Crypto license in Lithuania

Benefits of the Lithuania crypto license

Lithuania’s CASP license offers several advantages:

• Fast and cost-efficient. Lithuania is known for quick licensing: a well-prepared application can succeed in a few months. There are no onerous application fees (state fee is zero and the BoL fee is relatively modest), and annual upkeep costs are low (no fixed renewal fee). By contrast, some EU countries require much higher fees and longer lead times.
• One license for all services. Unlike regimes that require separate permits for exchange vs custody vs wallet services, Lithuania (like MiCA generally) issues a single CASP license covering all authorized crypto-asset services. This “all-in-one” approach lets an operator start with one business line (say crypto exchange) and later expand (into staking, custody, etc.) under the same license.
• EU market access and credibility. A Lithuanian license is recognized across the EU, giving access to a 450+ million consumer market. It signals compliance with EU standards (AML, consumer protection, transparency) which enhances trust with European banks, payment providers and customers. Having an EU-regulated license (as opposed to an offshore one) often simplifies partnerships and banking.
• Favorable tax regime. Lithuania applies a flat 15% corporate tax. There is no turnover or “GGR” tax on crypto revenue, and no VAT on crypto transactions (financial services are typically VAT-exempt). Profits can often be distributed efficiently via dividends (15% withholding) in Lithuania’s territorial tax system.
• Robust, transparent regulation. Lithuania was among the first EU countries to enact crypto rules and to implement MiCA. Its regime is seen as clear and business-friendly: licensing standards are demanding but transparent. This creates a stable environment for startups, with fewer regulatory surprises than in unclear jurisdictions.

Disadvantages of the Lithuania crypto license

There are also some drawbacks to consider:

• Regulatory burden. The MiCA regime (and Lithuania’s implementation) imposes strict compliance requirements. Applicants must commit substantial capital (125k+) and set up full AML/KYC programs and local governance. Ongoing compliance (reporting, audits, staffing) can be onerous for very small operators. The need for dedicated local management (AML officer, CEO, MLRO) means higher personnel costs.
• Limited global recognition. Even though Lithuanian CASP license is very prestigious, non-EU markets like the US, UK, China etc. do not accept it because of their own crypto regulation requires a local crypto license. Operators must geo-block those jurisdictions or obtain additional licenses if targeting them. (This is true of any EU license, but worth noting.)
• Legacy transition. The old Lithuanian “crypto exchange” and “wallet” licenses (historically registered with the FCIS) are being phased out. Operators previously on the old regime had to migrate to the CASP license by Dec 2025. This transition may cause paperwork and temporary overlap during 2023-25.

Types of Lithuania crypto licenses

Under the current framework, Lithuania does not issue different “levels” of crypto license beyond B2C (operator) versus B2B (service provider), but historically it had distinct categories:

• Virtual Currency Exchange Operator (VCESP) license: A legacy permit allowing a company to run a crypto exchange (crypto↔crypto or crypto↔fiat) and execute trades for customers.
• Virtual Currency Wallet Provider (VCWSP) license: A legacy permit for companies that custody and manage users’ crypto wallets/keys on their behalf.
• MiCA Crypto-Asset Service Provider (CASP) license: From January 2025 onward, Lithuania issues a single CASP license (under MiCA) that covers all virtual asset service activities, including those formerly falling under the above licenses. In practice, every VASP now applies for a CASP license, regardless of whether it is an exchange, custodian, broker or portfolio manager.

No white-label or sublicensing arrangements are used in Lithuania’s crypto regime. All licenses are granted directly by the BoL.

