Latvia EMI, PI & Specialised Banking License 2026 — Latvijas Banka Authorization Guide

Latvijas Banka-regulated EMI and PI authorization under EMD2/PSD2 — €350K EMI capital, a 3-month statutory review clock, EU passporting across 30 EEA states, and an Estonian-model 0%/20% deferred corporate tax. The Baltic EU passport alternative to Lithuania

REGULATOR
Latvijas Banka
MIN. CAPITAL
€350,000 (EMI)
TIMELINE
7–10 months (EMI)
LAST UPDATED
June 2026

— Last updated: June 2026 · 10 min read

Latvia — The Overlooked Baltic Fintech Jurisdiction

Latvia is the Baltic fintech jurisdiction that most founders overlook — and that is precisely why it offers strategic value in 2026. While Lithuania processes more EMI applications and has a larger fintech ecosystem, Latvia offers the same EU passporting, the same capital requirements, and the same PSD2/EMD2 framework under a single regulator: Latvijas Banka, the Bank of Latvia, which absorbed the former Financial and Capital Market Commission (FKTK) functions on 1 January 2023. The consolidation of financial supervision under a single authority has made Latvia's regulatory environment more coherent and predictable.

Latvia operates a three-month statutory review clock. English is accepted for the substantive application file (some statutory forms remain in Latvian). Capital is €350,000 for a full EMI and €20,000–€125,000 for a PI. The real-world timeline runs from 5–8 months (PI) to 7–10 months (EMI). Latvia's corporate income tax operates on an Estonian-inspired model — 0% on undistributed profits, 20% applied only on profit distribution — creating a genuine tax deferral advantage for reinvestment-focused fintechs. A Latvian EMI or PI provides full EU passporting across 30 EEA member states and positions the operator in the Baltic corridor bridging Scandinavia, the Baltics, Poland, and the wider EU.

Latvia in 2026 — Licensing Activity and Pipeline

The data from Latvijas Banka confirms Latvia's accelerating position as a serious EU fintech licensing hub. In 2025, Latvijas Banka issued 8 licences to fintech companies. As of May 2026, 7 further licences have already been issued in 2026 — across payment institutions, electronic money institutions, and crypto-asset service providers. Currently, 15 companies are in the active licensing stage and 29 companies are in the pre-licensing consultation stage simultaneously — over 44 live projects in the Latvijas Banka pipeline as of mid-2026.

International interest is broad and growing. Companies from Poland, Spain, Germany, Turkey, Canada, and the United Kingdom — among others — have sought licences for payment, EMI, and crypto-asset service provision in Latvia.

First MiCA licence in Latvia:

On 3 December 2025, Latvijas Banka issued Latvia's first MiCA CASP licence to BlockBen SIA — confirming Latvia as an active CASP authorization jurisdiction. Additional MiCA applications are currently in licensing and pre-licensing stages.

This pipeline activity signals that Latvia is no longer the overlooked Baltic alternative — it is an increasingly credible primary destination for EU payment and crypto licensing in its own right.

Why Latvia for Payment Businesses

Single Supervisor — Latvijas Banka

Since January 2023, one regulator supervises credit institutions, payment institutions, EMIs, and investment firms — one point of contact and consistent standards across all financial services.

0% / 20% Deferred Tax Model

An Estonian-inspired CIT system: 0% on undistributed profits, 20% only on distribution. A genuine deferral advantage for reinvestment-focused, capital-efficient fintechs.

Lower Application Competition

Latvia's smaller, less crowded ecosystem means lower competition for regulator attention compared to an oversupplied Lithuania — often a smoother path to authorization.

EU Passporting — 30 EEA States

Identical passporting rights to Lithuania — serve clients across all 30 EEA countries from a single Latvijas Banka authorization.

Latvijas Banka — The Single Supervisor

Since 1 January 2023, Latvijas Banka (the Bank of Latvia) became the single supervisor for credit institutions, payment institutions, electronic money institutions, and investment firms in Latvia — absorbing all functions previously held by the FKTK (Financial and Capital Market Commission).

