Quick Facts
| Parameter | Value |
|---|---|
| Regulator | Bank of Lithuania (Lietuvos bankas) |
| License types | MiCA CASP — Class 1 · MiCA CASP — Class 2 · MiCA CASP — Class 3 |
| Minimum capital | €50,000 / €125,000 / €150,000 (by CASP class) |
| Typical timeline | 3–6 months (Bank of Lithuania review) |
| Corporate tax | 16% (raised from 15% in 2025; 17% from 2026) |
| Region | Europe |
From VASP gateway to CASP filter: what happened to Lithuania's 800 providers
Lithuania built the EU's largest crypto on-ramp on a €2,500 share-capital VASP registration. That door closed in stages, and the numbers tell the story better than any explainer.
| Date | Change | Effect on the register |
|---|---|---|
| 1 Nov 2022 | Minimum share capital raised €2,500 → €125,000; local resident AML officer mandated; AML officer barred from serving more than one VASP | First major cull — undercapitalised shells exited |
| Nov 2024 | Travel Rule enforcement + MiCA migration looming | 300+ VASPs deregistered in a single month, from a register of roughly 700 |
| 31 Dec 2025 | Lithuanian VASP grandfathering ends | Operating without a Bank of Lithuania CASP licence becomes illegal financial activity |
The practical lesson: Lithuania's reputation for being fast and cheap is historical. The same ecosystem now runs one of the EU's most experienced — and most selective — CASP supervisors. You inherit the depth of local expertise, not the low bar.
The Bank of Lithuania's substance bar — where VASP-era shells fail
Under the old FCIS regime a Lithuanian VASP could run on a single local AML officer and a virtual office. The Bank of Lithuania assesses a CASP file the way it assesses a payment institution, and that is where former VASP operators most often stumble. It expects a management body that passes fit-and-proper, demonstrable local operational substance (not a nameplate), a DORA-grade ICT and resilience setup, segregation and safeguarding of client crypto-assets, a full view of own funds against the Annex IV floor, and a wind-down plan. The €50k/€125k/€150k figure is the floor — the binding number is often one-quarter of projected fixed overheads, which for a real exchange exceeds €125,000. A clean pre-MiCA VASP registration does not roll over automatically.
When Lithuania is the wrong choice
Honest answer to a question competitors skip. Consider another EU CASP jurisdiction if: you wanted the cheap, fast route — it is gone, and Lithuania no longer underprices Czechia, Poland or Slovakia on setup; your business is stablecoin (ART/EMT) issuance — that sits under MiCA Titles III–IV with credit-institution-grade requirements, which a CASP licence does not cover; or you have no genuine local presence — the Bank of Lithuania's substance bar makes a lighter-touch jurisdiction cheaper to run.
Why Lithuania?
- Deepest local supply of crypto-fluent lawyers, AML officers and banking contacts in the EU — a by-product of being the former #1 VASP hub;
- The Bank of Lithuania has processed more crypto applications than almost any EU regulator — its expectations and templates are well-mapped;
- EU passporting: one Lithuanian CASP licence services all 30 EEA states with no second authorisation;
- Competitive corporate tax versus Western Europe, plus a mature fintech / SEPA banking layer.
The legacy "FCIS VASP, €125k, 6–8 weeks" framing is no longer current — that regime closed on 31 December 2025. Supervision moved from FCIS to the Bank of Lithuania under the Law on Markets in Crypto-Assets (passed 11 July 2024).
Requirements for a Lithuania crypto license
Every Lithuania crypto application turns on six pillars. Get them right and the regulator interaction becomes routine; get them wrong and you spend the next six months in RFI cycles.
- A locally-registered company with a clear corporate structure and identified ultimate beneficial owners;
- A resident director and a Money Laundering Reporting Officer (MLRO) familiar with Lithuania compliance practice;
- An AML/KYC programme calibrated to Bank of Lithuania (Lietuvos bankas) expectations, including transaction monitoring rules and FATF Travel Rule readiness;
- A demonstrable office presence — physical address, document retention policies and incident response plan documented;
- Capital evidence consistent with the regime: €50,000 / €125,000 / €150,000 (by CASP class);
- A clean source-of-funds and source-of-wealth file for all controllers, with supporting documentation.
Step-by-step process for a Lithuania crypto license
- Strategy and gap analysis. We map your business model to the available licence categories at Bank of Lithuania (Lietuvos bankas) and identify the gaps before any regulator interaction.
- Incorporation and substance setup. Local entity formation, resident-director arrangement, registered office and AML officer appointment are completed in parallel to save weeks on the timeline.
- AML / KYC programme drafting. Transaction monitoring rules, sanctions screening, KYB onboarding flow, MLRO reporting matrix and Travel Rule provider selection are documented to regulator-grade standard.
- Application file and submission. The application file is built to the actual reading list of Bank of Lithuania (Lietuvos bankas) examiners — not a generic template — and submitted with a covering memo addressing the most common RFI triggers.
