E-MONEY LICENSE FOR GLOBAL PAYMENTS, PAYMENT CARDS, STABLECOINS. ELECTRONIC MONEY INSTITUTION (EMI) LICENSING IN THE EUROPEAN UNION
All payment services and payment cards. Equity capital – EUR 350,000.
Comprehensive Solutions for Your EMI License, Electronic Money License, Emoney License, and Electronic Money Institution License
Licensed Electronic Money Institution (EMI) allows provision of wider range of financial services compared with the Payment Institution and allows safeguarding of client funds for an unlimited period of time. The Electronic Money Institution licensed in one European Union (EU) member state opens up business opportunities to act and provide services in all other EU/EEA countries by enjoying the benefits of the single European financial market and Single Euro Payments Area (SEPA). Single Euro Payments Area has 450 million consumers and over 20 million businesses making and receiving payments in Euro fast and at a low cost regardless of their location in Europe. Payment and Electronic Money Institutions licensed in Lithuania are allowed to join SEPA directly through the Central Bank avoiding intermediary commercial banks.
Difference between Payment and Electronic Money Institution
The European Central Bank defined the Electronic Money (E-money) as an electronic store of monetary value on a technical device that may be widely used for making payments to entities other than the e-money issuer. The device acts as a prepaid bearer instrument, which does not necessarily involve bank accounts in transactions. The Directive 2009/110/EC established the legal basis for e-money issuing in the European Union (EU). The practical difference between the Electronic Money Institution (EMI) and the Payment Institution (PI) is that e-money institutions in addition to all payment services provided by the PI are entitled to issue Electronic Money and store clients’ funds. The Payment Institutions usually provide instant payment processing services. Possibility to safeguard client’s funds allows IBAN account opening, payment card issuing, and e-wallet services.
2024 Regulatory Update: The primary difference between a Payment Institution and an Electronic Money Institution (EMI) has been further clarified by the CJEU. Following the ruling in Case C-661/22 (ABC Projektai), the court established that receiving and holding funds on a payment account for the purpose of executing future payments does not, by itself, constitute the issuance of electronic money. This marks a significant shift in how funds held without an immediate payment order are classified.
Electronic Money Institution license is the right decision for the payment service providers planning wider range of services
ECOVIS network offers different European jurisdictions for EMI licensing as well as other jurisdictions for money service business licensing globally. Lithuania is one of the EU/EEA jurisdictions that may be considered for an EMI license.
The Electronic Money Institution registered in Lithuania provides a significant competitive advantage and opens up the European financial market at significantly lower incorporation and maintenance costs. Lithuania and primarily its capital Vilnius became a new hub for the FinTech companies focused on international financial markets. Business-oriented regulatory behavior and significantly lower finance institution’s incorporation costs make Lithuania attractive for large international financial institutions as well as innovative FinTech companies. The Bank of Lithuania also operates a regulatory “Sandbox” for innovative FinTech testing. Implemented EU Second Payment Services Directive (PSD2) allows provision of the Payment Initiation Service (PIS) – initiation of a payment order from the client’s bank account at the request of the client from the payment account held at another payment service provider (bank). PSD2 also allows E-money Institution to provide Account Information Service (AIS) by accessing consolidated information from the client accounts held at other payment service providers (banks) and have overall view of the client’s financial information.
Services provided by Electronic Money Institution – EMI
Licensed Electronic Money Institution provides the following payment services:
- services enabling cash to be placed on a payment account.
- services enabling cash withdrawals from a payment account.
- execution of payment transactions, including transfers of funds on a payment account with the payment service provider of the payment service user or with another payment service provider: execution of direct debits, including one-off direct debits, execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders.
- execution of payment transactions where the funds are covered by a credit line for a payment service user: execution of direct debits, including one-off direct debits, execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders.
- issuing and/or acquiring of payment instruments.
- money transfers.
- Payment Initiation Service (PSD2 implementation).
- Account Information Service (PSD2 implementation).
- issuing of Electronic Money and safeguarding of client funds.
Crypto Stablecoin Issuers and MiCA Compliance Obligations
The Markets in Crypto-Assets Regulation (MiCA) establishes strict compliance rules for stablecoin issuers within the European Union. Under MiCAR, Electronic Money Tokens (EMTs) are legally equated to electronic money, meaning their issuance is restricted strictly to regulated credit institutions and authorized Electronic Money Institutions (EMIs). Asset-Referenced Tokens (ARTs) and other digital assets are subject to distinct licensing, white paper notification timelines, and specific capital requirements depending on the home Member State.
