MiCA Regulation (EU) 2023/1114 — In force since December 2024
VASP→CASP Transition Deadline: 1 July 2026
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Lithuania Crypto License — CASP Authorization Guide 2026

Vilnius skyline — Lithuania CASP crypto license under MiCA and Bank of Lithuania supervision

Lithuania is one of the EU's foremost fintech hubs, home to 200+ licensed payment institutions including Revolut's EU banking headquarters, and a deep pool of regulatory expertise in Vilnius. The Bank of Lithuania (Lietuvos bankas) serves as the National Competent Authority under MiCA Regulation (EU) 2023/1114, accepting CASP authorization applications since December 2024. A Lithuania CASP license grants full EU passporting rights to all 27 member states. Capital requirements start from €50,000, the NCA review period is up to 65 working days, and Lithuania's shorter VASP transition window — which ended 30 December 2025 — means any crypto business operating here without a valid CASP authorization is now in breach of MiCA. Whether you are forming a new crypto company or converting an existing VASP, a crypto license in Lithuania through the Bank of Lithuania is among the EU's most strategic and efficient authorization routes in 2026.

Lithuania CASP License Requirements

To obtain a Lithuania CASP authorization, companies must satisfy the Bank of Lithuania's requirements under MiCA Regulation (EU) 2023/1114 and Lithuania's national implementing legislation — primarily the Law on Financial Institutions (Finansų įstaigų įstatymas) and the AML Law. The following are the core requirements:

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Lithuanian Legal Entity (UAB)
UAB (Uždaroji akcinė bendrovė — private limited company) or AB (public company) registered in Lithuania, with a registered office and genuine business substance in Vilnius or another Lithuanian city.
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Own Funds / Capital
Minimum €50,000–€150,000 depending on service type (MiCA Art. 67). Capital must be verifiable and maintained on an ongoing basis. UAB minimum share capital of €2,500 is separate from MiCA own funds.
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Fit & Proper Management
Board members and key function holders must pass the Bank of Lithuania's fit & proper assessment: professional qualifications, no criminal record, financial integrity, and sufficient time commitment to the role.
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AML/KYC Program
Full AML policy compliant with EU AMLA framework and Lithuania's AML Law. Includes KYC procedures, transaction monitoring, PEP screening, MLRO appointment, and reporting procedures to the FCIS.
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DORA Compliance
ICT risk management framework, digital operational resilience testing, and third-party ICT provider management policies — mandatory for all MiCA CASPs since January 2025.
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Business Plan & Documentation
Detailed business plan with financial projections, organizational chart, IT architecture description, outsourcing agreements, and — if issuing crypto-assets — a MiCA-compliant crypto-asset whitepaper (Art. 6).
Bank of Lithuania Substance Requirement — Key Point

The Bank of Lithuania requires genuine substance in Lithuania — not a letterbox company. This means a real office address (virtual offices are scrutinized), at least one senior manager who is a Lithuanian resident or demonstrates regular physical presence in Lithuania, and that key management decisions are made from Lithuanian territory. Lithuania's fintech ecosystem makes it straightforward to establish authentic local presence — Vilnius has a deep pool of qualified compliance and legal professionals.

Capital Requirements for Lithuania CASP

MiCA Article 67 establishes three minimum own funds tiers based on the CASP service types authorized. These are identical across all EU member states including Lithuania — MiCA harmonizes capital requirements at the EU level:

CASP Service Type Min. Own Funds MiCA Reference
Advice on crypto-assets; Reception & transmission of orders; Execution of orders on behalf of clients; Placing of crypto-assets €50,000 Art. 67(1)(a)
Exchange against fiat currency; Exchange against other crypto-assets; Portfolio management; Transfer services €125,000 Art. 67(1)(b)
Custody & administration; Operation of a trading platform for crypto-assets €150,000 Art. 67(1)(c)

Under MiCA Art. 67(2), own funds must at all times be at least one-quarter of the fixed overheads of the preceding year — so capital requirements scale with business size. The Bank of Lithuania may require higher own funds than the MiCA minimums if it assesses that the risk profile of a particular CASP warrants it. Capital must consist of instruments that are fully paid up and freely available, with no third-party claims or conditional encumbrances.

Lithuania's UAB structure offers flexibility in capital deployment: the UAB minimum share capital of €2,500 is paid upon formation, while the MiCA own funds requirement must be satisfied and evidenced to the Bank of Lithuania at the authorization stage and maintained throughout the license period.

