A Lithuanian Small EMI is an electronic money institution holding a licence for restricted activity, issued by the Bank of Lithuania under Article 7 of the Law on Electronic Money and Electronic Money Institutions. The full EMI (the unrestricted-activity licence under Article 25) carries a EUR 350,000 minimum initial capital requirement, the 2% own-funds ratio against average outstanding electronic money, full consolidated supervision and EEA passporting rights. The Small EMI has none of those: no statutory initial-capital figure, lighter governance, no passporting, and a ceiling on activity (EUR 900,000 average outstanding e-money per month, EUR 3 million in unrelated payment-service turnover) that converts it to the unrestricted file once breached.

The Bank of Lithuania issues both: an unrestricted-activity EMI authorisation that carries the EUR 350,000 initial capital, ongoing own-funds obligations, and full EEA passporting; and a restricted-activity registration (the Small EMI) that confines operations to Lithuania and dispenses with the initial-capital minimum. Public search queries for “emi license in lithuania” cover both, but the acquirer’s real question is which entity profile matches the commercial plan. If the plan is Lithuanian-domestic e-wallet issuance with a defined growth glide path into the full file, the Small EMI is the right entry. If the plan is cross-border from day one, the answer is a full Lithuanian EMI.

Both. The Lithuanian restricted-activity register holds enough seasoned entities that genuine buy-side mandates can be filled on the Small EMI side, although the unrestricted file is the larger and more liquid market. Cadena Brokers maintains a curated Lithuanian Small EMI shortlist behind NDA. Pricing structure, change-of-control conditionality and banking-continuity diligence look very different across the two registers. The Small EMI is the faster transaction, the unrestricted EMI is the broader-perimeter target. Acquirers should mandate against the perimeter they actually need, not the headline phrase.

Article 7 requires Lithuanian registration of the firm, fit-and-proper assessment of senior managers and qualifying shareholders, a viable business plan, an internal control framework proportionate to the limited perimeter, safeguarding arrangements compliant with Article 26 (segregated credit-institution account, low-risk-asset investment, or insurance/guarantee), AML/CFT controls under the Lithuanian Prevention of Money Laundering and Terrorist Financing Act, and adherence to the activity ceilings (EUR 900,000 average outstanding e-money, EUR 3 million unrelated payment-service turnover per month). The Bank of Lithuania publishes the application templates and assesses the file on a target two-month timetable for restricted activity.

No. The Article 7 restricted-activity registration confines the institution’s e-money issuance and payment services to Lithuanian territory. This is the structural distinction from the full Lithuanian EMI, which holds EU-wide passporting rights under EMD2. An acquirer using a Small EMI as the platform for a non-Lithuanian customer base will hit this wall quickly; the practical migration path is to grow the book, breach the EUR 900,000 / EUR 3 million ceiling, and use the thirty-day conversion window to upgrade the file. That upgrade should be modelled at the time of acquisition, not improvised under deadline.

The qualifying-holding regime in the Law on Electronic Money and Electronic Money Institutions mirrors the PSD2 / CRD architecture: any direct or indirect acquisition reaching or crossing 10%, 20%, 30% or 50% of the institution’s capital or voting rights requires prior written notification to the Bank of Lithuania and a fit-and-proper assessment of the proposed acquirer. The regulator’s statutory assessment clock runs in parallel with the share-purchase agreement’s conditions-precedent period. Cadena Brokers sequences the SPA against the qualifying-holding clock to achieve expedited closings without skipping any approval gate.