VASP Registration in Lithuania: Process and Requirements (Now CASP Under MiCA)

VASP registration in Lithuania is now a legacy term. The national VASP regime closed for new entrants when Lithuania's MiCA transitional period ended on 31 December 2025. To provide crypto-asset services in Lithuania today, you need a CASP authorisation from the Bank of Lithuania under MiCAR. (Bank of Lithuania)

If you searched for "VASP registration Lithuania," you were almost certainly looking for the route that lets a company legally offer crypto exchange, custody, or wallet services from a Lithuanian base. That demand is still valid. What changed is the legal mechanism behind it. The standalone notification-style VASP registration that operators used for years has been superseded by a full authorisation under the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114, known as MiCA or MiCAR. (EUR-Lex)

This guide explains what the Lithuanian crypto-licensing reality looks like in 2026: who issues the licence now, what minimum capital you need, what substance and governance the regulator expects, how long the statutory review runs, and why several of the figures circulating online (a flat EUR 125,000 share capital, a six-to-eight-week timeline, "no local director" claims) are outdated. Every number below is tied to MiCAR's text or to Bank of Lithuania guidance.

Is Lithuanian VASP registration still available in 2026?

No. The national VASP registration regime is closed to new entrants. Lithuania's MiCA transitional period for existing national crypto-asset operators ended on 31 December 2025, and the live legal route is now a Crypto-Asset Service Provider (CASP) authorisation granted by the Bank of Lithuania under MiCAR. New applicants apply directly for that authorisation. (Bank of Lithuania)

The practical takeaway is simple. If a provider tells you they can still secure a "Lithuanian VASP licence" through the old Financial Crime Investigation Service (FCIS) notification, treat that as a red flag. That door is shut. The accurate answer to "how do I get a crypto licence in Lithuania" is "apply for a MiCA CASP authorisation with the Bank of Lithuania."

What changed: national VASP regime to MiCA CASP authorisation

MiCAR entered into force and began applying to crypto-asset service providers on 30 December 2024. (EUR-Lex) Like most EU Member States, Lithuania applied a transitional period so that existing national crypto operators could continue trading while they obtained a MiCA licence. That transitional window in Lithuania ended on 31 December 2025. (Bank of Lithuania)

The shift is more than a name change. Under the old national regime, an operator essentially notified the FCIS and met a short list of national requirements. Under MiCA, you apply for a substantive authorisation: the Bank of Lithuania assesses your capital, governance, AML framework, and fit-and-proper management against the rules in MiCAR Title V (Articles 59 to 85) and Annex IV. (Bank of Lithuania) For a deeper view of how the terms relate, see our explainer on VASP vs CASP under MiCA.

What happens to unlicensed crypto activity after 31 December 2025

After the transitional period closed, providers that did not obtain a MiCA licence lost the right to operate. Accepting new clients, holding crypto in custody, and carrying out other crypto-asset services without a MiCA authorisation are treated as illegal financial activity in Lithuania. (Bank of Lithuania)

That is the risk framing every founder should internalise. There is no soft grace zone for new market entrants. You either hold a CASP authorisation (or operate under a valid passport from another EU/EEA authorisation) or you are not permitted to serve Lithuanian or EU clients with crypto-asset services. This is consistent with the wider EU pattern, and it mirrors the closure of national regimes elsewhere, as covered in our note on Estonia's VASP-to-CASP transition.

Who issues crypto licences in Lithuania now?

Crypto licences in Lithuania are now issued by the Bank of Lithuania (Lietuvos bankas), which authorises and supervises CASPs under MiCAR. It cooperates with the FCIS on supervision, but the old FCIS notification route is superseded. The Bank of Lithuania has already granted MiCA CASP authorisations, confirming the regime is live. (Bank of Lithuania)

The Bank of Lithuania (Lietuvos bankas) as competent authority

The Bank of Lithuania is the competent authority for CASP authorisation in Lithuania. It receives applications, runs the completeness and substantive assessments under MiCAR, grants or refuses authorisation, and then supervises licensed CASPs on an ongoing basis. (Bank of Lithuania) In short, it is the single regulatory counterparty that matters for a Lithuanian crypto licence today. It is the same institution that supervises banks, payment institutions, and other financial firms, which signals the level of scrutiny applicants should expect.

