COREDO > Financial Licence in Lithuania

Financial Licence in Lithuania

Lithuania holds a leading position among fintech jurisdictions in the European Union. Vilnius is the largest fintech hub in the EU by the number of licences issued — over 280 fintech companies are registered here, serving more than 30 million clients across Europe. The Bank of Lithuania (Lietuvos Bankas) consistently develops a transparent and supportive regulatory environment, making the country attractive to companies seeking to enter the EU payments and electronic money market.

COREDO has been operating in the legal and consulting services market since 2016 and provides full support for obtaining financial licences in Lithuania — from preliminary analysis to successful licensing with Lietuvos Bankas.

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Cost of the service
from 60 000 EUR

Regulatory Framework for Financial Licensing in Lithuania

Financial regulation in Lithuania is based on European directives transposed into national legislation. The key regulator is the Bank of Lithuania (Lietuvos Bankas), which issues licences, carries out prudential supervision and monitors compliance with regulatory requirements by all financial institutions in the country.

The main legislative acts forming the regulatory environment are as follows.

The Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania establishes the standards for issuing and circulating electronic money in accordance with the EMD2 Directive (2009/110/EC).
The Law on Payment Institutions regulates the provision of payment services under PSD2 (Directive 2015/2366).
The Law on Financial Institutions sets out the general rules for the activities of financial companies, including governance, financial reporting and capital requirements.
The Law on Markets in Financial Instruments implements the provisions of MiFID II (Directive 2014/65/EU) and regulates investment activities and brokerage services.
The Law on Banks transposes the CRD IV norms (Directive 2013/36/EU) for the banking sector.

In addition, the Law on the Prevention of Money Laundering and Terrorist Financing implements the requirements of AMLD5 and AMLD6, obliging financial institutions to conduct customer due diligence (CDD), transaction monitoring and reporting to the Financial Crime Investigation Service (FNTT).

Types of Financial Licences in Lithuania

The Bank of Lithuania issues several categories of licences allowing various types of financial activities:

Licence type	Description	Min. capital	Review period
EMI (Electronic Money Institution)	Issuance of electronic money, provision of payment services	EUR 350,000	3 months
Limited activity EMI	Issuance of electronic money within Lithuania only	Not established	2 months
PI (Payment Institution)	Payment services: transfers, acquiring, payment initiation	EUR 20,000 — EUR 125,000	3 months
Limited activity PI	Payment services within Lithuania only	Not established	2 months
Financial brokerage firm	Investment services, securities trading	EUR 750,000	up to 6 months
Financial advisory firm	Investment advice on securities	EUR 50,000	up to 6 months
Bank	Full range of banking services	EUR 5,000,000	up to 12 months

Capital requirements for PI vary depending on the type of activity: EUR 20,000 — for money remittance services (PSD2, Art. 7(a)), EUR 50,000 — for payment initiation services (PSD2, Art. 7(b)), EUR 125,000 — for the full range of payment services (PSD2, Art. 7(c)). For EMI, a single threshold of EUR 350,000 is established (EMD2, Art. 4).

Advantages of the Lithuanian Jurisdiction

Lithuania offers a number of significant advantages for fintech companies and financial service providers.

Streamlined licensing procedure

the Bank of Lithuania commits to reviewing EMI and PI licence applications within 3 months, which is two to four times faster than in most other EU jurisdictions.

Access to the CENTROlink payment system

provides direct connection to SEPA and TARGET2 without reliance on commercial banks. Direct settlements through a central bank account reduce payment processing times and optimise operational costs, eliminating the need to pay banking fees.

Licence passporting

allows companies with a full EMI or PI licence to provide services throughout the entire European Economic Area (EEA) without obtaining separate licences in each country. The passporting procedure is governed by Art. 28 of PSD2 for payment institutions and Art. 3 of EMD2 in conjunction with Art. 28 of PSD2 for electronic money institutions.

The Newcomer Programme

developed by the Bank of Lithuania provides startups with simplified market entry through limited activity licences (sandbox approach), with subsequent transition to a full licence.

A well-developed fintech ecosystem

over 280 licensed fintech companies in Vilnius create a favourable environment for knowledge sharing and professional development.

