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

Business name verification

1-2 days

Company formation

1-2 weeks

Documents preparation

2 weeks

Depositing and registering share capital

1 week

Crypto license obtainment from FCIS

1-2 weeks*

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

Legal services for obtaining Crypto license in Lithuania

Basic Package

16000EUR initial set up

  • UAB Company Registration
  • Provision of Legal Address for 1 year
  • Corporate documents
  • Comprehensive AML/KYC/CFT Policy compliant with MiCA
  • Registration as a licensed Crypto-Asset Service Provider (CASP)
  • Communication and representation with the Bank of Lithuania
  • Assistance with the employment and registration of AML Compliance Officer and Senior Manager
  • Legal Support throughout the entire licensing process

This package fully meets the minimum regulatory requirements for establishing a CASP-licensed company under the MiCA framework.

Additional Services

available upon request

  • Accounting Services
  • Additional Corporate Bank Account
  • Assistance with Share Capital Contribution
  • Bank Account Setup for Client Fund Safeguarding
  • Apostilled Corporate Documents
  • Professional Business Plan Development
  • AML/CFT Training Material
  • Legal Framework for Token Launch (ICO/STO)

Ready-Made solution

available upon request

  • Registered Lithuanian Company
  • Legal Address provided for 1 year
  • Company with No Debts or Liabilities
  • Fully Paid-up Registered Share Capital: EUR 125,000
  • Active CASP License
  • Complete Set of Corporate Documents
  • Assistance with Ownership Transfer

Eriks Fijalovs

Head of Blockchain and Crypto

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

List of Required Documents:

  • Power of Attorney:
    • Purpose: Authorizes a designated entity or individual, such as a legal consulting firm (e.g., Legalaes), to represent and act on behalf of the applicant throughout the company incorporation and CASP license application processes.
    • Requirements: Must be notarized and legalized if executed outside Lithuania.
    • Use Case: Essential for applicants unable to be physically present in Lithuania.
  • AML/KYC/CFT Policy:
    • Components:
      • AML (Anti-Money Laundering): Procedures for identifying, mitigating, and reporting money laundering activities.
      • KYC (Know Your Customer): Verification processes for customer identification, including identity documentation and ongoing transaction monitoring.
      • CFT (Countering Financing of Terrorism): Protocols aimed at detecting and preventing the financing of terrorism.
    • Implementation: Comprehensive customer due diligence (CDD), ongoing transaction monitoring, and timely suspicious activity reporting.
    • Regulatory Requirement: Must comply fully with MiCA standards and be approved by the Bank of Lithuania.
  • CASP Application Form:
    • Contents:
      • Business Description: Clearly outline the intended crypto-asset services, including exchange, custody, or advisory.
      • Operational Details: Detailed explanation of operational structures, locations, and methodologies.
      • Compliance Framework: Complete description of internal compliance systems and AML/KYC procedures.
    • Submission: Accurate completion and timely submission to the Bank of Lithuania alongside required documentation.
  • Memorandum and Articles of Association (MAA):
    • Memorandum of Association: Document specifying the company’s business objectives, initial shareholders, and share capital.
    • Articles of Association: Clearly defines governance structure, roles, responsibilities, and procedures for corporate governance.
    • Purpose: Provides essential legal and operational clarity for company incorporation and regulatory compliance.
  • Government Fees:
    • Company Registration: EUR 30.83 fee for registering a UAB (private limited liability company).
    • CASP License Application: Fees may be introduced under MiCA; applicants should verify current fees with the Bank of Lithuania.

Share Capital and Government Fees

  • Minimum Capital Requirement: Under MiCA, minimum share capital ranges from €50,000 to €150,000, depending on services provided.
  • Capital Flexibility: MiCA permits gradual funding; full capital need not be immediately deposited, providing financial flexibility.
  • Monitoring: Regular reporting on financial stability and adherence to MiCA capital adequacy rules.

Personnel Requirements

  • AML Compliance Officer:
    • Qualifications: Must be certified with substantial experience and training in AML/CFT practices.
    • Residency: Lithuanian or EU resident mandatory.
    • Registration: Officially listed within company organizational structure.
  • Senior Management (Director):
    • Qualifications: Relevant expertise in finance, compliance, crypto-assets, or blockchain technology.
    • Residency: Preferred EU residency; no explicit restriction, but at least one EU-resident director is recommended.
    • Responsibilities: Overseeing overall management, compliance adherence, and strategic implementation.

Business premises requirements

  • Physical Office Presence: Required by MiCA; companies must maintain verifiable business premises within Lithuania.
  • Options Available:
    • Physical Office Space: Dedicated office locations.
    • Coworking Spaces: Acceptable if clearly documented and verifiable.
    • Virtual Offices: Allowed only if they meet regulatory standards for verifiable presence and legitimate operation.
  • Compliance: Business premises must meet standards to enable inspections and regulatory oversight 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

Operating a crypto exchange business in Lithuania requires obtaining a Crypto-Asset Service Provider (CASP) license in accordance with the EU’s MiCA framework, overseen by the Bank of Lithuania. Lithuanian regulations offer equal treatment for foreign and Lithuanian entities, allowing international businesses seamless access to the Lithuanian market.

Eriks Fijalovs

Head of Blockchain and Crypto

1

Gathering Documentation

Collaborate with stakeholders to collect and prepare:
– Passport copies and proof of residence.
– Company name verification and reservation with Registrų centras (Centre of Registers).
– Detailed business plan description.
– Power of Attorney (PoA), notarized and legalized as necessary.

