Crypto-asset service provider licence (Lithuania)
The Crypto-asset service provider (CASP) licence in Lithuania is issued by the Bank of Lithuania under EU MiCA Regulation (EU) 2023/1114 and the Lithuanian Law on Markets in Crypto-Assets. It allows firms to provide crypto custody, exchange, trading platforms, and advice across 30 EU/EEA states via passporting. Authorisation requires EUR 50,000 to EUR 150,000 initial capital, local governance, and DORA compliance, taking 40 working days from a complete application.
At a glance
| Official name | Crypto-asset service provider licence1 |
|---|---|
| Local name | Kriptoturto paslaugų teikėjo licencija |
| Also known as | CASP · Lithuanian cryptocurrency licence · Lithuanian crypto exchange licence · Bank of Lithuania CASP licence |
| Issued by | Bank of Lithuania |
| Jurisdiction | Lithuania |
| Licence family | Crypto-asset service provider (MiCA CASP) |
| Legal basis | Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), Art. 59, 62, 632 Republic of Lithuania Law on Markets in Crypto-Assets No XIV-2879, Art. 33 |
| Passporting | EU/EEA passport available: Crypto-asset service providers authorised in Lithuania by the Bank of Lithuania have the right to provide crypto-asset services across all 30 EU and EEA member states, either through the free provision of services or by establishing a branch, upon submitting a passporting notification under MiCA Article 65.2 |
| Minimum capital | EUR 50,0002 |
| Application fee | EUR 2,4254 |
| Annual fee | 0.7% of annual income (minimum EUR 3,000)5 |
| Statutory decision time | 25 working days completeness assessment from receipt, followed by 40 working days decision period from receipt of a complete application2 |
| Public register | official register6 |
| Current holders | 46 |
What it lets you do, and where
What does a Lithuanian MiCA CASP licence let you do, and where can you serve clients?
A Lithuanian CASP licence allows you to provide crypto-asset services across EU Member States through cross-border passporting under MiCA Article 65, following notification to your home competent authority. The home competent authority sends that cross-border information to host Member States' single points of contact, ESMA and EBA within 10 working days under Article 65(2).17
Activities it covers
| Custody and administration of crypto-assets | Safekeeping or controlling crypto-assets, or the means of access to them such as private keys, on behalf of clients. |
|---|---|
| Operating a crypto-asset trading platform | Managing a multilateral system that brings together buying and selling interests in crypto-assets so that contracts are concluded. |
| Exchange of crypto-assets for funds | Buying or selling crypto-assets against fiat money using the provider's own capital. |
| Exchange of crypto-assets for other crypto-assets | Concluding contracts with clients to swap one crypto-asset for another using the provider's own capital. |
| Execution of orders for crypto-assets on behalf of clients | Concluding agreements to buy or sell crypto-assets on behalf of clients, including subscribing to offers. |
| Placing of crypto-assets | Marketing crypto-assets to purchasers on behalf of or for the account of the offeror or a related party. |
| Reception and transmission of orders for crypto-assets | Receiving a client's order to buy or sell crypto-assets and passing it to a third party for execution. |
| Advice on crypto-assets | Giving personalised recommendations to a client about transactions in crypto-assets or the use of crypto-asset services. |
| Portfolio management of crypto-assets | Managing portfolios that include crypto-assets on a discretionary, client-by-client basis under a mandate. |
| Transfer services for crypto-assets | Moving crypto-assets on behalf of a client from one distributed-ledger address or account to another. |
Where it is valid
Do you need it, and is Lithuania the right choice?
What is a Lithuanian crypto-asset service provider licence and do you actually need one?
A Lithuanian CASP authorisation is granted by the Bank of Lithuania under MiCA Regulation (EU) 2023/1114 and Lithuanian Law No XIV-2879 on Markets in Crypto-Assets. MiCA Articles 59 and 63 set the EU CASP licensing framework.23
Is a Lithuanian CASP licence right for your model, and when is Lithuania the wrong choice?