For a detailed analysis of token classification, procedural deadlines, and regulatory fees across key EU jurisdictions including Lithuania, Latvia, Estonia, and Ireland, explore our comprehensive MiCA Compliance and EU Jurisdiction Guide.
Direct access to Single Euro Payments Area (SEPA) through CENTROlink payment gateway managed by the Bank of Lithuania (Central Bank)
Why CENTROlink:
- Availability 24/7/365
- Low cost. SEPA Credit Transfer (SCT) and SCT Inst fees – EUR 0.01 – 0.024. SEPA Direct Debit (SDD) fees – EUR 0.08
- Linked with the European payment systems STEP2, RT1 and TIPS without any additional expense or integration
- No limitation on payment values, number of transactions and number of issued IBAN accounts
- No credit risk. Own and client funds safeguarded, and payments made through the Central Bank. It eliminates the risk and costs usually associated with the funds safeguarding with commercial banks
- Individual client IBAN account generation. Individual client IBAN account generation and opening in the own system. No assistance from the commercial banks needed
- Proxy Lookup Service. Payment initiation using payee’s mobile phone number linked to IBAN account
Reasons why Lithuania is top jurisdiction for E-money institution licensing:
- No particular requirement for company directors and board members to reside in Lithuania/Europe.
- Application process starts without establishing a company and freezing up capital.
- Fast licensing process.
- Licensing documentation can be submitted in English.
- Direct access to Single Euros Payments Area (SEPA) through the CENTROlink payment system managed by the Bank of Lithuania (Central Bank).
- Possibility to safeguard client’s funds in the accounts of the Bank of Lithuania (Central Bank of EU member state).
- Remote client verification. Innovative “know your customer” processes for remote client verification allows opening of accounts without physical presence of the client.
- License allows provision of the financial services in all EU/EEA without any additional licensing.
- Start-up visa. Special visas for citizens of non-EU/EEA countries running innovative businesses in Lithuania.
Principal Membership in Mastercard and VISA
ECOVIS ProventusLaw assists Payment, E-money institutions and other FinTech companies in preparation of applications for both Mastercard and VISA Principal Participation and represents them during all the process of becoming the Principal Member of Mastercard and VISA.
ECOVIS experience in finance institution licensing
ECOVIS is the leading global consulting group with over 9000 professionals operating in more than 90 countries around the world. Deep local knowledge in every country where ECOVIS office is located and international expertise of the interdisciplinary network of ECOVIS International professionals allows selection of the right licensing jurisdiction for every EMI business. ECOVIS licensed more than 40 payment and electronic money institutions including Nium and Contis Group. We provide all necessary licensing services, including preparation of licensing documentation, financial part of the application, representation during the licensing procedure, company incorporation, office registration, advice on AML, IT, HR, compliance and other issues arising during the business incorporation. When the license is issued, ECOVIS offers accounting, regulatory reporting, audit, compliance and legal services for the operational business.
Explore our full FinTech licensing solutions.
Learn why ECOVIS is a trusted partner in regulatory compliance.
Recent e-money licensing and electronic money institution related practice
Newrails
Advised a Bank of Lithuania–licensed EMI on drafting its General Terms and Conditions covering payment services, e-money, and e-money token services for retail and business clients. The core challenge was integrating traditional EMI contractual architecture with e-money token functionality within a single regulatory-compliant framework — distinguishing fiat, e-money, and token accounts while maintaining consistent safeguarding, redemption, and consumer protection standards across all service types.
Phoenix Payments
Advised a Bank of Lithuania–licensed EMI on restructuring a cross-border outsourcing arrangement with Emerchantpay (Bulgaria) following a Bank of Lithuania supervisory inspection. The engagement covered full governance framework design — contracts, audit rights, ICT risk, DORA compliance, sub-outsourcing controls, and exit arrangements — while ensuring the client retained regulatory accountability over critical functions across EU jurisdictions.
FINCI
Conducted an independent post-inspection remediation review for a Bank of Lithuania–licensed EMI, assessing whether corrective measures across governance, AML/CTF, sanctions compliance, CDD, transaction monitoring, and internal controls had been effectively implemented and were sustainable under ongoing supervisory scrutiny — including file reviews, system assessments, and senior management interviews.
