The Lithuanian CASP licence, from the applicant's side
A map of the decisions you make before drafting anything: what you intend to do, which regulated service that turns out to be, and what evidence each one drags behind it.
Start from the activity, not the licence
Almost every mistake in this process starts with an applicant deciding they want "a crypto licence" and working backwards. The regulation does not issue that. It authorises named services, and the set you pick determines your capital floor, the policies you have to write and the people you have to hire.
So the first question is narrow and concrete. When a client hands you value, whose balance sheet is it on, who can move it, and what do you do with it? Answer that honestly and the service classification usually writes itself. The service picker turns the answer into a class and a capital floor.
The distinction that trips up half the applicants
Firms describing themselves as "an exchange" usually mean the class 2 exchange services, quoting a price and trading against the client on their own account. Operating a trading platform means running a system that matches third-party buying and selling interests. That is class 3, €150,000, and it obliges you to produce operating rules and a working market-abuse detection system. One word in a business plan, two very different projects.
What changed, and when
Lithuania’s transitional period for obtaining a crypto-asset service provider licence ended on 31 December 2025.
Bank of Lithuania, Investors should find out if their crypto-asset service provider intends to be licensed (2025-07-21) · Verified on 2026-09-11 · Next review 2026-12-11
Anything written before that date describing a Lithuanian registration route is describing a regime that no longer exists. That includes a good deal of material still ranking for these queries.
Who has actually cleared the bar
As at 3 March 2026, the Bank of Lithuania had granted four CASP authorisations under MiCA: Robinhood Europe UAB, UAB “Decentralized” (CoinGate), Nuvei Liquidity UAB and Micar assets UAB.
Bank of Lithuania, An authorisation of a crypto asset service provider granted to Micar assets, UAB (2026-03-03) · Bank of Lithuania, Supervised financial market participants · Verified on 2026-09-11 · Next review 2026-10-11
The identity of those four is more instructive than the count. Two are subsidiaries of established international financial groups, one is a payments processor with roughly a decade of history, and the fourth is backed by a licensed finance brokerage. Every one had a regulated parent, a real operating record, or both. There is no rule requiring that, but it is the observable pattern, and it is worth looking at in full.
The four things the assessment turns on
- Prudential position. The higher of the Annex IV floor and a quarter of your fixed overheads, at all times, reviewed annually. How to work it out.
- Establishment. A registered office in a Member State where you carry out at least part of the services, effective management in the Union, at least one Union-resident director. What that does and does not require.
- Governance and people. Repute, collective competence and demonstrable time commitment on the management body; qualifying holders traced through to natural persons. The evidence involved.
- Controls that exist rather than adopted. Article 68(4) asks for policies "sufficiently effective to ensure compliance". A bought policy pack passes the completeness check and fails the assessment.
The timetable, briefly
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
Roughly 65 working days of statutory maximum, plus up to 20 suspended while the authority waits on a request for information. The preparation that precedes filing is governed by none of those periods and is where the schedule is actually decided. Stage by stage.
What ends an application
Two different things, and they are worth separating. Refusal on the merits comes from the four mandatory grounds in Article 63(10), management body, individual suitability, qualifying holders, or failing any requirement of the Title. Separately, an application still incomplete after the authority's deadline may simply not be reviewed at all. The grounds in detail.
What the authorisation is worth once you have it
Under Article 65 the home authority communicates a cross-border notification to host single points of contact, ESMA and EBA within 10 working days, and the provider may begin from receipt of that communication or at the latest from the 15th calendar day after submitting the information.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
This is the commercial case for the whole exercise: one authorisation, notified onward, and you may serve clients across the Union without a local entity, office or licence in any of those markets. How the notification runs.
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.