Requirements for obtaining a Lithuania crypto license

Prospective VASPs must meet extensive conditions, including (but not limited to):

• Corporate structure & capital. The applicant must be a Lithuanian legal entity (typically a UAB/LLC). Significant capital must be deposited: the exchange license historically required €125,000, and under MiCA the capital requirement ranges from €50,000 to €150,000 depending on services. The funds must be available (usually shown in audited accounts or bank statements).
• Local presence and personnel. MiCA mandates at least one EU-based director and a registered EU office. In Lithuania, law specifically requires licensed entities to employ key local officers: for example, a Chief Compliance Officer (CCO), a CEO, and a Money Laundering Reporting Officer (MLRO). (Smaller firms may combine roles, but in practice having distinct, experienced personnel is expected.) At minimum, the applicant must designate a qualified AML/KYC officer to handle compliance.
• Fit-and-proper vetting. All owners, directors, and managers undergo thorough background checks. Applicants must supply police clearance certificates, financial references and CVs. The BoL will refuse individuals with criminal records, unresolved financial issues, or other red flags. Ultimate Beneficial Owners (UBOs) must be declared and are scrutinized, especially any holding ≥10%.
• Business plan and documents. A detailed business plan and operational description must be submitted. The application package typically includes corporate documents, organizational charts, internal policies (AML/CFT, KYC procedures, governance), key contracts, accounting records, and proof of capital. For example, you need to demonstrate how you will conduct customer identity verification, transaction monitoring, and risk management.
• Technical infrastructure under DORA regulation. The crypto platform must be secure and robust. This generally entails hosting IT systems in the EU (or specifically in Lithuania if required), with strong cybersecurity (SSL, encryption, anti-hacking measures). Lithuanian regulators expect reliable transaction recording and backup procedures. (While not explicitly stated in public laws, in practice demonstrating a secure, high-availability IT setup is essential.)
• AML/KYC and risk controls. Operators must implement EU-grade AML/CFT frameworks. This means verifying customer identities at onboarding (KYC), ongoing transaction monitoring, reporting suspicious activity, and enforcing sanctions and PEP checks. Detailed AML/KYC policies and training programs must be ready before licensing. Additionally, risk management systems (business continuity plans, audit trails, conflict-of-interest policies, etc.) are required by MiCA.
• Application to the BoL. When ready, the company submits its license application through the BoL, providing all documentation and paying the fee. The Bank of Lithuania will then review the submission for completeness and conduct further due diligence.

Costs & taxes

Key costs to budget for include:

• State and BoL fees. The Lithuanian regulator does not charge a large government application fee (effectively zero). However, the Bank of Lithuania charges a licensing fee (roughly €2,425 upon approval. (This is paid once the BoL issues provisional approval and you proceed to final licensing.) Thereafter there is no fixed annual license fee.
• Share capital. As noted, the significant cost is meeting the capital requirement (e.g. €125,000). While companies may not need to fully pay this in cash for operations, it must be tied up as equity or equivalent until licensing is complete.
• Corporate and other taxes. Lithuania’s corporate income tax is 15% on net profits. There is no turnover or VAT on crypto transactions (financial services are VAT-exempt). Dividends distributed to shareholders are also taxed at 15%. Overall, the tax burden is considered light compared to many jurisdictions.
• Compliance and professional services. Aside from regulator fees, expect to pay for AML audit services, legal and consulting assistance, system audits, etc. For example, independent AML/IT audits and compliance reviews can each run several thousand euros per year. Accounting, audit, and secretariat services may add a few thousand more. Licensing consultants or lawyers may charge fees (e.g. 3–5k+) for helping prepare and submit the application. These costs vary by provider, but a first-year budget of tens of thousands is typical.
• Total first-year budget. A rough first-year estimate might include: €125k capital (tied up), €2k application fee, €40k in setup (legal/accounting/IT), plus ongoing €5–10k+ for compliance consulting and audits. Actual figures depend on scale and setup.

