Lithuania CASP Licence: MiCA Authorisation by the Bank of Lithuania
Lithuania CASP licence under MiCA: Bank of Lithuania requirements, €50,000 to €150,000 capital, Lithuanian documents, statutory timeline and EU passport.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 19 October 2026.
The short answer
A Lithuania CASP licence is an authorisation granted by the Bank of Lithuania under Article 63 of the Markets in Crypto-Assets Regulation (MiCA). A CASP, or crypto-asset service provider, is a firm that provides services such as crypto custody, exchange, brokerage or transfers for clients. The licence lets a Lithuanian company provide the crypto-asset services named on it in Lithuania and, after a simple notification, across the European Union.
The Lithuanian transitional period ended on 31 December 2025. Since 1 January 2026 every firm providing crypto-asset services in Lithuania needs a MiCA licence from the Bank of Lithuania or from another EU regulator. The old Lithuanian virtual asset service provider (VASP) registration no longer gives any right to operate.
The applicant must be a Lithuanian company with real management and operations in Lithuania, hold capital of €50,000, €125,000 or €150,000 depending on its services, and file a complete application in the Bank of Lithuania's prescribed format, with the business plan and client documents in Lithuanian. The Bank checks completeness within 25 working days and decides within 40 working days of a complete application.
Key facts at a glance
| Regulator | Bank of Lithuania (Lietuvos bankas), the competent authority for all of MiCA in Lithuania |
|---|---|
| Legal basis | Regulation (EU) 2023/1114 (MiCA), the Republic of Lithuania Law on Markets in Crypto-Assets and the Bank of Lithuania CASP Licensing Rules (Board Resolution No 03-157) |
| Permission | Crypto-asset service provider licence under MiCA Article 63, listing the specific services authorised |
| Entity | A Lithuanian company with its registered office in Lithuania, typically a UAB (private limited company), with its place of effective management in the EU |
| Management | At least one director resident in the EU (MiCA Article 59). The Bank of Lithuania expects at least part of the key decision makers to reside in Lithuania |
| Minimum capital | €50,000, €125,000 or €150,000 by service class (MiCA Annex IV), or one quarter of the previous year's fixed overheads if higher |
| Statutory timetable | Receipt confirmed within 5 working days, completeness checked within 25 working days, decision within 40 working days of a complete application |
| Language | Business plan and client-facing procedures in Lithuanian. The Bank may request other documents in Lithuanian |
| State fee | Payable before filing. Proof of payment is part of the application. The amount is set by Government Resolution No 1458 on state fee amounts |
| Transitional period | Ended 31 December 2025. A MiCA licence has been required since 1 January 2026 |
| EU passport | Article 65 notification. Services may start in each host state from the Bank's confirmation or, at the latest, the 15th calendar day after notifying |
| Licensed firms | Six entries with Lithuania as home state on the ESMA interim MiCA register (update of 16 October 2026) |
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What is the Lithuania CASP Licence (MiCA)?
The Lithuania CASP licence is the authorisation the Bank of Lithuania grants under the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114 (MiCA), to a Lithuanian company that provides crypto-asset services. It replaced the national VASP registration that Lithuanian crypto firms held before MiCA. That registration lost all effect when the transitional period ended on 31 December 2025.
The licence is valid across the European Union. A Lithuanian CASP can serve clients in other member states by notification, without separate authorisation in each country. The Bank of Lithuania is the competent authority for the whole of MiCA in Lithuania, and it applies the Lithuanian Law on Markets in Crypto-Assets and its own Licensing Rules alongside the Regulation.
MiCA sets the requirements: capital by service class, a fit and proper management body, governance and internal controls, safeguarding of client assets, complaints handling, conflicts of interest rules and service-specific conduct rules. Anti-money laundering law, the EU Travel Rule and the Digital Operational Resilience Act (DORA) apply in parallel.
Who needs Lithuania CASP Licence (MiCA)?
Any firm that wants to provide crypto-asset services from Lithuania, or to use Lithuania as its EU home state, needs this licence.
