Lithuania: EMI, Payment Institution and Specialised Bank Licences

In a decade Lithuania has assembled the EU's largest fleet of payment licences: in September 2026 the Bank of Lithuania register lists 70 electronic money institutions with an unrestricted licence plus two restricted ones, and the central bank's sector page counts 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: high-volume entry into the EEA

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 entry point. 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 regime's key parameters on one screen.

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

The first two floors are standard EU fare; the third is a Lithuanian speciality that exists nowhere else in the EU in this form. The floors differ by minimum capital and by what the licence allows.

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. The gap between the second floor and the third is not only capital: deposits and deposit insurance begin on the banking one.

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 — the same set of complaints, different institutions.

In March 2026 Paytend Europe followed: the filter works the same way for small institutions and for the sector's flagship.

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.

Choosing the member state: nine EMI jurisdictions

The capital number carries no information in this choice. EMI initial capital is €350,000 in every member state under article 4 of EMD2, a payment institution is €20,000, €50,000 or €125,000 by service under article 7 of PSD2, and the statutory clock is the same three months from a complete application everywhere, because article 12 of PSD2 governs e-money authorisations through article 3(1) of EMD2. What differs is how long the file sits before it is deemed complete, what rails the licence reaches, and how a correspondent bank reads the country on the letterhead.

Where a cell reads "not published", the regulator states no target beyond the three statutory months — which is exactly why the practical range cannot be taken from marketing material for those five countries.

The second cut is the one that actually decides the filing.

Read across the two tables, the choice collapses into four sentences. Lithuania sells speed and direct rails: CENTROlink is the only feature on this grid that removes the commercial-bank intermediary, and the specialised bank at €1 million is the only intermediate step between an EMI and a full credit institution anywhere in the EU. Luxembourg sells correspondent trust — the thing that is hardest to buy and impossible to build quickly — and bundles the EMI with a CASP under one regulator. Ireland sells the English language and a big-tech ecosystem, and charges for it in calendar time: a published 90-business-day standard for each assessment phase sits next to an average file of 763 days, because the phases are separated by deficiency correspondence. Malta and Cyprus sell price, with Cyprus adding the option of a MiFID firm beside the EMI; Estonia sells a lean process; the Netherlands sells how the jurisdiction reads to a correspondent; Poland sells a domestic market; and Bulgaria, inside the euro area since 01.01.2026, sells euro-area status at a Balkan cost base.

A worked comparison on one set of inputs. Take a card-issuing programme with €2 million of funding that needs to be live in twelve months and banked by a tier-one correspondent. Capital is €350,000 in all nine, so it is not a variable. Lithuania and Luxembourg are the only two where the practical range fits inside twelve months, which removes seven jurisdictions on timing alone. Of those two, Lithuania also removes the partner-bank dependency through CENTROlink, but the correspondent requirement pushes back: a Vilnius licence still carries the post-clean-up discount. The programme therefore either accepts Lithuania and budgets a longer banking search, or pays the Luxembourg premium and gets the correspondent question answered at authorisation. The Netherlands answers the correspondent question best of all and fails the twelve-month test. That is the whole trade: speed, rails and reputation are three different purchases, and no jurisdiction on this grid sells all three.

Bulgaria is the one row on this grid that competes with Lithuania for the same file rather than for a different kind of applicant. Initial capital is the same €350,000, the statutory clock is the same three months, and since 1 January 2026 the currency is the same too, so the comparison runs entirely on what each member state decides for itself: the review fee and the regulator's own sub-clock, whether a lighter domestic tier exists, whether the presence test sits in the statute or in supervisory practice, CENTROlink against an application under Art. 130a of the Bulgarian payment services act, a register of seventy against one of thirteen, and Bulgaria's FATF listing. That head-to-head is set out in EMI in Lithuania or Bulgaria.

