Lithuania has long been one of the most crypto-friendly jurisdictions in the EU, serving as a key entry point for fintech and digital asset businesses. With the Markets in Crypto-Assets (MiCA) framework taking effect, Lithuania is building a more mature and credible market by tightening its oversight and removing low-quality operators.
A MiCA-compliant license from the Bank of Lithuania enables businesses to operate across all 27 member states of the EU. This guide outlines the core rules, licensing steps, and compliance obligations for founders and executives seeking a crypto license in Lithuania.
TL;DR:
- As of April 29, 2025, Lithuania aligned its national rules with MiCA and extended the transition period for existing VASPs to December 31, 2025.
- Lithuania offers easy pathways to incorporation and clear procedures for licensing, giving founders regulatory clarity and remote access to local establishments.
- Obtaining and maintaining a CASP license issued by the Bank of Lithuania requires strong governance, AML/CFT systems, and financial transparency.
How Lithuania Regulates Crypto
Lithuania’s crypto regulation follows a dual model that combines EU-wide standards with strict national enforcement. MiCA is the core legal framework governing digital assets that allows licensed firms to “passport” services across the EU.
The Bank of Lithuania is the main authority overseeing the licensing and supervision of Crypto-Asset Service Providers (CASPs). It reviews applications, monitors compliance, and ensures firms meet MiCA’s prudential and conduct requirements.
Alongside MiCA, Lithuania enforces the Law on the Prevention of Money Laundering and Terrorist Financing, which remains central to the country’s oversight framework. This forms a two-tiered supervisory approach:
- The Bank of Lithuania handles licensing, ensuring that businesses meet prudential standards and maintain MiCA compliance.
- The Financial Crime Investigation Service (FCIS) focuses on effective anti-money laundering and countering the financing of terrorism (AML/CFT) standards, including know-your-customer (KYC) processes, transaction monitoring, and suspicious activity reporting.
Both agencies work closely, meaning every license application is evaluated for regulatory compliance and financial crime controls. Successful applicants must meet the specific requirements set by each government administrator.
How Tokens Are Classified Under MiCA
MiCA assigns legal status to tokens based on their economic purpose, not their underlying technology. This ensures consistent regulation across the EU. Lithuania’s regulatory framework features three main token categories:
- Utility tokens provide digital access to a product or service. No prior authorization is required for issuance, but issuers are legally responsible for publishing a factual whitepaper. A classic example is Filecoin, a token used to pay for decentralized storage services.
- Asset-referenced tokens (ARTs) are stablecoins backed by a basket of assets, such as multiple currencies, commodities, or crypto-assets. Issuers must be EU-based, authorized by the Bank of Lithuania, and comply with strict reserve, governance, and disclosure rules. An example is DAI, a stablecoin backed by multiple crypto assets.
- E-Money tokens (EMTs) are stablecoins pegged to a single fiat currency. These can only be issued by licensed banks or authorized electronic money institutions. A good example is EURT, a Euro-backed stablecoin issued by Tether.
Choosing a Lithuanian Crypto License
Any entity providing crypto-asset services on a professional basis must obtain a CASP license from the Bank of Lithuania. The scope of regulated activities is broad and covers most common crypto business models.
MiCA categorizes these regulated business activities into three classes, adjusting startup capital requirements in line with the level of risk.
Licensing Requirements
The Bank of Lithuania's vetting process is thorough. Applicants must demonstrate high organizational and compliance standards across their entire organization.
- Corporate setup: Every licensed CASP must be a duly registered Lithuanian UAB with a local bank account. As of Jan 1, 2025, the account must be with a Lithuanian bank or a foreign bank with a Lithuanian branch.
- Governance & Personnel: All directors, key executives, and beneficial owners must pass a "fit and proper" test, proving impeccable reputation, relevant experience, and clean criminal records. A permanent Lithuanian resident must be hired as the AML officer to facilitate constant communication with local authorities.