Under Lithuanian Law No XIV-2879 Article 4, a CASP must have a general meeting of shareholders, a board and a manager. As a planning assumption, an MLRO (Cyprus/Lithuania) costs €45,000 to €70,000 a year and a junior compliance officer €35,000 to €55,000.318
Yes. MiCA Article 65 provides cross-border passporting across all EU/EEA member states via a 10-day home NCA notification. On reverse solicitation, the ESMA Guidelines of 17 December 2024 set out the circumstances in which a third-country firm is deemed to solicit clients in the Union, and the supervision practices used to prevent circumvention of the exemption.2
Under MiCA Article 48, issuing e-money tokens is restricted to credit institutions and electronic money institutions. CoinGate and Nuvei Liquidity each obtained both a CASP licence and a Payment Institution licence in Lithuania in December 2025, the latter enabling e-money/EMT-related operations.219
No. The Bank of Lithuania kept CASP approvals at low single digits out of 102 applications, rejecting shell entities. ESMA's fast-track peer review, launched April 2025 and published 10 July 2025, covered the MFSA's authorisation of a CASP. Lithuania's €125,000 capital rule, in force since November 2022, cut registered VASPs from over 800 to a fraction.202122
It depends on the activity. Providing crypto advice requires staff with certified professional competencies under Law XIV-2879 Article 3(8). Publishing a white paper without custodial or brokerage services falls under MiCA Title II rules for offerors. MiCA Recital 22 excludes crypto-asset services provided in a fully decentralised manner without any intermediary.32
MiCA Article 75(8) imposes statutory liability on CASPs for lost client crypto-assets or compromised keys. ESMA's Second Consultation Paper on MiCA (ESMA75-453128700-438) interprets Article 75(8) as exempting CASPs from liability on permissionless DLT they do not control or manage, where there is no contractual arrangement.2324
What it really takes
How much capital do you really need for a Lithuanian CASP licence?
The capital needed is €50,000, €125,000 or €150,000, depending on which crypto-asset services you provide. These are the statutory minimums set by MiCA Article 67 and Annex IV. Lithuania separately had a national own-funds floor of €125,000 for VASPs, enacted in November 2022.21
The list is defined in Commission Delegated Regulation (EU) 2025/305, which specifies the information required in a CASP authorisation application. Law XIV-2879 Article 3 outlines the required application details and their integration with MiCA requirements. Bank of Lithuania Resolution No 03-157 approves the national CASP licensing rules and application filing procedures.253
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | EUR 50,0002 | |
| Ongoing own funds | Ongoing own funds must at all times equal or exceed the higher of the permanent minimum initial capital requirement (EUR 50,000, EUR 125,000, or EUR 150,000) or one quarter (25%) of the preceding year's fixed overheads. Capital must consist of Common Equity Tier 1 (CET1) items under CRR Articles 26-30. Prudential safeguards may partially be met by an approved professional indemnity insurance policy under Article 67(4).2 | MiCA Article 67(1) CRR Articles 26-30 Article 67(4) |
| Who is assessed | The Bank of Lithuania assesses the fitness and propriety of members of the management body (board members, executive directors / CEO), key function holders (Compliance Officer, AML/CFT Officer / MLRO, Risk Officer), and natural or legal persons holding qualifying holdings of 10% or more of share capital or voting rights, or exercising significant influence, including intermediate and ultimate beneficial owners (UBOs). Assessment examines business reputation, integrity, absence of criminal convictions relating to commercial or financial offenses, financial soundness, and adequate time commitment under MiCA Article 68 and Lithuanian Law XIV-2879 Article 4.3 | MiCA Article 68 Law XIV-2879 Article 4 |
| Substance and people | ||
| Registered office and place of effective management in Lithuania | A CASP must be incorporated in Lithuania as an akcinė bendrovė (AB) or uždaroji akcinė bendrovė (UAB), maintain its registered office in Lithuania where it provides at least part of its crypto-asset services, and have its place of effective management within the EU, with at least one executive director resident in the EU.2 | MiCA Article 59(2) Law XIV-2879 Article 3(2) |
| Three-tier corporate governance structure | A licensed CASP must operate a statutory three-tier governance framework comprising a general meeting of shareholders (visuotinis akcininkų susirinkimas), a board (valdyba), and a single-person head/CEO (vadovas).3 | Article 4(1) of the Lithuanian Law |
| Fit and proper leadership and prior regulatory clearance | Board members, executive managers, and key function holders (Compliance Officer, AML/CFT Officer / MLRO) must demonstrate good repute, appropriate qualifications, and sufficient professional experience under MiCA Article 68 and Lithuanian Law XIV-2879 Article 4(2), (5). Appointments require prior formal authorization from the Bank of Lithuania (statutory 30 working days evaluation period). Staff providing crypto advice must maintain certified professional competencies under Article 3(8).3 | MiCA Article 68 Law XIV-2879 Article 4(2) Article 3(8) |