The regulator's window: fees, clocks, safeguarding and owners

The two tables above explain where a licence leads. The third cut prices the filing itself and adds the United Kingdom, which since Brexit sells the same e-money licence without the EEA passport. Every figure below is the regulator's own: a filing fee from its published tariff, a decision clock from its statute or its service standard, a safeguarding venue from its implementing rules.

The fee column ranges from nothing to €30,000, and the spread is almost the inverse of the correspondent reading. The Central Bank of Ireland charges nothing to file and recovers its cost through the industry funding levy once the firm is authorised; the Bank of Lithuania asks €1,463; the Central Bank of Cyprus asks €10,000; and the CSSF, under the Grand-ducal regulation of 23 December 2022, charges €30,000 for the examination plus an annual lump sum of €30,000, or €40,000 once cumulative volume passes €1 billion, with a reduced €25,000 for institutions in their first three years. Malta repriced from 1 January 2025: Gonzi & Associates report an authorisation fee of €15,000 against €3,500 before, and an annual supervisory fee of €35,000 plus the higher of an asset-based or a volume-based variable. The FCA puts an authorised EMI in pricing category 5, £5,640, and a small EMI in category 3, £1,130.

The clock column is where the statute and the practice separate. Only two regulators publish an outer limit that runs from the filing date rather than from a complete file: Finantsinspektsioon decides within three months of receiving all documents and no later than six months after the application arrives, and the FCA works to three months for a complete file and twelve for an incomplete one. Ireland publishes service standards per phase and says openly that it can take firms over twelve months to supply everything a decision needs. Cyprus turns the question around: the regulator sets a deadline for each round of clarifications, and a file that misses one is deemed withdrawn.

Safeguarding is a single European menu with two national additions. Article 10 of PSD2, applied to e-money by article 7 of EMD2, allows a segregated account at a credit institution, secure low-risk assets, or an insurance policy or bank guarantee, and every member state on this grid transposes those three options. Lithuania and Bulgaria add a fourth venue — the central bank itself — which removes the commercial bank from the safeguarding chain as CENTROlink removes it from the settlement chain. The United Kingdom kept the same two methods and, from 7 May 2026, layered on the CASS 15 supplementary regime with monthly safeguarding returns and an annual audit. How those chains actually protect a customer balance is set out in correspondent banking and safeguarding.

Owners are the axis where marketing and statute diverge most. No member state on this grid tests the nationality or residence of a shareholder. PSD2 requires the head office in the licensing state and part of the business there, and article 6 subjects every qualifying holding of 10% or more to an assessment of the acquirer's reputation, the management it will appoint, its financial soundness, the supervisability of the group and any suspicion of money laundering. A non-resident owner passes the same five criteria as a resident one; what grows is the evidence — source of the capital, the group chart to the natural persons at the top, and the home supervisor's cooperation where the owner is itself regulated abroad. The presence requirement bites on management, not on ownership, which is why "nominee" structures fail at the interview rather than at the register. EU sanctions add one nationality-based rule, and only on the crypto side: the ownership bar for crypto-asset service providers, which reaches an EMI once it adds custody or transfer of its own tokens, is set out in EMI in Lithuania or Bulgaria, together with the fee and sub-clock comparison of those two regulators.

A worked bill on the fee column alone. For a new EMI below €1 billion of annual volume, three years of the regulator's own charges come to €30,000 plus three annual fees of €25,000 — €105,000 — in Luxembourg; €15,000 plus three years at €35,000 — at least €120,000 before the variable part — in Malta; €5,000 in filing fees in Bulgaria and €1,463 in Lithuania, whose annual supervision charges are not part of this comparison; and nothing at the door in Ireland. Against €350,000 of initial capital and a resident board, the difference between the cheapest and the dearest window is real but secondary: it decides the file only for a lean project, and in Luxembourg it is the visible price of the correspondent reading the second table describes.

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. Outside the EEA the same decision sits against Singapore's MPI, Hong Kong's SVF, the UAE's SVF and Canada's PSP registration in the fintech licence map, where the Lithuanian specialised bank also appears beside the EU, UK, US and Swiss banking licences in the bank grid.