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Legal services

Service offering

Limited-activity PI license in Lithuania

Obtain a limited-activity PI license in Lithuania

Limited-scope payment institution model

A comprehensive service for preparing the company, documents, and application for limited-activity PI licensing in Lithuania.

This service is suitable for early-stage payment projects that want to validate the model and enter the market in a limited format.

A limited-activity PI license in Lithuania is not just a separate legal option, but a licensing support service for a payment institution when a company wants to enter the market through a clear, reviewable, and manageable model. This service is especially valuable for founders of regulated fintech projects, operating platforms that want to move from a partner model to their own license, and companies preparing to launch in the EU that want to understand the real scope of requirements in advance. In fintech and related regulated sectors, it is almost never enough to simply “register a company” or “fill out a form.” You need to connect the corporate structure, contractual chain, product scenarios, compliance framework, payment infrastructure, website, and the actual allocation of roles within the business.

Regulatory framework. In payment and e-wallet projects in the EU, the starting point is usually PSD2 — Directive (EU) 2015/2366 on payment services in the internal market. Even when a project is built through a partnership with an existing licensed provider, the documents, user flows, allocation of functions, and website language must match the actual legal model, or questions will arise from banks, processing partners, and regulators.

Who needs this service and why. A limited-activity PI license in Lithuania is usually requested in four typical situations. First, the project is at the idea or MVP stage and wants to understand, before development and bank discussions, which model is actually viable. Second, the company has already started operating through partners but wants to move to its own license or its own regulatory framework. Third, the team has a product, website, and investor presentation, but no coherent legal structure, so every new partner starts asking uncomfortable questions. Fourth, the company needs to prepare for discussions with a regulator, bank, processing partner, auditor, or investor in a way that ensures the documents do not conflict with the actual operating model.

Why it is important to get this right from the start. The typical risks here include incorrect service classification, a conflict between the product’s marketing description and the actual customer journey, an unsuitable corporate structure, and weak internal policies and documentation, all of which can cause the project to stall at the bank, PSP, auditor, or licensing stage. In practice, mistakes rarely look like an “obvious rejection for one reason.” More often, they accumulate: the user journey says one thing, the Terms of Service say another, the partner agreement says a third, and the bank presentation says a fourth. As a result, the project loses months reworking materials that were supposedly already finished, changes its structure after incorporation, rewrites onboarding, revises pricing, or delays launch. That is why the "Limited-activity PI license in Lithuania" service is not about a polished legal package, but about creating a working model that can actually go to market.

What is actually built within the service. This service is suitable for early-stage payment projects that want to validate the model and enter the market in a limited format. It is important that the scope of work does not live separately from the business: every policy, every agreement, and every process description must answer practical questions — who is the service provider, where the customer’s rights and obligations arise, who holds the funds or assets, who performs KYC, how complaints are handled, who is responsible for incident management, and how post-launch compliance will be organized.

Who this service is especially suitable for

Which companies, roles and tasks this work usually brings the greatest practical value to

Payment services and platforms through which customer funds actually move - 94%

This service is especially important for companies that accept payments, send transfers, organize payouts, handle acquiring, merchant settlements, or other payment flows in the "Europe" region. Here, it is critical not to confuse a technology function with regulated activity or build the product on the wrong model.

Marketplaces and SaaS platforms adding a payment layer to their core product - 86%

If your core business was not originally financial, but you want to add money collection, payouts, user settlements, fee retention, and bank integrations, this service helps determine where the line falls between a permissible platform role and a licensable function.

Operations and legal teams preparing to launch or restructure a payment stack - 82%

This section is especially useful for those inside the business who are putting together bank and processing partner agreements, website copy, the customer journey, complaints handling, AML/KYC, and internal rules. These are exactly the points where mistakes most often arise and cause launch delays.

Companies that want to move beyond dependent intermediary status - 77%

If the business no longer wants to operate under someone else’s limits, pricing, onboarding rules, and product-change timelines, this service helps assess the transition to its own license or to a more sustainable corporate and contractual model.

Why this offering is often especially timely

At which project stages the service has the greatest effect and what it helps fix in advance

When the service is especially valuable

The "Limited-activity PI license in Lithuania" service is especially valuable for teams that already understand their product and commercial objective in Lithuania but have not yet finalized the legal architecture. At this stage, the company structure, contract logic, website, onboarding, and sequence of work with the regulator or key partners can still be adjusted without unnecessary cost.

What gets reviewed first

At the start of the "Limited-activity PI license in Lithuania" service, the review usually focuses on the types of payment services involved, the funds flow, the company’s role in settlement, outsourcing, and customer disclosures. The purpose of this review is to separate the company’s actual activities from how the service is described on the website, in presentations, and in the team’s internal assumptions. This is where it becomes clear which parts of the model are legally defensible and which need to be redesigned before filing or launch.