| Safeguarding and segregation of client crypto-assets and funds | CASPs holding client crypto-assets or fiat funds must implement robust safeguarding arrangements ensuring clients' property rights are protected and preventing the use of client assets for the firm's own account. Client fiat funds must be segregated and placed in designated accounts with a central bank or authorized EU credit institution by the close of the next business day, immune from third-party creditors in insolvency.2 | MiCA Article 70 |
| ICT and operational resilience (DORA compliance) | CASPs must maintain resilient digital operational systems, comprehensive ICT business continuity plans, and cybersecurity controls in full conformity with Regulation (EU) 2022/2554 (DORA) and MiCA Article 68(6), including major ICT-related incident reporting and risk management over critical third-party service providers.7 | MiCA Article 68(6) |
| Mandatory statutory annual audit | Annual financial statements must undergo statutory audit by an independent certified auditor, who must specifically examine and confirm compliance with MiCA Article 67 prudential own funds and Article 70 client asset safeguarding/segregation rules, reporting any breach to the Bank of Lithuania within 3 working days under Article 8(1).3 | Article 7(3) of Lithuanian Law XIV-2879 MiCA Article 67 Article 70 |
| Conditions to keep the licence | ||
| Activity commencement deadline | The Bank of Lithuania may withdraw the CASP licence if the institution does not make use of the authorisation within 12 months of the date of grant.2 | MiCA Article 64(1)(a) |
| Dormancy revocation | The Bank of Lithuania may withdraw the licence if the provider has ceased providing crypto-asset services for 9 consecutive months, or has expressly renounced its authorisation.2 | MiCA Article 64(1)(b) |
| Segregation of proprietary and client assets | CASPs must maintain strict accounting segregation between client crypto-assets or funds and proprietary assets. CASPs are prohibited from using client crypto-assets or fiat balances for their own account.2 | MiCA Article 70 |
| Prohibition of proprietary trading on operated platforms | Operators of crypto-asset trading platforms are prohibited from dealing on own account on the trading platforms they operate, even if authorized for exchange or order execution services.2 | MiCA Article 76(5) |
| Market abuse detection and prevention | CASPs must establish and maintain effective arrangements, systems, and procedures to prevent and detect insider dealing, unlawful disclosure of inside information, and market manipulation, with immediate reporting of suspicious transactions or orders to the Bank of Lithuania.2 | Articles 86-92) |
| Periodic supervisory reporting | CASPs must prepare and regularly submit supervisory reports, own funds calculations, and audited annual financial statements to the Bank of Lithuania according to prescribed formats and deadlines.3 | Law XIV-2879 Article 6 MiCA Article 68 |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| EU law | Markets in Crypto-Assets Regulation | Directly applicable EU regulation establishing the CASP authorisation regime, capital requirements, governance, conduct of business, refusal grounds, and passporting (Articles 59-75, 83-84, 94) |
| Act | Lietuvos Respublikos kriptoturto rinkų įstatymas Nr. XIV-2879 | Designates Bank of Lithuania as competent authority (Art. 2(1)), restricts legal form to AB or UAB (Art. 3(2)), mandates 20-working-day info response clock (Art. 3(4)), statutory three-tier governance and prior clearance of managers (Art. 4), supervisory reporting (Art. 6), annual statutory audit (Art. 7-8), and supervisory powers and sanctions (Art. 10-18) |
| Act | Lietuvos Respublikos Lietuvos banko įstatymas Nr. I-678 | Establishes institutional governance and supervisory powers of the Bank of Lithuania, rule-making authority (Art. 42(4)(1)), administrative court appeal procedure (Art. 43-6), and statutory annual supervisory contribution tariff for CASPs in Annex 1 item 42 |
| Regulator rules | Lietuvos banko valdybos 2024 m. gruodžio 17 d. nutarimas Nr. 03-157 „Dėl Kriptoturto paslaugų teikėjų licencijavimo taisyklių patvirtinimo“ | Defines CASP application procedure, 7 annex templates, 5-day receipt acknowledgement (§ 10), 5-day return rule (§ 11), 25-day completeness assessment (§ 12), Lithuanian language requirement for client-facing documents (§ 7-8), licence amendment (§ 18-20), and 15-day change notification duties (§ 21-23) |
| Regulator rules | Lietuvos banko valdybos 2004 m. gegužės 6 d. nutarimas Nr. 58 „Dėl Bendrųjų Lietuvos banko prižiūrimų finansų rinkos dalyvių prašymų išduoti leidimus pateikimo, nagrinėjimo ir leidimų išdavimo taisyklių patvirtinimo“ | Cross-applies general application format rules, filing language rules (Lithuanian or English accepted, foreign documents translated with translator certification), document legalization/apostille (§ 7), and procedural mechanics |
