What is a Lithuanian EMI electronic money license?
definition：It is Lithuania’s legal “authorized electronic money institution” qualification，Allow licensees toOperating electronic money and payment services across Europe。
Core business scope：
- 1、Issuance and Redemption：Legally issue electronic money，Supports digital wallet recharge and legal currency equivalent redemption。
- 2、Open an account：Provide customers with personal or corporate stored value accounts with independent IBAN accounts。
- 3、payment services：Perform SEPA (Single Euro Payments Area) transfers、direct debit、Acquiring and global remittance business。
- 4、issue card：Work with Visa or Mastercard to issue physical or virtual debit/prepaid cards。
- 5、comparative advantage：Compared to PI (Payment Institution) License，EMI has a stored value function，is builddigital bankingThe core qualification of ecology。
If the gateway is also involved、Merchant aggregation、Payment orchestration or cross-border collection，Linkable planning：Payment Gateway PSP and Cross-border payment solutions Architecture and Compliance Boundaries。
Regulatory framework and possible business scope (practical standards)
Create a definition of electronic money、issuance trigger、Redemption time limit and fee policy；Redemption arrangements need to be agreed with the customer、Accounting and liquidation logic are consistent。
Cover transfer、Payment、Collection、Payment account services, etc.；It is necessary to clarify whether the acquisition is involved、Payment initiation、Different regulatory categories such as account information services。
Usually via segregated accounts、Low-risk asset investment restrictions、Reconciliation and internal control implementation；Relevant control points must be auditable、Can be reviewed。
to agents、Distribution network、Technical service providers (including cloud and KYC/screening) need to carry out due diligence、contract governance、Performance and risk monitoring。
Coverage risk assessment、Customer due diligence、Continuous monitoring、Sanctions Screening、Suspicious transaction reporting and record retention；Need to be linked with transaction monitoring system。
Identity and access management、log、Change management、incident response、BCP/DR、third party risk；Need to form policy + process + evidence chain。
Regulatory reviews often begin with “Is it sustainable?、Stablize、Controlled protection of customer funds and prevention of financial crime"As the main line。It is recommended that the product (rate、redemption、Refund、Chargeback dispute)、Fund Flow (Customer Funds vs.. Institution’s own funds)、And system ledger (general ledger/sub-ledger/reconciliation) to form a closed loop，ensure policy、contract、System and operations consistent。
If it is planned to introduce automated KYC、Risk scoring and transaction monitoring，Can be referenced and combined：KYC identity verification system、risk assessment system、eDon TM Transaction Monitoring System or Hong Kong Xintong AML/CRM system。
Key points of application requirements：capital、governance、AML and IT (due diligence checklist perspective)
From the perspective of compliance implementation，Lithuania’s EMI application preparation proposal is advanced along “four parallel lines”：Corporate and Governance、Management qualifications、AML/CTF system、IT/Operations and Outsourcing Governance。The following are the key points that are most likely to be repaired in practice:：
- Shareholder and Beneficial Owner (UBO) Transparency：penetrating disclosure、Description of funding sources and continuous capital injection capabilities。
- Director/Executive Fit & Proper：Resume and Responsibilities、time investment、Conflict of Interest Policy and Board Decision-Making Mechanism。
- Three lines of defense and compliance independence：Compliance、risk、Boundaries of responsibilities and reporting lines of internal audit；Key position replacement and authorization matrix。
- AML/CTF infrastructure：Customer risk stratification、EDD trigger、Sanctions and PEP、Suspicious transaction identification and reporting process、Record keeping and training。
- Customer fund protection and reconciliation：Isolated account/guarantee mechanism selection、Daily/periodic reconciliation、Exception handling and audit trails。
- IT securityand outsourcing：System architecture、Permissions and logs、Encryption and key management、Supplier due diligence、SLA、Exit planning and business continuity。
If the business includes cross-border customers and multi-jurisdictional marketing/customer acquisition，Please include it simultaneously：Cross-border business compliance、Marketing material review and GDPR Compliance Consulting collaborative workflow。
Application process and cycle：From feasibility to approval and launch
Sorting out product features、capital flow、Role division and target market，Form license plate range mapping、Gap Analysis and Implementation Roadmap。