This consolidation is a material improvement: one regulator, one point of contact, and consistent supervisory standards across all financial services entities. Operators choosing Latvia for both an EMI/PI and an investment firm license (CMS equivalent or investment advisory) deal with a single regulatory body for both.

Direct EKS (Electronic Clearing System) access:

Non-bank payment service providers in Latvia can access the Electronic Clearing System (EKS) operated by Latvijas Banka directly — a significant infrastructure advantage for PI and EMI licensees. Direct EKS access reduces reliance on bank intermediaries for domestic Latvian payment clearing and complements SEPA access for cross-border transactions.

Latvia vs Lithuania — Which Baltic EMI?

This is the most common question from operators considering Baltic EU EMI jurisdictions:

FeatureLatviaLithuania
RegulatorLatvijas Banka (single)Bank of Lithuania
EMI capital€350K€350K
PI capital€20K–€125K€20K–€125K
Statutory clock3 months3 months
Real-world EMI timeline7–10 months6–12 months
Specialised banking licenseYes — €1M capital (Jan 2026)Yes — model Latvia followed
Standard bank license€5M capital€5M capital
MiCA CASPYes — €2,500 fee (lowest EU)Yes — well established
First MiCA license issuedDec 2025 (BlockBen)2024
EKS / CENTROlink direct accessEKS (Latvijas Banka)CENTROlink (BoL)
CIT model0% undistributed / 20% on distribution17% flat
Active licensing pipeline44+ companies mid-2026Larger, more established
Licences issued in 20258Higher volume
Fintech ecosystemSmaller, less crowdedLargest EU
Application competitionLowerHigher
Pre-licensing consultationsFree, unlimitedYes
LanguageEnglish + some Latvian formsEnglish
Best forCEE/Baltics, tax-efficient, less crowdedCrypto-fintech, neobanks, SEPA priority

Choosing Between Them:

Choose Lithuania when CENTROlink direct SEPA access is a priority — it is Lithuania's most material technical advantage and no other EU jurisdiction offers it. Choose Latvia when minimizing competition for regulator attention, optimizing for the 0%/20% distributed-profit tax model, or building a CEE/Baltic-focused operation where Lithuania is oversupplied with similar licensees.

Latvia's New Specialised Credit Institution License (January 2026) — The €1M Banking License

The most significant development in Latvian financial licensing since the FKTK merger: amendments to Latvia's Credit Institutions Law entered into force on 6 January 2026, introducing an entirely new category of financial market participant — the Specialised Credit Institution.

This is not an EMI or PI variant. It is a banking license with materially reduced capital — the first new banking license category introduced in Latvia in decades. For founders researching the new Latvia banking license 2026, the Latvia specialised credit institution is effectively a Latvia neobank license 2026: a €1 million capital requirement that unlocks deposit-taking, lending, and crypto services under Latvijas Banka supervision.

What the Specialised Credit Institution Can Do

A specialised credit institution operates with the capabilities of a traditional bank at a fraction of the capital threshold:

  • Accept deposits from the public (the defining banking activity — not available to EMIs or PIs)
  • Issue loans and credit
  • Provide the full range of payment services
  • Offer leasing and investment services
  • Provide crypto-asset services (CASP activities)
  • Operate across the entire European Union via passporting

Capital and Requirements

FeatureSpecialised Credit InstitutionStandard BankEMI
Minimum capital€1,000,000€5,000,000€350,000
Deposit-takingYesYesNo
LendingYesYesNo
Payment servicesYesYesYes
Crypto servicesYesYesNo (separate CASP)
EU passportingYesYesYes
SupervisorLatvijas BankaLatvijas BankaLatvijas Banka
Subject to banking supervisionYes — same frameworkYesNo
CRR/CRD complianceProportionate applicationFullNo
Annual auditMandatory (banking standard)MandatoryMandatory

The critical difference from an EMI:

A specialised credit institution can accept customer deposits as a principal activity — creating a liability on its balance sheet and providing the foundational banking service that no EMI or PI can offer. This enables true neobank functionality without the €5M capital barrier of a traditional banking licence.