| Procedure law | Lietuvos Respublikos administracinių bylų teisenos įstatymas Nr. VIII-1029 | Governs judicial review of Bank of Lithuania licensing decisions and refusals before the Regional Administrative Court (Regionų administracinis teismas), 1-month filing deadline (Art. 29(1)), and 2-month administrative inaction remedy (Art. 29(3)) |
| Fee schedule | Lietuvos Respublikos Vyriausybės 2000 m. gruodžio 15 d. nutarimas Nr. 1458 „Dėl Konkrečių valstybės rinkliavos dydžių sąrašo ir Valstybės rinkliavos mokėjimo ir grąžinimo taisyklių patvirtinimo“ | Sets statutory state levy of EUR 2,425 for CASP licence issuance in Item 3.157.1 and EUR 272 for licence variation in Item 3.157.2 (as amended by Government Resolution No. 809 of 25 September 2024) |
| Technical standards | Commission Delegated Regulation (EU) 2025/305 of 31 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the information to be included in an application for authorisation as a crypto-asset service provider | Specifies detailed information, business plans, governance policies, ICT and AML documentation required in a CASP authorisation application dossier under MiCA Art. 62(5) |
| Technical standards | Commission Implementing Regulation (EU) 2025/306 of 31 October 2024 laying down implementing technical standards for the application of Regulation (EU) 2023/1114 with regard to standard forms, templates and procedures for the information to be included in an application for the authorisation of crypto-asset service providers | Prescribes standard application forms, templates (Annexes I-IV), and procedures for CASP authorisation applications under MiCA Art. 62(6) |
| Technical standards | Commission Delegated Regulation (EU) 2025/414 of 18 December 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the detailed content of information necessary to carry out the assessment of a proposed acquisition of a qualifying holding in a crypto-asset service provider | Specifies detailed information requirements for prior notification and assessment of qualifying holding acquisitions in a CASP under MiCA Art. 84(4) |
| Technical standards | Commission Delegated Regulation (EU) 2025/299 of 31 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards on continuity and regularity in the performance of crypto-asset services | Specifies business continuity and operational resilience requirements for CASPs under MiCA Art. 68(10) |
| Technical standards | Commission Implementing Regulation (EU) 2025/294 of 31 October 2024 laying down implementing technical standards for the application of Regulation (EU) 2023/1114 with regard to standard forms, templates and procedures for the handling of complaints by crypto-asset service providers | Prescribes complaints-handling templates and procedures for CASPs under MiCA Art. 71(5) |
| Technical standards | Commission Delegated Regulation (EU) 2025/1140 of 27 February 2025 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken | Specifies CASP record-keeping requirements for orders and transactions under MiCA Art. 68(10) |
| Technical standards | Commission Delegated Regulation (EU) 2025/1142 of 27 February 2025 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the requirements for policies and procedures on conflicts of interest for crypto-asset service providers and the details and methodology for the content of disclosures on conflicts of interest | Specifies conflicts of interest policies, procedures, and disclosure methodology for CASPs under MiCA Art. 72(5) |
| Forms | Bank of Lithuania CASP application forms (Annexes 1-7 to the Crypto-Asset Service Provider Licensing Rules, Board Resolution No. 03-157 of 17 December 2024) | National application form templates (Annexes 1-7 to Board Resolution No. 03-157) prescribing specific dossier structures for Lithuanian CASP applicants alongside EU ITS 2025/306 templates |
8 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | ESMA Supervisory Briefing on the Authorisation of Crypto-Asset Service Providers under MiCA (ESMA75-453128328-1116) | Common supervisory expectations across EU NCAs for evaluating CASP business plans, outsourcing, operational substance, and governance under MiCA Arts. 62 and 63 |
| Guidance | Joint EBA and ESMA Guidelines on the suitability assessment of the members of the management body of issuers of ARTs and CASPs (EBA/GL/2024/09 / ESMA35-337584182-5067) | Supervisory methodology and criteria for evaluating fit and proper requirements for CASP managers and qualifying shareholders under MiCA Art. 63(11) and Art. 68 |
| Related regime | Digital Operational Resilience Act | Imposes ICT risk management, incident reporting, operational resilience testing, and third-party risk management directly binding on CASPs (Art. 2(1)(p); MiCA Art. 68(6)); supervised by Bank of Lithuania |
| Related regime | Transfer of Funds Regulation (travel rule) | Obligates CASPs to collect, verify, and transmit originator and beneficiary information accompanying crypto-asset transfers, including transfers to/from unhosted wallets |