- - Crypto exchanges and brokers serving retail or institutional clients
- - Custodial wallet providers holding crypto-assets for clients
- - Crypto payment and transfer providers, including merchant crypto payment services
- - Trading platform operators
- - Former Lithuanian VASPs that did not obtain a MiCA licence before 31 December 2025
- - Non-EU groups choosing Lithuania as their EU home state, with management that will genuinely sit in Lithuania
A Lithuanian VASP registration is not a licence and has given no right to operate since 1 January 2026. Equally, a Lithuanian e-money or payment institution cannot provide general crypto services under its existing licence: an e-money institution may use the Article 60 notification only for custody and transfers of the e-money tokens it issues itself. Everything else needs a CASP licence.
Which services need a Lithuania CASP licence?
MiCA lists ten crypto-asset services. Providing any of them in Lithuania, or to Lithuanian clients, requires a MiCA licence unless the firm is an existing financial institution using the Article 60 notification route. The Bank of Lithuania licence names each service the firm may provide, so the licence must match the business model exactly.
| Class | Services that place you in this class | Permanent minimum capital |
|---|---|---|
| Class 1 | Execution of orders, placing of crypto-assets, transfer services, reception and transmission of orders, advice, portfolio management | €50,000 |
| Class 2 | Any Class 1 service plus custody and administration, exchange of crypto-assets for funds, or exchange of crypto-assets for other crypto-assets | €125,000 |
| Class 3 | Any Class 2 service plus operation of a trading platform for crypto-assets | €150,000 |
Transfer services sit in Class 1 at €50,000. Custody and exchange move a firm to Class 2.
What the Bank of Lithuania expects from applicants
The Bank of Lithuania published its expectations for future CASPs on 16 August 2024 and it applies them to every application. The message is consistent: it licenses firms that will genuinely operate from Lithuania and that understand both MiCA and Lithuanian law.
- - A real operation in Lithuania, not an empty shell. A firm that has outsourced most of its key operational and control functions will not be licensed
- - At least part of the key managers who take decisions should reside in Lithuania, or the firm must show another way of ensuring proper management and access for the supervisor
- - Management that understands Lithuanian legal requirements as well as MiCA
- - A clear, documented origin of the funds used to capitalise the firm, including the funder's business history and the funding scheme
- - A simple, transparent ownership chain. Complex group structures must be justified and the Bank may ask for them to be simplified
- - Documents written for the applicant's own business model. Quoting the text of MiCA does not meet the standard
Governance and management body
The Bank of Lithuania expects either a single-tier board with enough non-executive members to keep decisions objective, or a two-tier structure with a management board and a supervisory board. No single person should dominate, and the same person should not perform a function and supervise it.
Every board member and every shareholder with a qualifying holding (10% or more) must prove good repute. Criminal record certificates and similar documents must be issued no earlier than three months before the application date. Suitability is assessed under the joint EBA and ESMA guidelines.
ESMA's supervisory briefing of January 2025 sets the same direction for all EU regulators: the chief executive should, as a rule, work full time for the CASP, other executive board members should give at least half their time, and at least one executive board member should be resident in the member state that grants the licence.
The application pack
The Bank of Lithuania prescribes the format. The Licensing Rules require an application form and up to six descriptive annexes, plus Lithuanian-language prudential and reporting tables completed as at the application date. An application that does not follow the prescribed form may be returned without review within five working days.
| Document | What it covers |
|---|---|
| Annex 1: Application | The licence request, applicant details, list of attached documents and proof that the state fee has been paid |
| Annex 2: Programme of operations | The business plan: services, clients, markets, marketing, three-year projections under a base case and a stress case |
| Annex 3: Organisational structure and internal control | Board, management, key functions, reporting lines, compliance, risk and internal audit |
| Annex 4: Anti-money laundering | Internal procedures for preventing money laundering and terrorist financing, including sanctions screening |
| Annex 5: ICT risk management | The information and communication technology risk framework required by DORA |
| Annex 6: Outsourcing and ICT third parties | Every outsourced function and ICT service provider, with oversight and exit arrangements |
| Annex 7: Trading platform | Operating rules and market abuse detection, only if the firm will run a trading platform |
| Prudential and reporting tables | Capital calculation and reporting forms, in Lithuanian, as at the application date |
The Article 62(2) MiCA list and ESMA's technical standards on the content of applications set the minimum content of each annex.
