Licensing & Regulatory Framework: Lithuania (PI vs. EMI)

Our expertise is grounded in the official regulatory standards of the Bank of Lithuania (Lietuvos Bankas). Leveraging our direct experience and established relationships with Lithuanian authorities, we prepare applications that minimize requests for additional information, significantly expediting the licensing process.

1. Payment Institution (PI) License

According to Article 5 of the Law on Payments of the Republic of Lithuania, a PI license covers:

  • Account Management: Services for depositing/withdrawing cash and managing payment accounts.

  • Transaction Execution: Transfers, direct debits, and credit transfers (including standing orders).

  • Payment Card Services: Execution of transactions via payment cards or similar devices.

  • Credit Lines: Execution of payment transactions covered by a credit line.

  • Issuance & Processing: Issuing payment instruments and/or processing transactions.

  • Remittances: Money transfer services.

  • Modern Fintech Services: Payment initiation services and account information services.

2. Restricted Activity License (The "Sandbox" Model)

To foster a favorable environment for startups, Lithuania offers a Restricted Activity License.

  • The Advantage: No minimum initial capital requirement.

  • The Limitation: Valid exclusively within the Republic of Lithuania (no passporting) and limited to specific payment services (Art. 5, 1–5).

  • The Goal: A stepping stone to access the European Economic Area (EEA) market after an initial growth phase.

3. Minimum Capital Requirements

Initial capital must meet the following thresholds (whichever is greater):

  • €20,000: For money transfer services only.

  • €50,000: For payment initiation services only.

  • €125,000: For full payment services (deposits, withdrawals, card transactions, and credit transfers).

4. The Authorization Process

The Bank of Lithuania maintains an open-door policy, encouraging pre-application discussions. Key Stages:

  1. Submission: Formal verification of documents within 5 business days.

  2. Review: Substantive review takes a minimum of 3 months. If additional information is requested (common for complex files), this period may be extended.

  3. Approval: Final decision by the Board of the Bank of Lithuania.

5. Official Fees (Levy)

A state fee must be paid to the State Tax Inspectorate (STI) prior to submission:

  • Standard License: €898

  • Restricted License: €682

  • Account Information Only: €693

The Bank of Lithuania's "LBChain" Sandbox

We help companies navigate the Regulatory Sandbox, a unique environment allowing Fintech startups to test innovative blockchain solutions under the Central Bank’s guidance.

LBChain is the world’s first blockchain sandbox developed by a financial regulator.

  • Technology: Based on Hyperledger Fabric and Corda.

  • Support: Offers both regulatory consulting and technical support.

  • Global Reach: Tested by fintechs from over 8 countries, covering everything from healthcare to energy-focused financial products.

‍ ‍For more information

"Information provided is for educational purposes and based on current Bank of Lithuania regulations. Please contact us for a tailored compliance assessment."

  • Parent Company: Service Europe Work Kft

  • Registered Address: Tompa utca 23, 1094 Budapest, Hungary

  • Tax ID: 33003218-2-43 (Verifica le ultime 3 cifre)

  • EU VAT Number: HU33003218

  • Bank: Raiffeisen Bank Zrt.

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