Payment Institution License - Lithuania

About Lithuania

Lithuania has made tremendous progress in establishing itself as a banking and payment institution. The country has taken the initiative to create a favourable regulatory environment for fintech enterprises, attracting a large number of payment service providers, electronic money institutions, and other financial institutions.

Lithuania has established a modern and transparent financial services regulatory framework. As the country’s central bank and financial supervisory authority, the Bank of Lithuania oversees the licencing and supervision of payment institutions, electronic money institutions, and other financial enterprises.

Payment Institutions (PIs) and Electronic Money Institutions (EMIs) are among the financial institutions that can be licenced in Lithuania. The licencing process is typically thought to be simplified, with well-defined rules and guidelines.

Lithuania is located in Europe’s geographic centre and has a short coastline along the southeastern part of the Baltic Sea. The state shares marine borders with Sweden and borders Belarus to the east, Latvia to the north, Poland and the Russian exclave of Kaliningrad to the southeast.

According to Worldometer’s analysis of the most recent United Nations data, the current population of Lithuania is 2,612,966 as of May 25, 2023.

Since 1991, the Baltic language of Lithuanian, which is closely linked to Latvian, has been the official language of Lithuania.

Lithuania’s legal system is based on continental European legal traditions. Lithuania’s legal system was transformed during Soviet rule to conform to that of the USSR, however the forced standards and practises have been abolished since 1990. Recent years have seen significant progress in the reform of the judicial system.

1. E-Money License Option
Lithuania also provides the Electronic Money Institution (EMI) Licence in addition to the PI Licence. Payment institutions can increase their variety of services and potential business prospects by obtaining an EMI Licence.

2. Cost-Effective Licensing Process
In comparison to other European jurisdictions, the licencing process in Lithuania is widely regarded as cost-effective. The PI Licence requirements are transparent, and the associated fees and capital requirements are reasonable, making it an appealing option for fintech startups and companies looking to enter the European market.

3. Strong IT Infrastructure
Lithuania has spent heavily in developing a robust IT infrastructure, making it a suitable site for digital payment services. The country has a high level of internet usage, advanced telecommunications networks, and a technologically competent workforce, all of which provide a solid platform for operating payment services.

4. Supportive Regulatory Authority
The Bank of Lithuania, the country’s central bank and financial supervisory authority, is known for its proactive approach to fintech regulation. They have established the “Regulatory Sandbox” and other measures to assist innovative financial services, promoting a collaborative connection between the regulator and industry participants.

5. Access to the European Single Market
Lithuania is a member of the European Union (EU) and the European Economic Area (EEA). By acquiring a PI License in Lithuania, you can benefit from the “passporting” rights provided by EU regulations. This means you can operate and provide your licenced services in other EU and EEA member countries without obtaining additional licences in each one.

6. Competitive Advantage in the Baltic Region
With its PI License, a company can establish a presence in Lithuania and tap into the growing Baltic market, which includes Estonia, Latvia, and Lithuania. This region is known for its strong digital infrastructure and technologically savvy population, which creates opportunities for market expansion and penetration.

7. Regulatory Framework
Lithuania has created a favourable regulatory environment for payment institutions, with clear standards and procedures for getting and maintaining a PI License. The regulatory environment is intended to promote innovation and the growth of fintech firms.

General

License: International Bank License
Timeframe for Approval: 3 to 4 months
Regulator: The Bank of Lithuania

Company Structure

Local Director: At least 1 director
Local Shareholder: At least 1 shareholder
Local Registered Office: Required
Local Staff: Required
Compliance Officer: Required
AML/KYC: Required
Audit: Required
Economic Substance: Required
Corporate Tax Rate: 15%
Currency: Euro
Minimum Paid-up Capital: EUR 125,000.00
Capital Requirements: $500,000
Tax Structure: 0% Tax on Offshore Profits

