1. How to verify Lithuania EMI、Payment infrastructure and related systems
Lithuanian Bank Public Directory
When verifying institutions, you should consult the List of Financial Market Participants of the Bank of Lithuania，Confirm legal name、Authorization category、approved service、Agent or branch and current status。Directory records do not represent the commercial performance of institutions recognized by regulatory authorities。
CENTROlink and bank access reviewed separately
Obtaining EMI authorization does not automatically obtain CENTROlink、commercial bank、Card organization or third-party wallet access。Each partner will conduct qualifications independently、risk、Technical and business review，Specific products must also be within the scope of authorization。
EEA notification and service model
Cross-border services、Different notification and registration arrangements apply to agents and branches；It is also necessary to check the consumer protection of the target country、AML/CFT and other host country rules。Passport notification does not mean uniform coverage of a fixed 27 countries or access to clearing channels。
DORA and MiCA Act Implementation
EMI applicable to DORA must establish ICT risks、event、test、Continuity and third-party risk arrangements。Cryptoasset services are not automatically approved for obtaining EMI；MiCA activities should be carried out、Transitional arrangements and requirements from competent authorities to determine whether additional CASP authorization is required，It cannot be called a unified "additional license"。
2. [Statutory classification and capital standards] of Lithuania BoL payment license
| Statutory license type | Business authority and regulatory definition | Legal minimum paid-in capital |
|---|---|---|
| electronic money institution (EMI) |
Authorized to issue electronic money (e-money) and e-wallet，And can provide a wide range of payment and SEPA transfer services。 | 350,000 EUR。Applicants must demonstrate that initial capital consists of eligible capital projects and is available at the time of authorization；Form of investment、Accounts and supporting documents are confirmed as required by the Bank of Lithuania。 |
| payment institution (PI) |
Payment services can be provided within the permitted scope，But cannot issue electronic money。Receipt of client funds、Holding and coverage depend on the specific service and applicable rules。 | According to specific service type，Usually between 20,000 to 125,000 EURbetween。 |
| Cryptoasset service provider (MiCA CASP) |
Independent authorization path under MiCA，Determine permissions by crypto asset service category。EMI status does not automatically cover redemption、trading platform、Custody or other crypto asset services。 | MiCA permanent minimum capital is divided by service category 50,000、125,000or €150,000，And compare it with one-quarter of the fixed administrative expenses of the previous year, whichever is higher.；Interoperability with EMI's own funds must be calculated based on the same entity and business structure。 |
illustrate：The original US regulatory annex is not a source of EMI capital for Lithuania。EMI must continue to maintain at least its own funds that are no less than the statutory initial capital.，And calculated based on the average outstanding electronic money and incidental payment services using the applicable method；The Bank of Lithuania can adjust according to law，Reporting and top-up deadlines are implemented on a case-by-case basis and current rules.。
3. Lithuania EMI’s [Statutory Requirements for Corporate Governance and Executive Officers]
Local entity vs. central management：The applicant must be a legal person registered in Lithuania and comply with applicable laws.，Its registered office and central administration are located in Lithuania；specific legal form、The location and substance are determined according to the organizational structure and the requirements of the Bank of Lithuania。
Governance and Management：Members of the administrative body and those actually responsible for operations must have good reputations，and knowledge commensurate with the responsibilities、Skills and experience。Number of people、place of residence、Perform duties and devote time as per legal form、Business complexity and Bank of Lithuania case review determination。
Compliance and AML/CFT Function：Applicants must configure compliance that is commensurate with the business、AML/CFT Management Responsibilities and Control Functions，clear independence、Permissions、resource、Reporting and substituting。Job title、concurrently、The place of residence and the scope of outsourcing must be confirmed according to Lithuanian law and individual cases.。
ICT and data protection responsibility：Organizations must clarify ICT security、DORA and data protection duties。Whether you have to set up a standalone ISO or DPO depends on the risk、Organizational and GDPR statutory conditions；DPO obligations are not simply judged by “processing large amounts of data”。
Eligible shareholding review：Directly or indirectly holds more than 10% of the capital or voting rights，may exert significant influence，Usually constitutes a qualifying holding。shareholder、chain of control、COUGH、Financial soundness and funding sources are reviewed against applicable standards，Document list determined on a case-by-case basis。
4. Submitted to the Central Bank of Lithuania (BoL) [List of statutory review documents]
