---
title: "Source register · LT MiCA Desk"
description: "Every primary source this site relies on, every claim drawn from it, and the date each claim was last read against the original."
url: https://unbui.lt/sources/
lang: en-GB
---

# Source register

Regulatory writing goes stale silently. This page exists so a reader can see exactly which document a statement came from and how old the reading is.

## Claims in use

| Claim | Read on | Next review |
| --- | --- | --- |
| Lithuania’s transitional period for obtaining a crypto-asset service provider licence ended on 31 December 2025. | 2026-09-11 | 2026-12-11 |
| Four firms hold a Lithuanian authorisation under Article 63 of MiCA: Robinhood Europe UAB, UAB “Decentralized” (CoinGate), Nuvei Liquidity UAB and UAB Micar assets. The most recent was granted on 26 February 2026, and on the ESMA register as last updated 20 October 2026 no fifth had followed it. | 2026-10-23 | 2026-11-23 |
| Lithuania shows six entries on the ESMA crypto-asset service provider register, not four. Two of them, Newrails UAB and UAB BLUE EMI LT, are recorded there as providing crypto-asset services under Article 60(4) of MiCA in relation to an e-money token they issue themselves. That is a notification by an institution already authorised for something else, not an authorisation under Article 63, and it cannot be applied for by a firm that has no other licence. | 2026-10-23 | 2026-11-23 |
| The ESMA crypto-asset service provider register does not consistently record whether an entry is an authorisation under Article 63 or a notification under Article 60. Of the 387 rows in the file read on 23 October 2026, covering 384 entities, 207 state a legal basis and 180 leave the field empty. The omission runs by national authority rather than by firm: eight authorities complete the field for every entry they report and nineteen leave it empty for all of theirs. | 2026-10-23 | 2026-11-23 |
| Among the 207 register rows that do state a legal basis, notifications under Article 60 outnumber authorisations under Article 63 by 131 to 76. Germany accounts for most of that gap by itself, reporting 109 Article 60 notifications against eight Article 63 authorisations. The ratio holds only for the rows that state a basis and cannot be read across the 180 that do not. | 2026-10-23 | 2026-11-23 |
| Operation of a trading platform is the rarest permission under MiCA. Of the 387 rows on the ESMA crypto-asset service provider register counted on 23 October 2026, 22 name it, spread across 12 home Member States with no more than three in any one of them. Lithuania has none. Nineteen of the 22 also hold custody and administration. | 2026-10-23 | 2026-11-23 |
| Counting execution of orders overstates the number of firms that provide it as a business. Of the 387 register rows counted on 23 October 2026, 111 name exactly one service, 88 of those 111 are recorded as Article 60 notifications, and 70 of them name execution of orders alone. Germany reports 87 of the 219 rows naming execution. | 2026-10-23 | 2026-11-23 |
| Article 60 lets six kinds of already-authorised firm provide crypto-asset services by notification rather than by authorisation: credit institutions, central securities depositories, investment firms, electronic money institutions, UCITS management companies and alternative investment fund managers, and market operators. A payment institution is not among them, although Article 3(1)(46) of the same regulation defines the term. | 2026-10-24 | 2027-04-24 |
| Each entity relying on Article 60 must notify the competent authority of its home Member State at least 40 working days before providing the crypto-asset services for the first time. Under Article 60(8) the authority then has 20 working days to assess whether the notification is complete, a request for missing information sets a deadline of no more than 20 working days and suspends the period, further requests do not suspend it, and the entity may not begin while the notification is incomplete. | 2026-10-24 | 2027-04-24 |
| Article 60(4) permits an electronic money institution to provide only custody and administration of crypto-assets on behalf of clients and transfer services for crypto-assets on behalf of clients, and only with regard to the e-money tokens it issues itself. | 2026-10-24 | 2027-04-24 |
| Article 60(3) permits an investment firm to provide crypto-asset services equivalent to the investment services and activities for which it is specifically authorised under Directive 2014/65/EU, and then sets out the equivalences one by one: custody mirrors the ancillary service in Section B(1) of Annex I, operating a crypto trading platform mirrors operating a multilateral or organised trading facility, exchange of crypto-assets mirrors dealing on own account, and execution, placing, reception and transmission, advice and portfolio management each mirror their MiFID counterpart. | 2026-10-24 | 2027-04-24 |
| Article 60(10) provides that where those entities provide crypto-asset services they are not subject to Articles 62, 63, 64, 67, 83 and 84 of MiCA. That removes the application for authorisation, the assessment procedure, the withdrawal regime, the prudential requirements and both articles governing the assessment of proposed acquisitions. The firm remains subject to the capital and supervisory requirements of the licence it already holds. | 2026-10-24 | 2027-04-24 |
| Under Article 60(11) the right to provide crypto-asset services by notification is revoked when the underlying authorisation that allowed it is withdrawn. The permission has no independent existence. | 2026-10-24 | 2027-04-24 |
| The two routes are used by visibly different businesses. On the ESMA register as counted on 23 October 2026, the 134 rows recorded under Article 60 name a median of one service, and 94 of them name execution of orders, while the 76 rows recorded under Article 63 name a median of four services built around custody, transfer services and exchange. Custody appears in 76 per cent of Article 63 rows against 22 per cent of Article 60 rows. | 2026-10-23 | 2026-11-23 |
