Regulations for Crypto license in Lithuania

Lithuania offers a robust regulatory environment for cryptocurrency businesses, aligned with the Markets in Crypto-Assets (MiCA) regulation, ensuring transparency, security, and compliance with international standards. The primary regulatory authority for crypto-asset service providers (CASPs) is now the Bank of Lithuania, following the implementation of MiCA, effective from June 29, 2024.
Previously known as Virtual Asset Service Providers (VASPs), companies must now transition to CASP licenses under the MiCA framework. This license covers various crypto-asset activities, including exchange services, custodial wallet services, and crypto-asset advisory services.
To obtain a CASP license in Lithuania, establishing a private limited liability company (UAB) is mandatory. Under MiCA, minimum capital requirements have been updated and vary between €50,000 and €150,000, based on the services provided. A detailed business plan, robust AML/CFT policies, secure IT systems, and qualified management are also essential criteria.
The updated legislation requires crypto businesses to appoint local management personnel, including a Senior Manager (director) and an AML Compliance Officer.
Below is a detailed overview of the regulations and requirements under MiCA for obtaining and maintaining a crypto license in Lithuania in 2025:

1. Legal and Regulatory Framework under MiCA

Legal and Regulatory Framework

Law on Prevention of Money Laundering and Terrorist Financing

This law is fundamental in ensuring that cryptocurrency businesses operate within the legal boundaries set to prevent illicit activities. Key provisions include:

  • KYC Requirements: Implementing robust Know Your Customer (KYC) processes to verify the identity of customers. This includes collecting and verifying personal identification information and maintaining accurate records.
  • AML Policies: Developing and implementing Anti-Money Laundering (AML) policies to detect and prevent money laundering and terrorist financing. This involves continuous monitoring of transactions and reporting suspicious activities to the FCIS.
  • Risk Assessment: Conducting regular risk assessments to identify and mitigate potential risks associated with money laundering and terrorist financing.

Law on Electronic Money and Electronic Money Institutions

Although primarily targeting electronic money institutions, this law is relevant for cryptocurrency service providers, particularly those offering payment services.

  • Licensing Requirements: Cryptocurrency businesses in Lithuania must obtain the necessary licenses if they engage in activities similar to those of electronic money institutions.
  • Capital Requirements: Businesses seeking for crypto license in Lithuania must demonstrate sufficient capital to ensure financial stability and support their operations.
  • Operational Standards: Ensuring compliance with operational standards, including safeguarding customer funds and maintaining the integrity of payment systems.

Guidelines by the Bank of Lithuania

The Bank of Lithuania provides additional guidance on regulatory compliance. These include:

  • Compliance Framework: Establishing a comprehensive compliance framework encompassing AML, KYC, and risk management procedures.
  • Enhanced Due Diligence (EDD): Conducting enhanced due diligence for high-risk customers, including politically exposed persons (PEPs) and individuals from high-risk jurisdictions.
  • Transaction Monitoring: Implementing effective transaction monitoring systems to detect and report suspicious activities.
2. Licensing Process with the Bank of Lithuania

Licensing Process

To operate a cryptocurrency business in Lithuania, entities must follow a structured licensing process:

Company Registration

Register a legal entity in Lithuania through the Lithuanian Centre of Registers. The company must have a local office and at least one director residing in Lithuania.

Preparation of Documentation

  • AML/KYC Policies: Develop comprehensive AML and KYC policies and procedures.
  • Organizational Structure: Provide information on the company’s organizational structure, including the roles and responsibilities of key personnel.
  • Shareholders and Beneficial Owners: Submit details of shareholders and ultimate beneficial owners.

Application Submission

Submit the complete application package to the FCIS for review. This includes all required documentation and compliance policies. FCIS then conducts background checks on the company’s directors, shareholders, and beneficial owners to assess their suitability and integrity.

Approval and Issuance

The FCIS reviews the application and, if all requirements are met, issues the crypto license. The review process typically takes a few months, depending on the complexity of the application and the responsiveness of the applicant.

