Requirements and Process for Obtaining EMI License in Lithuania
Lithuania has become a leading country for fintech startups due to the ease of obtaining an electronic money institution (EMI) license. The license is issued by the Lithuanian Central Bank, which also assesses the applications for these licenses. The process of obtaining the license takes around three months.
Initial Meeting and Application Submission
The first step is to discuss the business model and potential risks with the Lithuanian Central Bank. The applicant must submit an application form for an EMI license to the supervision service of the Bank of Lithuania for review.
Capital Requirements
The initial capital requirement for an EMI is 350,000 EUR. However, small EMIs are not subject to this initial capital. The founder(s) of an e-money institution must undergo an investor screening procedure with the CCSSO, which is a separate procedure from licensing.
Assessment and Decision
Once the application for a license and the documents are assessed, the information is analyzed, and the decision on whether to issue the license is made by the Board of the Bank of Lithuania. The fee for an EMI license is 1,463 EUR, and for a small EMI, it is 1,235 EUR.
Board and Personnel Requirements
The company must have a Board consisting of a minimum of three members and the CEO. When applying for a license, the company must provide information on key personnel, such as the anti-money laundering officer and information security officer. It is vital to prove that the relevant employees have the necessary qualifications and experience.
Required Documents
The documents needed for submission include:
- Documents confirming the legal status of the applicant
- Document confirming the right of representation of a representative
- Document confirming the payment of stamp duty for license issue
- Program of operations
- Business plan
- Documentary evidence that the minimum size of the equity capital does not fall below the amount specified in Article 22(2) for EMI or Article 14(2) for PI of the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions
- Description of measures taken (to be taken) to safeguard consumer funds
- Description of governance arrangements and internal control mechanisms, including administrative, risk management and accounting systems
- Description of structural organization
- Notification of the proposed acquisition
- Questionnaires of members of the management body and key function holders
- Professional indemnity insurance contract and documents confirming other equivalent liability guarantees and details and substantiation of calculation of the sum insured or of other comparable liability guarantee
- Questionnaire on the operational risk of the applicant’s activities
Small EMI Requirements
For a small EMI, the documents proving that the average outstanding electronic money of the electronic money institution will not exceed EUR 900k and the average of the preceding 12 months’ total amount of payment transactions executed by the payment institution will not exceed EUR 3m per month are required.
In summary, Lithuania offers a fast and straightforward process for obtaining an EMI license, making it an attractive destination for fintech startups.
Contact Valcorp lawyers in Lithuania to license your EMI patent in Lithuania by contacting us in email: info@valcorp.eu or via call +372 55658650