EMI Licensing in Europe 2026: Lithuania, Ireland, and UK Compared

EMI licensing opens fintech capabilities that crypto licenses alone don't provide. The choice of jurisdiction shapes costs, timeline, and what's actually possible.

Electronic Money Institution (EMI) licenses authorize firms to issue electronic money, provide payment services, and maintain payment accounts. For fintechs, neobanks, and crypto firms wanting to bridge into traditional payments, EMI authorization is often the next step after basic crypto licensing. Europe offers several jurisdictions with different trade-offs.

What an EMI license enables

EMI authorization under PSD2 and the E-Money Directive allows:

• Issuing electronic money (stored value, prepaid cards, e-wallets)
• Operating payment accounts for customers
• Executing payment transactions (transfers, direct debits, card payments)
• Issuing payment cards under Visa/Mastercard schemes
• Currency exchange services ancillary to payments

Within the EU/EEA, an EMI license from any member state can passport to all 30 countries. Post-Brexit, UK EMI licenses no longer passport to the EU, and EU licenses don't cover the UK.

Lithuania: the fintech favorite

The Bank of Lithuania built its reputation as Europe's fastest EMI licensing jurisdiction. The approach was deliberate: attract fintech businesses by reducing bureaucratic friction.

Capital requirements: EUR 350,000 initial capital for full EMI license. A "restricted" EMI license (average e-money under EUR 5 million monthly) requires only EUR 50,000.

Timeline: Official target is 3 months for complete applications. In practice, 4-6 months is more realistic with rounds of questions. Still faster than alternatives.

Substance requirements: Local director, operational presence in Lithuania, compliance function. The requirements are genuine but not onerous by European standards.

Reality check: Lithuania's volume has created bottlenecks. The central bank processed hundreds of applications in recent years and has tightened scrutiny. The "fast track" reputation still holds relative to alternatives, but expectations should be calibrated.

Ireland: post-Brexit EU access

The Central Bank of Ireland became attractive after Brexit for UK fintechs needing continued EU access. English-speaking, common law jurisdiction, well-developed financial services infrastructure.

Capital requirements: EUR 350,000 for full EMI. Safeguarding requirements add to working capital needs.

Timeline: 6-12 months for complete applications. The CBI is thorough and doesn't rush.

Substance requirements: Meaningful Irish presence expected. Directors should be genuinely involved, not nominal. CBI has rejected applications for insufficient substance.

Reality check: Ireland is a premium jurisdiction. Authorization from CBI carries weight with banks, partners, and institutional clients. The cost and time reflect that positioning. Don't choose Ireland for speed; choose it for credibility.

United Kingdom: large market, separate regime

The FCA administers EMI licensing in the UK under retained EU law, now evolving independently.

Capital requirements: GBP 350,000 equivalent. Same baseline as EU, though safeguarding requirements can push working capital needs higher.

Timeline: 12+ months typical. The FCA is notoriously slow for payment institution applications. Some applications have taken 18+ months.

Substance requirements: UK presence, UK-resident directors, operational capability. The FCA reviews substance seriously.

Reality check: UK EMI licensing makes sense if you need the UK market specifically. The UK population (68 million) and financial services concentration justify the effort for UK-focused businesses. For EU access, it's not relevant post-Brexit.

The cost picture

Full EMI licensing costs substantially more than crypto-only licensing:

Lithuania: EUR 350,000 capital, EUR 30-60,000 legal/consulting, EUR 20-30,000 annual local costs minimum. Year one total: EUR 450,000+.

Ireland: EUR 350,000 capital, EUR 50-100,000 legal/consulting (higher than Lithuania), EUR 50,000+ annual local costs. Year one total: EUR 550,000+.

UK: GBP 350,000 capital, GBP 50-100,000 legal/consulting, GBP 50,000+ annual local costs. Year one total: GBP 500,000+.

These figures exclude technology costs, banking setup fees, scheme membership (Visa/Mastercard), and ongoing compliance staff. Real operational budgets run 50-100% higher.

Choosing a jurisdiction

For speed to EU market: Lithuania remains the practical choice if timeline matters and costs need managing.

For premium positioning: Ireland provides credibility that helps with banking relationships and institutional partnerships.

For UK market specifically: FCA authorization is required. No EU license substitutes.

For both markets: Budget for two separate applications. There's no shortcut after Brexit.