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?

Applicant	Route	Authority	Output	EU Reach	Limit
New CASP applicant	Article 63 application	Bank of Lithuania	Authorized services	Article 65 notification	Approved services only
Eligible regulated financial entity	Article 60 notification	Home authority	Permitted notified services	Applicable MiCA rules	Eligibility and service equivalence required

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.

Support Options and Costs

Scope	Deliverables	Exclusions	Professional Fee	Official Charges	Third-Party Costs
Initial assessment	Identify permissions and missing documents	Filing and running the business	Agreed quote	Separate if applicable	Separate if commissioned
Application preparation	Corporate, governance, AML and ICT documents, answers to regulator questions	Approval, ongoing work unless agreed	Quote reflects services, missing documents and complexity	Current schedule requires confirmation	Bank, auditor and IT charges agreed separately

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

Current Rule	Legacy Rule	Practical Effect	Source
Article 63 or eligible Article 60 route	VASP transition ended December 31, 2025	Old registration no longer permits services from January 1, 2026. Verify authorization	Bank of Lithuania and MiCA

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

Route	Regulator	Scope	EU Reach	Establishment	Limitation
Another EU home country	Home regulator	Authorized services	MiCA notification	Genuine local operations	Choose where you can operate
Article 60	Home regulator	Eligible equivalent services	MiCA rules	Already regulated institution	Restricted to qualifying institutions
EMI/PI	Financial regulator	E-money/payments	Payment-sector rules	Local presence under those rules	Does not authorize all crypto services
Token issuer/investment firm	Relevant regulator	Token issuance/investments	Depends on applicable legislation	Depends on applicable legislation	Classify the token and activity first
Non-EU license	Local regulator	Locally permitted services	No MiCA passport	Local establishment rules	Does not authorize EU operations