🇱🇹 Lithuania vs 🇳🇱 Netherlands: e-money licensing compared
Decision context and regulator route
Lithuania's public EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. and Netherlands's public Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Lithuania: verified 2026-08-15 · Netherlands: verified 2026-08-15
| Dimension |
🇱🇹 Lithuania
partly open
Verified 2026-08-15
|
🇳🇱 Netherlands
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. | Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence |
| Regulator | Bank of Lithuania (Lietuvos bankas). | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Lithuania capital requirement is included in the £349 pass. | Netherlands capital requirement is included in the £349 pass. |
| Timeline to authorisation | Lithuania timeline to authorisation is included in the £349 pass. | Netherlands timeline to authorisation is included in the £349 pass. |
| Local substance | Lithuania local substance is included in the £349 pass. | Netherlands local substance is included in the £349 pass. |
| Application cost | Lithuania application cost is included in the £349 pass. | Netherlands application cost is included in the £349 pass. |
| Ongoing cost | Lithuania ongoing cost is included in the £349 pass. | Netherlands ongoing cost is included in the £349 pass. |
| Passporting | Lithuania passporting is included in the £349 pass. | Netherlands passporting is included in the £349 pass. |
| EMIs authorised | Lithuania emis authorised is included in the £349 pass. | Netherlands emis authorised is included in the £349 pass. |
| Key restrictions | Lithuania key restrictions is included in the £349 pass. | Netherlands key restrictions is included in the £349 pass. |
| Safeguarding | Lithuania safeguarding is included in the £349 pass. | Netherlands 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. | Netherlands 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.
🇳🇱 Netherlands (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 Netherlands?
Lithuania: Bank of Lithuania (Lietuvos bankas).. Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor).
What licence do you need in Lithuania compared with Netherlands?
In Lithuania the authorisation route is EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.; in Netherlands it is Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Lithuania vs Netherlands 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-netherlands.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.