Lithuania CASP Licence Under MiCA: Requirements and Timeline
Lithuania has transitioned its crypto licensing regime to fully comply with the EU Markets in Crypto-Assets Regulation (MiCA), which is in force as of 2026. The new Lithuania CASP licence under MiCA replaces the previous VASP registration model, introducing stricter capital requirements, enhanced governance rules, and a harmonised EU passport. This guide provides a factual, up-to-date overview of what crypto founders need to know to obtain a Lithuania CASP licence under MiCA, including requirements, costs, timeline, and key considerations.
Consulting24 has obtained over 500 crypto licences across Europe and delivers directly in Lithuania, Estonia, and Panama. For Lithuania, we handle the full application process for the CASP licence, ensuring compliance with MiCA standards. If you are exploring other jurisdictions, we advise and coordinate applications globally. Our flat-fee Panama company setup at EUR 6,000 remains a popular alternative for non-EU operations.
What Is the Lithuania CASP Licence Under MiCA?
The Lithuania CASP licence under MiCA is the new authorisation required for any entity offering crypto-asset services in Lithuania. It aligns with the EU-wide MiCA framework, which came into full effect in 2025-2026. The licence is issued by the Bank of Lithuania, which acts as the competent authority under MiCA. Key features include:
- Harmonised passporting rights across all EU member states.
- Three capital tiers based on service types: EUR 50,000 for simple services (e.g., custody), EUR 125,000 for exchange services, and EUR 150,000 for trading platforms.
- Mandatory governance, AML, and consumer protection measures.
- Transition period for existing VASPs ended in 2025; all new applicants must apply under MiCA.
This licence is essential for any crypto business targeting the European market from Lithuania. The Bank of Lithuania has a reputation for being thorough but fair, and the process is more predictable than in some other EU states. For example, the regulator publishes detailed guidance on application requirements, reducing uncertainty. The licence also allows firms to offer services across the EU without additional authorisation, making Lithuania a strategic hub for crypto operations.
Who Needs a Lithuania CASP Licence?
Any legal entity providing crypto-asset services in or from Lithuania must hold a CASP licence. This includes:
- Crypto exchanges (fiat-to-crypto and crypto-to-crypto).
- Custodial wallet providers.
- Brokers dealing in crypto-assets.
- Platforms offering crypto staking or lending services (if classified as crypto-asset services).
- Market makers and OTC desks.
If you plan to serve EU clients, the Lithuania CASP licence under MiCA is a strategic choice due to its efficient regulatory process and relatively lower costs compared to other EU hubs like Malta or Cyprus. For non-EU operations, Panama offers a simpler, flat-fee structure at EUR 6,000. Even if your target market is global, having an EU licence adds credibility and access to the single market. For example, a crypto exchange based in Lithuania can onboard clients from Germany, France, and Spain without needing separate licences, saving significant time and cost.
Licence Type and Regulator
The licence is a single CASP authorisation under MiCA, administered by the Bank of Lithuania (Lietuvos bankas). Unlike the previous VASP registration, which was a lighter-touch regime, the CASP licence requires a full application with detailed documentation, including a business plan, risk assessment, governance framework, and capital proof. The Bank of Lithuania is known for its pragmatic approach but enforces strict compliance with MiCA standards. There is no separate licence for different service types; instead, the licence scope reflects the services applied for, with capital adjusted accordingly. The regulator also conducts ongoing supervision, including periodic reviews and audits. For instance, the Bank of Lithuania may request updated AML policies annually or conduct on-site inspections. This regulatory rigour enhances trust among clients and partners.
