Lithuania finalised its MiCA CASP transition rules in March 2026. Existing crypto-asset service providers have until July 2026 to file. Miss the window — fall back to a fresh authorisation, plus six extra months.
Jurisdiction
Lithuania
Timeline
4-6 months
From
€18,000
A MiCA CASP license is the EU-wide authorisation that lets a firm offer crypto-asset services — custody, exchange, transfer, advice — across all 27 member states under a single regulator.
Issued by Bank of Lithuania (LB)
under Regulation (EU) 2023/1114 (MiCA), in force since 30 December 2024. License types: CASP — full authorisation, CASP — simplified (existing VASP transition). Built for mature crypto teams, projects needing end-to-end support.
Quick Facts
Parameter
Value
Regulator
Bank of Lithuania (LB)
Legal basis
MiCA Regulation (EU) 2023/1114
Minimum capital
€50,000 — €150,000 depending on services
Authorisation timeline
4-6 months from complete application
Application fee
€2,500 base + service-specific add-ons
Local substance
≥1 director resident in Lithuania, registered office in-country
AML/CFT
Full Lithuanian AML law compliance, MLRO required
Who needs a MiCA CASP license in Lithuania?
Any firm offering crypto-asset services to EU clients from Lithuania needs a CASP authorisation under MiCA.
That covers exchanges, custodians, brokers, advisers, portfolio managers, and transfer-service providers. Existing
Lithuanian VASPs registered before 30 December 2024 fall under a transitional regime — they can keep operating until
1 July 2026, but only if they file a CASP application before that date. After July 2026, no transition. New entrants
apply directly under the full CASP regime.
It's not the same as the old VASP register. CASP brings prudential capital, governance, conflict-of-interest, and
ongoing supervision rules that didn't exist in the 2020-2024 framework.
How long does CASP authorisation take in Lithuania?
4 to 6 months from filing a complete application, assuming no major deficiencies in the dossier.
The Bank of Lithuania has a statutory 40-working-day initial review, plus extensions when it issues information
requests. In practice, the clock pauses every time the regulator asks for clarification — and they will. Teams that
pre-clear governance, AML, and IT-resilience documents with counsel before filing typically clear the process in
around four months. Teams that file raw and respond reactively often take seven to nine.
What capital is required for a CASP in Lithuania?
Initial capital ranges from €50,000 to €150,000 depending on the services authorised.
MiCA sets three capital tiers. Class 1 covers reception, transmission, and advice (€50,000). Class 2 adds exchange,
execution, and placement (€125,000). Class 3 covers custody, operation of a trading platform, and crypto-asset
transfer for clients (€150,000). On top of capital, firms must hold professional indemnity insurance or extra own
funds proportional to assets under custody.
Can a non-EU founder hold a Lithuanian CASP license?
Yes — but the CASP entity itself must be Lithuanian, with at least one resident director and a real local presence.
Foreign ownership is permitted without restriction. What's not permitted is a letter-box. The regulator expects the
local director to actually direct the business — not act as a nominee. Outsourcing AML or compliance offshore is
allowed for routine functions, but the MLRO and key management decisions must sit in Lithuania. Recent supervisory
decisions have made this point bluntly: the Bank of Lithuania has refused authorisations where the resident director
could not explain core business decisions in interview.
What changes in 2026
The transition rules published in March 2026 finalised one open question — the exact documentation existing VASPs need
to file alongside their CASP application. Two items are new compared to the December 2024 draft: a written ICT
resilience plan aligned with DORA, and a board-approved conflict-of-interest matrix. Both are short documents, but both
have to be in the file at submission. Filing without them means a deficiency notice — and the clock pauses.
What we do
End-to-end CASP filing: dossier prep, regulator pre-clearance, board governance setup, MLRO sourcing if needed,
post-grant supervisory liaison. We don’t sub-contract any of it offshore.
Frequently asked questions
Does my existing Lithuanian VASP automatically convert to a CASP?
No. Existing VASPs must file a separate CASP application before 1 July 2026.
The transitional regime lets you keep operating during review, but the application itself is full-scope. Plan for the same documentary work as a new entrant — the only saving is supervisory continuity, not paperwork.
Is Lithuania faster than Estonia or Malta for CASP?
Yes — Lithuania currently averages 4-6 months; Estonia and Malta are running 6-9 and 9-12 respectively.
The gap is closing as workloads even out across regulators. By late 2026 the difference may shrink. For now, Lithuania remains the fastest mid-tier EU jurisdiction with full passporting rights.
Can I passport a Lithuanian CASP across the EU?
Yes. A CASP authorisation under MiCA grants single-market passporting to all 27 EU member states.
You file a notification with the home regulator (Bank of Lithuania) for each host state where you intend to operate. The host regulator cannot block notification on substantive grounds — only on procedural or AML deficiencies.