3. Ongoing Compliance and Reporting Obligations

Ongoing Compliance and Reporting

Licensed crypto businesses in Lithuania are required to maintain continuous compliance with regulatory standards:

Regular Reporting

  • Periodic Reports: Submit periodic reports to the FCIS detailing business operations, transaction volumes, and compliance activities.
  • Audit Requirements: Conduct annual audits to ensure ongoing compliance with regulatory standards.

AML/CTF Program Updates

  • Continuous Improvement: Regularly update and improve AML/CTF programs to address new risks and changes in the regulatory environment.
  • Employee Training: Provide ongoing training for employees to ensure they are aware of AML/CTF policies and can effectively identify and report suspicious activities.

Data Protection

Ensure compliance with the General Data Protection Regulation (GDPR) to protect personal data and privacy of customers.

4. Regulatory Supervision and Enforcement by the Bank of Lithuania

Regulatory Supervision and Enforcement

The FCIS actively supervises licensed crypto businesses in Lithuania to ensure compliance with all regulatory requirements. Non-compliance can result in enforcement actions, including fines, license suspension, or revocation.

Types of crypto licensing in Lithuania under MiCa in Lithuania (2025)

Under the European Union’s Markets in Crypto-Assets (MiCA) regulation, effective from June 29, 2024, Lithuania offers clear licensing categories for Crypto-Asset Service Providers (CASPs). The previously separate licenses for cryptocurrency exchanges and custodial services have been unified under a single comprehensive CASP license. CASPs must obtain authorization from the Bank of Lithuania, which serves as the national regulatory authority under MiCA.
CASP License for Crypto-Asset Services: This unified CASP license covers various crypto-asset services including exchange, custody, and advisory operations.
Previously operated VASP licenses:

License typeDescription of license
Virtual Currency Exchange Operator LicenseThis authorisation or license is for legal entities established in the Republic of Lithuania that offer services related to the exchange of virtual/crypto currencies, including the buying and/or selling of such currencies for a fee. 
Custodial Wallet Service Provider LicenseThis type of crypto license in Lithuania is granted to legal entities that provide custodial services for virtual/crypto currency wallets on behalf of their clients, managing these wallets under custodianship.

Overview of requirements to obtain crypto license in Lithuania

  • Company Registration: Must be legally registered as a private limited liability company (UAB) in Lithuania.
  • Capital Requirements: Minimum capital requirement ranges between €50,000 and €150,000, depending on the type and scope of crypto-asset services provided.
  • AML/KYC Compliance: Comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) policies must be implemented according to MiCA standards.
  • Business Plan: Submission of a detailed and viable business plan outlining operational strategies and compliance measures.
  • IT and Security Measures: Robust cybersecurity protocols and secure IT infrastructure to safeguard client assets and sensitive data.
  • Management Competence: Directors and key personnel must demonstrate appropriate qualifications, experience, and integrity.

The Bank of Lithuania supervises the compliance, reporting obligations, and ongoing enforcement of the CASP license requirements, ensuring adherence to MiCA regulations.

Estimated time frames

Company Incorporation

1-2 weeks

Preparation of Required Documentation

3–5 weeks

Establishing Minimum Capital Requirements

1–2 weeks

Appointment and Vetting of Qualified Management and AML Officer

1–2 weeks

Setting up Secure IT and Cybersecurity Infrastructure

2–4 weeks

Submission of CASP License Application to the Bank of Lithuania

2–4 months*

Regulatory Dialogue and Possible Additional Documentation Requests

2–4 weeks

* The timeline also depends on the workload of Bank of Lithuania and any clarifications and queries that BoL may request in relation to the application

Legal services for obtaining Crypto license in Lithuania

Basic Package

16000EUR initial set up

  • UAB company registration
  • Legal address provision for 1 year
  • Corporate documents drafting
  • Standard AML/KYC/CFT Policy (MiCA-aligned)
  • CASP license application submission to the Bank of Lithuania
  • Regulatory communication and representation
  • Guidance on document collection and preparation
  • Legal support throughout the licensing process

This package ensures your business meets the minimum regulatory requirements for CASP licensing under MiCA in Lithuania.