Cost and Timeline
The cost for obtaining a Lithuania CASP licence under MiCA includes government fees, legal and consulting fees, and capital requirements. Below is an indicative breakdown:
| Item | Cost (EUR) |
|---|---|
| Government application fee | ~2,500 - 5,000 |
| Consulting & legal (Consulting24) | From 15,000 (full service) |
| Minimum capital (by service) | 50,000 / 125,000 / 150,000 |
| Annual compliance & AML | ~5,000 - 10,000 |
| Total estimated cost (excluding capital) | ~20,000 - 30,000 |
Timeline: 3-6 months from application submission to approval, depending on completeness and complexity. Consulting24 can expedite by preparing a thorough application upfront. For exact pricing, a consultation is recommended. The timeline can be longer if the regulator requests additional information or if the business model is complex. For example, a straightforward custody service may be approved in 3 months, while a trading platform with multiple services may take 6 months. The government fee is non-refundable, so it is critical to submit a complete application.
Capital Requirement
Under MiCA, the minimum capital requirement for a CASP depends on the services offered:
- EUR 50,000 for custody and transfer services.
- EUR 125,000 for exchange services (fiat-to-crypto or crypto-to-crypto).
- EUR 150,000 for trading platforms (matching orders).
This capital must be held in liquid assets and demonstrated at application. The Bank of Lithuania may require additional capital based on risk assessment. Compared to Estonia, which also follows MiCA with similar tiers, Lithuania offers a slightly faster process. The capital must be maintained throughout the licence period and cannot be withdrawn without regulatory approval. For example, if you apply for a custody licence, you must show EUR 50,000 in a bank account or liquid securities. This capital serves as a buffer for operational risks and client protection. It is important to note that the capital requirement is separate from the company's share capital, which is typically EUR 2,500 for a UAB.
Tax Treatment
Lithuania applies a 15% corporate income tax on profits, with a reduced 5% rate for small companies (revenue under EUR 300,000, fewer than 10 employees). Crypto-to-crypto transactions are generally not taxable at the point of exchange; only realisation into fiat triggers a taxable event. VAT is not charged on crypto-asset services. Lithuania has a favourable tax environment for crypto businesses, especially compared to higher-tax EU jurisdictions. However, tax advice from a local specialist is essential. For example, if you hold crypto as an investment, capital gains tax may apply upon sale. Lithuania also has a participation exemption for dividends from subsidiaries, which can be beneficial for holding structures. Additionally, the country has a wide network of double tax treaties, reducing withholding taxes on cross-border payments. For a detailed analysis, see our cost page.
Allowed Activities
Under the Lithuania CASP licence, the following activities are permitted:
- Execution of orders on behalf of clients.
- Placing of crypto-assets.
- Reception and transmission of orders.
- Custody and administration of crypto-assets.
- Exchange services (fiat-to-crypto, crypto-to-crypto).
- Operation of a trading platform.
- Advice on crypto-assets.
Activities not covered (e.g., crypto derivatives) may require additional licences under MiFID II. The licence allows passporting across the EU, making Lithuania a gateway to the European market. If you plan to offer services that are not explicitly listed, you should check with the regulator or seek legal advice. For instance, if your platform offers staking as a service, it may fall under custody or advice, depending on the structure. The Bank of Lithuania provides a list of classified activities in its guidance, which is updated periodically.
Step-by-Step Process
Obtaining a Lithuania CASP licence under MiCA involves these steps:
- Pre-incorporation: Register a Lithuanian company (UAB) with a minimum share capital of EUR 2,500. Consulting24 can handle company setup.
- Documentation: Prepare a business plan, AML policies, risk assessment, governance framework, and capital proof.
- Application: Submit to the Bank of Lithuania with the application fee.
- Review: The regulator assesses the application; may request additional information.
- Approval: Licence granted, typically within 3-6 months.
- Post-licence: Ongoing compliance, reporting, and AML obligations.
Consulting24 manages the entire process, from company formation to application submission. For a detailed timeline, see our application process page. It is important to have all documents prepared in Lithuanian or English, as required by the regulator. For example, the business plan must include financial projections for three years, a description of the target market, and a risk management strategy. The AML policy should cover customer due diligence, transaction monitoring, and suspicious activity reporting. The regulator may also require a physical presence in Lithuania, such as a registered office and a local director.
