMI). Document safeguarding (segregated accounts/secure assets); maintain own funds ≥2% of average outstanding e-money. Restricted EMI has no initial-capital floor and is LT-only.
Key Documents: capital proof, safeguarding methodology, bank letters.
Estimated Cost: banking/legal €3,000–€10,000.
Timeline: 1–3 weeks (banking dependent). - Step 4: Build the application dossier 3-6 weeks
Draft the file: application, programme of operations, business plan, governance/risk, AML/CTF, IT/outsourcing, safeguarding, complaints/reporting. Foreign documents may need apostille/legalisation and translation.
Key Documents: complete EMI package; apostilled/legalised foreign docs.
Estimated Cost: drafting/translations €6,000–€20,000+.
Timeline: 3–6 weeks. - Step 5: Pay levy and submit 5 days
Pay €1,463 (EMI) or €1,235 (restricted) to the State Tax Inspectorate, then file. The regulator runs a 5-business-day completeness check.
Key Documents: levy proof, final forms.
Estimated Cost: official levy as above.
Timeline: same week for payment; 5 business days for completeness. - Step 6: Authorisation review and Q&A 2-3 months
Statutory decisions: up to 3 months from a complete file (up to 2 months for restricted). Information requests pause the clock—plan for iterative responses.
Key Documents: clarifications, revised policies, board confirmations.
Estimated Cost: advisory €3,000–€10,000.
Timeline: 2–3 months typical from completeness. - Step 7: SEPA access and operational readiness 4-8 weeks
Prepare CENTROlink direct participation—rules effective 9 Apr 2025, migration completion targeted 31 Dec 2025; align IT, treasury, and reporting. Consider later TARGET direct access for non-banks (from 6 Oct 2025).
Key Documents: technical readiness, participation agreements, liquidity tools.
Estimated Cost: integration/vendor €10,000–€40,000+.
Timeline: 4–8 weeks depending on vendors. - Step 8: Post-licensing compliance setup Ongoing
Activate reporting calendars, audits, safeguarding attestations, complaints handling. Map any crypto-adjacent flows to MiCA; where EMT/payment interplay applies, plan permissions accordingly.
Key Documents: reporting pack, audit engagement, AML monitoring, EMT/payments mapping.
Estimated Cost: ongoing €20,000–€60,000/yr (audit, reporting, controls).
Timeline: ongoing from go-live. - Step 9 (ready-made EMI only): Buy-side diligence and control change 4-8 weeks
Run legal, prudential, ICT, and operational diligence; notify/clear qualifying holding changes with the Bank of Lithuania before closing; align governance and safeguarding pre-handover.
Key Documents: SPA, qualifying-holding notification, updated policies.
Estimated Cost: legal/transaction €25,000–€70,000+.
Timeline: 4–8 weeks, deal-dependent.
General timeline and costs
- Allow 3–4 months from kick-off to decision in realistic cases (prep 4–8 weeks + statutory review up to 3 months; restricted up to 2). Official fees are limited to the state levy. Model documentation, translations/apostille, banking setup, CENTROlink migration, and annual audit/reporting. Lithuania’s CIT is 16% in 2025, rising to 17% in 2026—plan budgets accordingly.
Post-Licensing Compliance Obligations for an EMI in Lithuania
Licensing is the start. EMIs must maintain governance, safeguarding, reporting, and audit standards set by the Bank of Lithuania. Breaches can trigger restrictions or licence withdrawal under supervisory powers. If your flows touch crypto, MiCA influences controls and reporting.
Run continuous AML/KYC monitoring, file suspicious activity reports, and keep safeguarding in segregated accounts or secure assets. Governance and ICT controls must meet the Bank’s Description of Requirements and align with DORA obligations for resilience. Keep second-line functions effective and documented.
Expect periodic regulatory filings using the EMI forms (e.g., EM008 series for services, complaints, account closures, and safeguarding changes). Maintain an internal reporting calendar and submit annual financial statements on time.
There is no routine “renewal.” However, qualifying holding changes require prior notification and clearance before closing. Material changes to operations or outsourcing must be agreed with the supervisor.
If you handle electronic money tokens, note 2 March 2026: certain EMT transfers will also require payment services authorisation in addition to MiCA permissions. Plan early to avoid service pauses.
Keep tax and accounting current. Model Lithuania’s CIT 16% for 2025 and the legislated 17% rate from 2026 when forecasting buffers and dividends.
How Legasset helps: we implement reporting calendars, AML controls, and safeguarding attestations; prepare audit packs; manage qualifying-holding notifications; and map MiCA–PSD2 implications, including EMT/payment interplay and CENTROlink participation updates. Our goal is stable, inspection-ready operations after authorisation.
Common Pitfalls and Challenges of Operating Under an EMI in Lithuania
EMI license Lithuania offers EU credibility, but operations are demanding. Most issues arise from safeguarding, substance, and payments access. These risks are manageable with planning and documented controls.
