🇱🇹 Lithuania vs 🇱🇺 Luxembourg: e-money licensing compared
Decision context and regulator route
Lithuania and Luxembourg are commonly considered side by side for e-money authorisation. In Lithuania the route is the EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. overseen by Bank of Lithuania (Lietuvos bankas).; in Luxembourg it is the Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. under Commission de Surveillance du Secteur Financier (CSSF). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Lithuania: verified 2026-08-15 · Luxembourg: verified 2026-08-15
| Dimension |
🇱🇹 Lithuania
partly open
Verified 2026-08-15
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🇱🇺 Luxembourg
partly open
Verified 2026-08-15
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|---|---|---|
| Licence type | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. |
| Regulator | Bank of Lithuania (Lietuvos bankas). | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Lithuania capital requirement is included in the £349 pass. | Luxembourg capital requirement is included in the £349 pass. |
| Timeline to authorisation | Lithuania timeline to authorisation is included in the £349 pass. | Luxembourg timeline to authorisation is included in the £349 pass. |
| Local substance | Lithuania local substance is included in the £349 pass. | Luxembourg local substance is included in the £349 pass. |
| Application cost | Lithuania application cost is included in the £349 pass. | Luxembourg application cost is included in the £349 pass. |
| Ongoing cost | Lithuania ongoing cost is included in the £349 pass. | Luxembourg ongoing cost is included in the £349 pass. |
| Passporting | Lithuania passporting is included in the £349 pass. | Luxembourg passporting is included in the £349 pass. |
| EMIs authorised | Lithuania emis authorised is included in the £349 pass. | Luxembourg emis authorised is included in the £349 pass. |
| Key restrictions | Lithuania key restrictions is included in the £349 pass. | Luxembourg key restrictions is included in the £349 pass. |
| Safeguarding | Lithuania safeguarding is included in the £349 pass. | Luxembourg 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 | Lithuania difficulty rating is included in the £349 pass. | Luxembourg difficulty rating is included in the £349 pass. |
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What changed recently
🇱🇹 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.
🇱🇺 Luxembourg (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 Lithuania and Luxembourg?
Lithuania: Bank of Lithuania (Lietuvos bankas).. Luxembourg: Commission de Surveillance du Secteur Financier (CSSF).
What licence do you need in Lithuania compared with Luxembourg?
In Lithuania the authorisation route is EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.; in Luxembourg it is Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Lithuania vs Luxembourg 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/lithuania-vs-luxembourg.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.