The legacy role of FCIS under the old regime

Under the old national regime, the Financial Crime Investigation Service (FCIS) was the body crypto operators dealt with through a notification process. That role is now historical for licensing purposes. The FCIS remains a cooperation partner of the Bank of Lithuania on supervision, but it no longer registers crypto-asset service providers, and there is no FCIS-only route to legally operate. (Bank of Lithuania)

Proof the licence is live: first Lithuanian CASP authorisations

This is not theory. The Bank of Lithuania has begun issuing CASP authorisations, including one granted to Micar assets, UAB, recorded in its news index. (Bank of Lithuania) For founders, the existence of granted authorisations matters: it confirms the regulator has a working process, that real applications are being assessed and approved, and that a well-prepared file can clear the statutory review.

VASP vs CASP in Lithuania: what actually changed

The most useful thing you can do before applying is update your mental model from "VASP" to "CASP." The table below sets the legacy national-regime picture against the current MiCA reality, so the outdated figures still floating around online stop misleading your planning. (EUR-Lex)

Old VASP regime vs new CASP regime (side-by-side)

The pattern is consistent: more capital where you do more, more substance, a longer and more rigorous review, and a wider operating footprint once you are authorised. For the full conceptual breakdown, our VASP licensing explained pillar walks through how these license classes fit together worldwide.

Minimum capital for a CASP in Lithuania

Minimum capital for a Lithuanian CASP is class-dependent under MiCAR Annex IV: EUR 50,000 for Class 1, EUR 125,000 for Class 2, and EUR 150,000 for Class 3. On top of that, Article 67 requires prudential safeguards equal to the higher of the Annex IV minimum or one quarter of the preceding year's fixed overheads. (MiCAR Annex IV)

The three capital classes (EUR 50,000 / 125,000 / 150,000)

MiCAR assigns each crypto-asset service to a capital class, and your minimum capital follows the most demanding service you intend to offer. (MiCAR Annex IV)

• Class 1, EUR 50,000: reception and transmission of orders, execution of orders, placing, transfer services, advice, and portfolio management.
• Class 2, EUR 125,000: all Class 1 services plus custody and administration of crypto-assets, exchange of crypto for funds, and exchange of crypto for other crypto-assets.
• Class 3, EUR 150,000: all Class 2 services plus operation of a trading platform for crypto-assets.

So an advice-only firm sits at Class 1, a custody or exchange business at Class 2, and a trading-platform operator at Class 3. (MiCAR Annex IV)

The Article 67 prudential floor (one quarter of fixed overheads)

The Annex IV figure is a floor, not a ceiling. Under Article 67, a CASP must at all times hold prudential safeguards equal to the higher of (a) the relevant Annex IV minimum or (b) one quarter of the fixed overheads of the preceding year, reviewed annually. Those safeguards can take the form of own funds (Common Equity Tier 1 items) and/or an insurance policy covering EU territories. (MiCAR Art. 67)

In practice, this means a larger operation with higher running costs may need to hold more than the headline class figure. Budget for the Article 67 calculation from the start, not as an afterthought. Our sibling guide on VASP capital and AML requirements breaks down how these own-funds rules apply across activities.

Why the old "flat EUR 125,000" figure is now misleading

The widely repeated "EUR 125,000 share capital for a Lithuanian crypto licence" figure maps only to Class 2 under MiCA. It is no longer a universal number. An advice-only business needs less (EUR 50,000), while a trading-platform operator needs more (EUR 150,000), and any business must also satisfy the Article 67 fixed-overheads floor. (MiCAR Annex IV) Planning your capital around a single flat figure risks both under-capitalising and choosing the wrong service scope.

