--- title: "Lithuania vs France: CASP authorisation compared" description: "France is where advisory and portfolio-management permissions concentrate, and where an existing PACTE-law registration earns a simplified MiCA procedure. Lithuania offers neither." url: https://unbui.lt/services/mica-casp-licence/lithuania-vs-france/ lang: en-GB updated: 2026-09-15 --- [Home](/) / [Services](/services/mica-casp-licence/) / Lithuania vs France Jurisdiction comparison # Lithuania vs France: CASP authorisation compared France regulated this sector five years before MiCA and built the register to prove it. Whether that matters to you depends almost entirely on whether you already hold a French registration. The PACTE Law of 22 May 2019 created the French digital asset service provider regime, one of the first bespoke crypto frameworks in Europe. It is being phased out, but it did not vanish without trace: it shaped both who is authorised in France today and how quickly they got there. Read off each regulator's own pages: Bank of Lithuania on 2026-09-11, Autorité des marchés financiers (AMF) on 2026-09-15. Cells marked _not located_ are fields the regulator does not publish, or that were not found; no figure has been carried over from a secondary source. | Criterion | Lithuania | France | | --- | --- | --- | | Regulator | Bank of Lithuania | Autorité des marchés financiers (AMF) | | Legal framework | MiCA, with Lithuanian implementing law | MiCA. France ran the PACTE Law digital asset service provider regime from May 2019. | | Old regime transitional period | Ended 31 December 2025 | 18 months, to 1 July 2026. The DDADUE law of 9 March 2023 let DASPs registered or licensed in France on 30 December 2024 continue until then. | | Application fee | Not located on the regulator’s pages. Consultancy sites circulate a figure; no Lithuanian instrument found to support it. | Not stated on the AMF page read. | | Supervisory fee | Not located on the regulator’s pages. | Not stated on the AMF page read. | | Language of application | Not stated on the pages read. | Not stated on the AMF page read. | | How it is submitted | Not stated on the pages read. | Application file by email to the AMF’s PSAN address, on the Article 62(5) RTS form. | | Pre-application support | No published pre-application stage found on the pages read. | A simplified procedure for holders of an enhanced DASP registration or a DASP licence: the file reuses what the AMF already holds and flags what has changed. | | Completeness check | 25 working days (MiCA Article 63(2)) | 25 working days (MiCA Article 63(2)) | | Decision period | 40 working days from a complete application (MiCA Article 63(9)) | 40 working days from a complete application (MiCA Article 63(9)) | | Clock suspension | Up to 20 working days (MiCA Article 63(12)) | Up to 20 working days (MiCA Article 63(12)) | | Domestic authorisations granted | Four Article 63 authorisations, plus two entities providing services under Article 60(4): six entries in the ESMA register | 35 in the ESMA register, all under Article 63. Second largest in the EEA. | ## What is identical, because MiCA harmonises it The service list, the Annex IV capital classes, the Article 67 fixed-overheads test, the application contents, the establishment conditions, the governance requirements, the refusal grounds and the passporting mechanism are the same in both. [The full list, stated once](/services/mica-casp-licence/#harmonised). ## The one thing on this page that is genuinely a French invention A simplified procedure for firms that were already inside the PACTE regime. The AMF states that providers holding an enhanced DASP registration or a DASP licence may use a route designed to make examination faster. It is not a lighter standard: the applicant still files a complete authorisation file meeting the MiCA requirements. What changes is that the file carries over what the AMF already holds from the enhanced registration or licence, and states what has significantly changed since. If you hold one of those French registrations, that is a real asset and it does not travel. It is the strongest single argument for staying in France rather than moving to a smaller jurisdiction. If you do not hold one, the procedure is not available to you and France offers you nothing Lithuania does not. ## Where the French register is unusual Counted by permission, France is the advisory end of the European market. Share of authorised CASPs holding each permission. Counted from the ESMA register on 15 September 2026; the European column covers all 346 entries. | Permission | France (n=35) | Europe | Lithuania (n=6) | | --- | --- | --- | --- | | Providing advice on crypto-assets | 34% | 13% | 0% | | Providing portfolio management | 37% | 16% | 0% | | Operation of a trading platform | 3% | 6% | 0% | Advice and portfolio management run at more than double the European rate. Venues run below it: one French CASP in 35 may operate a trading platform. The names match the shape, with CACEIS Bank and CoinShares Asset Management alongside the payment and wallet firms. No Lithuanian CASP holds an advice or portfolio-management permission. That is not a criticism of