Why early model design benefits the project

A late legal review is expensive because the business has usually already tied together the product, marketing, and commercial agreements around an assumption that may turn out to be wrong. For a "Limited-activity PI license in Lithuania" project, a common mistake is choosing the PI route without a precise list of payment services. After launch, those mistakes affect not just one document, but the customer journey, support, contractor agreements, and internal controls.

What result the business should aim for

The practical result of the "Limited-activity PI license in Lithuania" service is not an abstract folder of texts, but a working framework for the next stage: a clear roadmap, priorities for documents and procedures, a list of weak points in the model, and a stronger position in negotiations with a bank, regulator, investor, or infrastructure partner.

What is included in the service

The scope of work, documents and stages of support

01

Corporate structure and preliminary requirements

  • Review of the initial corporate structure and project stakeholder setup for limited-activity PI licensing in Lithuania
  • Recommendations on the country of incorporation, governance bodies, capital, office setup, and key functions

  • 02

    Legal analysis of the business model

  • Legal analysis of the business model, services, customer flows, and payment or investment infrastructure for a limited-activity PI license in Lithuania
  • Determination of the regulatory perimeter, restrictions, and related authorizations that may be required for the project

  • 03

    Licensing plan and roadmap

  • Preparation of a step-by-step launch and authorization plan for limited-activity PI licensing in Lithuania
  • Definition of the document package, timeline, roles, and external providers

  • 04

    Business plan and financial model

  • Preparation or refinement of the business plan, financial forecast, growth scenarios, and operating model
  • Description of the organizational structure, control functions, IT landscape, and outsourcing arrangements

  • 05

    AML/KYC and internal controls

  • Development or adaptation of the AML/KYC approach, customer onboarding, monitoring, and escalation procedures
  • Design of the compliance model, risk management, internal audit, and reporting framework

  • 06

    Internal policies and procedures

  • Preparation of internal policies, approval procedures, reporting processes, incident management, and business continuity procedures
  • Documentation of corporate governance, conflicts of interest, information security, and access controls

  • 07

    Customer and partner documentation

  • Preparation of customer terms, disclosures, privacy documents, and agreements with technology and financial partners
  • Customization of documents for a B2B, B2C, marketplace, or white-label model

  • 08

    Application preparation and filing

  • Collection, completion, and final review of the document package for limited-activity PI licensing in Lithuania
  • Preparation of the package for approval of management, beneficial owners, and other relevant persons before the regulator

  • 09

    Communication with the regulator and partners

  • Support in responding to regulator requests and coordinating comments on the application
  • Assistance in negotiations with a bank, EMI, processing provider, acquiring partner, safeguarding or issuance partner, or other infrastructure partner

  • 10

    Launch and post-license readiness

  • Preparation of the project for the start of operations, reporting, and internal controls after approval
  • Recommendations on ongoing compliance support, document updates, and expansion of the model

  • Regulatory and legal framework

    Which rules and requirements usually determine the content of the service

    Legal framework. For payment and e-money projects in the EU, the key legal acts are usually PSD2 — Directive (EU) 2015/2366 on payment services in the internal market — and, for models involving the issuance of electronic money, Directive 2009/110/EC on electronic money. Depending on the product, the analysis may also include local implementing acts, AML/KYC requirements, GDPR, outsourcing rules, safeguarding of client funds, corporate governance, and customer disclosure obligations.

    In practice, this means that a legal service in this area must review not only the application text, but the product itself: who receives the funds, where the customer claim arises, who keeps the records, who conducts onboarding, how the integrations are structured, what the website says, and how the service is described in agreements with partners. Most licensing and bank onboarding issues arise at the intersection of these elements.

    Which risks proper legal preparation addresses

    Typical mistakes because of which projects lose time, money and partners

    Costly rework after launch

    For the "Limited-activity PI license in Lithuania" service, the core risk is building the model on an incorrect qualification of the actual activities. If the team has not analyzed the types of payment services involved, the funds flow, the company’s role in settlement, outsourcing, and customer disclosures, it can easily mistake the marketing label of the service for legal reality and move in the wrong direction in Lithuania.

    Misalignment between the website, contracts, and operations

    Even a strong product looks weak if the website, public promises, Terms of Service, internal procedures, and partner agreements describe different company roles. In that state, a "Limited-activity PI license in Lithuania" project will almost always face unnecessary questions during due diligence, bank review, or the authorization process in Lithuania.

    Incorrect qualification of the actual model

    A separate risk under the "Limited-activity PI license in Lithuania" service arises at points of dependency on counterparties and internal controls. If it is not clearly established in advance who is responsible for critical functions, how procedures are updated, and where the provider’s responsibility ends, the project remains vulnerable in precisely those areas that make up the types of payment services involved, the funds flow, the company’s role in settlement, outsourcing, and customer disclosures.

