The Markets in Crypto-Assets Regulation (MiCA) introduces a unified regulatory framework for crypto-assets across the European Union (EU), promoting legal certainty, investor protection, and market stability. One of the core requirements under MiCA is obtaining a Crypto-Asset Service Provider (CASP) license, mandatory for businesses offering crypto asset services.
This licensing ensures compliance with strict standards on governance, security, and anti-money laundering (AML), enabling licensed CASPs to operate seamlessly across all EU member states. Whether you are an emerging startup or an established operator, obtaining a CASP license is essential to access the EU’s vast and dynamic market for digital assets.
The Bank of Lithuania (Lietuvos bankas / BoL) is the competent authority overseeing CASP licensing under MiCA. Businesses operating or planning to provide crypto-asset services in Lithuania must adhere to local implementation requirements alongside MiCA’s EU-wide provisions.
Our firm has a thorough knowledge of Lithuanian law and BoL requirements, ensuring that your compliance efforts are efficient and effective.
We can help your business meet compliance requirements and unlock the potential of the EU crypto market!
In Lithuania, the Lietuvos bankas is the competent authority overseeing CASP licensing under MiCA
Key Numbers about a CASP License in Lithuania
3 monthsaverage term of obtaining CASP license after application submission |
at least severaldirectors in a CASP |
up to €150kamount of the share capital depending from CASP activity |
20/32%personal income tax (PIT) rate |
16%corporate income tax (CIT) rate |
15%capital gains tax (CGT) rate |
Legal Opinion about a CASP License in Lithuania
Ganna Voievodina
Manimama
|
CEO
“Obtaining a CASP license in Lithuania is essential for businesses offering crypto-asset services. Applicants must meet requirements, including robust AML/CFT compliance, a formal governance structure, and sufficient operational capital. Once licensed, CASPs must adhere to ongoing reporting obligations and maintain compliance with Lithuanian and EU regulations. A CASP license enhances credibility and provides access to the EU market under a clear regulatory framework”.
Types of Activities with a CASP License in Lithuania
Providing custody and administration of crypto-assets on behalf of clients
This service means safekeeping or controlling, on behalf of third parties, crypto-assets or the means of access to such crypto-assets, where applicable in the form of private cryptographic keys. Holdings of crypto-assets on behalf of the clients shall be segregated from CASP’s holdings.
Operation of a trading platform for crypto-assets
This service contains of the management of one or more multilateral systems, which brings together or facilitates the bringing together of multiple third-party buying and selling interests for crypto-assets – in the system and in accordance with its rules – in a way that results in a contract, either by exchanging one crypto-asset for another, or a crypto-asset for funds.
Exchange of crypto-assets for funds
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for funds by using proprietary capital.
Exchange of crypto-assets for other crypto-assets
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other crypto-assets by using proprietary capital.
Execution of orders for crypto-assets on behalf of clients
This service means concluding agreements to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets on behalf of third parties and includes the conclusion of agreements to sell crypto-assets at the moment of their issuance.
Placing of crypto-assets
This service includes the marketing, on behalf of or for the account of the offeror or of a party related to the offeror, of crypto-assets to purchasers. Before placing the crypto-assets a CASP shall obtain the agreement of the issuers or any third party acting on their behalf.
Reception and transmission of orders for crypto-assets on behalf of clients
This service means the reception from a person of an order to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets and the transmission of that order to a third party for execution.
Providing advice on crypto-assets
This service means offering, giving or agreeing to give personalized recommendations to a third party, either at the third party’s request or on the initiative of the a CASP providing the advice, in respect of one or more transactions relating to crypto-assets, or the use of crypto-asset services.
Providing portfolio management on crypto-assets
This service includes managing portfolios in accordance with mandates given by clients on a discretionary client-by-client basis where such portfolios include one or more crypto-assets.
Providing transfer services for crypto-assets on behalf of clients
This service means transfer, on behalf of a natural or legal person, crypto-assets from one distributed ledger address or account to another. Such service may be provided without virtual currency wallet opened for a CASP’s client.