Substance and governance requirements

CASP substance under MiCA is materially heavier than the old national regime. The binding test is an EU place of effective management and at least one EU-resident director under Article 59(2), supported by a fit-and-proper management body assessed under Article 68 and the EBA/ESMA suitability guidelines. (EUR-Lex)

EU place of effective management and an EU-resident director

MiCAR Article 59(2) requires a CASP to have its place of effective management in the EU and at least one of its directors resident in the EU. The head office must be in the EU and, for a Lithuanian licence, in Lithuania as the home Member State. (EUR-Lex)

Note the nuance founders often miss: the resident director must be EU-resident, not necessarily Lithuania-resident. That gives you some flexibility on where your director is based within the EU, but it firmly closes the old "registered address only, no real presence" model. The regulator expects genuine decision-making in the EU.

Fit-and-proper management body (EBA/ESMA suitability guidelines)

Under Article 68, the members of the management body must have appropriate knowledge, skills, and experience, both individually and collectively, to manage a crypto-asset business. The Bank of Lithuania assesses suitability under the Joint EBA/ESMA Guidelines on the suitability of management body members and qualifying shareholders of entities under MiCAR. (EBA/ESMA Joint Guidelines)

Practically, this means assembling a board and senior team with demonstrable financial-services and crypto experience, clean reputation records, and the time to dedicate to the role. Qualifying shareholders are assessed too. (EBA/ESMA Joint Guidelines PDF.pdf)) Expect to provide detailed fit-and-proper questionnaires and supporting documents for each relevant individual.

Setting up the Lithuanian company (UAB)

The standard corporate vehicle in Lithuania is the UAB (uždaroji akcinė bendrovė), a private limited company. Incorporating the UAB, opening the necessary accounts, and depositing the required capital are pre-application steps that sit on the critical path. (EUR-Lex) The company structure, its effective management arrangements, and its capital must all align with the MiCA substance and capital tests before you file, because the regulator assesses the firm as it will actually operate, not as a paper shell.

AML, KYC and Travel Rule obligations

CASPs in Lithuania are EU AML obliged entities from day one. That means a documented AML/CTF policy, an appointed AML/compliance officer (MLRO), KYC onboarding, sanctions screening, and Travel Rule controls for crypto-asset transfers. These are core conditions of the authorisation, not optional add-ons. (A&O Shearman)

CASPs as EU AML obliged entities

As obliged entities, CASPs must build and run a full AML/CTF programme: customer due diligence and KYC, ongoing monitoring, sanctions and PEP screening, suspicious-activity reporting, and Travel Rule implementation for transfers of crypto-assets. (A&O Shearman) The regulator expects these controls to be operational at authorisation, evidenced by written policies, procedures, and system configurations, rather than promised for later. For the full framework, see our crypto AML and KYC compliance guide.

The AML/compliance officer (MLRO) and the residency question

A CASP must appoint a compliance/AML officer (MLRO) responsible for the AML programme. Under the old national regime, Lithuania imposed a "permanent-resident Lithuania AML officer, one officer per company" expectation. Under MiCA, the binding substance test is the EU place of effective management plus an EU-resident director under Article 59(2). (EUR-Lex)

Whether the Bank of Lithuania still expects a Lithuania-resident AML officer as a national add-on is a point we verify case by case before advising, because national gold-plating beyond MiCAR is possible and the lb.lt pages need direct confirmation (see Open questions). We do not assert a fixed LT AML-officer residency rule until it is confirmed on the regulator's own pages.

The CASP authorisation process and timeline

The CASP authorisation timeline in Lithuania has two statutory windows under MiCAR Article 63: a completeness check within 25 working days of receipt, then a substantive decision within 40 working days of a complete application. Add pre-application preparation, and the realistic end-to-end is well beyond a couple of months. (Bank of Lithuania)

Pre-application preparation (entity, capital, packs)

Before the statutory clock even starts, you incorporate the UAB, deposit and evidence the required capital, build the AML and governance framework, and assemble the fit-and-proper packs for directors, key function holders, and qualifying shareholders. (EUR-Lex) This preparation phase is where most of the calendar time goes, and the quality of the file directly affects whether the regulator's later completeness check passes on the first attempt.

