Crypto License in Lithuania

Is This Route Right for Your Business?

May Fit
You provide crypto services to clients through EU operations.

Separate Assessment
You issue tokens or handle investments.

Additional Permissions
You provide payments or e-money services.

Which Application Route Applies?

Article 60 is for qualifying financial institutions, not simply any registered business.

Services Your Application Can Cover

Holding and Moving Assets
Request custody and administration or transfer permissions and explain how you separate client assets from your own.

Converting Assets
Exchanging crypto-assets for funds and swapping crypto-assets require separate permissions. Explain transactions and client-fund protection.

Orders, Advice and Investment Management
You can execute or forward orders, place crypto-assets for offerors, advise clients or manage portfolios. Request each relevant permission. Holding client assets or money brings safeguarding duties.

Running an Exchange Platform
Matching buyers and sellers needs trading-platform permission. Assess asset-referenced or e-money token issuance and payments separately.

What Gofaizen & Sherle Handles

• Check which permissions you need. Use your ownership and financial records to prepare formation documents and the application.
• Work with managers and technology providers on governance, anti-money-laundering (AML), customer checks, asset protection and information and communication technology (ICT) documents.
• Help arrange staff, training, accounting, audit and IT work included in the engagement. Management runs the business.
• Help answer the regulator, apply for accounts and notify EU expansion. Banks and regulators decide outcomes.

Local managers supply operational records. Auditors and vendors handle specialist tasks.

Support Options and Costs

Financial safeguards are an additional obligation, explained below.

Documents and Details to Prepare

• Provide shareholder and ultimate beneficial owner details, funding sources and records confirming managers’ suitability
• Provide a business plan and describe client transactions to define requested services
• Confirm a registered office in Lithuania, some services provided there, effective EU management and at least one EU-resident director
• Document financial resources and explain customer checks, asset protection, outsourcing and technology controls

For ordinary CASP applicants, the national-law translation linked by the Bank of Lithuania specifies a public or private limited company (AB/UAB), a general meeting, board and manager, with prior regulatory approval of managers.

Application Review Times

After receiving the application, the regulator has up to 25 working days to check that it is complete. Assessment takes up to 40 working days from a complete application. A first information request by assessment working day 20 pauses assessment until your reply, for at most 20 working days. Later requests do not pause it.

Gathering records, preparing documents and arranging providers add time before launch.

Lithuania’s MiCA Regulatory Framework

Lithuania’s CASP licensing and supervision follow the Markets in Crypto-Assets Regulation, MiCA (EU) 2023/1114, with the Bank of Lithuania as the regulator.
Article 59 explains who may offer services. Eligible financial institutions can use the Article 60 notification procedure. Other applicants follow Article 62 for application documents and Article 63 for the authorization process. Approval covers the services named in the decision. Article 67 requires continuing financial safeguards.

The national Law on Markets in Crypto-Assets adds Lithuanian requirements. Providers also need governance arrangements, AML and CFT controls, and technology safeguards under the Digital Operational Resilience Act (DORA).
EU expansion requires cross-border notification. Technical standards from the European Securities and Markets Authority (ESMA) and European Banking Authority (EBA) add detail.

Current Status and Legacy Registration

Obligations After Authorization

Financial Safeguards Under MiCA
Management must always maintain the higher of the service minimum or one quarter of last year’s fixed overheads, calculated under MiCA. New firms use their first 12-month forecast. Minimums start at €50,000 for orders, placing, transfers, advice or portfolio management, rising to €125,000 for custody/exchange and €150,000 for platforms. You can use own funds, qualifying insurance, a comparable guarantee or a combination. Check whether suitable cover is available. Recalculate at least annually and retain supporting financial records.

Client Protection Under MiCA
Management must maintain asset protection, complaints handling, conflict management, clear communications and applicable market-abuse controls. Keep records of this work.

AML and Sanctions
Under Lithuanian AML/CFT law, compliance staff check customers and transactions, enforce sanctions controls and report suspicious activity. Retain the checks and submitted reports. For transfers, verify sender and recipient information under the travel rule and EBA guidance.

IT Systems and External Providers
Management remains responsible for outsourced work and ongoing resilience testing under DORA. Retain test records and submit required regulatory reports and annual audited financial statements under Lithuanian law.

Risks of Operating Without Meeting the Rules

Missing permissions, expired registrations or weak controls can trigger fines, restrictions, corrective action or authorization refusal, suspension or withdrawal. Resolve control problems before adding activities.

Banking and Client Money

Account approval is not guaranteed. Providers review:

• Ownership and funding sources
• Authorized services and transaction flows

A corporate account does not replace client-money safeguarding.

Under Article 70, ordinary CASPs place client funds, excluding e-money tokens, in separately identifiable credit-institution or central-bank accounts by the next business day’s end. Article 70(5) exempts CASPs that are credit institutions, electronic money institutions (EMIs) or payment institutions (PIs) from paragraphs 2 and 3. For e-money-token (EMT) payments, ask advisers and regulators whether you need payment authorization or an authorized partner.

Tax Assessment for Your Business

Lithuania’s standard corporate income tax is 17% of taxable profits for 2026 periods onward. Company and client taxes differ. Check VAT for each service, plus payroll taxes, withholding, transfer pricing, permanent-establishment exposure and crypto-asset accounting. VAT exemptions and small-business relief have conditions. They do not apply automatically to every CASP.

When Another Route May Fit