2

UAB Company Registration & Share Capital

Establish a private limited liability company (UAB) remotely or in-person by:
– Opening an operational bank account.
– Depositing initial share capital (minimum 25% of total required €50,000–€150,000 depending on planned activities).
– Formalizing the registration via notarial confirmation.
– Registering business activity explicitly as a Crypto-Asset Service Provider (CASP).
– Translating, notarizing, and apostilling necessary documents as required.

3

Internal Policies, Management & HR Services

Ensure compliance by:
– Developing and implementing AML/KYC/CFT policies aligned with MiCA standards.
– Defining risk management strategies, customer due diligence processes, and operational risk appetite.
– Recruiting qualified local directors and an AML Compliance Officer.
– Securing and registering a local business presence (virtual office or physical premises) and personnel with Lithuanian authorities (Tax Office – SoDra).

4

CASP License Application Submission

Prepare and submit a complete application to the Bank of Lithuania, including:
– Fully completed application forms aligned with MiCA guidelines.
– Comprehensive internal documentation (AML/KYC/CFT policies, business plan, personnel structure).
– Continuous liaison and communication with the Bank of Lithuania during the review process.

5

Opening a Crypto-Friendly Corporate Bank Account

Identify and secure suitable banking options:
– Analyze business operations and choose appropriate crypto-friendly banks.
– Prepare and submit all required documentation, addressing bank-specific requirements.
– Support client onboarding until successful account opening.

6

Operational Launch & Ongoing Compliance

Begin business activities in Lithuania with continued support:
– Provide accounting, legal consultation, tax consulting, and HR services.
– Assist in drafting necessary operational agreements and compliance documentation.
– Monitor regulatory adherence, regularly report to the Bank of Lithuania, and adjust operations as necessary to maintain ongoing compliance with MiCA requirements.

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 Crypto license in Lithuania

1. How to get a crypto license in Lithuania?

Our lawyers have prepared detailed description of the whole process.
In short words: collect documents to establish a company in Lithuania, deposit and register share capital, prepare AML/KYC policy, appoint local AML officer and director, apply for license

2. How long does it take to obtain crypto (VASP) license in Lithuania?

Whole process can be done within 6-8 weeks, including opening UAB company, deposit and register share capital, prepare documentation for application process and await valid answers (license) from FCIS.

3. How much is share capital for crypto company in Lithuania?

From 1st of November 2022 requirement is to deposit 125,000 EUR.

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

Yes, it is possible to open multiple accounts with Lithuanian VASP license, mainly with European EMI’s (Electronic Money Institutions) , our company have partnership with 15+ crypto friendly EU banks, from which client can choose by their own preferences.

5. What types of crypto licenses are available in Lithuania?

Lithuania offers several types of crypto licenses, primarily focusing on Virtual Asset Service Providers (VASPs). These include licenses for:

  • Cryptocurrency Exchange Services: Allowing the exchange of virtual assets to fiat currencies and vice versa.
  • Cryptocurrency Wallet Services: Enabling the storage and management of virtual assets on behalf of clients.
  • ICO and Token Offerings: Licensing for Initial Coin Offerings and other token-based fundraising activities.

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

The primary regulatory authority for cryptocurrency businesses in Lithuania is the Financial Crime Investigation Service (FCIS), which ensures compliance with AML/KYC regulations and other financial laws.

7. What documents are required to apply for a crypto license in Lithuania?

Key documents include:

  • Power of Attorney: If using a representative for the application process.
  • AML/KYC/CFT Policies: Detailed procedures for preventing money laundering and terrorist financing.
  • Application Form: Completed form submitted to the FCIS.
  • Memorandum and Articles of Association (MAA): Legal documents for company incorporation.

8. What are the ongoing compliance requirements for licensed crypto businesses in Lithuania?

Ongoing compliance includes:

  • Regular Reporting: Submission of periodic reports to the FCIS.
  • AML/KYC Updates: Continuous improvement of AML and KYC policies.
  • Audits: Periodic audits to ensure compliance with regulatory standards.
  • Consumer Protection Measures: Ensuring transparent terms of service and secure handling of customer funds.

9. Do I need a physical office in Lithuania to obtain a crypto license?

Yes, there is a requirement for a local physical office. However, virtual office services or coworking spaces can be utilized to meet this requirement.

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

Lithuania offers a competitive corporate tax rate of 15%, with potential reductions to 5% for small businesses under certain conditions. There are no special taxes on cryptocurrencies, providing a favorable tax environment.

11. What are the personnel requirements for a crypto licensed company in Lithuania?

Key personnel requirements include:

  • AML Officer: A certified local AML Officer with knowledge of AML regulations.
  • Director: An experienced individual in finance or blockchain technology, with no residency restrictions.

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

Yes, foreign nationals and entities can apply for a crypto license in Lithuania. They may need to appoint a local representative or director and establish a local office.

13. How can I ensure my application for a crypto license in Lithuania is successful?

To ensure a successful application:

  • Prepare Thoroughly: Ensure all documents are complete and accurate.
  • Engage Local Experts: Work with local legal and financial advisors like ourselves here at Legalaes
  • Respond Promptly: Address any queries or requests from the FCIS quickly.
  • Maintain Compliance: Establish robust AML/KYC policies.

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