Language: what must be in Lithuanian
The programme of operations (business plan) and every procedure that will be given to clients before services start must be drawn up in Lithuanian. That includes the policy on segregating client assets, complaints handling, the custody policy, the execution policy, the commercial and pricing policy for exchange services, trading platform rules and the description of transfer services, where relevant. The Bank of Lithuania may also ask for other documents in Lithuanian.
In practice we prepare the full pack in English and Lithuanian in parallel, so the board works from one version and the regulator receives a consistent text.
Anti-money laundering, the Travel Rule and DORA
- - Anti-money laundering: Lithuanian law implementing Directive (EU) 2015/849 applies today. The EU Anti-Money Laundering Regulation (EU) 2024/1624 applies from 10 July 2027
- - Travel Rule: Regulation (EU) 2023/1113 has applied since 30 December 2024. It requires originator and beneficiary information to travel with every crypto-asset transfer, with no minimum threshold
- - DORA: the Digital Operational Resilience Act, Regulation (EU) 2022/2554, has applied to CASPs since 17 January 2025. It covers ICT risk management, incident reporting, resilience testing and oversight of ICT providers
- - Risk assessment: the Bank expects a business-wide money laundering risk assessment covering all activities, updated at least annually and after any material change
E-money tokens and the payment licence
An e-money token (EMT) is a stablecoin that references a single official currency, such as a euro or US dollar stablecoin. Following the EBA no-action letter of 10 June 2025, the Bank of Lithuania confirmed that a CASP providing custody of EMTs or transfer services involving EMTs on behalf of clients also needs a payment services licence under PSD2 from 2 March 2026, or must provide those services through a licensed partner. Exchanging EMTs for funds or other crypto-assets is not a payment service.
If your model includes EMT custody or transfers, we scope the payment institution application alongside the CASP application so both rely on the same governance, AML and ICT documentation.
Passporting from Lithuania across the EU
Once licensed, the firm notifies the Bank of Lithuania of the member states it will serve, the services and the start date (MiCA Article 65). The Bank passes the notification to the host states, ESMA and the EBA within 10 working days. Services may begin in each host state from the date the Bank confirms that communication or, at the latest, from the 15th calendar day after the firm submitted its notification. No physical presence is needed in host states for cross-border services.
After authorisation
- - Capital must be held at all times at the higher of the Annex IV floor and one quarter of fixed overheads
- - Regular reporting to the Bank of Lithuania under its reporting procedure (Resolution No 03-121) and payment of annual supervisory contributions
- - Prior permission for changes to the management body and prior notification of acquisitions of qualifying holdings
- - A wind-down plan for firms providing custody, trading platform, exchange, execution or placing services (MiCA Article 74)
- - The licence is withdrawn if it is not used within 12 months or if no services are provided for nine consecutive months (MiCA Article 64)
Lithuania and Ireland compared
Both regulators apply the same MiCA rules and statutory timetable. The differences are in process, language and local presence.
| Point | Lithuania (Bank of Lithuania) | Ireland (Central Bank of Ireland) |
|---|---|---|
| Transitional period ended | 31 December 2025 | 30 December 2025 |
| Pre-application stage | No formal stage published. The Bank meets applicants during the assessment as needed | Initial engagement meeting and Key Facts Document before the firm is invited to apply |
| Language | Business plan and client-facing procedures in Lithuanian | English |
| Local management | At least part of key decision makers resident in Lithuania | Local crypto-competent executive team and board with autonomy from the group |
| Application channel | Prescribed forms and annexes under the Licensing Rules | Central Bank Portal, mandatory since 2 April 2026 |
| Statutory timetable | 25 working days completeness, 40 working days decision | 25 working days completeness, 40 working days decision |
| Home-state entries on ESMA register (16 October 2026) | Six | Twelve |
Choose the home state where your management will genuinely sit and where your banking and client base fit best. The passport is identical from either.
Key requirements
Capital
The higher of the MiCA Annex IV floor (€50,000 for Class 1, €125,000 for Class 2, €150,000 for Class 3) and one quarter of the previous year's fixed overheads. New firms use projected overheads for their first 12 months. Capital may be Common Equity Tier 1 own funds, a qualifying insurance policy, or both.
Entity and substance
A Lithuanian company with its registered office in Lithuania, its place of effective management in the EU and a real operation in Lithuania. At least part of the key decision makers should reside in Lithuania. Key operational and control functions must not be outsourced to the point that the company becomes an empty shell.