Establishment entity、Equity and UBO Disclosures、Board of directors and key position arrangements、Conflict of Interest and Authorization Matrix、outsourcing framework。
AML/CTF、Client Fund Protection、risk management、Complaint handling、information security、BCP/DR、Audit and reporting mechanism。
KYC/screening/transaction monitoring、Accounts and Reconciliation、Reports and traces；with bank、Card/payment network、Service provider docking。
Submit application materials，Supplement evidence and explanations according to regulatory inquiries，Iterate business plan and risk control details。
Launch products according to approved scope，Create routine reports、Continuous due diligence、Model calibration、Audit and major event reporting process。
cyclical aspect，Depends on business complexity、Management qualifications and material maturity have a greater impact。In terms of compliance, it is more recommended to use "Auditable systems and systems" as a milestone，Instead of just targeting the submission date。The online rhythm needs to be consistent withBank account opening、Segregated account plan、Matching of reconciliation and clearing capabilities。Related collaborations can be referred to：European bank account opening and Payment system integration。
Application fees and budget
Government Fees for EMI in Lithuania、Statutory capital and professional service costs should be accounted for separately。The table below only lists projects that have been confirmed by the current licensing page of the Bank of Lithuania：
| project | official standard | Properties and description |
|---|---|---|
| Full Electronic Money Institution (EMI) Application Fee | 1,463 EUR | Government fees payable when submitting complete EMI license application |
| Restricted Electronic Money Institution Application Fee | 1,235 EUR | Applicable to applications for restricted activity permits in Lithuania |
| Full EMI Minimum Initial Capital | 350,000 EUR | Belongs to statutory initial capital，Not an application fee or advisory fee |
| Ongoing supervision charges | Approved according to current rules | No more fixed ranges not supported by official fee schedules；It should be confirmed according to the applicable rules and business conditions at that time. |
Official basis and last verification date：2026August。Bank of Lithuania EMI License、Fees and Capital Requirements。consultant、system、personnel、office、Audit and banking service fees are not included in the above government fees，should be evaluated separately。
Continuous Compliance：Supervision focus and common inspection items after approval
Consistency of segregated account funds and customer balances、Reconciliation frequency and exception handling、Redemption and refund time limit、Audit traceability。
Rules and Threshold Governance、Alarm closed loop、SAR/STR process、Record keeping and training；Make sure to "explain"、Can be replayed”。
Real-time/quasi-real-time screening、hit disposal、Secondary review and upgrade path；Associated with payment link (merchant/payee)。
Supplier due diligence、SLA and audit rights、Sub-processor management、Exit and replacement options、Data processing agreements and cross-border transfer arrangements。
Minimize permissions、Log retention、Vulnerability and patch management、Penetration testing、BCP/DR Walkthrough、Incident classification and notification。
Board oversight、Regular Compliance and Risk Meeting、Key indicator (KRI/KPI) dashboard、Major event reporting and internal audit plan。
Continuous compliance recommendations are based on four-level linkage of "system-system-operation-audit"：Institutional definition requirements，System solidification control point，Operational output evidence chain，Audit verification effectiveness。If it involves cross-border teams and multi-market customer acquisition，Data compliance and privacy document systems need to be planned in advance：Data privacy policy development、Personal information protection and Data security assessment。
Lithuania EMI License Application and Operational Boundaries
The Lithuanian Electronic Money Institution (EMI) license shall be based on the proposed issuance of electronic money、Provide payment services and judgment on customer fund arrangements。Register a company、Payment service provider technical access or agency relationship，Not equivalent to obtaining EMI clearance。
- draw accounts、pay、issued、redemption、Agency and Funding Guarantee Process。
- Prepare equity and management information、business plan、internal control、AML/CFT、IT security and outsourcing arrangements。
- Check Lietuvos bankas against initial capital、governance、risk management、Latest reporting and safeguarding requirements。
- If cross-border services are involved，passporting should be confirmed、Applicable procedures for target countries and marketing methods。
Official verification：Bank of Lithuania Electronic Money Institution Information。The scope of license and cross-border service authority are subject to the official decision of the regulatory agency.。