Benefits of Obtaining a CASP License in Lithuania
Reputation and trust:
- A CASP license from Lithuania boosts a company’s credibility, as the country has a well-established reputation for regulatory excellence.
- Clients and investors are more likely to trust a licensed crypto business, improving customer confidence and loyalty.
Developed financial ecosystem:
- Lithuania offers a developed and supportive financial ecosystem, with numerous banking partners and fintech services.
- Licensed CASPs can integrate seamlessly with banks and other financial institutions to offer payment solutions and other services to their clients.
EU passporting:
- With a Lithuanian CASP license, businesses can provide crypto services across all EU member states without additional licensing.
- This opens up access to a large market with over 450 million consumers, simplifying cross-border operations within the EU.
Access to blockchain and crypto community:
- Lithuania is home to a growing blockchain and crypto community, which includes industry experts, investors, and regulators.
- A CASP license facilitates networking and collaboration with other key players in the sector, fostering innovation and business development.
Access to talented workforce:
- Lithuania has a growing pool of highly skilled professionals in blockchain, fintech, and financial services, providing companies with access to talented employees.
- The country’s strong educational focus on technology and innovation ensures a constant flow of qualified talent.
Focus on blockchain innovation:
- Lithuania has a strong governmental focus on promoting blockchain technology and innovation, providing a supportive environment for crypto businesses.
- CASP license holders can take advantage of this favorable climate to explore new blockchain-based solutions and applications.
Our Services
STEP 1
Incorporation stage
- Company formation in Lithuania
- Provision of a registered address for 1 year
- Opening corporate bank account and transferring the share capital
- Appointment and employment of a local director
- Detailed company structure documentation
STEP 2
Pre-licensing stage
- Preparation and submission legal and financial documents (non-exhaustive list) according to MiCA
- Review of existing policies and procedures, if the company already has them
STEP 3
Licensing stage
- CASP license application assistance
- Conducting communication with the BoL during the license process
Our Experts in this Area
Step by Step Description
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Initial setup
- Initiating a preliminary project assessment
- Creating an action plan
- Preparation and filing of the package of documents
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Company registration
- Selection and verification of the company name in the Commercial Register
- Verification and reservation of the company name at the State Enterprise Centre of Registers
- Facilitating the notarial process for the company's official registration
- Opening a bank account in the owner's name and depositing a share capital
- Incorporating the company's data into the State Enterprise Centre of Registers
- Obtaining the Certificate of incorporation issued by the State Enterprise Centre of Registers and Articles of Association
- Registration for taxation purposes
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Obtaining a CASP license
- Preparation of documents according to MICA
- Submission an application to the licensing authority - Lietuvos bankas
- Reviewing the application to ensure it is complete (if any documents or information are missing, the applicant will be notified and given a specific deadline to provide the necessary additional documentation)
- Assessment of the documents` content submitted (a detailed review to verify that all regulatory requirements are met)
- Requesting of additional details (if applicable)
- Notification of grant or refusal of the CASP license
- Granting or refusal notification to European Securities and Markets Authority (ESMA)
- Publication in ESMA register
Lithuanian National Legislation
In Lithuania, the transition period means that applicants may continue to provide crypto-assets services until June 1, 2025
Regulation:
The Law on Crypto-Asset Markets of Lithuania (Lietuvos Respublikos kriptoturto rinkų įstatymas / MiCA Act) stands as key law concerning the implementation of the MiCA. The purpose of this Law is to ensure the fair, open and efficient functioning of the crypto-asset market.
The MiCA Law revised the provisions of the MiCA and clarified licensing and other processes (e.g. dispute resolution, imposition of enforcement measures, etc.).
Licensing authority:
Lietuvos bankas is the primary regulator overseeing the implementation of MiCA and the crypto-asset market in Lithuania. It is responsible for granting licenses to CASPs, ensuring compliance with AML regulations, and enforcing MiCA-related rules.
The Bank of Lithuania also acts as the primary supervisory authority, monitoring crypto-asset activities to ensure market integrity and protect investors. As part of its regulatory function, Lietuvos bankas has provided guidance and issued recommendations to crypto companies, ensuring that they meet the EU standards as outlined under MiCA.