1. PRELIMINARY ANALYSIS OF THE PROJECT

  • Legal analysis of the company’s business model and planned services
  • Company structure analysis
  • Calculation of total budget calculation (together with the salaries for the employees and any additional costs for the office).
  • Identification of requirements for the company’s personnel and their qualifications
  • Identification and approval of the requirements of the Bank of Lithuania for filing an application

2. ORGANIZATION OF THE MEETING WITH THE BANK OF LITHUANIA

(together with the document and project preparation)

  • Organization of a meeting with representatives of the Bank of Lithuania
  • Assistance in the preparation of documents describing the structure of the company
  • Analysis of the project platform/website, a guide to its presentation
  • Preparation of the application for a PSP license in Lithuania
  • Support when filling out the application form
  • Assistance in developing a business plan that meets the requirements Bank of Lithuania

3. LICENSE APPLICATION

  • Documentation of company policies for AML, KYC, and cybersecurity of client assets.
  • A financial plan for the next three years will be prepared, along with a profit and loss statement and cash flow statement.
  • Documentation for the company’s operational processes and procedures (internal policies, risk assessment policies, internal audit process, operational plan, accounting procedures).
  • The preparation of required documents, assistance with filling out the application.
  • Representatives of a company must sign this document to confirm their right to do so.
  • In compliance with Lithuanian legislation, a document describing internal control mechanisms for preventing money laundering and terrorist financing.
  • Incidences and complaints that relate to safety, as well as procedures for monitoring, handling, and investigating them.
  • Detailed description of the business continuity processes, procedures for testing the adequacy and effectiveness of such plans, and a statement of operations of exceptional importance.
  • Statistical data collection and notification of suspicious transactions are described in terms of the principles and definitions applicable to this process.
  • Licensing fee confirmation document.
  • Documentary proof that client funds are stored in a client account.
  • The company structure is described in detail.
  • Detailed CVs of company owners and key executives.
  • Agreement regarding the office of the company.

 

  1. Execution of Payment Transactions
  2. Money Remittance
  3. Issuing and Managing Payment Instruments
  4. Acquiring Payment Transactions
  5. Payment Account Services
  6. Foreign Exchange Services
  7. Payment Initiation Services
  • Notarized copy of valid passport
  • Notarized copy of 2nd ID
  • Notarized copy of proof of address (ex. utility bill)
  • Certified Bank reference letter
  • 2 Character Reference Letters issued by professionals
  • Detailed CV dated and signed by the applicant
  • Copies of Diplomas of Higher Education

General requirements

The application must demonstrate to the Bank of Lithuania that:

  • The applicant enjoys a high reputation and standing in the financial community or will be able to do so in connection with the business it seeks authority to carry on
  • Every person who is or will be a principal shareholder, director or heads of a payment institution must be of good repute and possess the qualification and experience necessary to properly perform their duties
  • The applicant will have in place appropriate systems and controls to manage the risks of its business
  • The applicant’s business plan must correspond to the possibilities of the payment institution’s founders to implement it and the payment institution itself must be prepared to provide financial services in a safe and sound manner

Documentation required:

  • Detailed Business Plan
  • Framework of activities, specifying the types of payment services to be provided
  • Evidence that the minimum size of the equity capital does not fall below the required amount
  • Various manuals (e.g. procedure manual, privacy policy, disaster recovery plan, complaints handing policy, AML policy, security policy and procedures)
  1. Incorporation of offshore corporation
  2. Arrange for local registered officer and local directors, if required
  3. Draft corporate bylaws, minutes and owner share issuances
  4. Establishment of corporate bank account suitable for forex operations
  5. Establishment of merchant service account for accepting credit and debit cards
  6. Draft requisite business plan, financial statements and financial projections
  7. Draft requisite Anti-Money Laundering & Know-Your-Customer policies
  8. Arrange for requisite surety bond
  9. Prepare and process application for Czech Republic Payment Service Provider License
  10. Representation before licensing regulatory authority, banks and liquidity providers.