Cryptocurrency License in Lithuania (MiCA CASP Authorisation) — An Overview
Private Financial Services specialists were among the first to assist with obtaining a cryptocurrency license in Lithuania. We saw the original regime open in 2020 — and we now work in the one that replaced it.
For five years Lithuania was the fastest and cheapest crypto entry point in the European Union. You registered a UAB, filed with the Financial Crime Investigation Service, appeared in the register, and started trading. Thousands of companies did exactly that.
That model ended on 31 December 2025. Since 1 January 2026, providing crypto-asset services in or from Lithuania requires a CASP authorisation from the Bank of Lithuania under the EU’s Markets in Crypto-Assets Regulation. Operating without it is not a technical breach — it is unauthorised financial activity, with potential criminal liability for the directors.
Here is the part worth understanding before you dismiss the change as bad news: what replaced the old regime is far more valuable. A single CASP authorisation from Vilnius passports across all 27 EU member states plus the EEA. The old Lithuanian registration never did that. The barrier went up, and so did what you get for clearing it.
What Changed — From VASP Registration to CASP Authorisation
The Old Regime and the New One
The two are not variations of the same thing. Every material parameter changed:
Legal basis. The old registration rested on national AML law. The new authorisation rests on Regulation (EU) 2023/1114 — MiCA;
Authority. Licensing moved from the Financial Crime Investigation Service to the Bank of Lithuania. The FNTT retains AML supervision only;
Nature. An entry in a register has become a full financial authorisation;
Minimum capital. None at first, then €125,000 from late 2022. Now €50,000, €125,000 or €150,000 depending on the service class;
EU market access. The registration covered Lithuania alone. The authorisation passports across all 27 member states and the EEA;
Substance. Minimal before; now a physical office, a resident director, a resident AML officer and substance interviews;
Timeline. Weeks before; months now;
Ongoing obligations. Basic AML reporting before. Now prudential, conduct and disclosure requirements, supervisory reporting, annual audit, the Travel Rule and DORA.
Guides still describing FCIS registration, a two-month timeline and a few thousand euros in fees are describing a jurisdiction that no longer exists. Some of them are still ranking.
Key Dates and the Transition
The Law on Markets in Crypto-Assets took effect on 11 July 2024, transferring CASP licensing to the Bank of Lithuania. The CASP regime became fully operational on 30 December 2024. The Seimas then extended the transitional window for existing VASPs to 1 January 2026 — earlier than the EU-wide backstop of 1 July 2026, which several member states also chose to shorten.
The market narrowed sharply in the process. Of more than 370 companies that had declared an intention to provide crypto-asset services to the Lithuanian register, only around 120 were actually trading and filing accounts, and as of mid-2025 roughly 30 had applied to the Bank of Lithuania. That is what a real authorisation regime does to a register full of shelf companies — and it is why a Lithuanian CASP authorisation now carries weight with banks and counterparties that the old registration never did.
What a CASP Authorisation Covers
A single authorisation can cover the crypto-asset services you apply for, which under MiCA include:
Custody and administration of crypto-assets on behalf of clients;
Exchange of crypto-assets for funds, and for other crypto-assets;
Operation of a trading platform;
Execution of orders on behalf of clients;
Placing of crypto-assets;
Reception and transmission of orders;
Advice on crypto-assets;
Portfolio management of crypto-assets;
Transfer services.
You specify the services in the application, and the capital requirement follows from them.
Capital by Service Class
Minimum own funds depend on which services the authorisation covers:
Class 1 — €50,000. Broadly covers advice, reception and transmission of orders, placing, transfers and execution;
Class 2 — €125,000. Custody, exchange for funds or for other crypto-assets, and portfolio management;
Class 3 — €150,000. Operation of a trading platform.
Own funds must be genuinely capitalised. Plan capital in euro fiat and be ready to evidence the source of funds through normal banking documentation — a contribution in crypto-assets should not be assumed acceptable.
Requirements, Compliance and Costs
Substance — What the Bank of Lithuania Actually Requires
This is where most applications fail, and where the gap between the old regime and the new one is widest.
Legal form. A Lithuanian UAB;
Physical office. A real office in Lithuania. Virtual office arrangements and nominee directors are rejected;
Board. At least two members, of whom at least one must be a Lithuanian resident. The place of effective management must be in the EU;
Management experience. Board members must show relevant senior management experience and knowledge of the crypto-asset business, assessed individually;
AML compliance officer. Must be a Lithuanian tax resident. EU residency alone does not satisfy this;
Fit and proper. Directors, key function holders and beneficial owners are assessed for reputation and clean criminal records;
Bank account. With a Lithuanian credit institution, or a foreign bank operating through a Lithuanian branch;
Ownership. 100% foreign ownership is permitted. There is no local shareholder requirement — ownership and governance are separate questions.
The Bank of Lithuania conducts substance interviews with key management as part of the assessment. A well-drafted file that falls apart in conversation with the regulator does not pass. Plan for real people in real roles.
