🇩🇪 Germany vs 🇱🇹 Lithuania: e-money licensing compared

Germany and Lithuania take recognisably different routes to e-money authorisation. In Germany the route is the E-Geld-Institut under the ZAG. overseen by BaFin, with the Deutsche Bundesbank.; in Lithuania it is the EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. under Bank of Lithuania (Lietuvos bankas).. The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.

Germany: verified 2026-07-03 · Lithuania: verified 2026-07-03

Dimension	🇩🇪 Germany partly open Verified 2026-07-03	🇱🇹 Lithuania partly open Verified 2026-07-03
Licence type	E-Geld-Institut under the ZAG. Verified 2026-07-02 Source: BaFin	EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. Verified 2026-07-02 Source: Bank of Lithuania, https://www.lb.lt/en/authorisation-of-electronic-money-institutions
Regulator	BaFin, with the Deutsche Bundesbank. Verified 2026-07-02 Source: BaFin, https://www.bafin.de/DE/Aufsicht/ZahlungsdienstePSD2/ZahlungsdienstePSD2_node.html	Bank of Lithuania (Lietuvos bankas). Verified 2026-07-02 Source: Bank of Lithuania, https://www.lb.lt/en/fs-electronic-money-institutions
Capital requirement	Germany capital requirement is locked. Unlock with the £349 pass.	Lithuania capital requirement is locked. Unlock with the £349 pass.
Timeline to authorisation	Germany timeline to authorisation is locked. Unlock with the £349 pass.	Lithuania timeline to authorisation is locked. Unlock with the £349 pass.
Local substance	Germany local substance is locked. Unlock with the £349 pass.	Lithuania local substance is locked. Unlock with the £349 pass.
Application cost	Germany application cost is locked. Unlock with the £349 pass.	Lithuania application cost is locked. Unlock with the £349 pass.
Ongoing cost	Germany ongoing cost is locked. Unlock with the £349 pass.	Lithuania ongoing cost is locked. Unlock with the £349 pass.
Passporting	Germany passporting is locked. Unlock with the £349 pass.	Lithuania passporting is locked. Unlock with the £349 pass.
EMIs authorised	Germany emis authorised is locked. Unlock with the £349 pass.	Lithuania emis authorised is locked. Unlock with the £349 pass.
Key restrictions	Germany key restrictions is locked. Unlock with the £349 pass.	Lithuania key restrictions is locked. Unlock with the £349 pass.
Safeguarding	Germany safeguarding is locked. Unlock with the £349 pass.	Lithuania safeguarding is locked. Unlock with the £349 pass.
Recent changes	PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Verified 2026-07-03 Source: EU	PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Continued AML tightening. Verified 2026-07-03 Source: EU
Difficulty rating	Germany difficulty rating is locked. Unlock with the £349 pass.	Lithuania difficulty rating is locked. Unlock with the £349 pass.

The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Unlock the pass to see each figure with its source and verification date.

What changed recently

🇩🇪 Germany (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.

🇱🇹 Lithuania (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Continued AML tightening.

Quick answers

Who regulates e-money licensing in Germany and Lithuania?

Germany: BaFin, with the Deutsche Bundesbank.. Lithuania: Bank of Lithuania (Lietuvos bankas)..

What licence do you need in Germany compared with Lithuania?

In Germany the authorisation route is E-Geld-Institut under the ZAG.; in Lithuania it is EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.. The comparison table on this page lines the two up dimension by dimension.

Where can I see the full Germany vs Lithuania comparison?

The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/germany-vs-lithuania.

Open this pair in the interactive benchmark Unlock every figure

Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.