How to Get a Lithuania Crypto License

1
Gap Analysis & Jurisdiction Assessment
We assess your business model, target crypto-asset services, and corporate structure against the Bank of Lithuania's MiCA requirements. We identify documentation gaps, capital needs, and confirm Lithuania as the optimal NCA for your CASP application given your operational footprint and EU passporting strategy. Timeline: 1 week.
2
Lithuanian UAB Formation
We establish a UAB (Uždaroji akcinė bendrovė) with genuine substance in Vilnius: registered office at our Konstitucijos pr. 21A address, local directorship arrangement or relocation support, and a corporate bank account with a Lithuanian or EU-passporting bank. UAB formation through the Registrų centras takes as little as 1–3 business days. Timeline: 1–2 weeks.
3
Compliance Documentation Package
We prepare the complete Bank of Lithuania CASP submission: business plan with financial projections, AML/KYC policy aligned with Lithuania's AML Law and FCIS guidance, DORA ICT risk framework, internal governance documents, fit & proper materials for board members, and any required crypto-asset whitepaper under MiCA Art. 6. Timeline: 4–6 weeks.
4
Bank of Lithuania Application Submission
We submit the complete CASP authorization application to the Bank of Lithuania. The NCA first confirms completeness (within 25 working days under MiCA Art. 63), then undertakes substantive review within 65 working days of receiving a complete application. We manage all correspondence, respond to information requests (RFIs), and liaise directly with the Bank of Lithuania's fintech authorization team. Timeline: up to 65 working days.
5
Authorization & EU Passporting Activation
Upon Bank of Lithuania CASP authorization, your company is entered into ESMA's public register of authorized CASPs. We immediately initiate EU passporting notifications for all target member states, enabling you to provide crypto-asset services across the full EU from your Lithuanian entity. Timeline: 1–2 weeks post-authorization.

EU Passporting from Lithuania

A Lithuania CASP license is an EU passport — a single Bank of Lithuania authorization grants your company the right to provide crypto-asset services in all 27 EU member states under MiCA's passporting regime (Article 65). This is one of Lithuania's most compelling advantages as a licensing jurisdiction: you gain access to the entire EU single market from one NCA relationship, without separate applications, filings, or fees in each country.

How Lithuania CASP Passporting Works

  • Notification to Bank of Lithuania: To begin providing services in another EU member state, your company submits a passporting notification to the Bank of Lithuania specifying the target country, service types, and intended start date.
  • 10-working-day forwarding: The Bank of Lithuania must forward the notification to the host state NCA within 10 working days. You may commence providing services in the host state on the day the notification is forwarded — without waiting for host NCA approval.
  • ESMA register publication: All authorized Lithuanian CASPs appear in ESMA's publicly searchable register, giving institutional clients, partner platforms, and counterparties across the EU immediate confirmation of your authorization status.
  • Home vs. host supervision: The Bank of Lithuania is your home-state prudential supervisor. Host-state NCAs supervise conduct-of-business requirements that apply in their territory. Lithuania's established regulatory dialogue with other EU NCAs facilitates smooth cross-border operations.

Lithuania's strategic position in the Baltics and its role as a hub for EU-regulated fintechs makes it a natural gateway for companies targeting both Northern and Eastern EU markets. With a Lithuania CASP license, you can serve clients in Germany, the Netherlands, France, Poland, and all other 24 EU member states. See our detailed guide on EU passporting under MiCA for the complete procedural framework. For a direct comparison with Estonia's FIU authorization route, see Estonia CASP License.

VASP to CASP Transition in Lithuania

Lithuania adopted a significantly shorter VASP-to-CASP transitional period than the maximum 18 months permitted under MiCA Article 143. Lithuania's transitional window ended on 30 December 2025 — meaning any crypto business that was operating as a VASP in Lithuania and had not obtained a CASP authorization by that date was required to cease providing crypto-asset services. As of early 2026, there is no grandfathering protection remaining for Lithuanian VASPs.

Lithuania VASP Transition Period Ended: 30 December 2025 ⚠️

Lithuania opted for one of the EU's shortest VASP transitional periods — only 12 months from MiCA's December 2024 application date. As of 30 December 2025, all crypto businesses operating in Lithuania must hold a valid Bank of Lithuania CASP authorization. There is no grace period remaining. Companies still operating without a CASP license face regulatory enforcement action. If you are currently operating without authorization, contact us immediately — we can help you regularize your situation. See also our VASP to CASP transition guide for EU-wide context.

