🇩🇪 Germany vs 🇱🇹 Lithuania: e-money licensing compared
Decision context and regulator route
Germany and Lithuania are commonly considered side by side for 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 public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Germany: verified 2026-08-15 · Lithuania: verified 2026-08-15
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-08-15
|
🇱🇹 Lithuania
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. |
| Regulator | BaFin, with the Deutsche Bundesbank. | Bank of Lithuania (Lietuvos bankas). |
| Capital requirement | Germany capital requirement is included in the £349 pass. | Lithuania capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Lithuania timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Lithuania local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Lithuania application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Lithuania ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Lithuania passporting is included in the £349 pass. |
| EMIs authorised | Germany emis authorised is included in the £349 pass. | Lithuania emis authorised is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Lithuania key restrictions is included in the £349 pass. |
| Safeguarding | Germany safeguarding is included in the £349 pass. | Lithuania safeguarding is included in the £349 pass. |
| Recent changes | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | Lithuania difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇪 Germany (verified 2026-08-15): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
🇱🇹 Lithuania (verified 2026-08-15): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
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.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.