Management and shareholders
Board members and qualifying shareholders of good repute, with criminal record documents issued no more than three months before filing. Collective knowledge of crypto-assets, MiCA and Lithuanian law. A board structure with non-executive members or a supervisory board.
Origin of funds
Full disclosure and documentary evidence of the source of the capital, the funder's business history and the funding scheme.
AML, Travel Rule and DORA
A money laundering and sanctions framework built for the firm's crypto business, Travel Rule compliance under Regulation (EU) 2023/1113, and an ICT risk framework meeting DORA, covering incident reporting and ICT third-party oversight.
Client protection
Segregation of client crypto-assets and funds, with client funds placed with a credit institution or central bank by the end of the next business day (MiCA Article 70), complaints handling, conflicts of interest controls and service-specific policies.
What does a Lithuania CASP licence cost?
The main cost items are regulatory capital, the state fee, and the people and systems the Bank of Lithuania expects to see in place in Lithuania.
- - Regulatory capital: €50,000, €125,000 or €150,000 depending on class, or one quarter of fixed overheads if higher. It can be held as Common Equity Tier 1 own funds, an insurance policy meeting Article 67, or a combination
- - State fee: payable before filing under Government Resolution No 1458. We confirm the current amount at scoping
- - Annual supervisory contributions to the Bank of Lithuania once licensed, set by Board resolution each year
- - People in Lithuania: resident decision makers, compliance and money laundering prevention staff, and a board with non-executive members
- - Systems: blockchain analytics, Travel Rule messaging, transaction monitoring, sanctions screening and DORA-compliant ICT arrangements
- - Translation of the business plan and client documents into Lithuanian, and audited financial statements once trading
- - Professional fees: we quote a fixed fee once the scope is confirmed
The application process
Scope services and class
We map your business model to the ten MiCA services, confirm your capital class and identify any EMT activity that also needs a payment licence.
Set up the Lithuanian company and team
Incorporate or adapt the Lithuanian company, appoint resident decision makers and a board with non-executive members, and evidence the origin of the capital.
Prepare the application pack
We draft the application form and Annexes 2 to 7, the Lithuanian prudential and reporting tables, and the Lithuanian-language business plan and client procedures, tailored to your model.
Pay the state fee and file
File the complete pack with proof of state fee payment. The Bank confirms receipt within 5 working days and checks completeness within 25 working days.
Assessment
The Bank decides within 40 working days of a complete application, with one possible pause of up to 20 working days for further information. We prepare management for meetings and handle all correspondence.
Licence and passport
On authorisation, we file Article 65 notifications for your target member states. Services may start in each from the Bank's confirmation or, at the latest, the 15th calendar day after notification.
Statutory timetable once filed: completeness within 25 working days and a decision within 40 working days of a complete application, with one possible pause of up to 20 working days. Preparation time depends on how ready your team, capital and documents are.
How long does a Lithuania CASP licence take?
The timetable is set by MiCA Article 63 and the Bank of Lithuania Licensing Rules. The Bank confirms receipt within 5 working days and checks completeness within 25 working days. Once the application is complete, it decides within 40 working days. It may pause that clock once, for up to 20 working days, to request further information, and must make that request by the 20th working day of the assessment.
The Bank sets the deadline for any missing information at the completeness stage and may refuse to review an application that remains incomplete. The preparation phase, and the completeness of what is filed, therefore decide the overall timeline. A complete, Lithuania-specific application moves through on the regulator's own timetable.
Why applications fail, and how we prevent it
Substance outside Lithuania
The Bank of Lithuania licenses firms run from Lithuania. Plan resident decision makers and an in-house control function from day one.
Origin of funds not evidenced
The Bank asks for documentary proof of where the capital comes from and the funder's business history. Prepare this before filing.
Documents not in the prescribed form
Applications that do not follow the Licensing Rules and annex templates can be returned within five working days. Use the Bank's forms and the Lithuanian tables.
Generic policies
Policies that restate MiCA without describing your own clients, products and controls do not meet the Bank's standard. Write every document for your business model.