Who This Is For

The specialised credit institution licence is designed for operators who need banking status but cannot justify the €5M capital of a traditional bank:

  • Neobanks targeting EU retail or business customers with deposit products
  • Fintech groups that have outgrown EMI/PI constraints and need lending and deposit-taking capability
  • Payment institutions looking to add deposit-taking to an existing PI framework
  • VASP operators seeking a combined banking + crypto service structure under a single Latvian licence

At least 3–4 market participants had already entered consultations with Latvijas Banka on the specialised credit institution licence within the first weeks of the law entering into force (January 2026). The framework was modelled on Lithuania's specialised bank licence, which has produced successful neobank authorisations including Revolut's Lithuanian banking licence.

Application Readiness

Applications for specialised credit institution status are submitted to Latvijas Banka. The supervisory framework — risk management, governance, capital adequacy, liquidity requirements — applies proportionately relative to the institution's scale and risk profile, but is based on banking supervisory standards, not EMI standards. Applicants should expect a more intensive review process than an EMI application.

Zitadelle AG advises fintech groups, neobanks, and scaling payment operators on specialised credit institution strategy and application preparation in Latvia.

Latvia MiCA CASP License — Lowest EU Application Fee

Latvia is an active CASP authorization jurisdiction under MiCA from early 2025. Latvijas Banka issued Latvia's first two MiCA licences in late 2025, with multiple additional applications in progress as of mid-2026.

Why Latvia for MiCA CASP: The most accessible EU CASP entry point by application cost — the MiCA examination fee in Latvia is €2,500, the lowest examination fee in the entire European Union. The annual supervision fee is 0.6% of gross revenue with a floor of €3,000.

MiCA CASP capital tiers in Latvia:

  • Class 1 (advisory, portfolio management): €50,000
  • Class 2 (exchange, custody): €125,000–€150,000
  • Class 3 (operating a trading platform): €150,000

Pre-licensing consultations are available for CASP applicants — Latvijas Banka allows document submission in English during the consultation stage and provides qualitative assessment of business model and governance readiness before formal submission. Approximately 100 free pre-licensing consultations are offered annually.

Once authorized, Latvian CASP licensees passport their services across all 30 EEA countries under MiCA's passporting mechanism. For crypto-fintech operators combining a payment/EMI function with CASP services — a Latvian EMI or PI plus MiCA CASP authorization under the same Latvijas Banka single supervisor provides the most integrated regulatory structure available in the Baltic region.

Full MiCA CASP Guide →

Key Requirements

  • Corporate structure — Latvian SIA (private limited company) with registered office and genuine operational presence in Latvia.
  • Management — minimum 2 board members with relevant financial services experience. Latvijas Banka conducts fit-and-proper assessment. Clean records required for all management and significant shareholders.
  • Capital — EMI: €350,000 paid up in a Latvian credit institution. PI: €20,000–€125,000. Capital buffer may be required above the minimum based on business plan.
  • Safeguarding — client e-money must be safeguarded in segregated accounts at an authorized credit institution or covered by insurance/guarantee.
  • AML/CFT — full AML programme: MLRO, risk-based CDD, transaction monitoring, and STR filing with the Latvian FIU.
  • Business plan — 3-year projections, services description, technology infrastructure, and target markets.
  • Office and substance — real Latvian office required. Management presence in Latvia. Latvijas Banka expects genuine operations, not a letter-box entity.

Latvia's Tax Advantage

Latvia operates a deferred CIT model:

  • 0% corporate income tax on retained (undistributed) profits
  • 20% CIT on distributed profits (dividends)

For fintech operators that reinvest operating profits into growth — product development, team expansion, technology infrastructure — the Latvian model provides a genuine deferral advantage. Tax is only triggered when profits are distributed to shareholders. This model is similar to Estonia's well-known 0%/20% CIT system and makes Latvia attractive for capital-efficient growth-stage fintechs that prioritize reinvestment.

