EU EMI License 2026 — Lithuania, 30-Country Passporting & PSD3 Transition Guide

What is an EU EMI License?

An Electronic Money Institution (EMI) is an entity authorized by an EU financial regulator to issue electronic money and provide payment services. The EMI license is issued under the Electronic Money Directive 2 (EMD2) and the Payment Services Directive 2 (PSD2) — a harmonized EU-wide framework that gives EMI-licensed entities the right to operate across all 30 EU/EEA countries through a single home-country authorization.

Electronic money (e-money) is a digital store of monetary value — held on a device, server, or card — issued on receipt of funds, accepted by persons other than the issuer, and redeemable for the equivalent in fiat currency. Under an EMI license, a company can issue e-money (e-wallets, prepaid cards, stored value) and provide the full range of PSD2 payment services — including credit transfers, direct debits, payment initiation (PIS), account information (AIS), merchant acquiring, and cross-border remittance.

If you are researching how to get an EMI license in Europe, the practical answer in 2026 is a Lithuania EMI license through the Bank of Lithuania. The core Lithuania EMI license requirements are €350,000 minimum capital, genuine local management, a DORA-aligned ICT framework, and a full AML/CFT programme. The defining benefit is EMI license EU passporting — a single authorization that grants access to all 30 EEA states. EU EMI license cost in 2026 spans regulatory, capital, and advisory components, and the PSD3 EMI transition (covered in detail below) makes applying now under the current framework strategically advantageous rather than something to delay.

The Single Most Powerful Feature: EU Passporting

EU passporting is the defining advantage of the EMI license over any offshore payment alternative. No other payment authorization provides this.

What passporting enables:

• •Serve retail and business clients across all 30 EEA member states under a single license
• •Open merchant accounts for EU businesses without separate national payment authorizations
• •Issue e-wallets and prepaid cards accepted across the EU/EEA
• •Provide cross-border SEPA transfers within the SEPA zone (36 countries including non-EU)
• •Partner with EU banks, card schemes (Visa, Mastercard), and payment infrastructure providers
• •Access the SWIFT network for international correspondent banking

Why Lithuania? The EU's Premier EMI Jurisdiction

Since Brexit removed the UK's FCA-authorized EMIs from EU passporting, Lithuania has become the dominant EMI licensing jurisdiction in the EU by volume of new licenses issued.

Permitted Activities Under an EU EMI License

• •Issuing electronic money — e-wallets, prepaid cards, stored value instruments
• •Payment account issuance — including IBAN accounts for clients
• •Executing payment transactions — credit transfers, SEPA transfers, direct debits
• •Card payment processing — issuing and acquiring under Visa/Mastercard schemes
• •Payment initiation services (PIS) — initiating payments from client accounts at other banks (PSD2)
• •Account information services (AIS) — aggregating client financial information from multiple banks (PSD2 / Open Banking)
• •Merchant acquiring — providing payment acceptance infrastructure to merchants
• •Cross-border money remittance — inbound and outbound international transfers
• •Currency exchange — FX services linked to payment transactions
• •Money-changing services — foreign exchange conversion

Critical 2026 Update: PSD3 and What It Means for Applicants

PSD3 and the Future of the EMI License

The most significant regulatory development affecting EU payment licensing in 2026 is the finalization of PSD3 (Payment Services Directive 3) and its companion instrument, the PSR (Payment Services Regulation). Understanding the PSD3 impact on EMI licenses is essential before applying.

On 27 November 2025, the European Parliament and the Council of the EU reached a provisional political agreement on both texts. The final published texts are expected in the Official Journal of the EU in H1 2026, with member state transposition required within 18 months — placing the effective compliance deadline at late 2027 to early 2028.

The single biggest structural change: EMIs become a sub-category of PIs

PSD3 repeals the Electronic Money Directive 2 (EMD2) and merges the EMI and Payment Institution frameworks into a unified licensing category: "payment institution authorized to issue e-money." There will no longer be a standalone EMI license under EMD2 — instead, e-money issuance becomes a specific permission within a broader Payment Institution framework.

What this means for existing EMI holders

Existing EMD2-authorized EMIs are grandfathered for 24 months after PSD3 enters into force (extendable to 30 months at the national competent authority's discretion). During this period, existing EMI licenses remain valid and fully operational. After 24 months, existing EMIs must submit a re-authorization application demonstrating compliance with PSD3's updated requirements — including governance, DORA-aligned ICT frameworks, updated safeguarding policies, and revised capital calculations. This will resemble the PSD2 grandfathering process. It is a compliance exercise, not a new application from scratch.

What this means for 2026 applicants

Applying for an EU EMI license in 2026 under the current EMD2/PSD2 framework is still correct and recommended. There is no benefit to waiting for PSD3 — which will not be transposed into national law before late 2027 at the earliest. An EMI authorized in 2026 will be grandfathered into the PSD3 framework automatically, with 24 months to formally re-authorize. Applying now locks in the grandfathering benefit.