    Costly rework after launch

    The most expensive mistake for a "Limited-activity PI license in Lithuania" project is postponing legal restructuring until a late stage. Once it becomes clear that the PI route was chosen without a precise list of payment services, the company ends up having to rewrite not only the documents, but also the customer journey, product copy, support scripts, onboarding, and sometimes even the corporate structure in Lithuania.

    What result the business receives

    What can be done next after the service is completed

    What the business receives in the end. At the end of the "Limited-activity PI license in Lithuania" service, the company receives more than just a set of files. It receives a legal foundation that can be used for the next steps: licensing, registration, negotiations with banks and processing partners, internal process setup, due diligence, changes to the corporate structure, or launching a new product.

    Why this has practical value. The result of this service helps the team make decisions faster: it becomes clear where the line falls between a permissible technology model and regulated activity, which documents must be published on the website, which procedures need to be implemented before launch, and which can be rolled out in stages. This work matters not only at launch. After it is completed, the company is in a stronger position to update the product, expand into new countries, negotiate new provider agreements, and pass further reviews by banks, investors, auditors, and other external stakeholders.

    What matters after the service is completed. The legal package should not remain an archive. Its purpose is to become a working tool for founders, operations, compliance, product, and business development. That is what reduces the risk that, a few months later, the project will have to rebuild its website, contracts, procedures, and customer journey from scratch to satisfy the requirements of a new bank, regulator, investor, or strategic partner.

    What the client receives in the end. The main value of this service is not a collection of unrelated files, but a coordinated legal foundation for launch and growth. After proper preparation, it becomes easier for the project to explain its model to banks, EMI/PI partners, processing providers, KYC/AML vendors, investors, and potential buyers of the business. Even if the final strategy is to launch through a partner framework, high-quality legal packaging reduces the risk that, a few months later, the company will have to rewrite its website, contracts, AML procedures, and internal staff workflows from scratch.

    Why this work should not be postponed. The later a company carries out a proper legal scoping exercise for the "Limited-activity PI license in Lithuania" service, the more expensive the fixes become. If you build the product, marketing copy, onboarding, and integrations first, and only later discover that the model requires a different regulatory perimeter or different allocation of roles, you end up reworking not only the documents, but also the interfaces, payment flow, support processes, accounting logic, and sometimes even the corporate setup. That is why this work should ideally be done before aggressive scaling, before entering a new country, and before serious discussions with banks or investors.

    How to use the result going forward. The materials prepared within this service usually become the foundation for the next stages: incorporation, bank onboarding, selection of technology vendors, preparation of the regulatory application, negotiation of partner agreements, building a data room, and internal team work. For founders, this also matters from a management perspective: it becomes clear which functions need to be kept in-house, what can be outsourced, which documents must be published on the website, which processes should be automated immediately, and which can be rolled out in stages.

    The practical outcome for the business. A well-prepared service helps the company make decisions faster and at lower cost: it becomes clear whether it is worth pursuing its own license, whether launching through a partner is possible, where the line falls between a technology service and regulated activity, which parts of the model are critical from the regulator’s perspective, and which issues can be addressed contractually. That is usually what determines how quickly a project moves from idea to actual go-live without unnecessary detours.

    Frequently asked questions

    Short answers to practical questions about the service scope and its result

    Does it make sense to start this service before the final go-to-market stage?

    It is best to begin before filing, before signing key agreements, and before publicly scaling the product. For the "Limited-activity PI license in Lithuania" service, this is especially important in Lithuania because defining the scope early makes it possible to adjust the structure and documents without triggering a cascade of changes to the website, onboarding, contract chain, and relationships with counterparties.

    Can we limit the work to only part of the service?

    Yes, under the "Limited-activity PI license in Lithuania" service, the work can be split into parts: for example, a memorandum only, a roadmap only, a document package, filing support, or review of a specific agreement. But before doing that, it is useful to briefly review the types of payment services involved, the funds flow, the company’s role in settlement, outsourcing, and customer disclosures; otherwise, you may end up ordering a fragment that does not address the main risk of this model in Lithuania.

    Why do strong projects still get stuck at the legal stage?

    Most often, a project is delayed not by a single form or a single regulator, but by a disconnect between the product, customer-facing texts, contract logic, internal procedures, and the company’s actual role. For a "Limited-activity PI license in Lithuania" project, that disconnect is usually the most expensive issue because it affects partners, the team, and ongoing compliance in Lithuania.

    What kind of result is actually useful for the business?

    A strong outcome under the "Limited-activity PI license in Lithuania" service is when the business ends up with a defensible and clear model for the next steps: which functions are permitted, which documents and procedures are mandatory, what needs to be fixed before launch, and how to discuss the project with a bank, regulator, investor, or technology partner without internal ambiguity in Lithuania.