Completeness check: 25 working days

Step one under Article 63 is the completeness check. Within 25 working days of receiving your application, the Bank of Lithuania checks whether the Article 62(2) information set is complete. If the application is incomplete, the authority sets a deadline for the missing information and may refuse to review applications that remain incomplete. (Bank of Lithuania) A complete, well-organised file is therefore the single biggest lever on your timeline.

Substantive decision: 40 working days

Step two is the substantive assessment. Within 40 working days from receipt of a complete application, the authority assesses compliance with MiCAR Title V and adopts a fully reasoned decision granting or refusing the authorisation. (EUR-Lex) Importantly, the clock can pause or extend while the regulator requests further information, so wall-clock time often exceeds the 40 working days on paper.

Why "6-8 weeks end-to-end" no longer applies

The "6 to 8 weeks" timeline associated with the old national regime is no longer credible under MiCA. The statutory review alone runs up to roughly 65 working days (25 plus 40), and that is before pre-application preparation. (Bank of Lithuania) We deliberately avoid promising a fixed week count: a clean, complete file moves faster, while gaps trigger information requests that pause the clock. Plan in months, not weeks.

From our practice

In our advisory work on EU crypto authorisations, the projects that clear the completeness check on the first pass share one trait: the application file is built to MiCAR's information set before filing, with capital evidenced, the management body's suitability documented, and the AML programme operational rather than aspirational. When founders treat MiCA as a substantive authorisation, not a notification, the substantive review tends to proceed without avoidable information requests. We deliberately do not quote a fixed timeline or success-rate figure here, because outcomes depend on file quality and the regulator's information requests in each case.

Does a Lithuanian CASP licence let you operate across the EU?

Yes. A MiCA CASP authorisation is designed to support passporting across the EU and EEA, so a single Lithuanian authorisation can underpin cross-border crypto-asset services in other Member States, subject to the passporting notification procedure. This single-licence reach is one of the main advantages of MiCA over the old patchwork of national regimes. (Bank of Lithuania)

EU/EEA passporting under MiCA

Under MiCA, one authorisation supports the provision of crypto-asset services across the EU/EEA without needing a separate licence in each country. (Bank of Lithuania) We frame this as "supports passporting subject to notification" rather than "automatic," because the passporting notification mechanics need to be followed and confirmed for your specific services. For the EU-wide picture, see our CASP authorisation under MiCA page and the broader MiCA regulation guide.

How much does a Lithuanian CASP licence cost?

There is no single published price for a Lithuanian CASP licence, and we do not invent one. Cost is driven by your capital class, the substance you build, and your ongoing compliance burden. Official application and supervisory fee figures were not found in primary sources during our research, so we scope cost per project rather than quoting a flat number. (MiCAR Annex IV)

Cost drivers (capital class, substance, ongoing compliance)

The main qualitative cost drivers are: the minimum capital tied to your service class (EUR 50,000, EUR 125,000, or EUR 150,000) plus the Article 67 fixed-overheads floor; the substance you set up (EU effective management, an EU-resident director, qualified key staff); and ongoing compliance (AML systems, audits, reporting). (MiCAR Art. 67) Because the Bank of Lithuania's exact application and supervisory fees are not published in the primary sources we reviewed, those figures must be confirmed before any budget is finalised. For a structured view of the recurring items, see our overview of VASP licensing costs and fees.

How we help with Lithuanian CASP authorisation

Crypto Valley Partners AG, based in Zug, Switzerland's Crypto Valley, advises founders and operators on obtaining and maintaining crypto-asset licences across the EU and beyond. For Lithuania, that means mapping your business to the right CASP class, building a MiCAR-grade application file, structuring EU substance and governance, and preparing the AML framework the Bank of Lithuania expects to see operational at authorisation.

Because MiCA is a substantive authorisation and not a notification, the quality of your file is the difference between a clean review and a chain of information requests. We work alongside your team to get the capital, management-body suitability, and compliance evidence right before you file, then support you through the completeness check and substantive assessment. The jurisdiction-specific detail also lives in our Lithuania crypto licensing guide, which sits alongside this VASP-to-CASP explainer.

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By Magnus Müller · Reviewed by Magnus Müller · Last updated: 2026-06-14