| Related regime | Lietuvos Respublikos pinigų plovimo ir teroristų finansavimo prevencijos įstatymas Nr. VIII-275 | Establishes customer due diligence, reporting of suspicious transactions, internal control systems, and dual AML supervision by Bank of Lithuania and FNTT |
| Related regime | Fourth Anti-Money Laundering Directive (as amended by the fifth, 2018/843) | EU framework directive on AML/CFT transposed into Lithuanian national law by Law No. VIII-275 |
| Related regime | Anti-Money Laundering Regulation (single rulebook) partly in force | Directly applicable EU single rulebook establishing harmonised customer due diligence and internal controls for CASPs as obliged entities from 10 July 2027 |
| Related regime | Capital Requirements Regulation | Defines Common Equity Tier 1 (CET1) capital instruments referenced by MiCA Art. 67 for CASP own funds calculations |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | None of the governing texts held for this licence (Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; Law of the Republic of Lithuania on Markets in Crypto-Assets; Law of the Republic of Lithuania on Markets in Crypto-Assets; Republic of Lithuania Law on Banks; Republic of Lithuania Law on Banks; Law of the Republic of Lithuania on Electronic Money and Electronic Money Institutions; Law on Financial Institutions of the Republic of Lithuania; Law on Financial Institutions of the Republic of Lithuania; Republic of Lithuania Law on Payment Institutions; Republic of Lithuania Law on Payment Institutions) contains a provision on the channel (portal, e-mail or paper) through which the application is submitted.89 | Lietuvos banko valdybos 2024 m. gruodžio 17 d. nutarimas Nr. 03-157, 4-5 punktai; Lietuvos banko valdybos 2004 m. gegužės 6 d. nutarimas Nr. 58, 5, 8, 20 punktai; Lietuvos Respublikos elektroninės atpažinties ir elektroninių operacijų patikimumo užtikrinimo paslaugų įstatymas |
| Language | None of the governing texts held for this licence (Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; Law of the Republic of Lithuania on Markets in Crypto-Assets; Law of the Republic of Lithuania on Markets in Crypto-Assets; Republic of Lithuania Law on Banks; Republic of Lithuania Law on Banks; Law of the Republic of Lithuania on Electronic Money and Electronic Money Institutions; Law on Financial Institutions of the Republic of Lithuania; Law on Financial Institutions of the Republic of Lithuania; Republic of Lithuania Law on Payment Institutions; Republic of Lithuania Law on Payment Institutions) contains a provision on the language in which the application must be filed. | |
| What the application contains | The national legal act on e-Seimas for CASP licence applications has seven annexes. At EU level, Delegated Regulation (EU) 2025/305 specifies the information to be included in a CASP authorisation application.810 | Regulation (EU) 2023/1114 (MiCA), Art. 62; Commission Delegated Regulation (EU) 2025/305; Commission Implementing Regulation (EU) 2025/306, Annexes I, IV; Lietuvos banko valdybos nutarimas Nr. 03-157, 5-6 punktai ir 1-7 priedai |
| Decision clock | The Bank of Lithuania must acknowledge receipt within 5 working days (MiCA Art 63(1)) and assess completeness within 25 working days of receipt (Art 63(2)). Once the application is deemed complete, the authority has 40 working days to decide. If incomplete, a deadline is set for missing information; refusal is possible if the file remains incomplete (Art 63(3)). Further-information requests during assessment can suspend the decision clock.1112 | |
| Fees set by law | Government Resolution No. 1458 of 15 December 2000 (List of Specific State Levy Amounts) sets the state levies for a crypto-asset service provider licence issued by the Bank of Lithuania: EUR 2,425 for issuance (point 3.157.1) and EUR 272 for amendment (point 3.157.2). These points were added by Resolution No. 809 of 25 September 2024 and took effect on 30 December 2024.13144 | Lietuvos Respublikos Vyriausybės 2000 m. gruodžio 15 d. nutarimas Nr. 1458, 3.157.1-3.157.2 papunkčiai (įsigaliojo 2024-12-30, redakcija Nr. 809); Lietuvos Respublikos Lietuvos banko įstatymas Nr. I-678, 1 priedėlis, 42 punktas (redakcija Nr. XIV-2880) |
| Grounds for refusal | Under MiCA (Regulation (EU) 2023/1114), paragraph 10 of the CASP authorisation provision requires authorities to refuse authorisation where there are objective and demonstrable grounds that: the management body threatens effective, sound and prudent management, business continuity, client interest or market integrity, or exposes the firm to serious money laundering or terrorist financing risk; management body members fail Article 68(1) criteria; qualifying-holding holders fail Article 68(2) good-repute criteria; or the applicant fails or is likely to fail any requirement of that Title. Another ground applies where third-country close links prevent effective supervision.1115 | |
