Forex License in Lithuania

Lithuania is one of the fastest-growing EU financial centres for fintech and forex licensing. The Bank of Lithuania completes the application completeness check within 5 business days and typically concludes assessment within 3–6 months from submission of a complete file. Document requests restart the assessment clock, so arriving with a thorough application package is the single most effective way to stay within the shorter end of that range.

Capital requirements under the Investment Firm Regulation (IFR EU 2019/2033) range from €75,000 (Type C — advisory and order transmission only) to €750,000 (Type A — dealing on own account). The state application fee is €947, and applications are accepted in English — removing a significant barrier for international founders. Once authorised, the licence carries full EU passporting rights under MiFID II.

For further context on Lithuania’s regulatory environment, see the ICLG Fintech Laws and Regulations — Lithuania guide.

A Lithuania-issued MiFID II investment firm licence provides passporting rights to 30+ EU/EEA countries under the freedom-of-services framework. Passporting notification typically completes within approximately one month after licence issuance. A single Bank of Lithuania authorisation covers your firm’s operations in Germany, France, the Netherlands, and all other EEA markets — without repeating the full licensing process in each country.

Since 30 December 2024, MiCA Article 60 lets MiFID II-licensed firms in Lithuania expand into crypto-asset services without obtaining a separate CASP licence. An existing or newly authorised investment firm can extend its activities into crypto-asset trading and related services after notifying the Bank of Lithuania at least 40 working days in advance. If you plan to offer both forex and crypto services, a single Lithuanian MiFID II authorisation now covers both regulatory perimeters. Read more in our MiCA framework guide for additional detail on the crypto-asset framework.

The highest tier. Required for any firm that trades on its own balance sheet, makes markets, or underwrites instruments. EUR 750,000 corresponds to IFR Article 9(1)(a). Use cases: B2B liquidity providers, proprietary trading desks, dealing-on-own-account brokers.

Most retail forex STP/NDD brokers fit here. The firm executes client orders, holds client money in segregated accounts, but does not trade on own account. EUR 150,000 corresponds to IFR Article 9(1)(b). A compliance officer with documented financial services experience is mandatory.

The entry-level licence. Suitable for investment advisors and order transmission firms that never hold client assets. Professional indemnity insurance is mandatory. EUR 75,000 corresponds to IFR Article 9(1)(c).

Capital must be CET1 (Common Equity Tier 1) own funds — paid-up share capital, retained earnings, share premium. Debt instruments do not count.

• Buffer above minimum — most firms hold 110–130% of the minimum to manage day-to-day fluctuations.
• Quarterly reporting cadence — the Bank of Lithuania receives quarterly capital adequacy returns.
• Intangibles deduction — goodwill and other intangible assets are deducted from CET1.
• CET1 instruments only — paid-up share capital, retained earnings, share premium account.

Five instruments form the backbone of forex licensing in Lithuania — one domestic primary statute, three EU instruments that apply directly or via transposition, and one Bank of Lithuania resolution that operationalises the licensing procedure:

• Law on Markets in Financial Instruments (LMFI) — Lithuania’s transposition of MiFID II into national law. Sets the scope of regulated investment activities, defines licence categories, and establishes substantive requirements for firms operating in or from Lithuania. Available at e-seimas.lrs.lt.
• MiFID II (Directive 2014/65/EU) — the EU directive on markets in financial instruments. Governs investment services and activities, organisational requirements, conduct-of-business rules, and authorisation of investment firms across the EU.
• MiFIR (Regulation (EU) 600/2014) — directly applicable EU regulation on transaction reporting, market structure, and pre-/post-trade transparency. Unlike MiFID II, MiFIR requires no national transposition and binds Lithuanian-licensed firms in its own terms.
• Investment Firm Regulation (IFR, Regulation (EU) 2019/2033) — sets the prudential capital thresholds for investment firms (the €75,000 / €150,000 / €750,000 figures used in Lithuania’s Type C / B / A categorisation derive from IFR). Authoritative text at EUR-Lex (CELEX:32019R2033).
• Bank of Lithuania Resolution No 03-114 (20 June 2018) — the procedural instrument that operationalises licensing. Specifies application forms (Forms 1–3), documentation requirements, and the internal review procedure the Bank follows when assessing each submission.

The Bank of Lithuania (Lietuvos bankas) is the sole licensing authority for investment firms. There is no separate financial market supervision commission in Lithuania — the Bank’s internal Financial Market Supervision Department handles every application from receipt through to the final decision, supervises ongoing capital adequacy, and enforces the licensing regime.

• Completeness check — 5 business days from submission. The Bank confirms that all required forms and supporting documents are present; an incomplete package is returned promptly rather than left pending.
• Assessment — 3–6 months in 3-month rounds. The statutory ceiling under MiFID II Article 7(3) is 6 months, but document requests that require applicant responses do not count against the assessment clock.
• Newcomer Programme — pre-application engagement service available to international applicants who want to validate their business model with Bank specialists before formal submission. Details at the Bank of Lithuania Newcomer Programme page.
• Authorisation page — the Bank’s published guidance for applicants, including the mandatory forms and the current fee schedule, is hosted at www.lb.lt.
• Regulatory Sandbox — available to innovative fintech firms. Allows pilot products to be tested in a controlled live environment under temporary regulatory relief, with direct Bank of Lithuania oversight.