Procedure, timelines, fees:
Following the full application of MiCA, i.e. after 30 December 2024, the Lietuvos bankas must assess within 25 working days of receiving an application for authorisation whether all of the required information has been included in the application. At this stage, however, the Lietuvos bankas will not assess the quality of the information provided. The Lietuvos bankas may ask the applicant to supplement the application if some or all of the required information is missing. The Lietuvos bankas will set a deadline for the submission of any missing information. After the submission of missing information, the Lietuvos bankas will have 40 working days to make a qualitative assessment of the application. During this period, the Lietuvos bankas has the opportunity to submit additional requests for clarification, but only the first of these requests will suspend the 40 working day assessment period, for a maximum of 20 working days. The Lietuvos bankas will notify the applicant of its decision within 5 business days of the date of adopting the decision.
The documents must be presented to Lietuvos bankas in line with the General Regulations on the Submission and Examination of Applications for Authorisations of Financial Market Participants Supervised by the Bank of Lithuania and on the Granting of Authorisation approved by Resolution No 58 of the Board of Lietuvos bankas of 6 May 2004.
Documents (procedures) must be prepared in Lithuanian and must be made available to clients in accordance with the prescribed procedures prior to the commencement of cryptocurrency services. The Bank of Lithuania shall have the right to require the applicant to submit other documents in Lithuanian.
Transition period:
Virtual currency exchange operators and depositary virtual currency wallet operators included in the list maintained by the Register of Legal Persons must, as from June 1, 2025, cease to be entitled to carry out the mentioned activities unless they have obtained a license in accordance with the procedure laid down in MiCA and in the procedure laid down in MiCA Act.
Within this transitional period, cryptoasset-related services may be provided in Lithuania and other EU countries in accordance with the requirements of the national legislation currently in force in those jurisdictions, considering the transitional period applicable in each of these EU Member States.
Requirements for Obtaining a CASP License in Lithuania
Capital requirements for a CASP vary depending on what services the company will provide - from €50,000 to €150,000
Physical office requirements
A CASP shall have a registered office in Lithuania where it carries out at least part of their crypto-asset services.
Requirements for key persons
-
Senior managers (directors):
- Number: MICA does not specify a minimum and maximum number of directors. However, MICA states (part 2, article 59) that there shall be at least several directors.
- Residency requirements: At least one director must be an EU resident.
- General requirements: Directories must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record
- a detailed CV
- statements on time commitment and past professional conduct
-
Shareholders:
- Number: MICA does not specify a minimum and maximum number of shareholders.
- Residency requirements: There is no restriction.
- General requirements: Shareholders must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record
- an ownership structure chart
Capital requirements
Capital requirements vary depending on what services the company will provide:
Class 1: A CASP authorized for the following crypto-asset services:
- execution of orders on behalf of clients
- placing of crypto-assets
- providing transfer services for crypto-assets on behalf of clients
- reception and transmission of orders for crypto-assets on behalf of clients
- providing advice on crypto-assets and/or
- providing portfolio management on crypto-assets
Minimum capital requirements - €50,000.
Class 2: A CASP authorized for any crypto-asset services under Class 1 and:
- providing custody and administration of crypto-assets on behalf of clients
- exchange of crypto-assets for funds and/or
- exchange of crypto-assets for other crypto-assets
Minimum capital requirements - €125,000.
Class 3: A CASP authorized for any crypto-asset services under Class 2 and:
- operation of a trading platform for crypto-assets
Minimum capital requirements - €150,000.
