Lithuania vs Latvia: CASP authorisation compared

Lithuania and Latvia apply the same core MiCA authorisation framework, including the service categories, the capital classes and the governance tests. The practical choice turns on national fees, the supervisory approach, the support available before filing, operating costs and where the applicant already has people.

What is identical, because MiCA harmonises it

There is no such thing as a "Latvian MiCA licence" that differs in substance from a Lithuanian one. These are the same in both, and any comparison that presents them as differentiators is padding:

• 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

Latvia publishes its price. Lithuania, on the pages read, does not.

Latvijas Banka states a fee of EUR 2,500 for reviewing the documents and information submitted, and says plainly that no additional costs arise during the assessment stage or on grant. After authorisation it charges up to 0.6% of annual gross income from crypto-asset services, with a minimum of EUR 3,000 per year.

Nothing equivalent was found on the Bank of Lithuania's CASP pages. Consultancy sites circulate Lithuanian figures that sit suspiciously close to Latvia's published ones: a state fee of around EUR 2,425 and a supervisory fee of 0.7% with a EUR 3,000 floor. Those may be right. They may also be Latvia's numbers with the country name changed. Until a Lithuanian instrument is produced, this site treats them as unverified, and you should ask anyone quoting them which provision they come from.

Latvia will meet you before the company exists

This is the most concrete procedural difference between the two, and it is unusual. Latvijas Banka's published process begins with a familiarisation stage: a meeting to discuss the planned activities, at which, in its own words, "the company does not necessarily have to be legally established". It advises on the applicable regulation and the documents to be submitted, conducts an initial compliance assessment, and tells the applicant whether it is possible to continue at all. The consultation response time is up to 30 days. The advice is free.

For an applicant who is not certain their model even fits the perimeter, that is a real option: a regulator-level read on viability before incorporation costs, capital and a compliance build.

Latvia assigns a project manager. And expects you in the room.

Once the file is complete, Latvijas Banka "designates the manager of the project on issuing authorisation and coordinates the process". The applicant appoints a contact person, and Latvijas Banka holds meetings during the assessment. Its own guidance adds a pointed line: representatives of the applicant, rather than only consultants, are invited to those meetings.

Read that as a statement of supervisory posture. A file assembled entirely by advisers, with management unable to explain it, is a recognised pattern and Latvia has written the expectation into its published process.

Qualifying holdings run through a named Latvian regulation

Latvia assesses qualifying holders under Latvijas Banka Regulation No. 241 on the acquisition or increase of a qualifying holding in a financial institution, and requires statements from the Punishment Register for both management and shareholders. The MiCA test is the same; the documentary route through national law is not.

Who Lithuania suits better

• Applicants who already have Lithuanian substance (a team, an entity, banking relationships), because moving that to Latvia buys nothing that MiCA does not already give.
• Firms whose comparators matter commercially: Lithuania has authorised recognisable names, and for some businesses being supervised alongside them has value with counterparties.
• Groups already supervised in Lithuania for payments or e-money, where Article 63(5) consultation runs inside one authority rather than across two.

Who Latvia suits better

• Applicants who are not yet sure the model is authorisable, and who would rather spend 30 days getting a regulator's initial read than six months building towards a refusal.
• Anyone who needs a defensible budget before committing. Latvia's published fees let you model the regulatory line items rather than estimate them.
• Teams that want a named project manager and scheduled meetings during assessment, rather than correspondence.

The full cost of entry, not the capital figure

The Annex IV capital is identical in both countries and is the item people quote. It is rarely the item that decides a budget. The real line items are the prudential requirement under Article 67: which for a firm with real staff is often a quarter of fixed overheads rather than the floor, plus the people who must exist for the governance evidence to be true, the ICT documentation and its non-technical description, audit, and the regulatory fees. Of those, only the last differs materially between Lithuania and Latvia, and only Latvia publishes it.

Risks and uncertainties in this comparison

• Lithuania's fee position is unresolved. Absence from the pages read is not proof that no fee exists.
• Latvia's transitional-period end date is not stated on the page read, so this comparison does not assert one.
• Authorisation counts move. Both should be read from the live registers, not from this page.
• Supervisory posture is observed from published process documents. It is a reasonable inference, not a guarantee of how any individual file will be handled.

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 Latvijas Banka: Crypto-asset service providers (updated 13 July 2026)

Questions

Is a Latvian CASP licence different from a Lithuanian one?

No. Both are authorisations as a crypto-asset service provider under Regulation (EU) 2023/1114, and both passport across the European Union on the same terms. The capital classes, application contents, governance requirements and refusal grounds are identical because MiCA harmonises them. What differs is national: fees, the support available before filing, and supervisory practice.

What does Latvia charge for a CASP authorisation?

Latvijas Banka states a fee of EUR 2,500 for reviewing the documents and information submitted to obtain authorisation, with no additional costs at the assessment or grant stages. Once authorised, a provider pays up to 0.6% of annual gross income from crypto-asset services, subject to a minimum of EUR 3,000 per year.

Does Latvijas Banka help before you apply?

Yes. Latvijas Banka runs a familiarisation stage with a meeting to discuss planned activities, and states that the company does not necessarily have to be legally established at that point. It provides advice on the applicable regulation and documents free of charge, with a consultation response time of up to 30 days depending on complexity.

Which is faster, Lithuania or Latvia?

Neither, as a matter of law. Both apply the MiCA timetable: 25 working days for the completeness check and 40 working days to decide on a complete application. Latvijas Banka adds that the review deadline may be extended for objective reasons where the information provided is insufficient. Real project duration is set by preparation, which precedes both clocks.