Competitive cost of doing business

office rental, staff costs and operational expenses in Lithuania are significantly lower than in Western European jurisdictions.

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General Requirements for Obtaining a Financial Licence

To obtain a financial licence in Lithuania, the applicant must comply with a number of regulatory requirements established by the Bank of Lithuania.

Capital requirements

are determined by the type of licence sought. The minimum share capital must be fully paid up at the time of filing the application. For limited activity licences, no minimum capital requirements are set; however, the Bank of Lithuania assesses the adequacy of the company’s own funds for its risk profile and planned activities.

Management requirements

stipulate the presence of qualified individuals with experience in management and work in financial markets. The head of the company must be a resident of Lithuania (there are no length-of-service restrictions). Board members and key employees undergo a fit and proper assessment to confirm their qualifications and business reputation.

The AML/CFT system

must include policies and procedures for customer identification (KYC), transaction monitoring and reporting of suspicious operations. Appointment of a Money Laundering Reporting Officer (MLRO) is mandatory. Supervision is carried out by two bodies: the Bank of Lithuania and the Financial Crime Investigation Service (FNTT).

Technical and organisational prerequisites

include the availability of IT infrastructure, data security systems, operational procedures and a business continuity plan (BCP). The company must have a registered physical office on the territory of the Republic of Lithuania.

Cost of COREDO Services

COREDO provides a full cycle of services for obtaining a financial licence in Lithuania:

Service	Cost
PI/EMI licence acquisition	from EUR 60,000 + VAT
Forex broker licence	from EUR 60,000 + VAT

The cost includes legal analysis, preparation of the document package, business plan, internal AML/CFT policies, support with communication with the Bank of Lithuania and consultations at all stages of the process. The final cost is determined individually, taking into account the specifics of the client’s business model, the type of licence and the scope of services required.

Regulatory capital requirements (minimum share capital of EUR 350,000 for EMI, EUR 20,000 to EUR 125,000 for PI) are paid by the applicant separately and are not included in the cost of COREDO services.

Payment Terms

Payment for COREDO services is made in stages according to a 40-40-20 scheme:

The first payment

40% of the cost is made upon signing the service agreement. This stage covers the preliminary analysis of the business model, preparation of the licensing strategy and the commencement of work on the documents.

The second payment

40% is made after the preparation of the main document package and its submission for preliminary review by the regulator. At this stage, the business plan, AML/CFT policies and organisational documentation are finalised.

The final payment

20% is made after the application is filed with the Bank of Lithuania and the official review process commences.

List of Documents for Obtaining a Licence

To file an application for a financial licence in Lithuania, the following document package must be prepared:

Application in the prescribed form (Annex 1 or 2 to the Rules for Licensing Electronic Money Institutions and Payment Institutions).

A business plan, including a financial plan for 3 years for full-activity EMI and PI (1 year for limited activity licences).

Documents on the founders and shareholders of the company, including information on the ownership structure and ultimate beneficial owners.

Information on board members and key managers with confirmation of qualifications and business reputation.

A description of the organisational structure indicating the delineation of functions, vertical and horizontal boundaries of responsibility.

AML/CFT policies and procedures, including the procedures for customer identification, transaction monitoring and reporting.

A description of the risk management system, internal controls and accounting.

A description of the IT infrastructure and software.

A data security and personal data protection policy.

An audit report (if the company is already operating).

Documents confirming the availability of a physical office in Lithuania.

Confirmation of payment of the share capital.

A business continuity plan (BCP).

Professional liability insurance (if required, depending on the type of licence).

All documents are submitted in Lithuanian or English. Originals or notarised copies.

Procedure for Obtaining a Financial Licence in Lithuania

The licensing process consists of several sequential stages:

Preliminary consultation and analysis.

COREDO conducts a detailed analysis of the client’s business model, determines the optimal licence type and develops an application strategy. The Bank of Lithuania also offers a pre-application stage, during which the applicant can discuss the project details with the regulator’s specialists. Duration: 2–4 weeks.

01

Document preparation.