Advanced Compliance Package

  • Development of full internal policy set (AML, risk, cybersecurity, client safeguarding)
  • Custom business plan preparation in line with MiCA scope
  • Regulatory strategy and legal advisory on MiCA compliance
  • Fit and Proper documentation for AML Officer and Director
  • Structuring and alignment of application to meet Bank of Lithuania requirements
  • Legal opinion from a certified Lithuanian lawyer
  • Assistance in increasing share capital
  • Preparation for potential regulator meetings

This package is designed for companies seeking a complete and structured CASP licensing strategy, including documentation, compliance, and regulatory readiness.

Ready-Made VASP Solution

on request

  • Registered Lithuanian company
  • Legal address provided for 1 year
  • No debts or liabilities
  • Fully paid-up registered share capital: €125,000
  • Active VASP license
  • Complete corporate documentation
  • Full assistance with company transfer and onboarding

Eriks Fijalovs

Head of Crypto

Detailed Requirements for Crypto Licensing in Lithuania under MiCA Regulations (2025)

List of Required Documents

  • Power of Attorney (PoA):
    • A notarized and, if issued abroad, legalized document authorizing Legalaes to incorporate the company and submit the CASP application on the client’s behalf.
  • AML/KYC/CFT Policy:
    • Comprehensive internal policy covering customer due diligence, transaction monitoring, and suspicious activity reporting. Must align with MiCA and Lithuanian AML law and be approved by the Bank of Lithuania.
  • CASP Application Form:
    • Detailed application outlining the business model, service types (e.g., exchange, custody, advisory), operational structure, and compliance framework.
  • Memorandum and Articles of Association (MAA):
    • Founding corporate documents specifying shareholding structure, business objectives, and governance mechanisms. These are required for both company registration and license application.

Share Capital and Government Fees

  • Minimum Share Capital: Under MiCA, the required capital ranges between €50,000 and €150,000, depending on the type of crypto services provided.
  • Government Fees:
    • Company registration (UAB): ~€30.83
    • CASP license application: Fees to be confirmed under MiCA framework
  • Capital Deployment: Full capital does not need to be deposited upfront — MiCA allows gradual funding subject to capital adequacy and financial monitoring rules.

Personnel Requirements

  • AML Compliance Officer: Must be a certified AML specialist with proven experience in Anti-Money Laundering and Counter-Terrorist Financing. The officer must be a resident of Lithuania.
  • Director / Senior Management: At least one company director is required with relevant experience in finance, compliance, or crypto-asset operations. The director must be based in Lithuania to ensure effective regulatory oversight and local governance.
  • Internal Auditor: A Lithuania-based auditor is required to supervise internal control systems and ensure compliance with MiCA reporting obligations. Background in financial or legal audit is expected.
  • IT Specialist: Responsible for system integrity, cybersecurity, and platform operations. The IT specialist must also be resident in Lithuania, with experience in infrastructure management and MiCA-aligned data security protocols.

Business Premises Requirements

  • Local Presence: A verifiable business address in Lithuania is required. This can be:
    • A physical office
    • A coworking space (with appropriate documentation)
  • Compliance Oversight: The business location must allow for regulatory access and supervision by the Bank of Lithuania.

By meeting these requirements, crypto businesses can successfully obtain a crypto license in Lithuania, positioning themselves in a well-regulated and supportive environment for cryptocurrency operations.

Roadmap of obtaining crypto exchange license in Lithuania

To operate a crypto-asset business in Lithuania under the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114), companies must apply for a CASP license through the Bank of Lithuania. The licensing framework allows both Lithuanian and foreign-owned companies to access the market under equal regulatory conditions. Lithuania remains a leading EU jurisdiction for crypto businesses due to its established infrastructure and regulator experience.