Compliance — Three Things That Did Not Exist Before
A crypto-specific AML programme. A generic AML framework, or one translated from another sector or jurisdiction, will not pass. The Bank of Lithuania expects blockchain analytics integration, crypto-specific customer risk typologies, and enhanced due diligence calibrated to crypto activity;
The Travel Rule. Regulation (EU) 2023/1113 requires originator and beneficiary information to accompany every crypto-asset transfer, and to be handled on the receiving side. This needs a working technical implementation, not a policy document;
DORA. The Digital Operational Resilience Act has applied since 17 January 2025 and covers CASPs. Expect to demonstrate an ICT risk management framework, an ICT risk register, incident reporting procedures, digital resilience testing, and documented control of third-party ICT providers. For most applicants this is the least anticipated and most time-consuming workstream.
Ongoing obligations after authorisation include periodic supervisory reporting to the Bank of Lithuania, annual external audit, continuous capital adequacy, and AML/CFT supervision by the FNTT.
The claim on older pages that companies involved in crypto activities have no specific reporting requirements, and can keep books like any ordinary company, was true in 2022. It is not true now, and it is not a small difference.
Timeline and Cost — Realistically
Timeline. MiCA sets a statutory clock: the regulator checks completeness, then assesses. In practice, expect three to six months from a complete submission, and longer if the file raises questions. Preparation — company, capital, substance, AML programme, DORA documentation — typically runs another three to five months before you are ready to file. Nothing shortens this. Flying to Vilnius does not accelerate a MiCA assessment; only application quality does.
Cost. All-in budgets for a Lithuanian CASP authorisation commonly run into six figures once minimum capital, legal and compliance build, local staffing, banking onboarding and translation are counted. The capital alone is €50,000–€150,000, and it is not a fee — it is your money, held as own funds.
Any quotation in the low thousands is describing the 2022 registration regime. That regime is closed.
Bank Account
Lithuania hosts the EU’s largest concentration of licensed payment and e-money institutions, which historically made accounts easy for crypto companies. That is less true than it was: banks have tightened on crypto generally, and a CASP must hold its account with a Lithuanian credit institution or a Lithuanian branch of a foreign bank.
The authorisation itself helps materially here — a supervised CASP is a fundamentally different counterparty to an FCIS-registered shell, and banks treat it accordingly. But the account should be planned alongside the application, not after it. We run both tracks together and will not promise a guaranteed account, because nobody can. More on bank account opening.
Tax Policy
Lithuania ran a tax reform effective 1 January 2026, so the figures on most pages are out of date.
Corporate income tax — 17% standard, up from 16% in 2025 and 15% before that. Qualifying new small companies pay 0% for their first two tax periods, then 7% while under €300,000 revenue with fewer than 10 employees — though a properly capitalised and staffed CASP will often exceed those thresholds;
Dividends. 15% personal income tax to individual shareholders; 17% where paid to a company, subject to the participation exemption (10% holding for 12 months) and the EU Parent-Subsidiary Directive;
VAT — 21% standard. Crypto-asset exchange services are VAT-exempt, following the European Court of Justice’s treatment of crypto as currency for VAT purposes. Ancillary services are not;
Treaty network. Around 55 double taxation agreements. Note that Lithuania’s treaties with Russia and Belarus both terminated with effect from 1 January 2026.
And the point most licensing pages skip entirely: low Lithuanian tax is not the same as low tax for you. Your own country of residence may tax the company through controlled foreign company rules, or treat it as resident where it is actually managed. We assess both sides.
For the corporate layer in detail, see company formation in Lithuania.
Is Lithuania the Right Choice?
It fits if the EU is genuinely your market, if you can capitalise properly, and if you can support a real office, a resident director and a resident compliance officer in Vilnius. The Bank of Lithuania operates in English, publishes structured guidance and offers pre-application engagement — its assessment timelines compare well against most EU regulators.
It does not fit if your customers are outside the EU and you are choosing Lithuania for its reputation rather than its market, or if the economics cannot carry the capital and substance. In those cases the honest answer is either the CySEC route in Cyprus or licensing outside the EU — and we will say so rather than sell you a file that will not clear.
One thing to be clear about in the other direction: no non-EU licence substitutes for this one. Since 1 July 2026, ESMA has confirmed that third-country firms cannot provide crypto-asset services to EU clients or solicit them, in B2C or B2B. If the EU is the market, MiCA authorisation is the only route.
Our Specialists Will Provide the Following Services:
Business model analysis and CASP service classification — which class, which capital tier;
Lithuanian UAB formation, structuring and capitalisation;
Substance: office, resident director and resident AML compliance officer;
AML/CFT programme built for MiCA and Lithuanian requirements, including Travel Rule implementation;
DORA and ICT governance documentation;
Business plan, financial projections and governance framework;
Full support through the Bank of Lithuania application, including regulator correspondence;
Legal address for the company and, if necessary, assistance in finding a separate office and hiring qualified staff;
Payment of all state, notary fees and duties;
Banking and payment account introductions;
Post-authorisation compliance, reporting and audit coordination;
Remediation for companies that held a Lithuanian VASP registration and did not transition before the deadline.