Lithuania CASP Licence under MiCA
We prepare and implement a crypto-asset service provider authorisation application to the Bank of Lithuania under Regulation (EU) 2023/1114: from regulatory scoping and the prudential capital calculation through to the application file and the regulator's questions.
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Quick facts
| Regulator | Bank of Lithuania |
|---|---|
| Legal framework | Regulation (EU) 2023/1114 (MiCA), plus Lithuanian national law |
| Minimum capital | €50,000 / €125,000 / €150,000, by class of services (Annex IV) |
| Actual prudential requirement | The higher of the Annex IV minimum and one quarter of annual fixed overheads (Article 67) |
| Decision period | 40 working days after the application is considered complete (Article 63(9)) |
| Completeness check | 25 working days from receipt (Article 63(2)) |
| EU passporting | Available after authorisation, by notification (Article 65) |
| Local presence | Registered office in a Member State where part of the services are carried out; effective management in the Union; at least one Union-resident director (Article 59) |
| Former VASP regime | Closed. Lithuania’s transitional period ended 31 December 2025 |
| Guarantee | Authorisation cannot be guaranteed by anyone |
Who needs a CASP licence in Lithuania?
Any firm providing one or more of the crypto-asset services named in MiCA to clients in the Union needs an authorisation as a crypto-asset service provider. Lithuania's former registration regime for virtual currency exchange and depository wallet operators is closed.
Lithuania’s transitional period for obtaining a crypto-asset service provider licence ended on 31 December 2025.
Bank of Lithuania, Investors should find out if their crypto-asset service provider intends to be licensed (2025-07-21) · Verified on 2026-09-11 · Next review 2026-12-11
The regulated services are these. Each one, on its own, brings you inside the regime.
| Service | What it means in practice | Class |
|---|---|---|
| Execution of orders on behalf of clients | You act on a client instruction to buy or sell, rather than trading against them yourself. | 1 |
| Placing of crypto-assets | You market a new issue to buyers on behalf of the offeror. | 1 |
| Providing transfer services for crypto-assets on behalf of clients | You move crypto-assets from one address to another on a client instruction. | 1 |
| Reception and transmission of orders for crypto-assets on behalf of clients | You take a client order and pass it to someone else to execute. | 1 |
| Providing advice on crypto-assets | You make personal recommendations about crypto-assets. | 1 |
| Providing portfolio management on crypto-assets | You manage a client portfolio on a discretionary basis. | 1 |
| Providing custody and administration of crypto-assets on behalf of clients | You hold clients’ crypto-assets, or the means of access to them. | 2 |
| Exchange of crypto-assets for funds | You quote a price and trade crypto against fiat on your own account. | 2 |
| Exchange of crypto-assets for other crypto-assets | You quote a price and trade one crypto-asset against another on your own account. | 2 |
| Operation of a trading platform for crypto-assets | You match third-party buying and selling interests in a system you run. | 3 |
Lithuania CASP capital requirements
Under MiCA Article 67, a Lithuanian crypto-asset service provider must maintain prudential safeguards equal to the higher of the applicable Annex IV minimum capital requirement and one quarter of the previous year's fixed overheads.
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
| Class | Typical services | Annex IV minimum |
|---|---|---|
| Class 1 | Orders, placing, transfers, advice, portfolio management | €50,000 |
| Class 2 | Class 1 plus custody and exchange services | €125,000 |
| Class 3 | Class 2 plus operation of a trading platform | €150,000 |
Four points that follow from Article 67, and are routinely misstated elsewhere:
- The two figures are not added together. The requirement is the higher of them.
- €50,000 to €150,000 is a floor. For a firm with real staff it is frequently not the final requirement.
- A company that has not traded for a year uses the projected fixed overheads for its first 12 months, as submitted with the application.
- Article 67(4) allows the safeguard to be held as own funds, as an insurance policy or comparable guarantee meeting the conditions the Article sets, or a combination: the precise wording requires legal confirmation for your structure.
Annex IV groups providers by prudential class rather than offering three separate licences to choose between. You do not pick a class; your services determine it. Work the calculation through, or find your class first.
