Capital: the Annex IV figure is a floor, not the requirement
Almost every page selling this service quotes €50,000, €125,000 or €150,000 and stops there. That is half of Article 67, and for a business with real staff it is usually the half that does not bind.
Article 67(1) requires prudential safeguards of at least the higher of the Annex IV minimum and one quarter of the preceding year’s fixed overheads, reviewed annually.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
Read it slowly, because the word doing the work is higher. The Annex IV number is a permanent minimum below which you may never fall. The second limb scales with the size of your operation. Whichever is larger at any given moment is your requirement, and it is reviewed annually rather than fixed at authorisation.
Work out which limb binds you
Enter your annual fixed overheads and the class you land in. If you have not worked out your class, the service picker does that first.
Where the crossover sits
One quarter of overheads overtakes the Annex IV floor at €200,000 of annual fixed costs for class 1, €500,000 for class 2 and €600,000 for class 3. Below those lines the floor governs; above them, your own cost base does. A serious class 2 applicant with a Vilnius team, a compliance function and audited infrastructure is frequently above the line, which is why the headline €125,000 so often turns out to be the wrong number to budget against.
What comes out of the overheads figure
Article 67(3) removes from the fixed-overheads figure: profit-dependent staff bonuses and remuneration, employees’, directors’ and partners’ shares in profits, other fully discretionary appropriations of profit and variable remuneration, and non-recurring expenses from non-ordinary activities.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
The exclusions matter more than they look. They are all forms of discretionary or non-recurring spending, and the logic is that fixed overheads should represent what you must keep paying if revenue stops. Variable bonuses tied to profit disappear in a bad year, so they are stripped out; salaries, rent, audit, licences and infrastructure do not, so they stay in.
If you have not been trading a year
Under Article 67(2), a provider that has not been in business for a year uses the projected fixed overheads for its first 12 months, as submitted with its application, for that calculation.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
This is the trap for new applicants. The projection you file with the application becomes the basis of your own-funds calculation, so an optimistic cost plan written to look lean can leave you holding less capital than your actual operation requires within months of authorisation. A projection that understates fixed costs is not a presentational choice. It sets a number you then have to meet.
Forms the safeguard may take
Article 67(4) allows the prudential safeguard to be held as own funds, as an insurance policy or comparable guarantee meeting the conditions the Article sets, or as a combination of the two. Applicants who assume it must be cash sitting in a Lithuanian bank account sometimes over-fund at the expense of working capital.
Still unverified: what Lithuania charges
Fees are a separate question from capital, and this site does not yet state a figure for them. Consultancy pages circulate a state fee and an annual supervisory fee for Lithuania, but no primary Lithuanian instrument or Bank of Lithuania schedule has been located to support them, so they are held in the source register rather than published here.
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.