| Appeal | MiCA requires Member States to make competent-authority decisions properly reasoned and subject to appeal before a court, also where no decision is taken within six months of a complete authorisation application. Under the Law on the Bank of Lithuania, filing a complaint to court does not suspend the challenged decision.1416515 | Lietuvos Respublikos Lietuvos banko įstatymas Nr. I-678, Art. 43-6; Lietuvos Respublikos administracinių bylų teisenos įstatymas (ABTĮ) Nr. VIII-1029, Art. 29(1), 132(1) |
| Validity | None of the governing texts held for this licence (Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; Law of the Republic of Lithuania on Markets in Crypto-Assets; Law of the Republic of Lithuania on Markets in Crypto-Assets; Republic of Lithuania Law on Banks; Republic of Lithuania Law on Banks; Law of the Republic of Lithuania on Electronic Money and Electronic Money Institutions; Law on Financial Institutions of the Republic of Lithuania; Law on Financial Institutions of the Republic of Lithuania; Republic of Lithuania Law on Payment Institutions; Republic of Lithuania Law on Payment Institutions) contains a provision on a fixed term or expiry of the licence. | |
| Change of control | The acquirer notifies the competent authority; the authority acknowledges in writing within 2 working days and assesses the acquisition within 60 working days of the acknowledgement. It may request information up to the 50th working day, suspending the clock up to 20 working days, extendable by up to 30 more if the acquirer is outside the EU or regulated under the law of a third country. If the authority does not oppose within the period, the acquisition is deemed approved; opposition is notified with reasons within 2 working days.1511 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; Law of the Republic of Lithuania on Markets in Crypto-Assets; Law of the Republic of Lithuania on Markets in Crypto-Assets; Republic of Lithuania Law on Banks; Republic of Lithuania Law on Banks; Law of the Republic of Lithuania on Electronic Money and Electronic Money Institutions; Law on Financial Institutions of the Republic of Lithuania; Law on Financial Institutions of the Republic of Lithuania; Republic of Lithuania Law on Payment Institutions; Republic of Lithuania Law on Payment Institutions) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | Yes: passporting. Regulation (EU) 2023/1114 lets a CASP operate throughout the Union through a branch/right of establishment or freedom to provide services; no physical presence in the host state is required. Under Art. 65 it notifies the Bank of Lithuania of the Member States, services and start date; the Bank forwards this within 10 working days to host states' single points of contact, ESMA and EBA. Services may start on receipt of the notice or 15 calendar days after submission (Art. 65(4)).15 |
How long it takes
How long does getting a Lithuanian MiCA CASP licence really take?
Plan for three to six months in total, from first submission to final decision, if your firm is well prepared. By law, MiCA Article 63 sets 25 working days for the completeness check and 40 working days for the authorisation decision.12
MiCA Article 63 sets the main clocks: 25 working days for the completeness check and 40 working days for the substantive assessment. Law XIV-2879 Article 3(4) caps the deadline for submitting missing information at a maximum of 20 working days. Article 63(4) only requires the authority to promptly notify the applicant once the application is complete.32
Statutory: 25 working days completeness assessment from receipt, followed by 40 working days decision period from receipt of a complete application2. Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.
What it costs
What does a Lithuanian MiCA CASP licence cost in total, first year and ongoing?
The state fee for issuing a CASP licence is €2,425, and €272 to amend it (Government Resolution No 1458 items 3.157.1 and 3.157.2, in force 30 December 2024). Ongoing, CASPs licensed under the Crypto-Asset Markets Law pay a supervisory charge of 0.7%, minimum €3,000. As a planning assumption, first-year compliance costs for a 10 to 30 person CASP are around €90,000 to €180,000, before prudential capital.5184
Approval odds and who can own it
Law XIV-2879 Article 4 requires prior authorisation (leidimas) from the Bank of Lithuania for all company heads and board members.3
How many CASP licences has the Bank of Lithuania actually granted?
Independent trackers reported approximately 6 authorised CASPs in Lithuania by May 2026. The Bank of Lithuania authorised CoinGate and Nuvei Liquidity as MiCA CASPs on 17 December 2025, and its register (credit and payment market filter) lists three entities also authorised as CASPs: Nuvei Liquidity, Robinhood Europe and UAB "Decentralized".19261
After you get the licence
It depends on your activity. MiCA Article 48 restricts issuance of e-money tokens to credit institutions and authorised electronic money institutions. Two firms, CoinGate and Nuvei Liquidity, each hold dual CASP and Payment Institution licences in Lithuania, granted in December 2025. DORA Regulation (EU) 2022/2554 also applies directly to CASPs from 17 January 2025.1927
Will a Lithuanian MiCA CASP get a bank account and payment processing?
