You want passportable e-money rails inside the EU, and you want them before the next board meeting. A Lithuanian EMI delivers both. Lithuania still authorizes more electronic money institutions than any other EU member state, and Cadena Brokers writes only one side of the deal: yours, the acquirer.
JURISDICTION
A regulator built for fintech, on purpose
The Bank of Lithuania (Lietuvos bankas) supervises EMIs under the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions, and it has spent the past decade positioning itself as the EU’s most accessible e-money authority. By the close of 2024 the regulator oversaw 119 licensed electronic money and payment institutions serving roughly 2.2 million active clients, with sector revenue at EUR 571 million and growing 15% year on year.
What that means for an acquirer is straightforward: every Lithuanian EMI carries an EEA passport. One change-of-control approval gives you a regulated entity that can market into Germany, France, the Netherlands and 24 other member states without filing a fresh authorization. (The passport notification itself runs through the home-state regulator, which keeps the ongoing supervisory relationship singular and predictable.)
SCOPE
Issue e-money. Run payment services. Passport everywhere.
A full Lithuanian EMI may issue, distribute and redeem electronic money, and operate any of the payment services listed in the Lithuanian transposition of PSD2: account-information and payment-initiation services, money remittance, card acquiring, card issuing, and the rest of the EMD2 catalogue. Statutory minimum initial capital sits at EUR 350,000.
Safeguarding is non-negotiable. Funds received against issued e-money must sit in a segregated account at an EU credit institution, in low-risk liquid assets, or behind a comparable insurance or guarantee policy. The Bank of Lithuania checks this on every supervisory review, and it is the single most common reason a target’s pre-acquisition diligence file gets reopened. We pre-test the safeguarding setup for every EMI in our Lithuanian book before introducing the file to a buyer.
OUR LITHUANIAN BOOK
What you can expect to see
Entities we present in Lithuania typically fall into one of three profiles. First, the operating EMI with live cards-issuing or e-wallet revenue, full Bank of Lithuania reporting current, two or more active correspondent banking relationships, and 8 to 25 retained FTE across compliance, ops and tech. Second, the regulated-but-quiet vehicle: licensed and clean, low transaction volume, useful where the acquirer brings their own product and just needs a permitted entity. Third, the carve-out subsidiary detaching from a larger group, with its own banking, AML program and key staff that the parent has agreed to release.
Every file is pre-screened for change-of-control viability, sanctions exposure on the UBO chain, and banking continuity. None of our Lithuanian targets is a shell. The Bank’s 1 January 2026 substance reforms have made shell entities unsellable to a serious acquirer, and we have walked away from listings that did not pass the resident-decision-maker test.
PROCESS
Mandate to change-of-control approval
The acquisition runs through four gates: NDA and acquirer brief, shortlist of pre-vetted Lithuanian EMIs against your operating thesis, structured diligence covering regulatory standing and banking continuity, and the Bank of Lithuania change-of-control filing. The Bank has 60 working days to oppose the proposed acquirer once a complete notification is filed, extendable by a further 30 days if it requests additional information. Detailed step description sits on the homepage at /#process.
WHY CADENA
Why acquirers come to us for Lithuanian files
One side of the table, every time
Sellers’ brokers optimize for closing the trade. We optimize for what you actually own on day one: a clean entity, a working banking stack, a compliance team that stays.
Pre-tested change-of-control file
The Bank of Lithuania publishes its fit-and-proper questionnaires. We run your acquisition vehicle and proposed senior team through them in advance, then tell you which positions need a second hire before you sign.
2026 substance reforms in the checklist
The January 2026 governance overhaul is a hard filter. Acquirers walking in with a non-resident board and outsourced everything will fail the assessment. We say so up front, and price the risk into the deal.
FAQ
Buyer questions on Lithuanian EMIs
What is the minimum initial capital for a Lithuanian EMI?
The statutory floor for a full EMI is set out in the Scope section above. Restricted-activity EMIs are exempt from that floor, but they face an activity cap (average outstanding e-money of EUR 900,000 over the prior six months under Article 12 of the Law). Most acquirers we work with find the restricted-activity ceiling too narrow for what they want to build.
Can a Lithuanian EMI passport into the rest of the EEA?
Yes. Once you complete change-of-control, the entity continues to passport into all EEA member states under its existing notifications. No fresh authorization is required. New host states can be added through a passporting notification filed with the Bank of Lithuania.
How long does Bank of Lithuania change-of-control approval take?
The Bank has 60 working days to oppose a proposed acquirer once it has a complete notification, extendable by 30 days if it requests additional information. We do not promise calendar dates. What we do is structure the file to minimize information requests and keep the clock running.
What changes on 1 January 2026?
New substance and governance requirements take effect: resident, competent and independent decision-makers, demonstrable risk management frameworks, agent oversight obligations, and an end to “empty shell” structures. Targets in our Lithuanian book have already been re-screened against the new rules.
Do you handle sell-side mandates on Lithuanian EMIs?
No. Cadena Brokers is buy-side only. Sellers should approach a different brokerage; we do not represent both sides on a transaction.
What if our preferred target is not in your book?
Send the acquirer brief. We source against your specification and revert with pre-vetted candidates, or with a clean note that we do not have a fit at the moment.
Acquire a Lithuanian EMI
Tell us your operating thesis, the service envelope you need (cards issuing, account-information, e-wallet, remittance), and the banking expectations on day one. We come back inside one working day with a shortlist or a clean “no fit right now.”
RELATED JURISDICTIONS
Adjacent files to consider
If Lithuania is not the right fit, two neighbouring EMI markets are worth a look: Poland for a larger domestic banking pool with a slower licensing cadence, and Estonia for a smaller register where the regulator runs a tighter substance test from day one. The full coverage page lists every licence family we handle.
