Sourced from Regulation (EU) 2023/1114 and the competent authorities. Page verified 14 September 2026. Source register
Lithuania MiCA Desk CASP authorisation and AML readiness in Lithuania

The application clock, stage by stage

The statutory timetable is short. The reason real projects take much longer is that most of the clock does not start until your file is complete, and you control that part.

There are two separate periods, and conflating them is the most common misreading of the process. The 25-working-day period is an administrative check that everything on the Article 62(2) list is present. The 40-working-day period is the substantive assessment, and it only begins once the file is complete.

  1. Within 5 working days of receipt

    Written acknowledgement

    The authority confirms in writing that it has your application. Nothing is assessed yet.

  2. Within 25 working days of receipt

    Completeness check

    The authority checks that the information listed in Article 62(2) has been submitted. If it has not, the authority sets a deadline for the missing pieces. This is a presence test, not a quality test: a policy can be present, counted, and still fail later on its substance.

  3. If you miss that deadline

    The authority may refuse to review at all

    Article 63(3) allows it to decline to review an application that is still incomplete once its deadline has passed. That is not a refusal on the merits; it ends the file.

  4. On completeness

    The 40-working-day assessment begins

    The authority notifies you promptly that the file is complete. Only now does the substantive clock start.

  5. No later than the 20th working day of the assessment

    One request that stops the clock

    The authority may request further information in writing. The assessment period is suspended from the request until your response arrives, for a maximum of 20 working days. Later requests are allowed but do not suspend anything.

  6. Within 40 working days of a complete file

    Fully reasoned decision

    Grant or refusal, with reasons. You are notified within five working days of the decision.

  7. Within 2 working days of a grant

    ESMA is told

    The authority passes the Article 109(5) information to ESMA for the public register. Refusals are reported to ESMA as well.

Article 63(2) gives the competent authority 25 working days from receipt to check whether the application is complete against the Article 62(2) list, and to set a deadline for any missing information.

EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14

Article 63(9) gives the competent authority 40 working days from receipt of a complete application to adopt a fully reasoned decision granting or refusing authorisation, and five working days from that decision to notify the applicant.

EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14

The suspension rule is the one worth planning around

Under Article 63(12) the 40-working-day assessment period is suspended between the date of that request and receipt of the applicant’s response, for no more than 20 working days. Any further requests are at the authority’s discretion and do not suspend the period.

EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14

Read that carefully, because it cuts both ways. The first request buys you time: up to 20 working days of stopped clock in which to produce whatever was missing. Every request after that runs against a clock that keeps ticking. So a file that generates a long tail of follow-up questions does not get a correspondingly long extension; the authority simply reaches its deadline with whatever it has.

There is also a deadline on the authority. It cannot open a clock-stopping request on the 35th working day. If a question that material has not been asked by the 20th, it is either not being asked or it is coming as a discretionary request that costs you assessment time rather than buying it.

What this means for a project plan

Roughly 65 working days of statutory maximum, plus up to 20 suspended, is around four to five months of regulator time in the best case. The preparation that precedes filing is not governed by any of these periods and is where the schedule is actually won or lost. A file assembled to survive the completeness check on the first pass avoids the one failure mode that can end the application outright.

Consultation the authority may run in parallel

Under Article 63(6) the competent authority may consult AML/CFT authorities and financial intelligence units to verify that the applicant has not been the subject of an investigation into money laundering or terrorist financing.

EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14

Article 63(5) additionally requires consultation with another Member State's competent authority where the applicant is a subsidiary of, or under common control with, a regulated entity authorised there, a credit institution, investment firm, payment institution, e-money institution, CSD, market operator, UCITS manager, AIFM, insurer or occupational pension institution. Group structures should expect this and should have the counterpart relationship documented before filing.

What the decision itself turns on is set out separately in the refusal grounds, and what must physically be in the file is in the application contents.

Regulatory references on this page were read against the primary text on 14 September 2026. Every figure is held in the source register with the document it came from.