Banking and Payments
Opening a bank account for a crypto business in Lithuania is challenging but possible. Major banks like Swedbank, SEB, and Luminor accept crypto clients with proper compliance. Consulting24 assists with bank introductions and account setup. Additionally, many crypto-friendly payment processors and EMI licences are available. For a comparison of banking options, see our cost page. Some banks may require a minimum deposit or charge higher fees for crypto-related accounts. It is advisable to have a backup banking solution, such as an EMI, to ensure continuity of operations. For example, a client may open a primary account with Swedbank and a secondary account with a licensed EMI like Revolut or Paysera. The Bank of Lithuania also authorises specialised crypto banks, but they are fewer in number. The application process for a bank account can take 1-3 months, so it is wise to start early.
Benefits of the Lithuania CASP Licence
- EU passport: Serve all 27 member states from one licence.
- Efficient process: 3-6 months, faster than many EU peers.
- Low operational costs: Competitive fees and tax rates.
- Strong regulatory reputation: Bank of Lithuania is respected.
- Access to skilled workforce and EU infrastructure.
For founders seeking a quick EU entry, the Lithuania CASP licence under MiCA is a top choice. Additionally, Lithuania has a supportive fintech ecosystem with networking events and government initiatives. For example, the country hosts the annual Fintech Day conference, attracting investors and partners. The licence also enhances credibility with clients and financial institutions, making it easier to secure partnerships and funding. Compared to Dubai, which offers a non-EU alternative, Lithuania provides a direct route to the European market.
Compliance and Trust
Compliance under MiCA is rigorous. Key requirements include:
- AML/CFT procedures aligned with EU directives.
- Secure custody of client assets.
- Transparent fee structures.
- Regular reporting to the Bank of Lithuania.
- Audited financial statements.
Consulting24 provides ongoing compliance support to ensure your licence remains valid. This is general guidance, not legal advice; always consult a qualified lawyer. Non-compliance can result in fines or revocation of the licence, so it is important to stay up to date with regulatory changes. For example, the Bank of Lithuania may require quarterly reports on transaction volumes and client complaints. The regulator also conducts thematic reviews, such as on cybersecurity practices. Maintaining a strong compliance culture not only satisfies regulatory requirements but also builds trust with clients and partners. For a deeper dive, see our requirements page.
Common Mistakes
Avoid these pitfalls:
- Underestimating capital requirements: Ensure you have the correct tier for your services.
- Incomplete documentation: The Bank of Lithuania rejects applications with missing information.
- Ignoring AML requirements: A strong AML programme is mandatory.
- Choosing the wrong jurisdiction: Compare Lithuania vs other jurisdictions before committing.
- Not planning for ongoing compliance: Annual reports and audits are required.
Working with an experienced consultant like Consulting24 minimises these risks. For example, we have seen applications delayed because the business plan lacked detail on risk management. Another common mistake is assuming that the capital requirement can be met with crypto assets; the Bank of Lithuania typically requires fiat or liquid securities. Also, some applicants fail to appoint a local AML officer, which is a mandatory requirement. By addressing these issues upfront, you can avoid costly delays and rejections.
Alternatives and Comparison
Compared to other EU jurisdictions, Lithuania offers a balanced mix of speed, cost, and regulatory clarity. Below is a comparison with Panama and two other popular options:
| Jurisdiction | Licence Type | Cost (approx) | Timeline | Capital | EU Passport |
|---|---|---|---|---|---|
| Lithuania | CASP under MiCA | EUR 20k-30k + capital | 3-6 months | EUR 50k-150k | Yes |
| Panama | Fintech licence | EUR 6,000 flat | 2-3 months | None | No |
| Estonia | CASP under MiCA | EUR 25k-35k + capital | 3-6 months | EUR 50k-150k | Yes |
| Malta | VFA licence | EUR 40k-60k + capital | 6-12 months | EUR 125k-730k | Yes |
For non-EU operations, Panama is the most cost-effective option with no capital requirement. For EU-focused businesses, Lithuania is often the best balance of cost and speed. Estonia is similar but has slightly higher costs and a longer track record. Malta is more expensive and slower but offers a well-established regulatory framework. Consulting24 can help you choose the right jurisdiction based on your business model. For a full comparison, see our jurisdictions page.
