Crypto licence in LithuaniaOverview
Between 2019 and 2024 Lithuania attracted a very large number of crypto exchange and wallet operators, registered with the Centre of Registers and supervised for AML purposes by the FNTT. The regime was tightened in 2022, and with MiCA the Bank of Lithuania became the national competent authority responsible for licensing and supervising CASPs and token issuers. National rules are set out in the Law on Crypto-Asset Markets and the central bank's licensing rules, which follow the same principles applied to other financial market participants.
Lithuania used its option to shorten the MiCA transition, which ended on 31 December 2025, six months before the EU-wide outer limit of 1 July 2026. In July 2025 the Bank of Lithuania urged investors to check whether their provider had applied for a licence and, if not, to move assets to a licensed CASP or a self-hosted wallet before the deadline. From 1 January 2026 a CASP licence has been mandatory, and former registered operators without one can no longer provide services.
The Bank of Lithuania has set out its expectations for future CASPs in published letters. It wants management body members and shareholders of sufficiently good repute with relevant knowledge, experience and time; good governance including separation of control functions and conflict management; a demonstrable understanding of MiCA and Lithuanian rules; and a documented legitimate origin of funds, including a review of shareholders' business history and financing arrangements. It also states plainly that applications which are incomplete, poorly prepared or inaccurate will not be accepted for evaluation.
For well-prepared applicants Lithuania remains attractive: an English-speaking supervisory dialogue, a large fintech ecosystem with experienced compliance professionals, euro-denominated operations and an established route to passport services across the Union. The trade-off is a supervisor that tests substance rigorously and expects the core of the business to be run from Vilnius or elsewhere in Lithuania.
Key benefits
- Mature fintech ecosystem with experienced compliance, risk and AML professionals
- Supervisor accustomed to English-language engagement with international groups
- Eurozone base with full EU and EEA passporting
- Capital requirements matched to the CASP class
- Possibility to combine with an EMI or payment institution group structure in the same jurisdiction
- Established infrastructure of auditors, IT security providers and payment partners
Requirements
- Lithuanian legal entity with registered office and place of effective management in Lithuania
- Operational centre in Lithuania with key functions performed locally rather than largely outsourced
- At least one EU-resident director and a management body that meets fit-and-proper standards
- Own funds of EUR 50,000, 125,000 or 150,000 by class, or one quarter of prior-year fixed overheads if higher
- Documented legitimate origin of capital and review of shareholders' business history
- Governance framework with independent risk, compliance and internal audit functions
- AML/CFT programme aligned with Lithuanian law and the EU travel rule
- DORA-compliant ICT risk management and business continuity
- Client-asset safeguarding policy where custody or exchange services are offered
Licence options & capital
Class 1 CASP
EUR 50,000 minimum own funds
Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, providing transfer services, advice on crypto-assets and portfolio management. Suited to brokerage, advisory and introducing models that never hold client assets. In Lithuania the Bank of Lithuania still expects a local operating team even for lighter models.
Class 2 CASP
EUR 125,000 minimum own funds
All Class 1 services plus custody and administration of crypto-assets on behalf of clients and exchange of crypto-assets for funds or for other crypto-assets. This is the usual tier for custodial wallets, brokers that hold client assets and exchange desks.
Class 3 CASP
EUR 150,000 minimum own funds
All Class 2 services plus operation of a trading platform for crypto-assets. Expect the most intensive review of market-abuse surveillance, rulebooks, matching systems and conflict management.
Step-by-step process
- 1
Strategic assessment
Review of the business model, services and ownership against the Bank of Lithuania's expectation letters to confirm Lithuania is the right home state.
- 2
Company formation and team
Incorporation, capitalisation, local office and recruitment of directors, compliance officer, risk manager and other key function holders.
- 3
Pre-application engagement
Introductory dialogue with the Bank of Lithuania where appropriate, to align on business model and file structure.
- 4
Application preparation
Complete MiCA application, policies, ICT and DORA documentation, financial projections and fit-and-proper files in the required format.
- 5
Bank of Lithuania review
Completeness check within 25 working days and a 40 working day assessment, paused for information requests.
- 6
Licence and passporting
Entry in the Bank of Lithuania list of licensed CASPs and the ESMA register, then cross-border notifications.
Typical documents
- Articles of association and Register of Legal Entities extract
- Programme of operations and three-year financial plan
- Proof of own funds and prudential calculation
- Fit-and-proper questionnaires, CVs and criminal record certificates
- Source-of-funds evidence and shareholders' business history
- Governance, internal control and outsourcing policies
- AML/CFT manual, risk assessment and travel-rule procedures
- ICT security policy, DORA documentation and business continuity plan
- Custody and safeguarding policy where relevant
How Legal Wealth helps
Legal Wealth helps clients judge whether a Lithuanian authorisation fits their operating reality, particularly the expectation of a genuine local team, and then coordinates incorporation, recruitment, local counsel and the full Bank of Lithuania application. We focus early on the areas the central bank scrutinises most: shareholder history, source of funds and governance. Sensitive ownership information is handled with discretion, and we can align the licensed company with the founders' broader holding, residence and succession arrangements.
Enquire with Legal WealthFrequently asked questions
Is my Lithuanian VASP registration still valid?
Not for MiCA services. The transitional period ended on 31 December 2025, and since 1 January 2026 a CASP licence from the Bank of Lithuania or a passport from another EU state is required.
Who supervises CASPs in Lithuania?
The Bank of Lithuania licenses and supervises CASPs, while AML/CFT compliance is overseen together with the Financial Crime Investigation Service.
Can I run a Lithuanian CASP with mostly outsourced functions?
The Bank of Lithuania has said it will not license empty-shell companies whose activities are largely outsourced. It expects an appropriate operational centre in Lithuania.
What capital is required?
EUR 50,000 for Class 1 services, EUR 125,000 for Class 2 and EUR 150,000 for Class 3, or one quarter of prior-year fixed overheads if higher.
What causes applications to be rejected at the outset?
The Bank of Lithuania has stated that incomplete, poorly prepared or factually inaccurate applications will not be accepted for evaluation, so file quality is decisive.
Can a Lithuanian CASP serve clients across the EU?
Yes. Once licensed, it notifies the Bank of Lithuania of the Member States and services concerned and may then operate cross-border.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