Client fiat funds must be segregated in credit institutions by the close of the next business day under MiCA Article 70. Direct CENTROlink access is limited to licensed payment and e-money institutions meeting internal control, safeguarding and DORA operational resilience requirements.227
To keep the licence, use it: MiCA Article 64 requires withdrawal after 12 months of non-use or nine consecutive months of ceased crypto services. Law XIV-2879 Article 7(3) mandates annual statutory audits of own funds and asset safeguarding. Lithuania's transitional window for legacy VASPs ended on 31 December 2025, shorter than the period MiCA Article 143(3) permits.226
Yes: a Bank of Lithuania administrative act can be appealed to the Regional Administrative Court within 1 month under ABTĮ Article 29. A further appeal to the LVAT must be lodged within 30 calendar days under ABTĮ Article 138.28
Two changes need prior approval: appointing heads of the management body (Law XIV-2879 Article 4(2)) and acquiring a qualifying holding, which requires prior notification and a 60 working-day review under MiCA Article 83. MiCA Article 64 allows withdrawal after 12 months of non-use or nine consecutive months of ceased services.23
Is an old Lithuanian VASP registration still valid, what happened after 1 January 2026?
No. Lithuania's national VASP regime under Law No XIV-2879 Article 22(3) ended on 1 June 2025, and the EU's MiCA transitional period expired on 1 July 2026. From 2026, operating crypto-asset services in Lithuania without a licence leads to immediate suspension of activities and the risk of large fines.32930
Buying a company that already holds it
The licence is attached to the specific corporate entity (UAB or AB) to which it was granted and cannot be assigned, sold, or transferred to another legal person. A change of ownership must take place via a share acquisition (corporate share deal) subject to the Bank of Lithuania's prior notification and qualifying holding assessment under MiCA Articles 83-84. An asset transfer or business transfer requires the acquiring entity to apply for and obtain its own separate CASP licence.3
Prior notification with an objection period. Any natural or legal person proposing to acquire or increase a qualifying holding (directly or indirectly reaching or crossing 10%, 20%, 30%, or 50% of capital or voting rights, or making the CASP a subsidiary) must give prior written notification to the Bank of Lithuania under MiCA Articles 83-84 and Lithuanian Law XIV-2879. The Bank of Lithuania conducts a suitability and AML/CFT evaluation within a statutory assessment period of 60 working days (interruptible once by up to 20 working days for additional information, or 30 working days for non-EU acquirers). If the regulator does not issue a written objection within this statutory period, the acquisition is deemed approved. Completing a transaction without notification or over regulatory objection divests the acquirer of voting rights and triggers administrative penalties.2
Ready-made companies holding this licence: see verified positions.
CASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Cyprus | Notification by financial entities providing crypto-asset servicesNotification by financial entities providing crypto-asset services under MiCAR Article 60 | CySEC | n/a | EUR 10,000 | ~1.8 mo |
| Cyprus | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under MiCAR Article 63 | CySEC | EUR 50,000 | EUR 5,000 | ~1.8 mo |
| Czech Republic | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under MiCA and Act No. 31/2025 Coll. | CNB | EUR 50,000 | CZK 20,000 | ~3 mo |
| Estonia | Authorisation to operate as a crypto-asset service providerAuthorisation to operate as a crypto-asset service provider under MiCA | FI | n/a | EUR 3,000 | ~3.9 mo |
| France | Crypto-asset service provider authorizationCrypto-asset service provider authorization under EU MiCA Regulation | AMF | n/a | n/a | ~1.8 mo |
| Germany | Crypto-asset service provider licence | BaFin | n/a | n/a | ~1.8 mo |
| Ireland | Crypto-Asset Service Provider Authorisation | CBI | n/a | n/a | ~1.8 mo |
| Italy | Crypto-asset service provider (CASP) authorization | CONSOB | n/a | EUR 20,000 | ~1.8 mo |
| Latvia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | LB | EUR 50,000 | EUR 2,500 | ~3 mo |
| Lithuania | Crypto-asset service provider licence | LB | EUR 50,000 | EUR 2,425 | ~3 mo |
| Luxembourg | Crypto-asset service provider authorisationCrypto-asset service provider authorisation under MiCA Regulation | CSSF | n/a | EUR 30,000 | ~1.8 mo |
| Malta | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under Regulation (EU) 2023/1114 | MFSA | EUR 50,000 | EUR 10,000 | ~1.8 mo |
| Netherlands | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under Regulation (EU) 2023/1114 (MiCA) | AFM | EUR 50,000 | EUR 200 | ~3 mo |
| Poland | Crypto-Asset Service Provider authorizationCrypto-Asset Service Provider authorization under MiCA | KNF | EUR 50,000 | n/a | ~3 mo |
| Slovakia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | NBS | EUR 50,000 | EUR 1,700 | ~3 mo |
| Spain | Crypto-asset service provider authorization | CNMV | n/a | n/a | ~1.8 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114
Getting this licence
Protegra handles this licence end to end: CASP license in Lithuania: process, timeline and our fee.