| File category | Submission details for statutory requirements (Important documents require notarized translations in Lithuanian) |
|---|---|
| Corporate foundation and audit documents | Lithuanian legal person registration、Registered office and central management information，Management and shareholder suitability documents，and the audit arrangements required according to the application list；The UAB or local auditor commitment letter should not be the only form for all cases。 |
| Financial planning and fund tracing | Business plan covering financial calculations and capital flow。35Composition of initial capital of 10,000 euros、Proof of provenance and availability。UBO Fund Source Legality Statement (provide bank statements/tax statements and other link certificates)。 |
| Compliance and IT Security Architecture | Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT)、Enhanced due diligence (EDD) procedures for high-risk customers。risk management structure。IT security instructions (including disaster recovery plan BCP/DRP) and data protection (GDPR) plan。 |
5. [Statutory Application and BoL Review Procedure] for Lithuanian EMI License
Stage one：Business scope and local entities
Determine EMI and payment service scope，Establishing a qualified Lithuanian legal entity，and planning a registered office、central management、personnel、Systems and Outsourcing Essence。
Stage 2：governance、Control and application documents
Prepare business plan、three-year financial forecast、governance、personnel、AML/CFT、Customer fund protection、ICT、outsourcing、Application information such as business continuity and audit arrangements。
Stage three：Capital and customer fund protection preparation
Proof of the composition of the initial capital of €350,000、Source and availability，and prepare proposed segregation or insurance/guarantee arrangements for client funds；Banks and insurance institutions will independently review。
Stage four：Submissions and Regulatory Review
Submit application to the Bank of Lithuania。Regulatory authorities may require supplementary documents or management explanations；Replacement deadline、The number of inquiries and interview format are decided on a case-by-case basis，It is not a uniform 30 days or mandatory fixed interview。
Stage five：Authorization decisions and cross-border notifications
Start business within the approved scope after authorization。When intending to enter other EEA countries, you must submit a notification according to the service mode and wait for the legal procedures to be completed.；Total turnaround time depends on application completeness and case-by-case review，Officials do not guarantee unification for 6 to 9 months。
6. Client funds segregation (Safeguarding) With [AML/IT Compliance Red Line]
Customer fund protection：Relevant client funds must be protected separately from own funds in accordance with applicable rules，Isolation or qualifying insurance/guarantee available。Account、assets、mechanism、Starting point of coverage、Reconciliation frequency and difference processing must be confirmed according to business and plan。
Suspicious activity and sanctions：Institutions must establish transaction monitoring、internal upgrade、Reporting to Lithuanian Competent Authorities and Sanctions Asset Freezing Process。Reporting time、Confidentiality and freezing obligations depend on current AML/CFT and sanctions laws，It cannot be written uniformly that all STRs are frozen within 24 hours.。
Security and data：Strong client authentication is only performed in PSD2 applicable scenarios.。Servers or cloud data are not prohibited simply because they are located outside the EEA，However, cross-border transfer must meet GDPR、DORA、access audit、Continuity and outsourcing requirements；Recording periods are determined by specific legal obligations。
ICT incident reporting：Major ICT incidents subject to DORA must be reported to the competent authority in accordance with the classification standards and current reporting templates。initial、Interim and final reports will be carried out in accordance with current DORA technical standards.，Cannot continue to use the old standard of unified 24/48 hours。
7. [Official Fees and Comprehensive Budget Standards] for Lithuanian EMI licenses
| Funding and Expense Categories | Legal requirements and budget standards (EUR) |
|---|---|
| Legal initial paid-in capital | lowest 350,000 EUR。Must prove capital composition、Source and availability at the time of authorization；The specific account and certification form shall be confirmed according to the requirements of the Bank of Lithuania.。 |
| BoL official application fee | The authorization information of the Bank of Lithuania once listed the national fee for EMI application as 1,463 EUR；Amount may be adjusted，Before payment, you must review it on the official authorization page and the current fee schedule.。 |
| Local rigid maintenance costs | audit、Banking and ICT testing scope depends on statutory requirements、Risks and supplier quotes。Commercial quotations are not government fees，DORA test depth and frequency are not uniformly fixed for all EMI。 |
| Agency consultants and legal budget | consultant、lawyer、Recruitment and documentation support are business services，Should be listed according to written scope and quotation，Not included in the Bank of Lithuania government fees，Nor can it imply a guarantee that the person is approved or authorized。 |