Eriks Fijalovs

Head of Crypto

1

Document Collection

The process begins with collecting required documents, including shareholder identification, proof of address, and a clear description of the business model. Company name verification is completed through the Centre of Registers (Registrų centras), and a notarized Power of Attorney is prepared if remote incorporation is planned.

2

Company Registration and Share Capital Deposit

A private limited liability company (UAB) is established either remotely or in person. This includes opening a corporate bank account and depositing the required share capital, which ranges from €50,000 to €150,000 depending on the planned services. The company is officially registered with crypto-asset services listed as its core business activity.

3

Internal Policies and Local Staffing

Internal compliance policies are developed in line with MiCA and Lithuanian AML laws. This includes AML/KYC/CFT procedures, client onboarding protocols, and risk management systems. Local personnel are appointed—including a director, AML officer, internal auditor, and IT specialist—all of whom must be residents of Lithuania. A verifiable local business address is secured, either as a physical office or a compliant virtual space. The company and staff are then registered with the tax authority and SoDra.

4

CASP License Application Submission

Once the company is structured and compliant, the CASP license application is submitted to the Bank of Lithuania. The application includes all corporate documents, internal policies, business plan, and proof of local governance. We maintain direct communication with the regulator throughout the review process and provide clarifications as needed.

5

Corporate Bank Account Setup

While not mandatory for the license application, we assist in selecting and opening a crypto-friendly corporate bank or EMI account. This includes preparing required documentation and supporting the onboarding process with the chosen financial institution.

6

Post-License Support and Compliance Maintenance

After license approval, we help implement MiCA-compliant operations and maintain communication with the regulator. Ongoing services include regulatory reporting, internal audits, policy updates, and strategic compliance advisory as your business grows within the EU crypto market.

Detailed Time Frames to Obtain a CASP License in Lithuania under MiCA Regulations (2025)

Obtaining a Crypto-Asset Service Provider (CASP) license in Lithuania involves a structured process guided by the Markets in Crypto-Assets (MiCA) regulation. Below is an estimated timeline for each stage of the licensing process:

1.  Company Registration (UAB Formation)

Time Frame: 1-2 Weeks

2.  Preparation of Documentation

Time Frame: 3-5 Weeks

3. Submission to the Bank of Lithuania

Time Frame: Immediate upon completion of documentation

4.  Regulatory Review and Background Checks by the Bank of Lithuania

Time Frame: 2-4 Months

5.  Approval and Issuance of CASP License

Time Frame: 1-2 Weeks

Total Estimated Time Frame

The total time required to obtain a CASP license under MiCA in Lithuania typically ranges between 4 to 6 months. This period can vary depending on application completeness, business complexity, regulatory queries, and responsiveness.

Factors Influencing the Time Frame

Partnering with a professional legal consulting service such as Legalaes ensures efficient and compliant preparation, facilitating a smoother and quicker licensing process. Legalaes provides comprehensive assistance throughout the CASP licensing procedure, offering a turnkey solution within Lithuania’s structured and supportive regulatory environment.

Advantages of the CASP license in Lithuania

Obtaining a Crypto-Asset Service Provider (CASP) license in Lithuania provides numerous strategic advantages, making it a highly attractive jurisdiction for crypto businesses. Here are the key benefits:

Links for legislation related to Crypto business in Lithuania

Serves as Lithuania’s premier agency tasked with investigating economic and financial crimes, including fraud, money laundering, and corruption, to uphold the integrity of the financial system and enforce compliance with financial regulations.

Establishes mandatory compliance standards for preventing money laundering and terrorism financing in Lithuania, including customer due diligence, risk assessment, and reporting suspicious activities by CASPs.

Outlines the obligations for Virtual Asset Service Providers to submit detailed operational and transactional reports, enhancing transparency and helping combat financial crimes.