Frequently asked questions
What is the difference between the old VASP registration and the new CASP licence in Lithuania?
The old VASP registration was a lighter-touch regime with no minimum capital requirement and simpler AML obligations. The new CASP licence under MiCA requires minimum capital of EUR 50,000 to EUR 150,000, a full application with detailed governance and risk documentation, and ongoing compliance with EU-wide standards. The transition period ended in 2025, so all new applicants must apply for the CASP licence.
Can I passport the Lithuania CASP licence to other EU countries?
Yes, the CASP licence under MiCA allows passporting across all EU member states. Once licensed in Lithuania, you can offer services in any other EU country without needing additional authorisation. This is one of the main advantages of the licence, as it provides access to a market of over 450 million consumers.
What are the ongoing compliance requirements after obtaining the licence?
Ongoing compliance includes annual AML/CFT audits, regular reporting to the Bank of Lithuania on transaction volumes and client complaints, maintaining minimum capital, and updating policies as regulations change. The regulator may also conduct on-site inspections. Consulting24 offers ongoing compliance support to help you meet these obligations.
How long does the Lithuania CASP licence application process take?
The process typically takes 3 to 6 months from submission to approval. The timeline depends on the complexity of your business model and the completeness of your application. Consulting24 helps prepare a thorough application to minimise delays. For simple services like custody, approval can be closer to 3 months.
Is there a physical presence requirement for the Lithuania CASP licence?
Yes, you need a registered office in Lithuania and a local director or AML officer. The Bank of Lithuania requires that the company has a real presence, including staff and operational capacity. Consulting24 can assist with finding a registered office and recruiting local personnel if needed.
Can I use the Lithuania CASP licence to offer crypto derivatives?
No, crypto derivatives (such as futures and options) are not covered under MiCA and require a MiFID II licence. The CASP licence covers only crypto-asset services as defined in MiCA. If you plan to offer derivatives, you may need a separate investment firm licence under MiFID II.
What happens if I fail to maintain the minimum capital requirement?
If you fail to maintain the minimum capital, the Bank of Lithuania may impose fines, suspend your licence, or revoke it. It is critical to monitor capital levels and report any changes to the regulator. Consulting24 can help set up systems to track capital adequacy.
Is the Lithuania CASP licence recognised outside the EU?
While the licence is an EU authorisation, it is recognised globally as a sign of regulatory compliance. Many non-EU jurisdictions and financial institutions view an EU CASP licence as a mark of credibility, which can facilitate partnerships and banking relationships outside the EU.
Can I apply for the Lithuania CASP licence if my company is already registered in another EU country?
Yes, you can establish a Lithuanian subsidiary and apply for the CASP licence. Alternatively, if your existing company is already licensed as a CASP in another EU member state, you can passport into Lithuania without a separate application. However, if you want to be regulated in Lithuania, you must apply through the Bank of Lithuania.
What are the tax implications for crypto-to-crypto transactions in Lithuania?
Crypto-to-crypto transactions are generally not taxable at the point of exchange. Tax is triggered only when crypto is converted to fiat currency or used to purchase goods and services. Corporate income tax of 15% (or 5% for small companies) applies on profits. It is advisable to consult a local tax advisor for your specific situation.
Does Consulting24 provide support for the Lithuania CASP licence application?
Yes, Consulting24 delivers the full application process for the Lithuania CASP licence, including company incorporation, document preparation, submission, and ongoing compliance. We have extensive experience with the Bank of Lithuania and can help you navigate the requirements efficiently. Contact us for a consultation.
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