Notes & Assumptions EMI License Lithuania


  • An accumulative bank account must be opened at the incorporation of the EMI and is used for the sole purpose of company establishment (for the payment of share capital and reserves) and cannot be used for operational purposes prior to the conversion to a current bank account.
  • The conversion of the accumulative bank account to a current bank account is a quite lengthy process and may be carried out after the incorporation of the company since a bank/EMI would need to run AML/KYC
  • Since we and our partners are providing law firm legal services, the following licensing-related documents fall out of our scope of work: preparing business plan, activity program, financial modeling, and financial forecasts;
  • preparing IT policies and security descriptions of IT systems as well as a description of the implementation of the technical API;
  • preparing the description of operational risk and operational and security risk assessment report; and
  • description of administrative, risk management, and accounting risk control systems.
  • If required, we may outsource the preparation of the above-mentioned documents to reputable specialized local service providers with whom we have good partnership relations and team up on similar projects.
  • The fee quotes from these specialized local service providers may be provided upon request
  • The EMI license issued by the BoL is conditional upon opening the safeguarding account for keeping the clients’ funds.
  • We may assist in the safeguarding account opening process for an additional fee to be agreed upon once the scope of our services becomes clear
  • In order to provide services across the EU, the EMI needs to undergo the passporting process after the license is issued. We may assist in this process for a separately discussed fee after the license is issued.
  • In order to connect to CENTROlink, the EMI needs to undergo a separate process after the license is issued. We may assist in this process for a separately discussed fee after the license is issued


The fixed fee indicated in the fee section is offered on the basis of the following assumptions:

  • the Client will be cooperative in providing input in respect of activities, models, and essential processes as well as providing responses to our queries and submitting documents of shareholders, UBOs, and managers (CVs, certificates of non-conviction, etc.)
  • license application documents will be prepared within 3 months from the start of the assignment
  • all documents will be prepared in either English or Lithuanian
  • our assistance will be limited to up to two rounds of comments on each document from our side
  • what we have learned from all our previous licensing procedures is that pricing extremely depends on:
    • how much is undertaken by the Client / what the Client shares with us vs. What is needed from our side plus
    • how BoL reacts.

As both aspects are outside of our control, we cannot offer a cap. The fee quote is based on our experience from previous procedures.

This page was last updated on June 5, 2023.

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