Documentation requirements
There are list of documents that must be submitted with the application:
-
Documents required for all CASPs:
- The articles of association of the applicant CASP
- Identity and proof of good repute, knowledge, skills, experience and of sufficient time commitment of the members of the management body
- Information relating to shareholders or members with qualifying holdings
- A program of operations setting out the types of crypto-asset services that the applicant CASP wishes to provide, including where and how these services are to be marketed
- A description of the applicant CASP’s prudential safeguards (insurance policy)
- A description of the applicant CASP’s governance arrangements and internal control mechanisms
- A description of the applicant CASP’s business continuity plan
- Detection and prevention of money laundering and terrorist financing (full packet of policies)
- Descriptions both in technical and non-technical language of applicant CASP’s IT systems and security arrangements
- A description of the applicant CASP’s procedures to handle complaints from clients
- Documents required in case CASP wishes to offer services in other countries:
- List of EU countries where the company wishes to offer its services
- Documents required for certain services (each of the 10 services requires its own documents):
- Custody and administration policy
- A description of the procedure for the segregation of client’s crypto-assets and fund
- The operating rules of the trading platform and market abuse detection
- Information on the exchange of crypto-assets for funds or other crypto-assets (commercial policy)
- The execution policy
- Information on the provision of advice or portfolio management on crypto-assets
- Information on transfer services
Taxes in Lithuania
The CIT rate of 16% applies to most companies
Corporate Income Tax (CIT)
The CIT in Lithuania is 16% for Lithuanian entities and permanent establishments of foreign entities.
For small businesses with fewer than 10 employees and annual income not exceeding €300,000, profits are taxed at a rate of 0% during the first tax period and at a rate of 6% during other tax periods, except for the cases specified in the Law on Corporate Income Tax.
Cryptocurrency income earned by companies is considered taxable business income, and it is taxed under the standard CIT rules. Companies engaging in crypto-related activities must report their income, profits, and transactions accurately, as well as follow Lithuania's AML and KYC regulations.
Capital Gains Tax (CGT)
Capital gains are generally taxed at 15% for individuals, but if the annual amount of this and other non-employment taxable income exceeds 120 average national wages (ANW), the portion exceeding this threshold is taxed at an additional 20%.
For corporations capital gains are generally taxed at the standard CIT.
The sale of property, shares, or securities (excluding real estate) is subject to this tax. Real estate sales are subject to additional provisions.
Personal Income Tax (PIT)
The personal income tax rate for employment-related income is 20% for annual income up to €126,532.
For income above €126,532, the rate increases to 32%.
Frequently Asked Questions
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What is a CASP license in Lithuania?The CASP license allows companies to legally offer crypto asset services in Lithuania.
-
Who issues the CASP license in Lithuania?The Lietuvos bankas issues CASP licenses.
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What services can be provided under a CASP license?
It allows services such as:
- 1) Providing custody and administration of crypto-assets on behalf of clients
- 2) Operation of a trading platform for crypto-assets
- 3) Exchange of crypto-assets for funds
- 4) Exchange of crypto-assets for other crypto-assets
- 5) Execution of orders for crypto-assets on behalf of clients
- 6) Placing of crypto-assets
- 7) Reception and transmission of orders for crypto-assets on behalf of clients
- 8) Providing advice on crypto-assets
- 9) Providing portfolio management on crypto-assets
- 10) Providing transfer services for crypto-assets on behalf of clients
-
What are the key requirements to obtain a CASP license in Lithuania?Companies must meet physical office requirements, requirements for managers and shareholders, minimum capital requirements, documentation requirements.
-
Is it mandatory to have a physical office in Lithuania to obtain a CASP license?Yes, a local office in Lithuania is required for regulatory oversight.
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Is there a minimum capital requirement for obtaining a CASP license?Yes, applicants must meet specific financial and operational adequacy standards, but the exact minimum capital depends on the services offered (€50,000, €125,000, €150,000).
-
What is the process for applying for a CASP license?The process involves submitting an application to the Lietuvos bankas with detailed documentation on the company structure, management, AML policies, and financial plans, etc.
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How long does it take to obtain a CASP license?The preparation of documents and the review process typically takes several months, depending on the completeness of the application and the authority's workload.
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What are the fees associated with obtaining and maintaining a CASP license?Application and annual supervision fees apply, and they vary based on the scale of services provided.
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What is the role of management in meeting CASP license requirements?The management team must demonstrate relevant experience, integrity, and the ability to manage crypto-related risks.
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Can an individual apply for a CASP license, or is it limited to companies?The CASP license is typically issued to legal entities, not individuals.
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