Lithuania: EMI Licences and the Specialised Bank — the EEA's Second Door After the Clean-up

In a decade Lithuania has assembled the EU's largest fleet of payment licences: as of July 2026, the Bank of Lithuania register shows 80 electronic money institutions and 43 payment institutions. One Vilnius authorisation opens all 30 EEA markets, which makes this the highest-volume entrance into European payments. Yet the jurisdiction of 2026 bears little resemblance to the one that handed out "licences in three months" back in 2018: after a run of revocations and a record fine, the Bank of Lithuania has rebuilt its conveyor belt into a filter. Here is what Vilnius issues and on what terms — and what Revolut's Lithuanian registration means for anyone who simply keeps money there.

Why Lithuania: the EEA's high-volume door

The Lithuanian model grew out of Brexit arithmetic: British fintechs needed a fallback EU passport, and a small central bank needed critical mass for a new sector. The Bank of Lithuania offered what no large regulator would: a clear process in English, a statutory three-month review and — the trump card — CENTROlink, the central bank's own payment system, through which EMIs and payment institutions reach SEPA directly, without a commercial bank intermediary. For a payments company that removes the classic dependence on partner banks that chokes licensees elsewhere.

The result is an e-money sector with €2.4 billion outstanding and €357 million in income (figures as at the end of Q3 2024) and the status of the EEA's second door. The first, by weight, is still Luxembourg: costlier and slower, but its licences raise no eyebrows among correspondents — see our Luxembourg EMI breakdown. Lithuania competes on speed, cost and infrastructure; institutional gravitas is not part of the package.

The Bank of Lithuania line-up: PI, EMI and the specialised bank

The first two floors are standard EU fare. A payment institution (PI) under PSD2 — transfers, acquiring, payment initiation — takes €20,000–125,000 of capital depending on the services. An EMI under EMD2 — e-money issuance plus everything a PI can do — takes €350,000. The state fee for reviewing an EMI application is €1,463; the statutory clock is three months from a complete file, and in practice, with pre-application meetings and rounds of questions, the route runs 6–12 months. There is also a restricted licence with no minimum capital, but it works only inside Lithuania and carries no passport.

The third floor is a Lithuanian speciality that exists nowhere else in the EU in this form.

The specialised bank: a bank for €1 million

A specialised bank is a fully-fledged credit institution with minimum capital of €1 million, against €5 million for a regular bank. It takes deposits insured by the Lithuanian deposit guarantee scheme up to €100,000, lends, and provides the full set of payment and e-money services. Investment services are off limits: no brokerage, no portfolio management, no custody of financial instruments. The entry mechanics are a state fee plus paid-up capital; the Bank of Lithuania runs the file, but the licence itself is granted by the ECB, as for any euro-area credit institution — the route is unpacked in our guide to the EU banking licence via the ECB. A realistic horizon is a year or more.

Twelve such licences have been issued since 2017; eight specialised banks operate today, among them Mano Bank, European Merchant Bank, SME Bank, GF bankas, Finland's Saldo Bank and Estonia's Finora Bank. Two outgrew the format: Revolut and PayRay both started with specialised licences. And the licence of Fjord Bank, granted back in 2019, became deal currency in January 2026: UK BNPL player Zilch agreed to buy the bank outright to enter Europe through a ready-made banking licence, with the deal awaiting regulatory approval. A telling outcome: the Lithuanian banking licence has become an M&A asset in its own right.

The Revolut case: what the Lithuanian licence delivered

The regime's story is best told by its star graduate. In December 2018 Revolut received specialised bank and EMI licences; in December 2021 the ECB lifted the restrictions and granted a full banking licence. The Vilnius entity, Revolut Bank UAB, serves tens of millions of customers across the EEA, and by 2025 it had become the largest bank in Lithuania itself, with 30.8% of sector assets.

The practical headline: money in Revolut Business and retail EEA accounts sits not "in an app" but in a Lithuanian bank, with deposits insured up to €100,000 — unlike neobanks running on EMI licences, where safeguarding is all there is.

But the Vilnius monopoly is over. On 10 August 2026 Revolut Bank S.A. received a full French licence from the ECB and the ACPR: from 2027 Paris becomes the headquarters for Western Europe — around 30 million customers and a declared investment of over €1 billion. Revolut Bank UAB remains the bank for the rest of the EEA, but the era of "all of Europe out of Lithuania" has ended — an honest verdict on the jurisdiction's ceiling, delivered by its own flagship.

The clean-up of 2022–2026: PayrNet and the rest

The flip side of volume surfaced quickly. In June 2023 the Bank of Lithuania revoked the licence of UAB PayrNet — the Lithuanian entity of the UK BaaS platform Railsr and the country's fifth-largest EMI by turnover (€7.5 billion in 2022). The regulator counted some 90 intermediaries onboarded without proper checks and found the institution did not even know the exact number of its own end users. For everyone building products on a rented licence, this remains the decade's core lesson — provider risk is dissected in our guide to BaaS and sponsor banks.

Then came the series. Transactive Systems lost its licence and paid €280,000 over AML failures. In November 2024 Foxpay's licence was revoked — from safeguarding gaps to an unfit controlling shareholder; in March 2026 Paytend Europe followed. The flagship was not spared either: in April 2025 Revolut Bank received the Bank of Lithuania's record €3.5 million fine for shortcomings in anti-money-laundering monitoring.

These are not isolated episodes but policy. As early as 2022 the regulator and the finance ministry committed to "sustainable development" of the sector — quality over quantity. The licence fleet has not grown since; it rotates: the weak are removed from the register, the strong face higher demands.

The 2026 bar: substance instead of a conveyor belt

The formal thresholds have not moved — the filter has. The Bank of Lithuania now expects real presence: a management board of three plus a CEO, an AML officer and key control functions in Lithuania, a working office rather than a mailbox. The €350,000 capital is a floor on top of which the regulator almost always requires a buffer sized to the business plan. Fees remain nominal, but the cost of entry has shifted into substance: the team and the compliance stack are built before the licence, not after it.

The horizon adds another layer: PSD3 and the Payment Services Regulation will merge the PI and EMI regimes into one and force existing licensees through reauthorisation — a 2027–2028 window. What that means for Lithuanian licence holders is covered in our PSD3/PSR breakdown.

Crypto and MiCA: Lithuania plays it cautious

On crypto, Lithuania behaves in the exact opposite way to its payments story. After hundreds of VASP registrations in the 2018–2021 era, the regulator turned the valve: capital and resident-AML-officer requirements went up, and the MiCA transition period became one of the shortest in the EU. The result: by April 2026 only four CASP licences had been issued — Robinhood Europe was first, picking Vilnius as its European hub, followed by CoinGate and Nuvei Liquidity in December 2025. For comparison, Luxembourg has collected Ripple and Coinbase, and Malta has handed out dozens. Lithuania clearly does not want to be a crypto hub — it wants to stay a payments one. The full CASP route is in our CASP licence guide; the wider regime in the MiCA overview.

Lithuania vs Luxembourg vs Malta vs Ireland

EMI capital under EMD2 is identical everywhere — €350,000; jurisdictions are chosen on timelines, infrastructure and reputation.

If you need the opposite pole — institutional weight and the "EMI + CASP + bank account" bundle under one regulator — that is the Luxembourg route. If your own licence is premature altogether, there is business under someone else's regulation and the agent schemes from our passporting breakdown.