--- title: "Lithuania vs Malta: CASP authorisation compared · LT MiCA Desk" description: "Malta holds 21 Article 63 authorisations to Lithuania's four, because it regulated crypto from 2018 under its own Virtual Financial Assets regime. What that means for an applicant choosing a home state." url: https://unbui.lt/services/mica-casp-licence/lithuania-vs-malta/ lang: en-GB updated: 2026-09-15 --- [Home](/) / [Services](/services/mica-casp-licence/) / Lithuania vs Malta Jurisdiction comparison # Lithuania vs Malta: CASP authorisation compared The short answer is a ratio. Malta holds 21 Article 63 authorisations to Lithuania's four, because Malta had been regulating crypto for six years before MiCA arrived. This is the comparison where the two jurisdictions are genuinely different, rather than differing in fees and paperwork. Malta ran its Virtual Financial Assets framework from 2018. It came into MiCA with a supervised population of firms and an authority that had already assessed them once. Lithuania supervised its sector through an anti-money-laundering registration rather than a financial licence, so both sides of the table started further back. Read off each regulator's own pages: Bank of Lithuania on 2026-09-11, Malta Financial Services Authority (MFSA) 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 | Malta | | --- | --- | --- | | Regulator | Bank of Lithuania | Malta Financial Services Authority (MFSA) | | Legal framework | MiCA, with Lithuanian implementing law | MiCA. Malta ran its own Virtual Financial Assets regime from 2018, before MiCA existed. | | Old regime transitional period | Ended 31 December 2025 | 18 months, the longest MiCA allows, running from 30 December 2024. Reported to ESMA by the national authority. | | Application fee | Not located on the regulator’s pages. Consultancy sites circulate a figure; no Lithuanian instrument found to support it. | Not read. The MFSA site refused access, so no Maltese fee is stated here. | | Supervisory fee | Not located on the regulator’s pages. | Not read, for the same reason. | | Language of application | Not stated on the pages read. | Not read, for the same reason. | | How it is submitted | Not stated on the pages read. | Not read, for the same reason. | | Pre-application support | No published pre-application stage found on the pages read. | Not read, for the same reason. | | 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 | 22 entries in the ESMA register, of which 21 are Article 63 authorisations and one provides services under Article 60(4). Fifth 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). ## What actually differs ### The size of the authorised population Read from the ESMA register on 15 September 2026, Malta had 22 entries against Lithuania's six. Strip out the entities operating under Article 60(4), which are e-money institutions adding crypto services by notification rather than firms authorised under Article 63, and it is 21 against four. The names are recognisable in a way Lithuania's are not yet, and they are mostly international venues choosing Malta as an EU base: - OKX Europe Limited - Foris DAX MT Limited (Crypto.com) - Gemini Intergalactic EU Ltd - Blockchain.com Operations (Malta) Limited - Gate Technology Limited - FalconX Limited - Bequant Pro Limited - Calamatta Cuschieri Investment Services Limited Three of the Maltese authorisations carry permission to operate a trading platform, the class 3 service. In Lithuania that number is zero. If your model is a venue matching third-party orders, that difference in supervisory experience is the most concrete thing on this page. ### Malta took the longest transitional period, Lithuania a middling one On the list Member States reported to ESMA, Malta took the full 18 months and Lithuania took 12. From 30 December 2024 that puts Malta at 30 June 2026 and Lithuania at the end of December 2025. Latvia took six months, Poland reported six and never legislated it at all. ### A caveat ESMA prints on its own list The periods were communicated by national authorities and reflected their expectations. ESMA records that some of them had not been incorporated into national law when the list was published. Poland is the proof of what that caveat means in practice: it reported six months, the implementing act never entered into force, and the full period to 1 July 2026 applied instead. Treat the list as a reliable record of what regulators said, not as a statement of national law. [The Polish case](/services/mica-casp-licence/lithuania-vs-poland/). ### Counting authorisations is less simple than it looks The Bank of Lithuania has announced four CASP authorisations. The ESMA register shows six Lithuanian entries. Both are correct, and the difference is the point: two of the six are entities providing crypto-asset services under Article 60(4) in relation to their own e-money tokens, which is a notification route open to regulated financial institutions rather than an authorisation under Article 63. Anyone quoting a headline count for a jurisdiction should be able to say which of the two they mean. Most cannot. ## Who Lithuania suits better - Applicants who already have Lithuanian substance, or who are part of a group supervised there for payments or e-money, where the Article 63(5) consultation stays inside one authority. - Firms that would rather not be the smallest client of an authority handling a large and prominent caseload. - Anyone weighing operating costs, where the Baltic salary base is materially below Malta's for compliance and technology staff. ## Who Malta suits better - Trading platforms. Three Maltese CASPs hold the class 3 permission and Lithuania has none, so the supervisory precedent exists in one place and not the other. - International venues wanting recognisable peers under the same regulator, which matters to counterparties and banking partners more than it should. - Firms that held a Virtual Financial Assets licence, whose existing documentation and supervisory history are already in the right hands. ## The full cost of entry, not the capital figure Capital is identical under Annex IV. The Maltese fee position is not stated on this page, because the MFSA site refused our requests and we do not publish a regulatory fee we have not read. What can be said is that the cost difference between these two is unlikely to be the fee line at all. It is staff: Malta's compliance and technology salaries sit well above the Baltic base, and under Article 67 a higher fixed cost base can raise the capital you must hold, since the requirement is the higher of the Annex IV floor and a quarter of fixed overheads. [How that calculation runs](/requirements/capital/). ### Limits of this check - **MFSA pages: unavailable.** The site returned a firewall block, so no Maltese fee, application language, submission channel or pre-application process is stated here. Those rows are marked not read rather than filled from secondary sources. - **ESMA register: full text**, read 15 September 2026, file last updated 31 August 2026. Counts move; read it again before relying on them. - **Grandfathering list: full text**, carrying ESMA's own caveat that some periods may not have been written into national law. - Salary and operating-cost comparisons are our assessment, not a sourced figure, and are flagged as such rather than given a number. ## 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 · unavailable [MFSA: authorisation pages](https://www.mfsa.mt/) ## Questions ### How many CASPs are authorised in Malta? The ESMA register listed 22 entries with the Malta Financial Services Authority as competent authority when it was read on 15 September 2026. Twenty-one are authorisations under Article 63 of MiCA and one provides crypto-asset services under Article 60(4). That makes Malta the fifth largest home state in the EEA, behind Germany, France, the Netherlands and Cyprus. ### Why does Malta have so many more CASPs than Lithuania? Malta regulated crypto before MiCA existed. Its Virtual Financial Assets framework ran from 2018, so when MiCA applied there was an existing population of supervised firms and an authority with years of practice assessing them. Lithuania supervised its sector through an AML registration rather than a financial licence, so both the firms and the regulator started the MiCA assessment from further back. ### Does Malta have a longer transitional period than Lithuania? Yes. On the list Member States reported to ESMA, Malta took 18 months, the longest MiCA permits, while Lithuania took 12. Running from 30 December 2024, that is 30 June 2026 for Malta and the end of December 2025 for Lithuania. ESMA notes that some reported periods had not been written into national law when the list was published. ### Can a Maltese CASP serve clients in Lithuania? Yes, and the reverse is equally true. An authorisation from either state passports across the Union under Article 65 by notification, with no requirement for a physical presence in the host state. The choice of home state is about where you are supervised and what that supervision costs, not about which markets you can reach. Readiness assessment ## Choosing a home state We compare your target markets, services, management structure, substance plan and regulatory dependencies before recommending where to apply. [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.