What is a Lithuanian EMI electronic money license?
definition：it is lithuanialegal"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 reviewUsually ends 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
The cost of an EMI project usually consists of four parts：Establishment and Operation Basics(company、office、personnel)、Compliance and Audit(Policy document、independent functions、External Audit/Legal)、Systems and Security(KYC/Screening/Transaction Monitoring、Account reconciliation、IT security)、as well asRegulatory applications and communications(Application materials、Response to inquiries)。
The following is an indication of the budget caliber：Lithuania EMI in EUR：
| Expense Category | Specific project name | Estimated cost range (EUR) | Nature of expenses | Remark / illustrate |
|---|---|---|---|---|
| one、Official license fee | Central bank license application fee (Full EMI) | 1,463 | Disposable | Statutory audit fee submitted to the Bank of Lithuania (BoL)，Pay in full before application (€1,235 for small license plates)。If urgent, additional charges may be incurred。 |
| Central Bank Annual Supervision Fee | 2,000 – 10,000+ | Pay annually | Calculated on a pro-rata basis based on the company’s trading volume and turnover for the year。 | |
| two、statutory capital requirements | Minimum registered capital (Share Capital) | 350,000 | capital injection | Full-featured EMI statutory mandatory bottom line。Full payment must be deposited into a bank account recognized by the EU for capital verification and lock-in，Not available for dividends。 |
| capital buffer (Capital Buffer) | Depends on business size | capital injection | The central bank will make decisions based on the Business Plan andrisk assessment，Mandatory requirement to set aside additional risk buffer。 | |
| three、Company registration and establishment | UAB (limited liability company) establishment and notary fees | 500 – 1,500 | Disposable | Covers government online registration and name reservation fees，And notarization of personal materials of directors/shareholders、Apostilleand Lithuanian translation。 |
| Corporate bank account (capital verification account) establishment | 500 – 2,000 | Disposable | To inject legal capital of 350,000 euros。Due to strict anti-money laundering scrutiny in the financial industry，Account opening and compliance costs are high。 | |
| Four、Compliance and Substantive Operations | Legal and compliance advisory fees | 30,000 – 100,000 | Core front-end | Depends on the complexity of the business architecture。Mandatory coverage of highly customized "Business Plan"、AML/CTF mechanism establishment and supervisory interview coaching。 |
| Physical office rental | 500 – 2,000 / moon | Ongoing expenses | Legal compliance red lines：Virtual addresses are strictly prohibited。Real physical space must be leased according to law for future reference，Submit an application to force the submission of a lease contract。 | |
| IT systems and risk control infrastructure | Starting from tens of thousands of euros | prefix/continue | Procurement and docking compliance systems (such as KYC/KYT monitoring)、Isolated account access，Must strictly comply with SCA and GDPR mandatory requirements。 | |
| yearContinuous Complianceand personnel maintenance | 50,000 – 100,000+ / Year | Ongoing expenses | Covers the mandatory appointment of full-time anti-money laundering officers (MLROs) with more than 3 years of experience.，and annual independent financial and compliance audit fees。 |
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 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.。
After obtaining full EMI license，Enjoy absolute EU “single passport” rights of passage。Just go through the simple regulatory notification procedure through the Central Bank of Lithuania，You can automatically operate legally in the 27 member states of the European Economic Area (EEA)，No need to apply for local licenses country by country，It is the lowest-cost shortcut to enter the EU market.。
Complete EMI without business volume restrictions。Restricted EMI (Small EMI) faces strict legal caps：The average monthly outstanding electronic currency amount in the first six months shall not exceed 900,000 euros，And the average monthly payment transaction volume not related to electronic money shall not exceed 3 million euros，At the same time, it is strictly prohibited to do business outside Lithuania.。
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 full EMI filing fee is €1,463，Restricted EMI of €1,235。If the case file is complete，The statutory review period of the central bank is 3 months at the earliest (limited to 2 months)。However, in practice, due to inquiries and supplements，The entire case usually takes about 3 to 6 months，HKIT can help shorten the communication cycle。
A local registered address and physical office in Lithuania must be established。No nationality restrictions for shareholders，However, the company must have at least 3 members of the supervisory board、31 director and 1 chief executive (who may also serve as anti-money laundering officer)。Core executives must have a bachelor's degree in law/finance and more than 2 years of senior management experience in the payment industry，All employees passed the central bank's "fit and proper candidate" review。
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。
After approval, you can apply for direct access to the CENTROlink payment system operated by the Central Bank of Lithuania.，No need to rely on commercial banking intermediaries，Can independently issue personal/corporate IBAN，and enable efficient and low-cost Single Euro Payments Area (SEPA) transfers，This is the core infrastructure dividend of Lithuania’s EMI。
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 is limited to fiat currency electronic currency business。If you add crypto asset exchange or wallet custody，A separate Virtual Asset Service Provider (VASP) registration with FCIS is required，Mandatory paid-in capital of 125,000 euros，and appoint a local resident anti-money laundering officer，Meet dual regulatory red lines。
