Lithuania CASP Licence — MiCA Authorisation via Bank of Lithuania
MiCA CASP authorisation via the Bank of Lithuania — fastest EU route to crypto licensing with full EU passporting. Expert advisory.
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What is the Lithuania CASP Licence?
The Lithuania CASP licence is a MiCA authorisation granted by the Bank of Lithuania (Lietuvos bankas), providing full EU-wide passporting rights across all 27 member states. Lithuania is the fastest EU authoriser for Crypto-Asset Service Providers — the Bank of Lithuania typically completes NCA assessment within 3–4 months from receipt of a complete application.
The Bank of Lithuania is commercially engaged with the fintech sector, operates an English-language application portal (LLTA) and provides structured pre-application guidance. Capital requirements are set by MiCA: €50,000 for advisory, reception and transmission, and execution services; €125,000 for custody and exchange services; €150,000 for operating a trading platform.
DORA (Digital Operational Resilience Act) applies from January 2025. Annual regulatory reporting, ongoing AML programme maintenance and Travel Rule compliance under TFR Regulation 2023/1113 apply post-authorisation.
Who Needs Lithuania CASP Licence?
Lithuania is particularly suited to firms seeking the fastest route to MiCA authorisation and full EU passporting rights.
- —Crypto exchanges seeking the fastest EU MiCA authorisation
- —Custodian wallet providers requiring EU-wide passporting
- —Crypto brokers and transfer service providers targeting EU markets
- —Non-EU founder teams benefiting from the Bank of Lithuania's accessible, English-language processes
- —Firms converting from Lithuanian VASP registration to MiCA authorisation
- —Trading platform operators seeking a commercially engaged NCA
A common misconception is that Lithuania's speed implies lower standards. The Bank of Lithuania applies MiCA in full — including substance requirements, DORA compliance and AML programme quality. Speed comes from efficient NCA processes, not reduced regulatory scrutiny. Firms that prepare insufficient applications expecting a rubber-stamp are rejected.
Key Requirements
Initial Capital
€50,000 for advisory, reception and transmission, or execution of orders. €125,000 for custody and administration of crypto-assets or exchange services (fiat-to-crypto and crypto-to-crypto). €150,000 for operating a trading platform. Capital must be maintained on an ongoing basis.
Entity & Substance
Lithuanian UAB (private limited company) required. At least one EU-resident director with genuine operational involvement — the Bank of Lithuania conducts substance interviews. Compliance officer must be Lithuania-based or closely connected to Lithuanian operations.
AML & Financial Crime Controls
AML programme must be crypto-specific: chain analysis tool integration (e.g. Chainalysis, TRM Labs), Travel Rule framework under TFR 2023/1113, crypto-specific customer risk typologies and enhanced due diligence for high-risk crypto activities. Generic AML frameworks from other sectors will not pass.
DORA ICT Risk Management
Digital Operational Resilience Act (DORA) applies to MiCA CASPs. ICT risk management framework, ICT risk register, incident reporting procedures, resilience testing and third-party ICT provider documentation must be demonstrated in the application.
Operational Requirements
Adequate IT infrastructure, business continuity plans, complaints handling procedures and outsourcing governance. Operational resilience proportionate to the scale of crypto-asset services.
Regulatory Reporting
Annual regulatory reporting to the Bank of Lithuania. Ongoing AML programme maintenance and compliance monitoring. Travel Rule compliance reporting.
The Application Process
Jurisdiction Confirmation and Capital Tier Mapping
Regulatory Counsel confirms Lithuania as the optimal NCA for your business model and maps services to MiCA CASP categories and capital tiers. We assess substance requirements and banking partner access. Timeline: 1–2 weeks.
Lithuanian UAB Incorporation and Substance Establishment
Incorporate a Lithuanian UAB. Appoint an EU-resident director with genuine operational involvement. Establish local compliance officer arrangement. Open a Lithuanian or EU bank account. Timeline: 4–6 weeks.
Application Documentation
Regulatory Counsel prepares the full MiCA application: regulatory business plan, AML/CTF programme, governance framework, DORA ICT risk management documentation, management body fitness submissions, financial projections and MiCA white paper where applicable. Timeline: 6–8 weeks.
