Electronic Money Institution Licence - Lithuania
An EU e-money institution licence is granted nationally under Directive 2009/110/EC and passports across the EEA.
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The short answer
Issuing electronic money in the European Union requires authorisation as an electronic money institution under national law implementing Directive 2009/110/EC, read with PSD2 for the payment services an e-money institution also provides. Authorisation is granted by the national competent authority of the member state of establishment and passports across the EEA.
Initial capital is EUR 350,000. Ongoing own funds are calculated on average outstanding electronic money under Method D, together with the applicable payment services requirement for unrelated payment services. Funds received in exchange for e-money must be safeguarded, and e-money must be redeemable at par at any time.
The practical distinction from a payment institution is the stored balance. If customers hold redeemable value they can spend with third parties, the firm is issuing e-money and a payment institution licence is not sufficient.
Key facts
E-money institution or payment institution?
An e-money institution can issue electronic money and can also provide payment services. A payment institution can only provide payment services. The additional cost of the e-money authorisation is the higher capital requirement and the redemption and safeguarding obligations that attach to outstanding e-money.
Firms distributing cards or wallets under another institution's licence are distributors or agents rather than issuers. That arrangement is quicker to launch but it places the economics and the regulatory relationship with the issuer, which is why successful programmes eventually apply in their own right.
What the competent authority assesses
- •A programme of operations and a business plan with forecasts consistent with the own funds calculation
- •Initial capital of EUR 350,000 held and evidenced, and a credible own funds trajectory
- •Safeguarding arrangements, with the chosen method documented and operationally tested
- •Governance, internal control, risk management and the suitability of the management body and qualifying shareholders
- •Anti-money laundering framework, including customer due diligence, monitoring and the transfer of funds information requirements
- •ICT and operational resilience arrangements, security policy and incident management
- •Structural organisation, outsourcing arrangements and, where used, the distributor and agent network
Ongoing obligations
- •Redemption at par on request, with clear contractual terms
- •Safeguarding reconciliation and evidence of segregation
- •Own funds monitoring against average outstanding e-money
- •Prudential, statistical, fraud and incident reporting to the competent authority
- •Notification of material changes, changes to the management body and changes in qualifying holdings
- •Passport notifications maintained and host state conduct requirements observed
Definitive guides for this market
UK Electronic Money Institution licence
The parallel UK permission for firms serving both markets.
EU MiCA CASP authorisation
Where the model also involves crypto-asset services, including e-money tokens.
UK Authorised Payment Institution licence
Where the model executes payments rather than issuing e-money.
Ongoing compliance support
Safeguarding, reporting and supervisory engagement after authorisation.
Primary sources
- Directive 2009/110/EC on electronic money institutions
- Directive (EU) 2015/2366 (PSD2)
- Bank of Lithuania: licensing of financial market participants
Last reviewed by the Regulatory Counsel team on 28 August 2026.
Frequently Asked Questions
Initial capital is EUR 350,000, with ongoing own funds of at least 2 per cent of average outstanding electronic money under Method D, plus the applicable payment services requirement for unrelated payment services.
Yes. Once authorised by the national competent authority of the member state of establishment, the institution can provide its services across the EEA following home state notification, either by establishment or by services.
Not always. E-money is electronically stored value, issued on receipt of funds, accepted by persons other than the issuer, and redeemable at par. Closed-loop prepayment for the issuer's own goods and services generally falls outside the definition, but the analysis is model specific.
Yes. An e-money institution can provide payment services connected to e-money issuance and, subject to the authorisation, unrelated payment services, in which case the corresponding own funds requirement applies.
Choose on supervisory throughput, banking access, language and available management substance, and then commit properly. The head office, central administration and effective management must genuinely sit in the member state of authorisation.