EU — Electronic Money Institution (EMI) License 2026
The EU Electronic Money Institution (EMI) license is the definitive authorization for payment companies, e-wallet operators, and fintech businesses seeking access to all 30 EEA countries from a single EU license. Lithuania is the preferred route — 180+ licensed EMIs, English-language process, Bank of Lithuania's fintech-friendly reputation. Critical 2026 update: PSD3 provisional agreement reached November 2025 — apply now under PSD2/EMD2 for grandfathering benefits.
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.
| Feature | Details |
|---|---|
| Primary framework | EMD2 (Electronic Money Directive 2) + PSD2 |
| Preferred jurisdiction | Lithuania (Bank of Lithuania) |
| EMIs licensed in Lithuania | 180+ — most of any EU jurisdiction |
| Min. initial capital | €350,000 |
| EU/EEA passporting | 30 EEA countries from one license |
| SEPA access | Yes — direct CENTROlink access (Lithuania) |
| DORA compliance | Required — mandatory since January 2025 |
| PSD3 update | Provisional agreement November 2025 — apply now for grandfathering |
| Timeline | 6–12 months |
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.
An EMI authorized in Lithuania can legally provide e-money and payment services in all 30 EEA countries — Germany, France, Spain, Italy, the Netherlands, Poland, and 24 others — without separate national authorizations. The company notifies each country's regulator of its intent to operate there; the home-country authorization covers the activity.
This passporting right is not available from any offshore jurisdiction. A Curaçao gaming license, a Mauritius PIS license, a Labuan Payment System license — none can substitute for EU passporting rights. The EU EMI is the only route to 30-country EU market access under a single regulatory framework.
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.
180+ Licensed EMIs
Lithuania has more licensed EMIs than any other EU jurisdiction. The Bank of Lithuania has actively cultivated a fintech-friendly regulatory environment — resulting in Europe's deepest concentration of payment and e-money institutions.
English-Language Applications
Unlike many EU regulators, the Bank of Lithuania accepts applications and conducts regulatory correspondence in English — making it the most accessible EU regulator for international applicants.
CENTROlink SEPA Access
Lithuanian EMIs get direct access to the Single Euro Payment Area (SEPA) through the CENTROlink payment system managed by the Bank of Lithuania — covering SEPA Credit Transfers, Instant Payments, and Direct Debits at low cost.
No Local Residency Required
Lithuania does not require directors to be Lithuanian residents — unlike Cyprus, Malta, and Ireland which require some local management presence. Shareholders can be from any country, aged 18+.
Startup Visa Available
Lithuania offers special startup visas for non-EU/EEA citizens establishing innovative businesses — including EMIs and payment institutions — making it accessible for founders from MENA, Asia, and Africa.
Regulatory Sandbox
The Bank of Lithuania operates a regulatory sandbox for innovative fintech businesses — allowing EMI applicants to test products under regulatory supervision before full authorization.
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 Provisional Agreement: November 27, 2025
The EU reached a provisional political agreement on PSD3 (Payment Services Directive 3) and the associated Payment Services Regulation (PSR) on November 27, 2025. Key implications for EMI applicants in 2026:
- —Expected Official Journal publication: Q2 2026
- —18-month national transposition period: approximately late 2027
- —Existing EMI license grandfathering: 24 months after PSD3 enters into force
- —PSD3 will merge the EMI licensing framework (EMD2) into the PSR, making EMIs a sub-category of Payment Institutions
Why applying now under PSD2/EMD2 is strategically advantageous: Any EMI license obtained before PSD3 enters into force will be grandfathered for 24 months — remaining valid without immediate re-authorization well into 2028 or beyond. Operators waiting for PSD3 to be finalized will face a more demanding framework. Apply now to lock in the current EMD2 requirements.
DORA Compliance Note
Even under the current framework, all regulated EMIs and PIs are subject to the Digital Operational Resilience Act (DORA) effective January 2025. New EMI applications must demonstrate DORA-aligned ICT risk frameworks as part of the documentation package. This includes ICT risk management policies, third-party provider oversight, incident reporting protocols, and digital resilience testing.
Full Capital and Financial Requirements
| Requirement | Full EMI | Restricted EMI |
|---|---|---|
| Min. initial capital | €350,000 | €0 (no share capital requirement) |
| Ongoing capital (higher of) | €350,000 OR method-based calculation | Method-based |
| Own funds floor | €350,000 maintained at all times | Proportional |
| Client fund safeguarding | Mandatory — segregated accounts or insurance/guarantee | Same |
| Capital calculation method | Own funds method (A), Expenditure-based method (B), or Combined (C) | Same |
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.