Practitioner notes on Lithuanian CASP applications
- - Write the business plan in Lithuanian from the start. Translating late is where inconsistencies between versions creep in
- - Document the origin of funds with the funder's full business history before filing. The Bank asks for it in every case
- - Put real decision makers in Vilnius. A Lithuanian director with no authority does not satisfy the Bank or the ESMA briefing
- - Keep key operational and control functions in-house. Outsourcing is allowed, but not to the point where the Lithuanian entity has no real activity
- - Map EMT activity early. Custody or transfer of e-money tokens needs a payment licence or a licensed partner
- - Order criminal record certificates last. They must be no more than three months old on the filing date
- - Check the ESMA interim register and the Bank of Lithuania list of licensed CASPs when choosing partners. A former VASP registration is not a licence
How we help
Application management
We scope your services and class, plan your Lithuanian substance and manage the filing and every round of Bank of Lithuania correspondence through to licence.
Application pack in English and Lithuanian
Business plan, Annexes 2 to 7, AML and Travel Rule framework, DORA ICT documentation and client procedures, prepared in parallel in both languages.
Compliance after licensing
Passporting notifications, Bank of Lithuania reporting, AML risk assessment updates, DORA incident processes and change of control filings.
Regulatory Counsel obtains licences and runs compliance across 65+ jurisdictions. For a Lithuania CASP licence we prepare the full application in the Bank of Lithuania's prescribed format, build the Lithuanian-language documents with you, and keep your capital, governance and AML framework aligned with MiCA after authorisation. We answer every enquiry the same business day with a written proposal, and we quote a fixed fee once the scope is confirmed.
Frequently asked questions
Set up a Lithuanian company with real management in Lithuania, hold the MiCA capital for your services, pay the state fee and file a complete application with the Bank of Lithuania using its Licensing Rules and annex templates. The Bank checks completeness within 25 working days and decides within 40 working days of a complete application.
MiCA sets it, not Lithuania: €50,000 for Class 1 services such as execution, transfer, advice and order transmission; €125,000 if you add custody or exchange; €150,000 if you operate a trading platform. You must hold the higher of that floor and one quarter of your previous year's fixed overheads.
MiCA sets the timetable: receipt confirmed within 5 working days, completeness checked within 25 working days, and a decision within 40 working days of a complete application. The Bank may pause the assessment once for up to 20 working days to request more information.
A non-EU group can own the licensed company. The licence itself is granted to a Lithuanian company with its registered office in Lithuania, its effective management in the EU and at least part of its key decision makers resident in Lithuania.
The business plan and all procedures given to clients before services start must be in Lithuanian, and the prudential and reporting tables are provided in Lithuanian. The Bank of Lithuania may ask for other documents in Lithuanian too.
No. The transitional period ended on 31 December 2025. Since 1 January 2026 crypto-asset services in Lithuania require a MiCA licence from the Bank of Lithuania or from another EU regulator with a passport notification.
A state fee is payable before filing and proof of payment forms part of the application. The amount is set by Government Resolution No 1458 on state fee amounts. We confirm the current figure when we scope your application.
Yes. After authorisation you notify the Bank of Lithuania of your target member states. Services may start in each from the Bank's confirmation or at the latest on the 15th calendar day after your notification, with no local presence needed for cross-border services.
For custody or transfers of e-money tokens on behalf of clients, yes: since 2 March 2026 a CASP also needs a PSD2 payment licence or a licensed partner. Exchanging e-money tokens for funds or other crypto-assets does not require one.
Only in part. Under MiCA Article 60 an e-money institution can notify the Bank of Lithuania 40 working days in advance to provide custody and transfers for the e-money tokens it issues itself. Any other crypto service needs a CASP licence.
The ESMA interim MiCA register update of 16 October 2026 shows six entries with Lithuania as home state. Robinhood Europe UAB received the first Bank of Lithuania CASP licence in May 2025.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- Regulation (EU) 2023/1114 on markets in crypto-assets (EUR-Lex)
- Bank of Lithuania: authorisation of crypto-asset service providers
- Bank of Lithuania: markets in crypto-assets
- Bank of Lithuania: CASP Licensing Rules (Resolution No 03-157, English)
- Bank of Lithuania: expectation letter to future CASPs (16 August 2024)
- Bank of Lithuania: end of the crypto transitional period (31 December 2025, Lithuanian)
- ESMA: MiCA page and interim MiCA register
- ESMA: supervisory briefing on the authorisation of CASPs (January 2025)
Last reviewed by the Regulatory Counsel team on 19 October 2026.