Two exemption provisions shape how a MiFID II authorisation interacts with adjacent regulatory regimes — one for distributed-ledger market infrastructure, one for crypto-asset services:

• DLT Pilot Regime (Regulation (EU) 2022/858) — firms operating DLT-based market infrastructure may rely on the exemptions in Articles 8(1)(2) and 10(1)(2). The claim is declared to the Bank of Lithuania via Form 3 at the application stage, with substantiated reasoning showing the exemption applies to the firm’s actual business model.
• MiCA Article 60 — since 30 December 2024, MiFID II–licensed investment firms may provide crypto-asset services without obtaining a separate CASP licence under MiCA. The cross-authorisation runs through a streamlined 40-day notification to the home regulator rather than a full second licence application, which lets a single MiFID II authorisation cover both traditional financial instruments and in-scope crypto-asset services.

You must incorporate a Lithuanian UAB (uždaroji akcinė bendrovė — private limited company) before submitting your licence application. A foreign branch or shelf company does not satisfy the requirement. The Bank of Lithuania verifies that the entity has a physical office in Lithuania — not merely a registered address. See the Bank of Lithuania authorisation page for current guidance.

• Entity type — Lithuanian UAB (private limited company)
• Physical office — operational premises in Lithuania
• Forms 1, 2, and 3 — required application documents
• Articles of association — drafted and notarised in Lithuanian

Every shareholder holding 10% or more (qualifying holder) of voting rights must pass the Bank of Lithuania’s fit-and-proper assessment. The firm must appoint at least two board members, each with a minimum of 3 years’ relevant experience in financial services.

• Qualifying holders (≥10%) — fit-and-proper assessment, source-of-funds declaration
• Board composition — minimum 2 members
• Experience requirement — minimum 3 years in financial services per board member
• Compliance officer — qualified individual with documented experience in financial instruments markets

The Bank of Lithuania expects a fully functioning operational setup at the time of application, not after authorisation. This includes documented internal controls, audit arrangements, and an AML/KYC programme.

• Compliance officer appointment with documented financial services experience
• Internal audit function (in-house or outsourced to a qualified provider)
• External audit firm meeting Lithuania’s Law on Financial Institutions
• AML/KYC programme with customer due diligence, transaction monitoring, and STR procedures

Professional indemnity insurance (PII) is mandatory for Type C advisory firms and may be required for some Type B firms providing advisory services. The sum-insured calculation must be submitted with the application and reflect the firm’s exposure to advisory liability. The Bank of Lithuania reviews coverage adequacy as part of the fit-and-proper assessment.

• Form 1 — General Information
• Form 2 — Information in Application
• Form 3 — MiFID/MiFIR Exemption Declarations (DLT, scope carve-outs)
• Business plan — 3–5 year projection covering services, target markets, and growth strategy
• AML/KYC policies — customer due diligence, transaction monitoring, suspicious transaction reporting
• IT security policies — covering systems, access controls, data protection, incident response
• Financial projections — 3-year forward financials with capital adequacy modelling
• Proof of capital — paid-up CET1 capital documentation
• Management CVs — for all board members, demonstrating 3+ years of financial services experience
• Shareholder disclosures — for every qualifying holder (≥10%), with source-of-funds declarations
• Compliance officer appointment — qualifications and engagement letter
• Audit firm appointment — external auditor meeting Law on Financial Institutions criteria
• Professional indemnity insurance — where required, with sum-insured calculation

Licensed firms file quarterly capital adequacy reports to the Bank of Lithuania, demonstrating that own funds remain at or above the IFR minimum for the licence class. Capital must be CET1 — paid-up share capital, retained earnings, share premium — net of intangibles.

Every licensed firm must operate a documented AML/KYC programme with risk-based customer due diligence (CDD), enhanced due diligence (EDD) for higher-risk relationships, ongoing transaction monitoring, and suspicious transaction reporting (STR). A designated AML compliance officer must be in place.

The Financial Crime Investigation Service (FCIS) receives suspicious transaction reports within 7 working days of detection. Firms file ongoing reports and respond to FCIS requests for transaction or client information.

The Bank of Lithuania may revoke the licence for material breaches of regulatory obligations. The most common revocation triggers are capital adequacy shortfalls, AML/KYC failures, and absence of a qualified compliance officer.

• External audit — annual statutory audit by an approved firm
• Internal audit — function maintained in-house or outsourced
• Compliance officer continuity — vacancy must be filled and notified to regulator
• Regulatory notifications — material changes (qualifying holder, management, services) require prior notice

The current licensed firm register is published on the Bank of Lithuania public register. Under MiCA Article 60, the same MiFID II licence covers crypto-asset services after a 40-day notification — review your scope before adding new services.

Investment firms pay the standard 17% CIT rate from 1 January 2026 (increased from 16%). Crucially, the 5% bank surcharge that brings credit institutions to an effective 22% rate does not apply to licensed investment firms. Lithuania also operates a participation exemption for qualifying intra-group dividends and capital gains, useful for firms operating within a multi-jurisdiction group structure.

Firms with annual revenue at or below €300,000 qualify for a reduced 7% CIT rate. Newly registered small companies are exempt from CIT for their first two years of operation under the 2026 tax reform — a potential saving of up to €51,000 over two years for a firm earning €300,000 annually.