Lithuania, it is a description of a register with six entries in it, but if your model is discretionary management of client crypto then France has supervisory precedent and Lithuania does not. ## Where the two are simply different sizes Thirty-five against six. France took the full 18-month transitional period and Lithuania took 12, which gave French firms until 1 July 2026 and Lithuanian firms until the end of December 2025 to convert. Six extra months on a population that was already registered under PACTE is a large part of why the gap looks the way it does. ## Who Lithuania suits better - Applicants with no French history, for whom the simplified procedure is unavailable and France is simply a larger, busier queue. - Custody and exchange models, which is what the Lithuanian register consists of. - Anyone weighing operating costs against a Paris compliance base. ## Who France suits better - Holders of an enhanced DASP registration or PACTE licence. The simplified procedure is worth more than any fee difference on this page. - Advisory and discretionary-management models, where the French register shows the AMF has done this repeatedly and most authorities have not. - Firms whose clients are French retail investors and whose distribution depends on it. ## What this comparison cannot tell you Neither fee is stated here. The AMF page sets out the procedure rather than the price, and this site does not publish a regulatory fee it has not read. The difference that is visible is procedural: France offers a documented shortcut to one specific group of applicants, and to nobody else. ### What this page could not verify - **AMF: full text**, read 15 September 2026, but the page covers scope and procedure and states no fee. French fees are therefore absent rather than estimated. - **ESMA register: full text**, file last updated 31 August 2026. Every percentage above is counted from it and moves as it does. - Reading France as the advisory end of the market is an inference from permission counts, not a statement by the AMF. ## Primary sources - Read 2026-09-11 [Bank of Lithuania: transitional period ends 31 December 2025](https://www.lb.lt/en/news/lietuvos-bankas-investors-should-find-out-if-their-crypto-asset-service-provider-intends-to-be-licensed-and-continue-its-business) - Read 2026-09-11 [Bank of Lithuania: fourth CASP authorisation granted](https://www.lb.lt/en/news/an-authorisation-of-a-crypto-asset-service-provider-granted-to-micar-assets-uab) - Read 2026-09-15 · full text [ESMA: interim MiCA register of crypto-asset service providers (CASPS.csv, last updated 31 August 2026)](https://www.esma.europa.eu/sites/default/files/2024-12/CASPS.csv) - Read 2026-09-15 · full text [ESMA: list of grandfathering periods decided by Member States under Article 143(3)](https://www.esma.europa.eu/sites/default/files/2024-12/List_of_MiCA_grandfathering_periods_art._143_3.pdf) - Read 2026-09-15 · full text [AMF: in-depth guide to the MiCA Regulation](https://www.amf-france.org/en/news-publications/depth/mica) ## Questions ### What does an existing French DASP registration buy you under MiCA? A simplified procedure. The AMF states that holders of an enhanced DASP registration or a DASP licence may use a route designed to speed up examination: the applicant still files a complete authorisation file meeting MiCA requirements, but it reuses information already supplied under the enhanced registration or PACTE licence and identifies what has significantly changed since. ### How many CASPs are authorised in France? The ESMA register listed 35 entries with the Autorité des marchés financiers as competent authority when it was read on 15 September 2026, all under Article 63. That is the second largest population in the European Economic Area after Germany. ### Is France a good jurisdiction for crypto asset management? On the register it is where advisory and portfolio permissions concentrate. Thirty-four per cent of French CASPs may advise on crypto-assets and 37% may manage portfolios, against European averages of 13% and 16%. No Lithuanian CASP holds either permission. ### When did the French transitional period end? On 1 July 2026, the full 18 months MiCA allows. The French DDADUE law of 9 March 2023 provided that digital asset service providers registered, enhanced-registered or licensed in France on 30 December 2024 could continue to provide those services in France until July 2026. Readiness assessment ## If you hold a French registration The first question is whether your enhanced registration or licence still reflects the business you run, because the simplified procedure turns on what has changed since. We work through that before recommending where to file. [How an engagement starts](/services/mica-casp-licence/). [Request an assessment](/assessment/) [Check your licensing scope first](/requirements/service-classes/) Enquiries go by email for now. Nothing on this site collects your details, and [the assessment page](/assessment/) sets out what to include. Regulatory references on this page were read against the primary text on 15 September 2026. Every figure is held in the [source register](/sources/) with the document it came from.