EMI Applicant in Latvia
Advised an applicant on obtaining a Latvijas Banka EMI licence covering e-money issuance, payment accounts, SEPA, card payments, remittance, and payment initiation — targeting tourists and SMEs across the EU, US, Canada, and Mexico. The engagement covers the full licensing package, cross-border operational structuring, and forward-looking analysis of potential EMT/MiCA integration as the platform evolves.
deVere E-Money
Advised a regulated fintech institution following a supervisory inspection of its sanctions compliance framework by the Bank of Lithuania. The engagement covers formal responses to inspection findings — including challenging disproportionate or insufficiently substantiated supervisory conclusions — and parallel design of a comprehensive sanctions compliance remediation programme spanning governance, screening controls, transaction monitoring, and escalation frameworks.
Acquisition of a regulated EMI group (confidential client)
Advised on the acquisition of a regulated electronic money institution group operating in the UK, Lithuania, and Latvia, involving multi-round amendments to the Share Purchase Agreement, bespoke carve-out and phased wind-down of the Lithuanian EMI, and a coordinated multi-jurisdictional closing structure aligned with FCA, Bank of Lithuania, and Latvijas Banka requirements.
Investment in a Lithuanian EMI (confidential client)
Advised a Switzerland-based investor on a proposed equity investment in a Lithuanian-licensed EMI, combining full regulatory due diligence — covering safeguarding, AML/CTF, governance, ICT, and operational resilience — with transactional structuring, including a letter of intent and call option agreement providing staged, conditional acquisition rights subject to regulatory approvals.
Cross-border EMI outsourcing framework (confidential client)
Advised on a complex three-party cross-border outsourcing framework involving a Latvian EMI and UK regulated entity, covering card programme management, fraud monitoring, KYC/AML tooling, and transaction monitoring across the US, UK, and Latvia. The engagement structured a DORA and EBA Guidelines-compliant outsourcing governance framework with precise regulatory accountability allocation across three contracting parties.
DORA implementation for a hybrid telecoms-financial group (confidential client)
Advised a telecommunications group holding an EMI licence on DORA implementation across a hybrid corporate structure combining telecoms and regulated financial services. The engagement included regulatory scoping to determine proportional DORA application, direct supervisory engagement to clarify interpretative expectations, and full redesign of ICT risk governance, incident reporting, and outsourcing controls — reconciling telecom-scale ICT infrastructure with financial services regulatory accountability.
AML/CTF enforcement defence for a Lithuanian EMI (confidential client)
Represented a Bank of Lithuania–licensed EMI in administrative court proceedings challenging an AML/CTF enforcement action and regulatory fine. The defence strategy included detailed analysis of inspection findings, a comparative expert opinion from German AML/CTF specialists, and a structured reassessment of approximately 30 customer files — identifying instances where supervisory conclusions did not fully reflect available evidence or proportionality standards applicable to regulated fintech institutions.
Qualifying holding acquisition of a Lithuanian EMI (confidential client)
Advised on a proposed acquisition of a Bank of Lithuania–licensed EMI through a qualifying holding process, including governance remediation, AML/CTF controls, DORA compliance, and shareholder suitability assessment. The matter concluded with strategic advice on transaction withdrawal following identification of heightened supervisory risk exposure at the target institution.
Regulatory due diligence and acquisition remediation for a Latvian EMI (confidential client)
Advising on regulatory due diligence and transaction-readiness structuring for a contemplated acquisition of a Latvijas Banka–licensed EMI, converting supervisory findings across AML/CTF, DORA, governance, outsourcing, and ICT risk into a comprehensive pre- and post-closing remediation framework — including transaction document structuring covering warranties, covenants, and regulatory closing conditions.
Licensing capital structuring for a Latvian fintech applicant (confidential client)
Advised a fintech group on restructuring its funding model in response to Latvijas Banka supervisory concerns, including structuring initial capital via subordinated loan, source of funds transparency, and a revolving credit facility as a secondary liquidity layer — ensuring prudential capital buffer compliance throughout the licensing process.
Kęstutis Kvainauskas
Lawyer, attorney at law, partner of the law firm.
+370 5 212 40 84
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