Key Points for Companies Seeking Lithuania CASP Authorization Now

  • Immediate authorization required: Any company wishing to provide crypto-asset services in Lithuania must apply for and obtain CASP authorization from the Bank of Lithuania before commencing operations. The VASP transitional protection has expired.
  • Former VASPs may benefit from streamlined review: The Bank of Lithuania may take into account prior VASP registration history and compliance track record when assessing CASP applications from previously registered entities, potentially reducing review time for well-documented applicants.
  • New service types require separate authorization: Companies adding CASP service categories not covered by prior VASP registration must obtain full authorization for those additional services. The Bank of Lithuania assesses each service type against MiCA requirements individually.
  • EU passporting rights require CASP: Transitional rights — which have now expired in Lithuania — did not carry passporting privileges. Full EU passporting to all 27 member states is available only upon CASP authorization, not under any transitional or provisional arrangement.
  • FCIS AML register vs. Bank of Lithuania CASP register: Lithuania's historic VASP AML registrations were maintained by the FCIS (Finansinių nusikaltimų tyrimo tarnyba). The MiCA CASP authorization is a separate Bank of Lithuania authorization — prior FCIS VASP registration does not constitute CASP authorization.

For companies comparing Baltic jurisdictions, note that both Lithuania and Estonia adopted shorter transitional windows than Poland. If your business was operating as a VASP under Estonia's FIU, the Estonian transition timeline may differ — see Estonia CASP License for details.

Fintech and legal team in Vilnius working on Lithuania CASP license application

Lithuania Crypto Regulation Background

Lithuania established itself as an EU fintech powerhouse well before MiCA — driven by the Bank of Lithuania's proactive LBChain sandbox initiative and the FCIS's relatively open VASP registration regime, which attracted hundreds of crypto businesses to Vilnius from 2018 onwards. This regulatory head start gave Lithuania deep institutional knowledge of crypto business models and a well-staffed NCA team with direct experience of crypto-asset supervision.

Key Regulatory Timeline

  • 2018–2020: FCIS introduced a straightforward AML-based VASP registration framework, making Lithuania one of Europe's most accessible crypto licensing jurisdictions. This attracted hundreds of crypto exchanges, wallet providers, and asset managers to register Lithuanian UABs.
  • 2020–2022: Following FATF pressure and AMLD5 transposition, Lithuania tightened VASP registration requirements — introducing enhanced due diligence, minimum capitalization guidance, and fit & proper requirements that pre-empted many MiCA provisions.
  • 2022–2024: The Bank of Lithuania's Innovation Lab engaged actively with ESMA on MiCA technical standards. Lithuania was among the first member states to publish national MiCA transposition guidance and begin internal preparation for NCA designation.
  • December 2024: MiCA becomes fully applicable. The Bank of Lithuania is formally designated as Lithuania's MiCA NCA and begins accepting CASP authorization applications. Lithuania formally adopts a 12-month VASP transitional period — the shortest among the Baltic states.
  • January 2025: DORA becomes applicable to all MiCA CASPs, adding mandatory ICT resilience requirements to every Bank of Lithuania CASP authorization.
  • 30 December 2025: Lithuania's VASP transitional period expires. All crypto businesses operating in Lithuania must hold a valid CASP authorization — there is no remaining grandfathering protection.

Today, Lithuania's fintech ecosystem is one of the most developed in the EU. The country hosts Revolut's EU banking entity, Bankera, Paysera, and dozens of other licensed financial institutions — creating a rich network of compliance professionals, legal experts, and banking partners that significantly reduces the practical cost and complexity of establishing and maintaining a CASP in Vilnius. Crypto License Europe maintains its Baltic office at Konstitucijos pr. 21A in Vilnius — our local team has direct relationships with Bank of Lithuania's supervisory staff and has guided 40+ companies through Lithuanian licensing processes since 2019. Contact us to discuss your Lithuania CASP application.

Lukas Berg — Lithuania Expert, Senior Crypto Licensing Consultant
Lithuania Expert
Lukas Berg
Senior Crypto Licensing Consultant — Crypto License Europe

Lithuania specialist with 10 years of experience in Bank of Lithuania licensing and Lithuanian financial market regulation. Lukas has guided more than 30 companies through Lithuanian VASP registration and MiCA CASP authorization, and maintains active working relationships with the Bank of Lithuania's fintech supervision and innovation teams. Prior to joining Crypto License Europe, Lukas worked as a junior associate at EY Vilnius in the financial services regulatory practice, later serving as legal counsel at a Vilnius-based payment institution. He holds an LL.M. from Vilnius University Faculty of Law. Full profile →

140+
Successful Licenses
96%
Approval Rate
3–5 mo
Lithuania Timeline
€50k
Min. Capital

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