8. Lithuania EMI application support provided by Hong Kong Huitong
Corporate establishment and localization of senior management
Can assist in sorting out Lithuanian entities、Governance and staffing needs，and coordinate third-party services according to project scope。Personnel recruitment、Eligibility and suitability are ultimately reviewed by the applicant and the Bank of Lithuania。
Core legal documents and system compliance
Can assist in preparing business plans based on actual business、Fund flow and governance、AML/CFT、ICT、continuity、Outsourcing and data protection documentation；Applicant management must review、Approval and responsible for execution。
BoL Application and Interview Agent
Can assist with capital certification、Bank contact、Application submission and management explanation preparation；Banks and regulators decide independently，Account not guaranteed、personnel、Authorization or cross-border notification results。
9. Lithuania EMI / CASP Regulatory License Core Legal Questions and Answers (FAQ)
EMI plans cross-border services、When appointing an agent or establishing a branch，Notification information consistent with the model and target country must be submitted to the Bank of Lithuania，and wait for the legal procedures to be completed。Timing and host country requirements depend on model and case-by-case，We cannot promise that 20 working days plus 30 days will take effect uniformly.。
PI can provide payment services within the approved scope but cannot issue electronic currency.；EMI can issue electronic money and provide approved payment services。Crypto asset activities must be judged according to the MiCA service category whether additional CASP authorization is required.，It is not a unified add-on license for EMI。
EMI initial capital must not be less than 350,000 euros，and must prove capital composition、Source and availability at the time of authorization。Can be included in capital items、The form of capital contribution and account certificate shall be determined in accordance with applicable laws and the requirements of the Bank of Lithuania。
EMI must continue to meet its own capital requirements that are at least no less than the statutory initial capital.，And calculated based on the average outstanding electronic money and incidental payment services using the applicable method；Regulatory authorities may adjust according to law。Shortage reporting and replenishment arrangements are implemented in accordance with current rules and cases.。
Relevant client funds must be protected separately from own funds in accordance with applicable rules.，Segregation or qualifying insurance/bondage available。Account、assets、mechanism、Reconciliation frequency and discrepancy processing must be determined based on business and security plans。
Governing body members、Personnel actually responsible for operational and compliance and AML/CFT functions must have experience commensurate with their responsibilities、Permissions and input。Number of people、place of residence、Job title、Part-time and resident arrangements are governed by legal forms、Business and Bank of Lithuania case review decisions。
“Substantial shareholders” holding ≥10% of the shares must undergo statutory due diligence that reaches the ultimate beneficiary (UBO)。Complete bank statements must be submitted、Tax statements or equity transaction documents，Prove the absolute legality and traceability of capital injection。
The use of servers or providers outside the EEA is not always prohibited，However, cross-border transfer must meet GDPR、DORA、access audit、continuity、Subcontracting and exit requirements。Certification control and recording periods should be determined based on risks and specific legal obligations。
The Bank of Lithuania will conduct a completeness and substantive review，You can also request supplementary documents or management explanations.。The total period depends on the scope、Material、personnel、system、Third Party Arrangements and Inquiries；The official does not guarantee a uniform 6 to 9 months or a fixed 30 days for replacement documents and mandatory interviews.。
Authorized institutions must continue to fulfill financial、capital、Customer fund protection、AML/CFT、audit、Statistics and major change reporting。specific form、frequency、The deadline and audit scope are checked item by item according to the current Bank of Lithuania rules and reporting calendar.。
CASP usually must apply for authorization according to MiCA，Instead of submitting a unified "additional notification form"。Permanent minimum capital is 50,000 by service category、12.510,000 or 150,000 euros，and compared with fixed overhead indicators；Different systems apply to the issuance of asset reference tokens or electronic currency tokens.。
The continued validity of the authorization is subject to continued compliance with conditions and performance of obligations.。Failure to conduct business within the legal period、Long term closure、Situations such as obtaining authorization through false representation or serious violations may trigger revocation.；The specific procedures and deadlines are subject to current laws and decisions.。
10. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
|---|---|
| Professional interpretation | |
| Legislation and regulatory guidance | |
| Licensing and regulatory authorities | |
| Fact-checking sources for this page |
