Lithuania vs Estonia: CASP authorisation compared

Estonia was, for years, the default answer to "where do we get a crypto licence". That answer is now historical, and anyone reasoning from Estonia's old reputation is reasoning from a market that has been deliberately dismantled by its own supervisors.

What is identical, because MiCA harmonises it

• The list of crypto-asset services that require authorisation (MiCA Article 3 and Annex IV)
• Minimum capital of EUR 50,000 / EUR 125,000 / EUR 150,000 by class (Annex IV)
• The fixed-overheads test: prudential safeguards at the higher of the Annex IV floor and a quarter of fixed overheads (Article 67)
• Application contents (Article 62(2)), and the RTS and ITS that specify their form
• Establishment conditions: registered office, effective management in the Union, at least one Union-resident director (Article 59)
• Governance and fit-and-proper requirements (Article 68)
• The mandatory refusal grounds (Article 63(10))
• EU passporting by notification, with the 15-calendar-day backstop (Article 65)

What actually differs

The application is filed in Estonian

Finantsinspektsioon states it twice on its own licensing page: the application must be submitted in Estonian, and if the applicant intends to submit documents in English, that intention must be clearly stated in the application.

For an international applicant this is the single most consequential difference on this page. It is not a formality. It shapes who drafts the file, what translation costs, how long revisions take, and how directly management can engage with the supervisor's questions. Neither Lithuania nor Latvia states an equivalent requirement on the pages read.

Estonia has its own act on top of MiCA

Applicants are assessed against MiCA and the Estonian Crypto Markets Act. Finantsinspektsioon describes the assessment as testing whether the applicant "meets the requirements of MiCA and CMA", and the conditions for providing services sit in both Article 62 of MiCA and § 6(1) of the CMA. Lithuania and Latvia, on the pages read, point to MiCA with national law around the edges rather than a dedicated crypto act.

Estonia runs the process through a portal, on ESMA's forms

Since 18 March 2026 applications go through the Finantsinspektsioon application portal, on the form at Annex VI to ESMA's RTS, with documents per Annex V. That is a more prescriptive intake than either neighbour publishes, and it means less latitude in how a file is presented.

The transitional periods ended six months apart: with very different results

Lithuania closed its old regime on 31 December 2025. Estonia ran to 30 June 2026. The extra six months did not produce a larger surviving market; it produced a longer wind-down of a much larger one.

Estonia's Financial Intelligence Unit put numbers on that. There were 641 valid licences when it began cleaning up the virtual currency services sector in mid-2021, and 36 valid licences at the start of 2026. As at 14 September 2026 the Finantsinspektsioon register listed one Estonian-established CASP. Lithuania had authorised four as at 3 March 2026.

The FIU's own framing is worth quoting for what it says about supervisory intent: risks "cannot be managed just by supervisory assessment of anti-money laundering documentation, as there must also be supervision of how client assets are safeguarded, and supervision over cyber resilience". That is a regulator describing why it reduced a sector by two orders of magnitude on purpose.

What happened to firms that did not make it

Finantsinspektsioon set out the consequences plainly: companies without an authorisation by 1 July must cease their activities or limit them so that clients' interests are protected, and no unauthorised company may accept new clients, open new accounts or actively market its services. Firms that provided services in the second quarter, including those whose licences were cancelled, still had to file their regular reports.

If you are buying an Estonian shelf company on the strength of an old licence, this is the paragraph to read twice. The licence it holds no longer exists as a register entry.

Who Lithuania suits better

• Applicants without Estonian-language capability, which is most international teams. Filing in a language your management cannot read is a governance problem as well as a cost.
• Firms that want visible peers under the same supervisor. Lithuania's four authorisations include recognisable international groups.
• Anyone who would rather be assessed against MiCA plus implementing law than MiCA plus a separate national crypto act.

Who Estonia suits better

• Applicants who already operate in Estonia with Estonian-speaking management and counsel: the language requirement stops being a cost and the existing substance is real.
• Firms that value a prescriptive, portal-driven intake on ESMA's own forms, because it removes ambiguity about what "complete" means.
• Businesses that were already mid-transition there and would lose ground restarting elsewhere.

The full cost of entry, not the capital figure

Capital is identical under Annex IV. Estonia's published processing fee of EUR 3,000 is a known quantity; Lithuania's is not published on the pages read. The line item that genuinely separates the two is translation and Estonian-language drafting across a file that runs to the full Article 62(2) list plus service-specific policies, and the slower revision cycle that comes with it. Against that, Estonia charges nothing to process the cross-border notification.

Risks and uncertainties in this comparison

• Estonia's supervisory fee is not stated on the page read. Only the application processing fee is.
• Lithuania publishes neither fee on its CASP pages, so the fee row is one-sided rather than a comparison.
• The Estonian register count is a snapshot. New authorisations appear; read the live register.
• The 641 and 36 figures are the FIU's, describing the former virtual currency regime. They are not CASP authorisation counts and should not be presented as though they were.

Primary sources

• Read 2026-09-11 Bank of Lithuania: transitional period ends 31 December 2025
• Read 2026-09-11 Bank of Lithuania: fourth CASP authorisation granted
• Read 2026-09-14 Finantsinspektsioon: The operating license in markets of crypto assets
• Read 2026-09-14 Finantsinspektsioon: The transitional period for providers of crypto asset services is ending (30 June 2026)
• Read 2026-09-14 Finantsinspektsioon: Crypto-asset Service Provider (CASP) register

Questions

Can I still use an Estonian crypto licence?

Not the old one. Finantsinspektsioon stated that Estonia’s transitional period ended on 30 June 2026, and that from 1 July crypto-asset services may be provided in Estonia only under a MiCA authorisation. The Financial Intelligence Unit cancelled the register data for the former virtual currency service provider licences on 1 July.

In what language is an Estonian CASP application submitted?

Estonian. Finantsinspektsioon states that the application must be submitted in Estonian, and that if the applicant intends to submit accompanying documents in English, this must be clearly stated in the application. This is a practical difference from Lithuania and Latvia that affects drafting cost and timeline.

What does Estonia charge to process a CASP application?

Finantsinspektsioon states a processing fee of EUR 3,000, payable when applying for authorisation as a crypto-asset service provider, an issuer of an asset-referenced token, or an e-money institution. No processing fee is payable for the cross-border notification under MiCA Article 65.

How many crypto firms survived Estonia’s transition?

Estonia’s Financial Intelligence Unit reported 641 valid virtual currency service provider licences when it began cleaning up the sector in mid-2021, and 36 valid licences at the start of 2026. As at 14 September 2026, the Finantsinspektsioon register listed one Estonian-established CASP; the remainder of the register consists of cross-border providers authorised in other member states.