Cost Breakdown

ItemCost
Latvijas Banka application fee~€1,000–€2,500
Minimum capital (EMI, held in company)€350,000
PI capital (minimum)€20,000–€125,000
Company incorporation (SIA)€500–€1,500
Advisory/legal service€15,000–€40,000
Annual audit€8,000–€18,000
Annual compliance (MLRO etc.)€12,000–€30,000
Office/substance€8,000–€20,000/year
Year 1 all-in (excl. capital)€45,000–€115,000

How Zitadelle AG Assists

  • Initial regulatory scoping — determining whether a Latvian EMI or PI is the right authorization, and benchmarking against Lithuania
  • Latvian SIA incorporation and operational substance setup
  • Full Latvijas Banka application preparation — business plan, financial projections, compliance and AML/CFT programmes
  • Management suitability — preparing board members and key function holders for fit-and-proper assessment
  • Safeguarding and capital structuring with a Latvian credit institution
  • EU passporting notifications across the 30 EEA states
  • Tax structuring advice around the 0%/20% deferred CIT model
  • Post-authorization compliance support and ongoing regulatory obligations

Zitadelle AG assists Baltic and CEE-facing fintechs, e-wallet operators, and PSPs with Latvian EMI and PI authorization — from initial scoping and SIA incorporation through the full Latvijas Banka application and EU passporting. Contact Zitadelle AG for a confidential initial consultation on your Latvia EMI or PI License.

Disclaimer:

Last updated: June 2026. Sources: Latvijas Banka (Bank of Latvia), Latvia Law on Payment Services and Electronic Money, EU EMD2/PSD2. This page is for informational purposes only and does not constitute legal or regulatory advice.

How the Process Works

01

Initial Consultation

1–2 days

Free scoping call — jurisdiction selection, structure, capital requirements, and timeline assessment.

02

Document Collection

2–4 weeks

Gather all required KYC, corporate, and background documentation for all directors, shareholders, and UBOs.

03

Application Preparation

4–12 weeks

Preparation of the full application package — business plan, compliance programme, financial projections, and regulatory documentation.

04

Submission & Review

7–10 months

Submission to the regulator. Our team manages all follow-up queries and information requests during the assessment period.

05

License Issued

7–10 months

Authorization granted. Post-licensing support covers compliance setup, banking introductions, and ongoing regulatory obligations.

Frequently Asked Questions

On 1 January 2023, Latvijas Banka (the Bank of Latvia) absorbed all supervisory functions previously held by the FKTK (Financial and Capital Market Commission). Latvijas Banka is now the single supervisor for credit institutions, payment institutions, electronic money institutions, and investment firms in Latvia. This consolidation created a single point of contact for all regulated financial entities, making Latvia's regulatory framework more coherent and predictable.

Ready to apply for a Latvia EMI or PI License?

Zitadelle AG provides end-to-end Latvian EMI and PI authorization — from regulatory scoping and SIA incorporation through the full Latvijas Banka application, EU passporting notifications, and post-authorization compliance support.

Quick Facts

Regulator
Latvijas Banka (Bank of Latvia) — since Jan 2023
Framework
PSD2 / EMD2 / Law on Payment Services (Latvia)
Capital (EMI)
€350,000
Capital (PI)
€20,000–€125,000 (PSD2 Article 7)
Timeline
5–8 months (PI); 7–10 months (EMI)
Statutory Clock
3 months from complete file
CIT
20% (0% on undistributed profits — Estonian-model)
Passporting
30 EEA countries
Best For
Baltic/CEE-facing fintechs, e-wallets, PSPs
Updated
June 2026

Disclaimer: This page is for informational purposes only and does not constitute legal or regulatory advice. Requirements, timelines, and fees are subject to change. Always consult directly with the relevant regulatory authority or a qualified professional for the most current information. Zitadelle Advisory Group LTD is not a law firm and does not provide legal representation.