EMI license in Lithuania

According to The Fintech Landscape in Lithuania 2022-2023, by the end of 2022, there were 263 fintech companies operating in Lithuania. These figures make Lithuania the largest European hub in terms of issued licenses. Entrepreneurs choose Lithuania for registering startups due to the highly conducive conditions created here for foreign investors and the development of businesses in the electronic financial services field. The process of obtaining an EMI [Electronic Money Institution] license involves only a few key stages without complex bureaucracy.

EMI License Lithuania — Prospects for Fintech Business

In Lithuania, several types of licenses can be obtained [EMI, PI, and their small variants, Account Information Services]. Among these permissions, specifically, the EMI license allows fintech startups to provide the widest range of services:

• electronic money issuance;
• funds transfer and placement into user accounts;
• card payment operations, including using credit funds;
• cash withdrawals;
• foreign currency exchange;
• payment system management.

The Lithuanian regulator, the Central Bank, issues the EMI license on an indefinite basis. Among the advantages of this jurisdiction is that the licensee has the right to provide payment services throughout the states within the European Economic Area. Broadening the geographical scope of activities is enabled by the passporting procedure. To achieve this, the Lithuanian electronic money institution simply needs to notify regulators in other countries without additional licensing procedures.

Procedure for Obtaining EMI Lithuania — Requirements and Documentation Package

In contrast to other European jurisdictions, obtaining a Lithuania EMI license involves fewer bureaucratic procedures. However, to successfully launch, certain requirements must be met:

• open a bank account;
• contribute the share capital [the minimum payment is €350,000];
• develop AML and KYC policies, as well as operational, business, and financial plans with forecasts for the first three financial years;
• prepare IT documentation detailing the technical solution;
• describe internal control mechanisms;
• outline the organizational structure. The company should have a head, a general assembly of shareholders, and a board. Usually, a board of directors is established, with the position of CEO as its head. The regulator does not require the creation of a supervisory board;
• provide information about employees involved in anti-money laundering and information security. They must possess relevant experience and qualifications;
• in the questionnaires of company owners and key management, include information confirming their reputation, relevant work experience, and higher education in economics, law, management, or business administration;
• confirm the legitimate source of finances and others. 

The final stage is obtaining the license.

Since 2013, SBSB experts have been assisting in the successful licensing process and launching fintech projects in Lithuania. We offer each client an individual approach based on the company’s business model.

Timeline for Obtaining EMI Licence Lithuania

The Central Bank is responsible for issuing the Electronic Money Institution Lithuania. On average, the regulator reviews the submitted documents for obtaining the license within three months from the submission date. However, the review period may change if additional information is required or if discrepancies with the specified requirements are identified.

For more detailed information about Lithuanian jurisdiction and the Lithuania Electronic Money Institution, SBSB lawyers will consult you on the licensing procedure. Our experts provide clients with comprehensive turnkey legal support for a successful project launch: we analyze the risks of the business model, help register the office, develop a business plan, choose the optimal company structure, and prepare the documentation package.