Frequently asked questions
What is a Lithuanian crypto-asset service provider licence and do you actually need one?
A Lithuanian CASP authorisation is granted by the Bank of Lithuania under MiCA Regulation (EU) 2023/1114 and Lithuanian Law No XIV-2879 on Markets in Crypto-Assets.
How much capital do you really need for a Lithuanian CASP licence?
The capital needed is €50,000, €125,000 or €150,000, depending on which crypto-asset services you provide.
How long does getting a Lithuanian MiCA CASP licence really take?
Plan for three to six months in total, from first submission to final decision, if your firm is well prepared.
What does a Lithuanian MiCA CASP licence cost in total, first year and ongoing?
The state fee for issuing a CASP licence is €2,425, and €272 to amend it (Government Resolution No 1458 items 3.157.1 and 3.157.2, in force 30 December 2024).
What does a Lithuanian MiCA CASP licence let you do, and where can you serve clients?
A Lithuanian CASP licence allows you to provide crypto-asset services across EU Member States through cross-border passporting under MiCA Article 65, following notification to your home competent authority.
Will a Lithuanian MiCA CASP get a bank account and payment processing?
Client fiat funds must be segregated in credit institutions by the close of the next business day under MiCA Article 70.
Is a Lithuanian CASP licence right for your model, and when is Lithuania the wrong choice?
Under Lithuanian Law No XIV-2879 Article 4, a CASP must have a general meeting of shareholders, a board and a manager.
Is an old Lithuanian VASP registration still valid, what happened after 1 January 2026?
No. Lithuania's national VASP regime under Law No XIV-2879 Article 22(3) ended on 1 June 2025, and the EU's MiCA transitional period expired on 1 July 2026.
How many CASP licences has the Bank of Lithuania actually granted?
Independent trackers reported approximately 6 authorised CASPs in Lithuania by May 2026.
Sources
- lb.lt: sfi financial market participants · retrieved 2026-09-24
- EUR-Lex: CELEX 32023R1114 · retrieved 2026-09-24
- Lithuanian Register of Legal Acts (e-seimas) · retrieved 2026-09-24
- Lithuanian Register of Legal Acts (e-seimas) · retrieved 2026-09-24
- Lithuanian Register of Legal Acts (e-seimas) · retrieved 2026-09-24
- lb.lt: sfi financial market participants · retrieved 2026-09-24
- EUR-Lex: CELEX 32022R2554 · retrieved 2026-09-24
- Lithuanian Register of Legal Acts (e-seimas) · retrieved 2026-10-01
- lb.lt · retrieved 2026-10-01
- EUR-Lex: oj · retrieved 2026-10-01
- EUR-Lex: oj · retrieved 2026-10-01
- globallawexperts.com: mica application lithuania · retrieved 2026-10-01
- Lithuanian Register of Legal Acts (e-seimas): TAIS.116101 · retrieved 2026-10-01
- Lithuanian Register of Legal Acts (e-seimas): TAIS.15110 · retrieved 2026-10-01
- Markets in Crypto-Assets Regulation · retrieved 2026-10-01
- Lithuanian Register of Legal Acts (e-seimas): TAIS.73693 · retrieved 2026-10-01
- cysec.gov.cy · retrieved 2023-06-09
- chainscreen.io: crypto compliance cost small casp · secondary · retrieved 2026-03-13
- legasset.com: lithuania mica casp coingate nuvei · secondary · retrieved 2025-12-18
- esma.europa.eu: ESMA42 2004696504 8164 Fast track peer review on a CASP auth (PDF) · retrieved 2025-07-10
- coincub.com: lithuania vasp update · secondary · retrieved 2024-05-15
- fintechbaltic.com: lithuanias crypto sector shrinks following mica implementati · secondary · retrieved 2026-01-20
- esma.europa.eu: ESMA75 453128700 438 MiCA Consultation Paper 2nd package (PDF) · retrieved 2024-10-21
- Lithuanian Register of Legal Acts (e-seimas) · retrieved 2024-07-24
- EUR-Lex: CELEX 32025R0305 · retrieved 2025-02-14
- itispay.com: mica deadline vasp transition status · secondary · retrieved 2026-05-15
- pwc.com: pokyciai dalyvaujant CENTROlink sistemoje · secondary · retrieved 2025-04
- ecovis.lt: e money institutions · retrieved 2024-02-22
- coredo.eu: crypto regulation in lithuania what changed in 2026 · secondary · retrieved 2025-11-17
- finance.yahoo.com: july 1 mica deadline looms 103215096 · secondary · retrieved 2026-06-28
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