Governs company formation, operations, governance, and dissolution in Lithuania, ensuring transparency, accountability, and robust corporate governance.

Regulates licensing, operational guidelines, and prudential standards for financial entities, ensuring sector stability and robust consumer protection.

Adapts Lithuania’s financial market regulations to EU standards, emphasizing transparency, investor protection, fairness, and market efficiency under the MiCA framework.

VII. Markets in Crypto-assets (MiCA) Regulation

is the official EU legal reference for the Markets in Crypto-assets (MiCA) Regulation (Regulation (EU) 2023/1114). This document is the authoritative legal source for MiCA regulations applicable to all EU member states, including Lithuania.

Lithuania crypto license regulatory body

Financial Crime Investigation Service under The Ministry of the Interior of the Republic of Lithuania

Taxation of Cryptocurrency Companies in Lithuania in 2024

Lithuania provides a competitive tax environment for cryptocurrency companies, aligning with broader EU standards while addressing specific requirements for the crypto sector. Below is a detailed overview of the 2025 taxation framework for cryptocurrency businesses operating in Lithuania:

1. Corporate Income Tax

1. Corporate Income Tax

Standard Corporate Tax Rate

The standard corporate income tax rate in Lithuania is 15%. This rate applies universally, including to cryptocurrency businesses.

Reduced Tax Rate

Small cryptocurrency firms with fewer than ten employees and annual gross revenues below EUR 300,000 may qualify for a reduced corporate tax rate of 0-5%.

Taxable Income

Taxable income includes profits from all crypto-related business activities, such as cryptocurrency trading, exchange operations, custodial services, and advisory services. Operational costs, employee salaries, and certain capital expenditures are deductible from taxable income.

2. Value-Added Tax (VAT)

2. Value-Added Tax (VAT)

VAT Exemptions

In line with the Court of Justice of the European Union (CJEU) ruling in the Hedqvist case, cryptocurrency transactions involving exchanges between fiat currencies and cryptocurrencies are exempt from VAT.
Virtual currency exchanges and wallet services are classified as financial services and are thus VAT-exempt.

Standard VAT Rate

Lithuania’s standard VAT rate is 21%, applicable to the sale of goods and services, including those priced and sold using cryptocurrencies.

3. Personal Income Tax

3. Personal Income Tax

Income from Cryptocurrency

Individual income derived from cryptocurrency activities (e.g., trading, mining) is subject to personal income tax.
The progressive personal income tax rate is 20% for annual income up to EUR 120,000 and 32% on income exceeding this threshold.

Capital Gains Tax

Capital gains from cryptocurrency transactions are treated as personal income and taxed accordingly. Losses from cryptocurrency activities can offset gains within the same tax year.

4. Social Security Contributions

4. Social Security Contributions

Employee Contributions

Employees in cryptocurrency companies are subject to social security contributions, with the employee contribution rate at 19.5%.
Employers contribute approximately 1.77% to 3.03%, depending on the nature of work and other relevant factors.

5. Tax Incentives and Deductions

5. Tax Incentives and Deductions

Research and Development (R&D) Incentives

Crypto businesses engaging in R&D can deduct up to three times their eligible R&D expenses from taxable income. Additional tax relief may be provided for innovation and technological advancement.

Startup Incentives

Crypto startups may access incentives including reduced corporate tax rates, grants, and subsidies, provided they fulfill specific conditions.

6. Reporting and Compliance

6. Reporting and Compliance

Annual Tax Returns

Crypto businesses must submit annual corporate tax returns to the Lithuanian State Tax Inspectorate (STI) by the 15th day of the sixth month following the fiscal year-end. Comprehensive transaction records must be maintained and readily available for tax audits.

VAT Returns

Businesses registered for VAT must submit monthly or quarterly returns based on turnover, detailing taxable and exempt transactions.

7. International Considerations

7. International Considerations

Double Taxation Treaties

Lithuania maintains double taxation agreements with numerous countries to mitigate double taxation on international income, benefiting cryptocurrency businesses with cross-border operations.

