Crypto trading platform

Twenty-two rows. Twelve countries. Never more than three in any one of them, and none at all in Lithuania. Set that against the 387 rows on the register as a whole and the shape of the thing is clear: this is not a licence class that firms are getting in volume anywhere in Europe, and a page offering you one on a timetable is describing a transaction that has happened twenty-two times.

What makes you a platform rather than a dealer

You match third-party buying and selling interests in a system you run. That is the whole test, and it is about the mechanism rather than the product. If the counterparty to a client's trade is another client, and the meeting of the two happens inside a system you operate, you are running a trading platform within the meaning of MiCA, whatever the service is called commercially.

Being the counterparty yourself is the other business, and it is a class lower. Exchange against your own book is where most firms that use the word exchange actually sit. A firm that does both, matching where it can and filling from its own inventory where it cannot, is a platform for regulatory purposes and should stop looking for a reading that makes it something cheaper.

The two documents that are not documents

Class 3 adds one line to the Article 62(2) list, and that line is the reason this permission is rare: operating rules of the platform, plus the procedure and system to detect market abuse (article 62(2)(n)).

The operating rules are writing, and they are demanding writing: admission criteria for crypto-assets, the order types you support, how and when trading halts, how settlement works, what happens when a participant defaults. Firms underestimate them but they can be produced.

The market-abuse system is not writing. It is software that has to be running, ingesting your order flow, and raising alerts that someone reviews and dispositions on a schedule you can evidence. You are being asked to show a working surveillance capability, with the thresholds that trigger it, the people who sit behind it and the record of what they did with what it produced. That is an engineering project and a hiring plan, not a chapter in a policy pack, and it is where a class 3 budget actually goes.

You will also be a custodian

Of the 22 rows naming a trading platform, 19 also name custody and administration. The classes are cumulative, so class 3 already covers every class 2 and class 1 service, but the point is practical rather than formal: a venue holds participant balances to settle against, which is custody, which brings the custody policy and the client-asset segregation with it. What that adds.

The capital floor for class 3 is €150,000, and as everywhere it is only the floor. Article 67 takes the higher of it and a quarter of annual fixed overheads, and a firm running surveillance software and a trading operation passes the point where overheads govern early. Work it through on your own cost base.

What zero means if you were planning to file in Lithuania

It does not mean the Bank of Lithuania refuses trading platforms. Nothing published says that, and we are not going to imply it from an absence. What it means is narrower and still worth knowing: the authority has not yet granted this permission, so there is no local precedent, no sense of how it handles surveillance evidence, and nobody ahead of you whose file shaped the expectations yours will be read against.

Weigh that against where the permission does exist. Malta and the Netherlands have three rows each, and Malta has regulated this sector since 2018. Lithuania against Malta sets out what that history changes. The honest version of this advice is that jurisdiction choice matters more for a venue than for any other model on this site, and it is not a question we would answer from a page.

What this page could not verify