COREDO develops the full document package, including the business plan, AML/CFT policies, organisational documentation and IT system descriptions. Duration: 4–8 weeks.

02

Filing the application.

The document package is submitted to the Bank of Lithuania. The regulator checks the completeness of the application within 5 business days and notifies the applicant that the review has commenced.

03

Review of the application.

The Bank of Lithuania assesses the documents, business model, management qualifications and risk management system. During the review, additional requests and clarifications may be made. The formal review period is 3 months for a full EMI and PI licence, 2 months for limited activity licences.

04

Receiving the licence and launching operations.

After a positive decision, the company receives the licence and can commence operational activities. If necessary, COREDO assists with the licence passporting procedure for operating in other EEA countries.

05

The total period from the start of preparation to receiving the licence is 3 to 9 months, depending on the type of licence and the client’s readiness.

Our Experts

The process of obtaining a financial licence in Lithuania is supported by qualified COREDO specialists:

Pavel Kos

Head of Legal. Has been working at COREDO since June 2017 and has headed the legal team since July 2020. Specialises in financial licensing, corporate law and regulatory procedure support across EU jurisdictions.

Basang Ungunov

Lawyer. A specialist with a Master of Laws (LLM) qualification, has been working at COREDO since June 2022. Provides legal support at the stages of document preparation and interaction with the regulator.

Frequently Asked Questions

Which regulator issues financial licences in Lithuania?

Financial licences in Lithuania are issued by the Bank of Lithuania (Lietuvos Bankas). This is the central bank and the main supervisory authority that carries out the licensing and supervision of banks, electronic money institutions, payment institutions and other financial institutions in the country.

How long does it take to obtain an EMI licence in Lithuania?

The formal review period for an EMI licence application is 3 months from the date of filing the complete document package with the Bank of Lithuania. Taking into account the preliminary document preparation, the total project duration is 3 to 9 months.

Can a Lithuanian licence be used to operate in other EU countries?

Yes, a company with a full EMI or PI licence in Lithuania can provide services throughout the entire European Economic Area through the passporting procedure. This procedure is provided for by PSD2 (Art. 28) and EMD2 (Art. 3) and requires notification to the Bank of Lithuania, which forwards the information to the regulator of the host country. Limited activity licences are valid only within Lithuania.

Is it mandatory to have an office in Lithuania?

Yes, to obtain a financial licence in Lithuania, a registered physical office on the territory of the Republic of Lithuania is required. Subsidiaries and branches are not subject to this requirement.

What is the minimum capital required for a PI licence?

The minimum share capital for a PI licence depends on the type of activity: EUR 20,000 — for money remittance services, EUR 50,000 — for payment initiation services, EUR 125,000 — for the full range of payment services. For a limited activity PI licence, no minimum capital requirements are set.

What is CENTROlink and why is it needed?

CENTROlink is a payment system operated by the Bank of Lithuania that provides direct access to SEPA and TARGET2 for non-bank financial institutions. Connecting to CENTROlink allows settlements to be made through a central bank account without reliance on commercial banks, reducing payment processing times and lowering operational costs.

What AML/CFT requirements apply to licensed companies?

All licensed financial institutions are required to implement a comprehensive AML/CFT system, including customer identification (KYC), transaction monitoring, reporting of suspicious operations and appointment of a Money Laundering Reporting Officer (MLRO). Supervision is carried out by the Bank of Lithuania and the Financial Crime Investigation Service (FNTT).

What is the difference between a full licence and a limited activity licence?

A full EMI or PI licence allows services to be provided throughout the entire EEA through passporting and requires minimum share capital (EUR 350,000 for EMI, EUR 20,000 to EUR 125,000 for PI). A limited activity licence is valid only in Lithuania, is not subject to passporting, but has no minimum capital requirements — this is an equivalent of the sandbox approach for new companies.

Start the Licensing Process with COREDO

COREDO has been providing full support for obtaining financial licences in Lithuania since 2016. Our team will analyse your business model, determine the optimal licence type and ensure the preparation of all necessary documents for successfully completing the procedure with the Bank of Lithuania.

To receive an individual consultation, contact us:

Phone: +420 228 886 867 Email: info@coredo.eu