LLTA Portal Submission
Submit via the Bank of Lithuania's LLTA electronic portal. Completeness is checked within 25 working days. Well-prepared applications proceed to substantive assessment without delay. Timeline: 1 week.
Bank of Lithuania Assessment
The Bank of Lithuania issues queries and may conduct management interviews. Regulatory Counsel manages all NCA correspondence and prepares responses. Lithuania's efficient assessment process typically completes within 3–4 months. Timeline: 3–4 months.
Authorisation and EU Passporting
On authorisation, passporting notifications are filed with ESMA for all target EU member states. Services commence in each state 15 working days after notification. Timeline: 2–3 weeks post-decision.
Total expected timeline: 5–7 months from instruction to authorisation and EU passporting.
Why Applications Fail — and How We Prevent It
Letterbox Entity Rejected
The Bank of Lithuania specifically targets nominee directors and virtual offices. Applications with no evidence of real local management presence are rejected at substance assessment. The NCA conducts interviews with key persons and rejects firms where the substance is superficial — a physical office and genuinely involved management are essential.
AML Programme Not MiCA-Compliant
Generic AML frameworks from other jurisdictions or sectors fail. The Bank of Lithuania requires a crypto-specific AML programme addressing chain analysis integration, Travel Rule compliance under TFR 2023/1113, and crypto-specific customer risk typologies. Firms submitting adapted bank or payment institution AML programmes are rejected.
DORA Readiness Gap
MiCA applications must demonstrate ICT risk management frameworks consistent with DORA. Firms without an ICT risk register, incident reporting procedure and third-party ICT provider documentation are rejected or asked to pause the application pending DORA compliance. This is a new failure mode that many applicants miss.
White Paper Deficiency
Where a white paper is required for token-related services, defective white papers missing mandatory MiCA disclosures result in rejection. MiCA white papers have specific content requirements that differ from marketing-grade documentation. Regulatory Counsel prepares MiCA white papers as part of the standard application.
How Regulatory Counsel Can Help
End-to-End Application Management
From Lithuanian entity establishment through to Bank of Lithuania authorisation and EU passporting — we manage every aspect of your Lithuania CASP application.
Regulatory Business Plan
We prepare MiCA-standard regulatory business plans with crypto-specific AML programmes, DORA ICT risk frameworks and internally consistent financial projections tailored to the Lithuanian NCA.
Ongoing Compliance Support
Post-authorisation compliance support including ESMA passporting notifications, Bank of Lithuania reporting, AML programme updates and DORA compliance maintenance.
Regulatory Counsel has extensive experience with the Bank of Lithuania's CASP authorisation process. We combine deep MiCA expertise with practical knowledge of Lithuanian regulatory procedures, LLTA portal requirements and NCA assessment expectations. Our Lithuanian advisory practice is led by senior consultants with direct NCA relationship experience.
Frequently Asked Questions
The Bank of Lithuania has deliberately positioned as a fintech-friendly regulator — it operates an English-language licensing portal (LLTA), provides structured pre-application guidance and has built significant CASP assessment capacity. Assessment typically takes 3–4 months from complete submission, compared with 6–12 months in Ireland.
A Lithuanian UAB (private limited company), at least one EU-resident director with genuine operational involvement, and a compliance officer who is Lithuania-based or closely connected. Virtual offices and nominee directors are specifically rejected — the Bank of Lithuania conducts substance interviews with key management as part of the assessment.
Yes. After authorisation by the Bank of Lithuania, the CASP notifies ESMA and relevant host NCAs. Services can begin in each passported EU member state 15 working days after notification — no separate national authorisation is required in any of the 27 member states.
Capital is set by MiCA: €50,000 for advisory, RTO and execution services; €125,000 for custody, fiat exchange or crypto-to-crypto exchange; €150,000 for operating a trading platform. Capital must be maintained in liquid form on an ongoing basis.
Yes. Non-EU shareholders and parent companies are permitted — the Bank of Lithuania does not restrict ownership nationality. However, the Lithuanian UAB must be genuinely managed and controlled from Lithuania; non-EU founders must appoint EU-resident management with real operational authority, not nominal roles.