Governance and Operational Requirements
| Role | Requirement |
|---|---|
| Directors | Min. 2 with relevant payments/financial services experience |
| Local management | Mind and management principle — senior decision-makers must be Lithuania-based (or genuinely involved from Lithuania) |
| MLRO | Designated Money Laundering Reporting Officer — mandatory |
| Compliance Officer | Separate from MLRO where possible |
| CISO / IT Security | Required under DORA (January 2025) |
| Board oversight | Independent oversight of management function |
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
Company Incorporation in Lithuania (2–4 weeks)
Incorporate a UAB (private limited company) in Lithuania with the correct corporate purpose covering EMI activities. Prepare constitutional documents, shareholder structure, and appoint the initial management. Zitadelle AG manages the full Lithuanian company registration process.
Application Preparation (2–4 months)
Compile the comprehensive application package — detailed business plan covering all e-money and payment services, financial projections (3 years), AML/CFT framework, DORA-aligned ICT risk management framework, governance policies, compliance procedures, safeguarding arrangements, and fit-and-proper documentation for all directors and key personnel.
Bank of Lithuania Submission
Submit the complete application to the Bank of Lithuania's Supervisory Service. Engage proactively with all Bank of Lithuania questions and information requests — typically 2–3 rounds of clarification. Zitadelle AG manages all regulatory correspondence.
Regulatory Review and Approval (3–6 months)
The Bank of Lithuania assesses the application against EMD2 and PSD2 requirements — evaluating business model viability, capital adequacy, AML/CFT robustness, DORA compliance, and management fitness. Upon satisfactory review, the EMI authorization is granted.
EU Passporting Notifications
After home-country authorization, notify the Bank of Lithuania of each EEA country where services will be provided. The Bank of Lithuania notifies each host country's regulator. The passporting process takes approximately 1–3 months per country.
Timeline note: 6–12 months total from incorporation to EMI authorization. Passporting notifications add 1–3 months per target country. Total time to full EU/EEA operational readiness: 8–15 months.
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
Financial License Market(financiallicensemarket.com) — Zitadelle AG's sister platform — lists verified Lithuanian EMI entities available for acquisition. Lithuanian EMI licenses with full EEA passporting, direct Visa/Mastercard status, SEPA Instant capability, and individual IBAN infrastructure are available from €4,000,000–€6,000,000 (excluding paid-up capital). Zitadelle AG advises on EMI M&A transactions.
EU EMI vs. Other Payment Authorizations
| Feature | EU EMI (Lithuania) | UK EMI (FCA) | Mauritius PIS | Singapore MPI |
|---|---|---|---|---|
| EU passporting | Yes — 30 EEA | No (post-Brexit) | No | No |
| E-money issuance | Yes | Yes | Limited | Yes |
| IBAN accounts | Yes | Yes | No | No |
| SEPA access | Yes (direct) | No | No | No |
| Min. capital | €350,000 | £350,000 | USD $45,000 | SGD $250,000 |
| Timeline | 6–12 months | 12–18 months | 6–9 months | ~12 months |
| Crypto services | Limited | Limited | Via VASP | Yes (MPI) |
| Best for | EU market access | UK market | Africa/Asia offshore | ASEAN institutional |
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
Frequently Asked Questions
An Electronic Money Institution (EMI) license is an EU authorization issued under EMD2 and PSD2 allowing a company to issue electronic money (e-wallets, prepaid cards, stored value) and provide payment services across all 30 EEA countries through EU passporting from a single home-country license.
Ready to obtain your EU EMI License?
Zitadelle AG provides end-to-end EU EMI licensing support — from jurisdiction selection and Lithuanian company incorporation through Bank of Lithuania application, MLRO and compliance officer placement, safeguarding account establishment, and EU passporting notifications across all target EEA countries.
Related Licenses
UK FCA Small Payment Institution
FCA SPI registration — no capital requirement, €3M monthly cap. UK payment services entry point post-Brexit.
Mauritius PIS License
FSC Mauritius PIS — USD $45,000 capital, ~3% tax, 6–9 months. Cost-efficient offshore alternative for non-EU markets.
Singapore MPI License
MAS Major Payment Institution — unlimited volumes, crypto permitted, SGD $250,000. ASEAN institutional benchmark.
Kazakhstan AIFC MSP
AFSA Money Service Provider — 0% tax, digital asset payment services, English common law. CIS market access.
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Disclaimer: This page is provided for informational purposes only and does not constitute legal or regulatory advice. EU regulatory requirements including EMD2, PSD2, and PSD3 may change. Always consult a qualified advisor before initiating a licensing process. Last updated: April 2026.