| On ESMA data cited by the Bank of Lithuania on 3 March 2026, Finland had issued five CASP authorisations, Lithuania four, Latvia two and Sweden one. | 2026-09-11 | 2026-10-11 |
| Annex IV sets permanent minimum capital of EUR 50 000 for class 1, EUR 125 000 for class 2 and EUR 150 000 for class 3, by reference to the crypto-asset services the provider is authorised for. | 2026-09-14 | 2027-03-14 |
| 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. | 2026-09-14 | 2027-03-14 |
| Under Article 67(2), a provider that has not been in business for a year uses the projected fixed overheads for its first 12 months, as submitted with its application, for that calculation. | 2026-09-14 | 2027-03-14 |
| Article 67(3) removes from the fixed-overheads figure: profit-dependent staff bonuses and remuneration, employees’, directors’ and partners’ shares in profits, other fully discretionary appropriations of profit and variable remuneration, and non-recurring expenses from non-ordinary activities. | 2026-09-14 | 2027-03-14 |
| Article 63(1) requires the competent authority to acknowledge receipt of an application in writing within five working days. | 2026-09-14 | 2027-03-14 |
| Article 63(2) gives the competent authority 25 working days from receipt to check whether the application is complete against the Article 62(2) list, and to set a deadline for any missing information. | 2026-09-14 | 2027-03-14 |
| Article 63(3) allows the competent authority to refuse to review an application that remains incomplete after the deadline it set. | 2026-09-14 | 2027-03-14 |
| Article 63(9) gives the competent authority 40 working days from receipt of a complete application to adopt a fully reasoned decision granting or refusing authorisation, and five working days from that decision to notify the applicant. | 2026-09-14 | 2027-03-14 |
| Article 63(9) requires the assessment to take into account the nature, scale and complexity of the crypto-asset services the applicant intends to provide. | 2026-09-14 | 2027-03-14 |
| Under Article 63(6) the competent authority may consult AML/CFT authorities and financial intelligence units to verify that the applicant has not been the subject of an investigation into money laundering or terrorist financing. | 2026-09-14 | 2027-03-14 |
| Article 63(8) requires the competent authority to refuse authorisation where third-country law governing persons with close links to the applicant, or difficulties enforcing it, prevent effective supervision. | 2026-09-14 | 2027-03-14 |
| Article 63(12) allows the competent authority to request further information during the assessment period, but no later than the 20th working day of that period, in writing and specifying what is needed. | 2026-09-14 | 2027-03-14 |
| 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. | 2026-09-14 | 2027-03-14 |
| Article 63(10) requires refusal where there are objective and demonstrable grounds that the management body threatens sound management, business continuity, clients’ interests or market integrity or exposes the applicant to serious money laundering or terrorist financing risk; that management body members fail the Article 68(1) criteria; that qualifying holders fail the Article 68(2) repute criteria; or that the applicant fails, or is likely to fail, any requirement of the Title. | 2026-09-14 | 2027-03-14 |
| Article 63(13) requires competent authorities to communicate the Article 109(5) information to ESMA within two working days of granting authorisation, and to inform ESMA of refusals. | 2026-09-14 | 2027-03-14 |
| Article 59 requires a registered office in a Member State where at least part of the crypto-asset services are carried out, the place of effective management in the Union, and at least one director resident in the Union. | 2026-09-14 | 2027-03-14 |
| Article 59(5) prohibits a person that is not an authorised crypto-asset service provider from using a name or issuing marketing communications suggesting that it is one, or likely to create confusion in that respect. | 2026-09-14 | 2027-03-14 |
| Article 59(7) provides that a crypto-asset service provider serving clients cross-border is not required to have a physical presence in the host Member State. | 2026-09-14 | 2027-03-14 |
| Under Article 65 the home authority communicates a cross-border notification to host single points of contact, ESMA and EBA within 10 working days, and the provider may begin from receipt of that communication or at the latest from the 15th calendar day after submitting the information. | 2026-09-14 | 2027-03-14 |
| Article 68(1) requires members of the management body to be of sufficiently good repute and to possess appropriate knowledge, skills and experience both individually and collectively, and to demonstrate that they can commit sufficient time to their duties. | 2026-09-14 | 2027-03-14 |
| Article 68(2) requires direct and indirect holders of qualifying holdings to be of sufficiently good repute, and in particular not to have been convicted of money laundering or terrorist financing offences or other offences affecting their repute. | 2026-09-14 | 2027-03-14 |
| Article 68(3) allows competent authorities to act where a qualifying holder’s influence is likely to be prejudicial to sound and prudent management, including suspending the voting rights attaching to those holdings. | 2026-09-14 | 2027-03-14 |
| Article 62(2)(j) requires the technical documentation of ICT systems and security arrangements to be accompanied by a description in non-technical language. | 2026-09-14 | 2027-03-14 |
| Article 62(2)(d) requires a programme of operations setting out the types of crypto-asset services the applicant intends to provide, including where and how those services are to be marketed. | 2026-09-14 | 2027-03-14 |