- Banking and SEPA access. Some banks avoid crypto-adjacent models. Safeguarding account opening and CENTROlink onboarding can take longer than expected. Mitigation: prepare multiple banking options, agree monitoring rules up front, and stage liquidity tests before launch.
- Regulatory change and governance. The Bank of Lithuania regularly updates expectations on internal control, outsourcing, and ICT resilience. Weak minutes, unclear second-line reporting, or outdated policies prolong supervision. Mitigation: keep a living programme of operations, board calendars, and evidence of on-site decision-making.
- Market scope limits. A restricted-activity EMI is Lithuania-only and subject to quantitative caps. Passporting requires the full licence and prior notifications. Mitigation: map services and volumes early and plan the upgrade path before breaching thresholds.
- Cost of compliance. Annual audits, reporting packs, safeguarding attestations, and payments-infrastructure changes add recurring costs that new teams often underbudget. Mitigation: build a year-one compliance budget and assign owners for each obligation.
- Staffing and substance. Key control roles must be effective and typically employed by the entity. Purely outsourced models trigger delays. Mitigation: hire an on-staff compliance lead and define escalation lines.
- MiCA interplay. Crypto flows involving electronic money tokens may require additional payment-services permissions under EU timelines. Mitigation: run a permissions gap-analysis and phase any upgrades.
How we help. Legasset designs banking strategies, hardens safeguarding, sets reporting calendars, rehearses regulator Q&A, and roadmaps MiCA/SEPA changes—so you operate reliably, not just legally.
FAQ About Purchasing Lithuania EMI License
How long does an EMI license in Lithuania take from submission to decision?
A complete EMI license in Lithuania is typically decided within 3 months for a full EMI (and 2 months for restricted) after the Bank of Lithuania accepts the file as complete. The completeness check itself is 5 business days, and any regulator queries pause the clock.
What capital and official fees apply to an EMI license in Lithuania?
A full EMI license in Lithuania requires €350,000 initial capital and ongoing own funds of ≥2% of average outstanding e-money. The state levy is €1,463 for a full EMI and €1,235 for a restricted EMI, paid to the State Tax Inspectorate before filing.
What’s the difference between a restricted EMI and a full EMI in Lithuania?
A restricted EMI in Lithuania operates in Lithuania only and is subject to scale limits; it’s often used to launch locally before upgrading. A full EMI may passport across the EEA once notified to the supervisor, enabling cross-border services.
Will my Lithuanian EMI get SEPA access and what is changing in 2026?
Yes—Lithuanian EMIs access SEPA via CENTROlink. From 9 April 2025, the Bank of Lithuania started migrating participants to direct participation, replacing addressable-BIC arrangements; migration was targeted to complete by end-2025. Plan for IT, treasury, and reporting work during onboarding or migration.
Are there banking or crypto-related limitations with an EMI license in Lithuania?
Banks may be cautious with crypto-adjacent models; many operators keep multiple providers and robust AML/KYC to pass onboarding. If your flows involve electronic money tokens (EMTs) under MiCA, EU guidance requires payment-services authorisation for certain EMT transfers from 2 March 2026 (or partnering with a licensed PSP).
How can Legasset help with a ready-made EMI purchase—or applying for a new EMI under the Lithuanian regime (including MiCA alignment)?
We support both routes. For a ready-made EMI in Lithuania, we run buy-side due diligence and manage qualifying holding notifications before closing. For a new EMI license in Lithuania, we handle incorporation (UAB/AB), the programme of operations, AML/KYC, safeguarding, filing, and regulator Q&A. We also plan CENTROlink migration and map MiCA–PSD2 overlaps so EMT-related services remain compliant after 2 March 2026. Next step: outline your services and geography; we’ll propose the optimal path and timeline.
Additional Links and Resources for an Authorised Electronic Money Institution (EMI) in Lithuania
Official guide to how EMIs are authorised in Lithuania, including licensing steps, capital requirements, and regulatory expectations.
II. Law on Electronic Money and Electronic Money Institutions (Republic of Lithuania)
The full legal text (in Lithuanian) setting out who can hold an EMI licence, scope of activities, capital requirements and supervision.
III. Bank of Lithuania – FAQ on Client Fund Safeguarding
Explains specific safeguarding requirements for e-money and payment institutions in Lithuania – segregated accounts, insurance or guarantees.
IV. Directive 2009/110/EC on Electronic Money Institutions – EU Law
The EU directive that underpins national EMI laws (including Lithuania), useful for understanding cross-border and harmonised aspects.
V. EBA Register of Payment and Electronic Money Institutions
EU-level public register under the European Banking Authority, listing authorised EMIs across the EEA including Lithuanian ones – useful for transparency checks.