PSD3 key changes beyond the EMI/PI merger

• •Payee name verification (IBAN-name matching) for credit transfers — mandatory for all PSPs
• •Stronger open banking performance standards — API uptime and response time requirements tightened
• •Enhanced fraud liability framework — stricter PSP liability for authorized push payment (APP) fraud
• •DORA full application (in force January 2025) applies to all EMIs and PIs — ICT risk management, incident reporting, and digital resilience are now explicit ongoing license conditions
• •Direct access to payment systems — non-bank PSPs gain strengthened rights to access EU payment infrastructure

EMT issuers under MiCA + PSD3

EMI authorization under EMD2 is the prerequisite for issuing e-money tokens (EMTs — stablecoins) under MiCA Article 48. When PSD3 enters into force, this requirement transitions to payment institution authorization to issue e-money under PSD3. The 24-month grandfathering covers existing EMT issuers. Crypto-fintech operators seeking to issue a stablecoin in the EU must hold (or obtain) EMI/PI authorization — there is no EMT issuance pathway without it.

DORA Compliance — Mandatory for All EU EMIs from January 2025

The Digital Operational Resilience Act (DORA, EU 2022/2554) applies to all EU EMIs from 17 January 2025. DORA is not a one-time compliance exercise — it is an ongoing regulatory obligation that supervisors (including the Bank of Lithuania) assess as part of ongoing license supervision. DORA compliance for an EMI is now a standing license condition, not an optional add-on.

Key DORA requirements for EMIs:

New EMI license applicants must demonstrate a DORA-compliant ICT risk framework as part of their authorization application — the Bank of Lithuania now assesses DORA readiness at the application stage, not just post-authorization. Zitadelle AG prepares complete DORA-ready compliance frameworks as part of the EMI license application package.

Full Capital and Financial Requirements

Safeguarding Requirements

Client funds must be protected through one of two methods: (1) segregation in a dedicated safeguarding account at an EU credit institution, or (2) an insurance policy or guarantee from an EU insurer or credit institution covering the equivalent amount. The safeguarding method must be established before operations begin.

Restricted EMI (Small EMI) — The Entry-Level Route

The Bank of Lithuania offers a Restricted EMI authorization for companies operating at smaller scale or entering the market for the first time. A restricted EMI in Lithuania is the lower-barrier alternative to a full EMI license — useful for validating a payment product before scaling EU-wide.

The Restricted EMI is the correct starting point for:

• •Startups validating a payment product in the Lithuanian market before scaling EU-wide
• •Companies that need Lithuanian regulatory standing but whose initial volumes will remain under the €900,000 e-money outstanding threshold
• •Operators building toward a full EMI who want regulatory status faster and at lower cost

Once a Restricted EMI exceeds the €900,000 outstanding threshold or decides to passport into other EEA countries, it must convert to a full (unrestricted) EMI authorization. The conversion process with the Bank of Lithuania is structured and well-defined.

Governance and Operational Requirements

Local Presence Requirements

• •Registered office in Lithuania — mandatory
• •Genuine operational presence — the Bank of Lithuania applies the mind and management test
• •Key decision-makers must demonstrably manage the EMI from Lithuania
• •Virtual offices without genuine management presence are rejected

AML/CFT Framework

• •Full AML/CFT programme aligned with EU AML Directives (AMLD 6)
• •Customer due diligence (CDD) and enhanced due diligence (EDD) for high-risk clients
• •Transaction monitoring systems
• •GDPR-compliant data processing framework
• •Suspicious transaction reporting to FIU (Financial Intelligence Unit)
• •Staff AML training programme

Step-by-Step Application Process

EMI Acquisition Alternative

For operators requiring faster EU market access, acquiring an existing Lithuanian EMI-licensed entity is an increasingly popular alternative to fresh applications.

Acquisition Advantages

• ✓Immediate operational status — no 6–12 month application wait
• ✓Existing banking relationships — SEPA, safeguarding accounts, correspondent banks already established
• ✓Existing passporting — already notified across multiple EEA countries
• ✓Existing card scheme access — Visa/Mastercard principal or affiliate memberships
• ✓IBAN infrastructure — individual client IBAN accounts already operational

EU EMI vs. Other Payment Authorizations

EU EMI Jurisdiction Comparison: Lithuania vs Latvia, Cyprus, Ireland & Germany

Lithuania's standard corporate income tax (CIT) rate is 17% as of 1 January 2026 (increased from 16%), with a reduced 5% rate available to small companies meeting specific turnover and headcount thresholds. Note that the 0% CIT on retained/undistributed profits model applies to Latvia and Estonia — not Lithuania.

How Zitadelle AG Assists

• ✓Jurisdiction selection — Lithuania vs. Cyprus, Malta, Ireland, or other EU jurisdictions
• ✓Lithuanian UAB company incorporation
• ✓Full EMI application preparation — business plan, AML/CFT framework, DORA ICT risk framework, financial projections
• ✓Bank of Lithuania submission and regulatory liaison — all correspondence managed
• ✓MLRO, Compliance Officer, and CISO placement via HRFinEase
• ✓Safeguarding account establishment — banking introductions for segregated client fund accounts
• ✓EU passporting notifications — managing notifications to each target EEA country
• ✓Post-authorization compliance — annual reporting, DORA compliance maintenance, license renewal
• ✓EMI acquisition — Lithuanian EMI M&A transactions via Financial License Market

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Frequently Asked Questions

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