- Compliance framework & Documentation: A comprehensive set of internal policies is required, including AML/CFT, risk management, business continuity, and ICT security.
Applying for a Lithuanian Crypto License
Successfully applying for a CASP license in Lithuania demands careful preparation, but a clear and straightforward structure helps to keep the process transparent.
Pre-Application Phase (2–3 weeks)
- Incorporate a Lithuanian UAB. This can be done entirely online on the Register of Lithuanian Entities.
- Register an address in Lithuania to serve as the primary place of business. Virtual offices are allowed, making it easy for founders to quickly set up their operations.
- Appoint key personnel, making sure to prioritize hiring a qualified, Lithuanian-resident AML officer.
Phase 2: Prepare Documentation (3–5 weeks)
- Compile all required personnel documents, including notarized passports, proofs of address, detailed CVs, and recent criminal record certificates for all directors, beneficial owners, and key executives.
- Draft a comprehensive business plan that includes a detailed description of services, target market analysis, and three-year financial projections.
- Develop the full suite of internal policy documents detailing AML/CFT, risk management, and ICT security processes.
Submission and Review (3-6 months)
- Submit the complete application package electronically to the Bank of Lithuania on the e-Government gateway portal.
- The official timeline for the Bank of Lithuania to assess a CASP application is up to 65 working days after the application is deemed complete. Applications with false or misleading information will be referred to relevant law enforcement bodies, and may delay the final decision-making process. In practice, founders should anticipate that the entire process from submission to a final decision will likely take between 3 to 6 months.
- Prepare for a dialogue with the regulator. Prompt, transparent, and professional responses to any queries are crucial for a smooth review.
Post-Licensing Obligations
Securing a Lithuanian CASP license is only the start. Keeping it means commitment to strict ongoing compliance requirements.
Ongoing Reporting
- File Suspicious Activity Reports (SARs) with the Financial Crime Investigation Service (FCIS) for any unusual transactions.
- Report all crypto transactions of €15,000 or more to the FCIS, even if not suspicious.
- Submit regular financial and operational reports to the Bank of Lithuania.
- Provide audited financial statements each year.
AML/CFT Compliance
- Apply full customer due diligence (CDD) checks for every new client, including KYC.
- Use real-time transaction monitoring to detect suspicious activity.
- Comply with the Travel Rule by sending sender and recipient information for every crypto transfer between CASPs.
- Comply with the Transfer of Funds Regulation (TFR) by confirming ownership of self-hosted wallets for transfer amounts exceeding €1,000.
Governance and Capital
- Maintain the required minimum share capital at all times.
- Keep all customer and transaction records readily available for audits for at least five years.
- Perform regular internal audits and train staff on current regulations.
Benefits of a Lithuanian Crypto License
- EU passporting: One license allows legitimate operations across all 27 EU countries with no need for separate national approvals.
- Regulatory credibility: The Bank of Lithuania has a strong reputation in the European crypto market, and licensed CASPs can benefit from building trust with banks, investors, and clients.
- Favorable business environment: Lithuania offers easy company setup, remote-friendly procedures, a 15% corporate tax rate, and tax incentives that encourage innovative enterprises.
- Competitive talent pool: Lithuania is a leading fintech hub in Europe, providing advanced financial infrastructure, active government support, and a skilled local workforce.
Get the free CASP/VASP Licensing & Compliance Handbook to understand your obligations under MiCA and DORA frameworks.
Conclusion
Lithuania has emerged as one of the most structured and accessible paths for crypto businesses entering the EU market. It aligns with the MiCA framework in a way that combines regulatory certainty with operational flexibility, allowing firms to scale without compromising high governance, AML/CFT enforcement, and technological standards.
For founders and executives, Lithuania offers both opportunity and accountability. Licensing provides legitimate access to EU markets, a trusted status with financial institutions, and strategic advantages for growth. As the market matures, well-prepared firms that meet these standards will be best positioned to capture long-term advantages across Europe.