Transfer Pricing

Cryptocurrency companies involved in transactions with related parties must adhere to Lithuanian transfer pricing regulations, ensuring arm’s-length pricing and appropriate documentation for regulatory compliance.

FAQ about CASP license in Lithuania

1. How can I obtain a CASP license in Lithuania?

Our legal experts provide comprehensive guidance throughout the entire licensing process, which includes establishing a UAB company, depositing required share capital, drafting AML/KYC/CFT policies, appointing a local AML compliance officer and director, and submitting the complete application to the Bank of Lithuania.

2. How long does it take to obtain a CASP license in Lithuania?

Typically, obtaining a CASP license takes around 4 to 6 months. The timeline includes company formation, capital deposit, documentation preparation, application submission, and regulatory review by the Bank of Lithuania.

3. What is the required share capital for a CASP license in Lithuania under MiCA regulations?

Under MiCA regulations, minimum share capital requirements vary based on services provided:
⦁ Basic crypto-asset services: EUR 50,000
⦁ Intermediate crypto-asset services: EUR 125,000
⦁ Comprehensive crypto-asset services: EUR 150,000

4. Is it possible to open a crypto-friendly bank account?

Yes, CASP-licensed companies can open multiple accounts, particularly with European Electronic Money Institutions (EMIs). Our company maintains partnerships with over 15 crypto-friendly EU-based financial institutions, allowing flexible banking options for CASP license holders.

5. What services does the CASP license cover in Lithuania under MiCA regulations?

A CASP license covers:
⦁ Crypto exchange services (crypto-to-fiat and crypto-to-crypto exchanges)
⦁ Custodial wallet services (secure storage and management of crypto assets)
⦁ Crypto-asset advisory and related services
⦁ Token issuance (including ICOs and other token offerings)

6. What are the key regulatory authorities overseeing crypto licenses in Lithuania?

The primary regulatory body is the Bank of Lithuania. The Financial Crime Investigation Service (FCIS) also plays a vital role, enforcing AML/CFT regulations.

7. What documents are required for obtaining a CASP license?

Required documents include:
⦁ Power of Attorney (notarized and legalized, if applicable)
⦁ Comprehensive AML/KYC/CFT policies
⦁ CASP Application Form (submitted to the Bank of Lithuania)
⦁ Memorandum and Articles of Association (company incorporation documents)
⦁ Detailed business plan and organizational structure

8. What ongoing compliance obligations do CASPs have?

Ongoing compliance obligations include:
⦁ Regular reporting to the Bank of Lithuania
⦁ Maintenance of AML/KYC/CFT standards
⦁ Continuous operational monitoring and annual audits
⦁ Regulatory reporting and adherence to MiCA guidelines

9. Is a local physical office required for a CASP license?

Yes, CASPs must have a verifiable local office presence. Cost-effective solutions like virtual offices or coworking spaces can fulfill this requirement.

10. What are the tax implications for crypto companies in Lithuania under MiCA?

Lithuania offers a competitive corporate tax rate of 15%, with potential reductions to 5% for eligible small businesses. Crypto transactions are exempt from specific crypto taxes.

11. What are the personnel requirements under MiCA?

CASPs must appoint the following Lithuanian-resident staff:
– AML Compliance Officer
– Director with relevant experience
– Internal Auditor
– IT Security Specialist
– Risk Manager
A Data Protection Officer (DPO) may also be required depending on the business model.

12, Can foreign nationals or entities apply for a CASP license in Lithuania?

Yes, foreign nationals or entities can apply for a CASP license by appointing local representatives, establishing a Lithuanian entity (UAB), and maintaining a local office presence.

13. How can I ensure a successful application for a CASP license in Lithuania?

Ensure comprehensive documentation, robust compliance frameworks, prompt responses to regulatory queries, and consider professional assistance from legal experts such as Legalaes, experienced in crypto licensing and MiCA regulations.

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