Is Malta emerging as a preferred hub for EMI licensing as Lithuania tightens oversight?

A growing conversation among European fintech professionals suggests that Malta may be regaining traction as a jurisdiction of choice for Electronic Money Institution (EMI) and Payment Institution (PI) licences, as Lithuania adopts a more selective regulatory approach.

The discussion was sparked by Vykintas Barakauskas, a Director at Epico Finance in Lithuania (a finance and banking solutions consultancy firm), who pointed to a noticeable shift in licensing trends across the EU. According to figures he cited, Malta issued 12 new EMI and PI licences in 2024 out of a total of 90 across Europe, followed by four additional licences in early 2025.

Lithuania, which rose to prominence after Brexit as a leading EU hub for EMIs, appears to be moving in the opposite direction. The Bank of Lithuania issued just three new licences in 2024 while revoking nine, resulting in a net decline. No new licences were issued in the early months of 2025.

Mr Barakauskas attributed this shift to a deliberate tightening of regulatory scrutiny. He noted that Lithuanian authorities have become increasingly focused on the “substance” of applicants, including their local presence and the nature of their business models. Firms targeting offshore markets or operating in higher-risk sectors are reportedly facing greater resistance, while underperforming institutions have seen licences withdrawn.

This recalibration, described by some industry participants as a move towards “quality over quantity”, appears to be influencing where fintech firms choose to establish themselves.

Within the same discussion, several contributors highlighted Malta’s positioning as an alternative jurisdiction, particularly for firms operating in sectors such as crypto, gambling and forex.

One commenter pointed to findings from the European Banking Authority’s peer review covering 2022–2024, noting that Malta recorded a 43 per cent increase in applications over the two-year period. The country also reportedly received the third-highest number of applications in the EU and granted the highest number of authorisations, totalling 21.

Market expectations suggest that demand for licensing in Malta could remain strong in the coming years, particularly with the introduction of the Markets in Crypto-Assets (MiCA) framework, which is expected to drive further regulatory activity.

Another contributor described Malta not as a new entrant, but as a jurisdiction “re-emerging”, noting its longstanding role in the payments space and its growing reputation for a more pragmatic and responsive regulatory approach.

The discussion also placed these developments within a wider European context. Cyprus was cited as an example of a jurisdiction that has undergone similar cycles, moving from periods of strong licence issuance to more selective regulatory oversight.

At the same time, some industry participants noted that founders are increasingly looking beyond the EU altogether, with jurisdictions such as the United Arab Emirates entering the conversation as alternative bases for fintech operations.

Taken together, these perspectives suggest a broader shift in how fintech firms approach jurisdiction selection. Rather than prioritising speed to authorisation, there is an increasing focus on long-term regulatory fit, operational substance, and alignment with evolving compliance expectations.