Lithuania EMI Electronic Money License FAQs(FAQ)
Fully supervised by the Bank of Lithuania in accordance with the EU PSD2 and EMD2 directives。Once approved, electronic currency can be legally issued.、Provide IBAN account、Issuance of Visa/Mastercard payment cards and cross-border payment transfers，It is a rigid compliance base for conducting legal currency electronic currency business.。
Full EMI clearance available on approved service scope、After applicable laws and notification procedures are met，Providing corresponding services to other European Economic Area countries；This is not automatic、unconditional right of way，It does not mean that there is no need to abide by the rules of the target country.。Specific services、Agency or branch arrangement、Marketing methods and notification requirements，should beCurrent requirements of the Bank of Lithuaniaand the rules of the competent authority of the target country.。
Restricted EMI applies to narrower business scope and regulatory restrictions，May involve electronic money balances、Caps and conditions for payment transactions or cross-border services。specific amount、Statistical caliber and overseas service restrictions，It should be checked item by item according to the applicable laws at the time of application and the current rules of the Bank of Lithuania.，All cases cannot be summarized with fixed numbers。
The statutory minimum initial paid-up capital for a full EMI is €350,000，Must be paid in full and deposited into a bank account of a credit institution recognized by the EU。Restricted EMI has no statutory minimum capital requirement，However, in practice, the central bank will approve a higher capital buffer based on the business plan.。Hong Kong Xintong can assist in completing compliance capital verification arrangements。
The complete EMI filing fee is 1,463 EUR，Restricted EMI is 1,235 EUR。Regulatory review node、The time for supplementary documents and final processing depends on the completeness of the case file.、Business complexity and regulatory inquiries，You cannot use "fastest" 3 months" or "usually 3 to 6 Months" summarizes all applications。
Applicants need to demonstrate governance commensurate with the size of the business、Management and operational arrangements。Is a physical office required?、Which positions must be local or full-time?、Number and qualifications of directors or supervisors，Depends on legal form、Business scope and current review of Bank of Lithuania，A fixed number of staff or a uniform number of years cannot be written as the threshold for all applications。
The core difference is the "right to retain funds"。PI is only a capital transit channel，Client funds are not allowed to be retained for a long period of time；EMI is legally authorized to issue electronic currencies (such as e-wallets、Prepaid card)，Can legally deposit and manage customer funds for a long time，So capital requirements and regulatory standards are higher。
Client funds must be completely separated from own working capital，Mandatory deposit into a separate secured account with a qualified credit institution in the EU (such as a central bank or a commercial bank)，or provide equivalent coverage through a compliant insurance policy，Guard against misappropriation risks。Hong Kong Xintong can provide fund isolation plan design。
Can I access CENTROlink after being approved?，Need to meet additional requirements from Lithuanian banks and system operators for access、technology、Risks and Contractual Requirements。EMI licensing itself does not equal automatic access，There is also no guarantee that an IBAN can be issued directly or that commercial banks can be bypassed。
Must submit a detailed three-year business plan and financial forecasts、Fund isolation protection plan、System IT architecture and data protection strategy、AML/CTF Compliance Policy Manual、Internal risk control and governance structure diagram，As well as double certification of the executive’s criminal record and proof of source of funds。Hong Kong Xintong provides full document writing services。
Strict KYC customer due diligence and transaction monitoring mechanisms must be established，Submit compliance and financial statements to the central bank at the end of each quarter，Annual submission of external independent audit report，and report suspicious transactions to the Financial Crimes Investigation Bureau (FCIS) in accordance with the law。Anti-money laundering is the absolute focus of regulatory inspections。
The EMI license itself does not cover all crypto asset services。If the business involves crypto asset exchange、Hosting or other related activities，CASP authorization under MiCA should be judged separately、Transition Arrangements and Target Business Jurisdiction Requirements；Cannot put old FCIS、Fixed capital amount or local MLRO parlance as prevailing uniform threshold for all projects。