- Regulator engagement and RFI cycles. We respond to Requests for Information within published service-level windows and brief you weekly on engagement progress.
- Approval and onboarding. On approval, the post-licence onboarding sprint covers banking, payment rails, audit firm appointment, and the first annual return calendar.
- Ongoing supervision. Annual reporting, AML programme refresh, MLRO appointments and material change notifications are calendared and monitored.
Costs breakdown
Total first-year all-in cost combines four lines: regulator fee, statutory capital tied up unproductively, legal fees, and substance (resident director, office, AML officer, technology audit). Ongoing supervision sits on top from year two onwards. We model three-year total cost upfront so the budget is realistic.
| Cost line | Indicative range |
|---|---|
| Regulator fee | Confirmed in writing at engagement |
| Statutory capital | €50,000 / €125,000 / €150,000 (by CASP class) |
| Legal fees | Fixed-scope quote at kickoff |
| Substance (year 1) | Resident director, office, AML officer |
| Ongoing supervision (year 1+) | Annual audit, returns, AML refresh |
Taxation
The corporate tax position in Lithuania is 16% (raised from 15% in 2025; 17% from 2026). Tax is structuring-dependent — the headline rate is rarely the rate a properly-structured group ends up paying. Tax advice is provided in cooperation with locally-admitted tax counsel and is scoped separately from the licensing engagement.
Documents required
- Certificate of incorporation, articles, shareholder register and group ownership chart;
- UBO identification — passports, addresses, source-of-funds and source-of-wealth documentation for all controllers;
- Director and senior-management CVs, regulatory references, fit-and-proper questionnaires;
- Business plan with three-year financial projections and stress-tested assumptions;
- AML/KYC policy pack — programme manual, risk assessment, transaction-monitoring rules, sanctions-screening procedure, MLRO appointment and reporting matrix;
- Technology architecture description — wallet model, custody segregation, key management, incident-response plan, cybersecurity certifications;
- Lease and proof of substantive office in Lithuania where applicable.
Our experts for Lithuania
Tomáš Novák
Senior Counsel — EU & Eastern Europe
Six years at the European Banking Authority working on MiCA technical standards and the Transfer of Funds Regulation.
- LL.M. KU Leuven
- Czech Bar
- Former EBA Senior Policy Officer
Daniel R. Whitmore
Founder & Managing Partner
Founder. Eight years at a Magic Circle firm leading the financial-regulation emerging-tech desk before founding the firm in 2018.
- LL.M. Financial Regulation, LSE
- Solicitor (England & Wales)
- New York Bar
- CLLS Financial Law Committee
Frequently asked questions
I already hold a Lithuanian VASP registration — does it convert to a CASP licence automatically?
No. The pre-MiCA VASP registration expired with the grandfathering period on 31 December 2025. To keep operating you needed to file a full CASP application with the Bank of Lithuania, assessed against new fit-and-proper, substance, capital and governance requirements — not a rollover of your old FCIS registration.
Who issues the crypto licence now — FCIS or the Bank of Lithuania?
The Bank of Lithuania (Lietuvos bankas) is the competent authority that grants and supervises MiCA CASP authorisations. The Financial Crime Investigation Service (FCIS/FNTT) no longer registers crypto providers; it now sits on the AML/CFT enforcement side. This is a genuine shift from the old VASP era.
Why did so many crypto firms leave Lithuania in 2024?
Two filters hit at once. The €125,000 minimum capital (in force since November 2022) and the approaching MiCA migration made a paper-thin VASP uneconomic. In November 2024 alone, over 300 of roughly 700 registered VASPs deregistered ahead of Travel Rule enforcement and the licensing deadline.
How much capital do I really need for a Lithuanian CASP licence?
The MiCA floor is €50,000 for Class 1 (advisory / order-handling), €125,000 for Class 2 (custody and exchange), and €150,000 for Class 3 (operating a trading platform). But own funds must be the higher of that floor or one-quarter of prior-year fixed overheads — so an active exchange typically needs more than the headline number.
Is Lithuania still faster and cheaper than other EU jurisdictions?
Not meaningfully. The regime is now MiCA-standard, so capital tiers, substance expectations and review timeline align with hubs like Poland, Czechia and Slovakia. Lithuania’s real edge today is the depth of crypto-experienced lawyers and a regulator that has handled more applications than most — predictability, not discount pricing. Expect roughly 3–6 months end-to-end for a well-prepared file.
What 2026 obligations are specific to operating a CASP from Lithuania?
Beyond standard MiCA conduct and prudential rules, DAC8 obliges your CASP to collect, verify and annually report user and transaction data to the Lithuanian tax authority from 2026, and corporate income tax rose to 16% (2025) with a further step to 17% reported for 2026 (verify the final rate). You also operate under DORA and the Travel Rule for transfers.