Lithuania EMI License Application Guide: Central Bank Process, Fees and the 3-Month Statutory Review

The Bank of Lithuania (Lietuvos bankas) is one of the EU licensing authorities most open to fintech; Revolut's early EU license came from here. The appeal rests on three things: a transparent published fee schedule, a codified statutory review period (3 months once the file is complete), and an application process that accepts documents in English. Once licensed, a Lithuanian EMI can passport across the entire EEA like any other EU EMI.

Capital requirements follow the standard EU tiers: EUR 350,000 for an EMI, EUR 20,000 to 125,000 for a PI depending on the services. Lithuania also offers a restricted licence option: no minimum capital and a faster review, but the business may only operate within Lithuania and is subject to volume caps. It suits a path of validating the model first, then upgrading to a full license.

Applications are prepared against the annex checklists in the central bank's licensing rules: Annex 1 for EMIs, Annex 2 for PIs. They cover the business plan, three-year financial projections, governance structure, safeguarding arrangements for customer funds, AML/CFT policies, IT and security descriptions, and fit-and-proper documentation for shareholders and management. Documents must be in Lithuanian or English, foreign-issued documents need an Apostille, and the application can be submitted online with an electronic signature.

Procedurally, the central bank may issue a request for additional documents within 1 to 2 months of acceptance (the review clock pauses while you respond), after which the file, once complete, enters the 3-month statutory review. In practice, the total timeline depends mostly on how many rounds of follow-up requests occur. Getting the safeguarding and AML documents right the first time is the key to a shorter process.

The state fees (paid to the State Tax Inspectorate, STI) are published and transparent: EUR 1,463 for an EMI license, EUR 1,235 for a restricted EMI, EUR 898 for a PI license, EUR 682 for a restricted PI, and EUR 693 for account information services (AIS) only. These are just the government fees; lawyers, compliance consultants and a local team are the main cost items.

Licensed institutions are entered in the Bank of Lithuania's public register and synchronized to the EBA's EUCLID EU-wide register. Both can be checked free of charge.