Until 2025, crypto companies in Lithuania registered as virtual currency exchange or wallet operators with the Register of Legal Entities, and their compliance with anti-money laundering rules was supervised by the Financial Crime Investigation Service (FCIS). This regime no longer applies: since 30 December 2024, crypto-asset services are governed by the EU Markets in Crypto-Assets Regulation (MiCA), and since 1 June 2025 they may only be provided with a crypto-asset service provider (CASP) licence issued by the Bank of Lithuania.
Below we explain what changed and which requirements apply to crypto businesses in Lithuania today. A detailed overview of the licensing regime: MiCA licence in Lithuania.
Is a licence needed for your activity?
A CASP licence is required if the company provides any of the crypto-asset services listed in MiCA, for example:
- exchange of crypto-assets for funds (fiat) or for other crypto-assets;
- custody and administration of crypto-assets on behalf of clients, including safekeeping of private keys;
- transfer services for crypto-assets;
- operation of a trading platform, execution of orders, reception and transmission of orders, placing of crypto-assets;
- advice on crypto-assets and portfolio management of crypto-assets.
Crypto-assets are digital representations of a value or a right that can be transferred and stored electronically using distributed ledger technology. The licensing and supervisory authority is the Bank of Lithuania.
What changed compared with the FCIS regime
- Registration with the Register of Legal Entities was replaced by a licence of the Bank of Lithuania.
- Companies registered as virtual currency exchange or wallet operators could continue their activities only until 1 June 2025 (five-month transitional period).
- The minimum authorised capital of EUR 125,000 for virtual currency operators (introduced in 2022) was replaced by the MiCA requirements: EUR 50,000, 125,000 or 150,000, depending on the services.
- The FCIS remains the financial intelligence unit of Lithuania: suspicious transactions are still reported to it.
CASP licence in Lithuania
MiCA Authorisation Timeframes
The Bank of Lithuania assesses whether an application is complete within 25 working days of receipt. It then assesses a complete application and adopts a decision within 40 working days. A request for additional information may suspend the assessment period for up to 20 working days. These periods do not guarantee authorisation or permit services to commence before authorisation is granted.
Application for MiCA Authorisation
Applicants must submit an application to the Bank of Lithuania under Article 62 of Regulation (EU) 2023/1114. The application must include the programme of operations, governance arrangements, information on management and qualifying shareholders, evidence of prudential safeguards, AML/CFT controls, business continuity arrangements, ICT security documentation and the policies required for the intended crypto-asset services. The registration rules for ordinary currency exchange operators do not constitute the authorisation procedure for crypto-asset service providers.
Authorisation Before Commencing Activities
Lithuania’s transitional period for previously registered virtual-currency operators ended on 31 December 2025. From 1 January 2026, former registration and notifications to the Register of Legal Entities do not authorise continued crypto-asset services. Providers must hold the required MiCA authorisation or qualify for the procedure under Article 60 before commencing services. AML/CFT duties, including reporting suspicious activity to the Financial Crime Investigation Service (FNTT), remain separate obligations.
Minimum capital and key requirements
Under Article 67 and Annex IV of MiCA, the permanent minimum capital depends on the services. Own funds must always be at least the higher of this amount and one quarter of the fixed overheads of the preceding year.
- Class 1 — EUR 50,000: reception and transmission of orders, execution of orders, placing, transfer services, advice, portfolio management
- Class 2 — EUR 125,000: in addition custody and administration, exchange for funds or other crypto-assets
- Class 3 — EUR 150,000: in addition operation of a trading platform
- Registered office in Lithuania and place of effective management in the EU
- At least one member of the management body resident in the EU
- Fit and proper management body and qualifying shareholders
If you are not sure which MiCA requirements apply to your business and how to comply with them, our team at Company in Lithuania UAB will be glad to help. Contact us today to receive a tailored consultation for your crypto business.
Based on the needs of clients from all over the world, Company in Lithuania UAB has developed the “COMPANY & CRYPTO LICENSE IN LITHUANIA” package, which includes the purchase of a Lithuanian company and the services needed to apply for a CASP licence: drafting the documents required by MiCA, drawing up the company’s procedural and KYC rules and support throughout the licensing process.
