🇱🇹 Lithuania vs 🇳🇱 Netherlands: e-money licensing compared
On paper, Lithuania's EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. and Netherlands's 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 answer the same question; in practice the detail decides it. The two regimes differ on 8 of 10 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Lithuania: verified 2026-07-03 · Netherlands: verified 2026-07-03
| Dimension |
🇱🇹 Lithuania
partly open
Verified 2026-07-03
|
🇳🇱 Netherlands
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Netherlands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Lithuania timeline to authorisation is locked. Unlock with the £349 pass. | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Lithuania local substance is locked. Unlock with the £349 pass. | Netherlands local substance is locked. Unlock with the £349 pass. |
| Application cost | Lithuania application cost is locked. Unlock with the £349 pass. | Netherlands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Lithuania ongoing cost is locked. Unlock with the £349 pass. | Netherlands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Lithuania passporting is locked. Unlock with the £349 pass. | Netherlands passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Lithuania emis authorised is locked. Unlock with the £349 pass. | Netherlands emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Lithuania key restrictions is locked. Unlock with the £349 pass. | Netherlands key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Lithuania safeguarding is locked. Unlock with the £349 pass. | Netherlands 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. Continued AML tightening. | EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months). |
| Difficulty rating | Lithuania difficulty rating is locked. Unlock with the £349 pass. | Netherlands difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 8 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
🇱🇹 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.
🇳🇱 Netherlands (verified 2026-07-02): EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months).
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.