CASP authorisation process in Lithuania
| Stage | You | Us | Output |
|---|---|---|---|
| 1. Regulatory scoping | Describes the business model, flows of value, markets and counterparties. | Maps each activity to a named MiCA service, identifies the class, and flags where an EMI, payment or MiFID permission may also be engaged. | Regulatory perimeter memorandum and licence-class determination. |
| 2. Readiness and gap assessment | Opens up ownership, management, budget, AML and ICT arrangements. | Tests the current position against every Article 62(2) item and the Article 63(10) refusal grounds. | Go/no-go, gap list, indicative budget and a project road map. |
| 3. Corporate structure and governance | Confirms the shareholding chain and appoints the management body. | Builds the governance framework, control-function mandates and the qualifying-holder evidence trail through to natural persons. | Governance framework and fit-and-proper evidence pack. |
| 4. Capital and financial projections | Provides the cost base and funding plan. | Runs the Article 67 calculation both ways and models where the fixed-overheads limb overtakes the floor. | Prudential calculation and 12-month projection consistent with the application. |
| 5. AML/CFT, risk and ICT implementation | Makes people and systems available. | Writes the frameworks and works through implementation, including the non-technical ICT description Article 62(2)(j) requires separately. | Implemented AML/CFT, risk, ICT and resilience documentation. |
| 6. Preparation of the application | Reviews and approves. | Assembles the programme of operations and every service-specific policy the chosen services attract. | Complete application file. |
| 7. Completeness review and filing | Signs off. | Runs the file against the Article 62(2) list as the authority will, then files. | Submission, and the acknowledgement due within five working days. |
| 8. Regulatory questions | Supplies source material. | Drafts responses, tracking which requests suspend the assessment period and which do not. | Responses filed inside the suspension window. |
| 9. Authorisation and passporting | Confirms target markets. | Prepares the Article 65 notification and the post-authorisation compliance calendar. | Passporting notification and an annual prudential recalculation schedule. |
How long does CASP authorisation take in Lithuania?
MiCA Article 63 provides a 40-working-day assessment period, but it begins only after the Bank of Lithuania considers the application complete. Preparation, the completeness review, requests for additional information and the implementation work all sit outside that period and lengthen the project.
- 5 working days: written acknowledgement of receipt (Article 63(1))
- 25 working days: completeness check against Article 62(2) (Article 63(2))
- 40 working days: assessment of a complete application (Article 63(9))
- 5 working days: notification of the decision (Article 63(9))
These periods should not be added together and presented as a total time to licence. They describe the regulator's obligations at separate stages, and one request for further information can suspend the assessment for up to 20 working days on top. How the clock actually runs.
Under Article 63(12) the 40-working-day assessment period is suspended between the date of that request and receipt of the applicant’s response, for no more than 20 working days. Any further requests are at the authority’s discretion and do not suspend the period.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
Key requirements for a Lithuanian CASP
| Corporate establishment | Registered office in a Member State where at least part of the services are carried out. |
|---|---|
| Effective management | Place of effective management in the Union, as a question of fact rather than of minutes. |
| Directors and key function holders | Repute, individual and collective competence, and demonstrable time commitment. |
| Shareholders and source of funds | Direct and indirect qualifying holders traced through to natural persons. |
| Governance | Control functions with named owners, clear responsibilities and managed conflicts. |
| Prudential safeguards | The higher of the Annex IV floor and a quarter of fixed overheads, at all times. |
| AML/CFT | Procedures to identify, assess and manage money laundering and terrorist financing risk. |
| ICT and operational resilience | Technical documentation plus a description in non-technical language. |
| Safeguarding and segregation | The procedure for segregating clients’ crypto-assets and funds. |
| Complaints and conflicts | Complaints-handling procedures and conflict management. |
| Operational substance | Control functions performed by identifiable people with the time to perform them. |
A requirement we will not state
Some sources say Lithuania requires two EEA-resident directors, one ordinarily resident locally. MiCA Article 59 requires at least one Union-resident director, and no Lithuanian instrument imposing more has been located. This point requires confirmation under Lithuanian national law before anyone builds a structure around it.
What we do, and what we do not
We do not sell "a licence in 40 days". We reduce the risk of refusal and delay by producing a complete and operationally truthful application capable of surviving regulatory scrutiny.
Deliverables
- Regulatory perimeter memorandum
- Licence-class determination
- Capital and fixed-overheads calculation
- Readiness report with gap list
- Application project plan
- Programme of operations
- Governance framework
- AML/CFT framework
- Risk-management policies
- ICT and security documentation, with the non-technical description
- Complaints and conflicts-of-interest procedures
- Service-specific policies for the services you apply for
- Application completeness review
- Regulatory Q&A support
- Passporting assistance
Not included by default
- State and supervisory fees
- Recruitment of directors and staff
- Statutory audit
- Insurance
- Development of IT systems
- Translation and notarial services
The limits of this service
We prepare and support the authorisation process, but we cannot guarantee approval and we do not control the length of the regulator's review. Legal conclusions, national requirements and fees are confirmed for each engagement against the rules applicable at that time.
