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| Dimension |
Pinned 🇱🇻 Latvia partly open Verified 2026-11-01
|
🇱🇹 Lithuania
partly open
Verified 2026-11-01
|
|---|---|---|
| Licence type | Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. |
| Regulator | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | Bank of Lithuania (Lietuvos bankas). |
| Capital requirement | Latvia capital requirement is included in the £349 pass. | Lithuania capital requirement is included in the £349 pass. |
| Timeline to authorisation | Latvia timeline to authorisation is included in the £349 pass. | Lithuania timeline to authorisation is included in the £349 pass. |
| Local substance | Latvia local substance is included in the £349 pass. | Lithuania local substance is included in the £349 pass. |
| Application cost | Latvia application cost is included in the £349 pass. | Lithuania application cost is included in the £349 pass. |
| Ongoing cost | Latvia ongoing cost is included in the £349 pass. | Lithuania ongoing cost is included in the £349 pass. |
| Passporting | Latvia passporting is included in the £349 pass. | Lithuania passporting is included in the £349 pass. |
| EMIs authorised | Latvia emis authorised is included in the £349 pass. | Lithuania emis authorised is included in the £349 pass. |
| Key restrictions | Latvia key restrictions is included in the £349 pass. | Lithuania key restrictions is included in the £349 pass. |
| Safeguarding | Latvia safeguarding is included in the £349 pass. | Lithuania safeguarding is included in the £349 pass. |
| Recent changes | Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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 Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time. |
| Difficulty rating | Latvia difficulty rating is included in the £349 pass. | Lithuania difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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