## Claims held back

These have not been checked against the primary text. They are listed rather than hidden, because the honest position is that they are widely repeated and not yet confirmed here. No page may publish them. The production build fails if one is referenced.

| Claim | Why it is held back |
| --- | --- |
| The Lithuanian state fee for issuing a CASP licence is EUR 2 425, and the Bank of Lithuania charges an annual supervisory fee of 0.7% of revenue subject to a EUR 3 000 minimum. | Sourced only to consultancy blogs. No Lithuanian fee resolution or Bank of Lithuania fee schedule located. Not publishable. |
| Lithuania requires at least two EEA-resident directors, one of them ordinarily resident in Lithuania. | Conflicts with Article 59, which requires effective management in the Union and at least one Union-resident director. If Lithuania imposes more, it must be cited to national law. Probably wrong as stated. |

## Primary documents

-   EUR-Lex [Regulation (EU) 2023/1114 (MiCA), consolidated text](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1114)
-   Bank of Lithuania · 2025-07-21 [Investors should find out if their crypto-asset service provider intends to be licensed](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)
-   Bank of Lithuania · 2026-03-03 [An authorisation of a crypto asset service provider granted to Micar assets, UAB](https://www.lb.lt/en/news/an-authorisation-of-a-crypto-asset-service-provider-granted-to-micar-assets-uab)
-   Bank of Lithuania [Supervised financial market participants](https://www.lb.lt/en/sfi-financial-market-participants)
-   Bank of Lithuania [Authorisation of crypto-asset service providers](https://www.lb.lt/en/authorisation-of-crypto-asset-service-providers)
-   ESMA [Markets in Crypto-Assets Regulation (MiCA)](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica)
-   ESMA · 2026-10-20 [Interim MiCA register, crypto-asset service providers (CASPS.csv)](https://www.esma.europa.eu/sites/default/files/2024-12/CASPS.csv)
-   ESMA [List of MiCA 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)

## What counts as a source here

In order: the text of the regulation, then the national law, then the competent authority's own published material, then the European supervisory authorities' standards and guidelines. Commentary by law firms and consultancies is not a source for a date or a figure, however confidently it is written. That rule exists because a specific piece of commentary was nearly cited on this site as current guidance when it was in fact published in December 2023, before the regulation applied.

Readiness assessment

## Work out whether you are ready to file

We map your business model onto the named MiCA services, work out the class and the capital that follows, and test the gaps against the grounds an authority refuses on. The output is a go or no-go, a gap list, a budget and a route.

[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.