🇮🇪 Ireland vs 🇱🇹 Lithuania: e-money licensing compared
Choosing between Ireland and Lithuania for a e-money licence starts with who you will answer to: Central Bank of Ireland (CBI). on one side, Bank of Lithuania (Lietuvos bankas). on the other, via the E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. and the EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. respectively. The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Every figure behind the comparison carries a last-verified date and a primary source.
Ireland: verified 2026-07-03 · Lithuania: verified 2026-07-03
| Dimension |
🇮🇪 Ireland
partly open
Verified 2026-07-03
|
🇱🇹 Lithuania
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. |
| Regulator | Central Bank of Ireland (CBI). | Bank of Lithuania (Lietuvos bankas). |
| Capital requirement | Ireland capital requirement is locked. Unlock with the £349 pass. | Lithuania capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Ireland timeline to authorisation is locked. Unlock with the £349 pass. | Lithuania timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Ireland local substance is locked. Unlock with the £349 pass. | Lithuania local substance is locked. Unlock with the £349 pass. |
| Application cost | Ireland application cost is locked. Unlock with the £349 pass. | Lithuania application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Ireland ongoing cost is locked. Unlock with the £349 pass. | Lithuania ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Ireland passporting is locked. Unlock with the £349 pass. | Lithuania passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Ireland emis authorised is locked. Unlock with the £349 pass. | Lithuania emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Ireland key restrictions is locked. Unlock with the £349 pass. | Lithuania key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Ireland 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. | 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. |
| Difficulty rating | Ireland 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
🇮🇪 Ireland (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 Ireland and Lithuania?
Ireland: Central Bank of Ireland (CBI).. Lithuania: Bank of Lithuania (Lietuvos bankas)..
What licence do you need in Ireland compared with Lithuania?
In Ireland the authorisation route is E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.; 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 Ireland 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/ireland-vs-lithuania.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.