How it is priced
Not as a single "licence price", because the work is not a single thing. A fixed fee for the readiness assessment; a separate fixed fee for the application build; a monthly retainer for implementation and regulatory support; and a separate package for post-authorisation compliance. What moves the numbers is the class of services, the ownership structure, the team, the ICT estate and how ready your AML controls already are.
Questions
What is a CASP licence in Lithuania?
A CASP licence in Lithuania is an authorisation as a crypto-asset service provider granted by the Bank of Lithuania under Regulation (EU) 2023/1114 (MiCA). It permits a firm to provide the specific crypto-asset services named in the authorisation, and it replaced the former Lithuanian registration regime for virtual currency exchange and depository wallet operators.
Who regulates crypto-asset service providers in Lithuania?
The Bank of Lithuania is the competent authority for authorising and supervising crypto-asset service providers in Lithuania under MiCA. It receives the application, runs the completeness check and the substantive assessment, and grants or refuses the authorisation.
How much capital does a Lithuanian CASP need?
Under MiCA Article 67, a Lithuanian CASP must hold prudential safeguards equal to the higher of the Annex IV minimum for its class and one quarter of its previous year’s fixed overheads. The Annex IV minimums are EUR 50,000 for class 1, EUR 125,000 for class 2 and EUR 150,000 for class 3. The two figures are not added together.
Is EUR 50,000 enough for a CASP licence?
EUR 50,000 is the Annex IV minimum for class 1 services only, and it is a floor rather than the requirement. If one quarter of the firm’s annual fixed overheads exceeds it, that larger figure governs. A class 1 firm with EUR 400,000 of annual fixed costs must hold EUR 100,000, not EUR 50,000.
How long does CASP authorisation take in Lithuania?
MiCA Article 63 gives the competent authority 40 working days to decide, but that period begins only once the application is considered complete. Before it runs a separate 25-working-day completeness check, and one request for further information can suspend the assessment for up to 20 working days. Preparation before filing is not governed by any of these periods.
Does a Lithuanian CASP licence cover the whole European Union?
Yes, through notification rather than a second authorisation. Under MiCA Article 65, the provider notifies the Bank of Lithuania of the Member States and services concerned, the Bank communicates this to host authorities, ESMA and EBA within 10 working days, and the provider may begin on receipt of that communication or at the latest on the 15th calendar day after submitting the information.
Does a CASP need employees in Lithuania?
MiCA Article 59 does not set a headcount. It requires a registered office in a Member State where at least part of the services are carried out, the place of effective management in the Union, and at least one director resident in the Union. Staffing is assessed indirectly: an applicant whose described control functions have no identifiable people performing them struggles against the governance and internal-control requirements.
Must a director be resident in Lithuania?
MiCA Article 59 requires at least one director resident in the Union, not in Lithuania specifically. Some secondary sources state that Lithuania requires two EEA-resident directors with one ordinarily resident locally. No Lithuanian legal instrument imposing that has been located, so this point requires confirmation under Lithuanian national law before anyone relies on it.
What documents are required for a CASP application?
MiCA Article 62(2) lists them: corporate identification and legal form, articles of association, a programme of operations, proof of prudential safeguards, governance arrangements, evidence on the repute and competence of the management body, qualifying holders and their source of funds, internal control and risk procedures including AML and business continuity, ICT documentation with a non-technical description, asset segregation procedures, and complaints handling. Service-specific policies attach on top.
Can an existing Lithuanian VASP continue operating?
No. The Bank of Lithuania confirmed that Lithuania’s transitional period for obtaining a crypto-asset service provider licence ended on 31 December 2025. Operators registered under the previous Lithuanian regime for virtual currency exchange and depository wallet services lost the right to continue on that basis and now require an authorisation under MiCA, held in Lithuania or another Member State.
Can authorisation be guaranteed?
No. Authorisation is a decision of the Bank of Lithuania, and MiCA Article 63(10) obliges it to refuse where specified grounds are made out. Nobody advising on an application can guarantee the outcome or control the length of the regulator’s review. What preparation changes is the probability of refusal and the number of information requests, not the decision itself.
What happens if the application is incomplete?
Under MiCA Article 63(2) the competent authority sets a deadline for the missing information. If the application is still incomplete after that deadline, Article 63(3) permits the authority to refuse to review it at all. That is not a refusal on the merits. It ends the file without a decision, and the 40-working-day assessment period never starts.
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.