Ongoing maintenance of your crypto license

After licensing, a company must maintain strict compliance:

• Regulatory reporting. CASPs must file regular reports to the Bank of Lithuania. This typically includes annual financial statements, periodic AML summaries, transaction volume reports, and disclosures of governance changes. A compliance calendar is recommended to track these deadlines.
• AML/KYC obligations. Continuous enforcement of AML/KYC measures is mandatory. This means ongoing customer screening, transaction monitoring, and suspicious activity reporting (e.g. report to the FIU within 24 hours for any unusual transactions). Records of customer identities and transactions must be retained (at least 5 years). The BoL or FCIS may audit these procedures at any time.
• Audits and testing. Licensed entities are expected to undergo periodic independent audits. While Lithuania does not impose standardized crypto-specific audits, in practice companies often commission annual compliance audits (AML, IT security, etc.) to reassure regulators. Financial accounts should be audited annually by an approved firm.
• Change management. Any significant change (e.g. new shareholders, change of CEO/AML officer) must be notified to and approved by the BoL in advance. The license requires that the licensed activities and company structure remain consistent with what was approved.
• Consumer protection. Although Lithuania has no formal player-protection rules for crypto, licensed VASPs must follow MiCA’s provisions on transparent disclosure, fair execution, and orderly business conduct. This means clear terms of service, protection of client funds, and a documented complaints process.

Suspension or revocation of a Lithuania crypto license

The Bank of Lithuania can suspend or revoke a CASP license for serious breaches. Grounds include: unresolved AML/CFT violations, fraud, insolvency, failure to maintain capital, non-cooperation with regulators, or operation outside the licensed scope. In case of suspected wrongdoing (e.g. money laundering or regulatory evasion), the BoL may immediately suspend services pending investigation. Prolonged non-compliance or failure to correct issues would lead to full license revocation. The Lithuanian legal framework emphasizes enforcement to protect clients and financial stability, so licensees must be diligent about compliance.

Updates to Lithuania crypto licensing (2024–2025)

Lithuania’s crypto regime has been evolving rapidly in 2023–25:

• MiCA adoption. On the EU level, the MiCA regulation (Regulation (EU) 2023/1114) was adopted and entered into force in 2023. Its rules for significant crypto-assets (EMTs and ARTs) took effect on 30 June 2024, and the requirements for CASP licensing became binding from 30 December 2024. Lithuania promptly aligned with MiCA, and as of 1 Jan 2025 all crypto-asset service providers in Lithuania must be licensed under the MiCA framework.
• Transitional regime. Lithuania allowed existing crypto businesses to continue under the old regime during a transition. Until 30 December 2025, operators could register under pre-MiCA rules; after that date only MiCA-based licenses are valid. During 2023–2025, new applicants began applying under the MiCA CASP regime, while legacy exchanges and wallet providers completed their conversion to the CASP license.
• Stricter substance and AML. Alongside MiCA, Lithuania has strengthened local substance requirements. Licensed firms are expected to have real economic presence (physical offices, local senior management) and meet enhanced AML standards (in line with the 6th EU AML Directive). Lithuania continues to follow FATF guidelines and the EU’s Transfer of Funds Regulation for crypto transactions.
• Transparency. The BoL now maintains a public register of all licensed CASPs. Lithuania has also moved toward greater transparency by requiring firms to disclose governance and key policies (for example, transaction reporting to the Bank).

Who issues Lithuania crypto licenses?

Historically, Lithuania’s approach was regulatory (no “master license” system). Before MiCA, crypto businesses simply registered their activities with the Financial Crime Investigation Service (FCIS/FNTT) and were subject to Lithuanian AML law. No third-party “sublicensing” was involved.

Today, under the MiCA framework, the Bank of Lithuania is the sole licensing authority for CASPs. All cryptocurrency-exchange and wallet operators must apply directly to the BoL. There is no master-subsidiary license structure. In effect, every Lithuanian virtual currency exchange or wallet provider now holds a license granted by the national regulator, not by any private licensee.

Why the Lithuania crypto license is attractive for startups

For entrepreneurs and startups, Lithuania offers a compelling entry point into regulated crypto markets:

• Moderate costs and quick setup. Lithuania’s licensing and capital requirements are lower than many Western European countries. There are no hefty application fees (only ~€2k to the BoL), and the licensing process is relatively streamlined. Incorporation and bank account setup in Lithuania can be done swiftly. This allows startups to conserve capital and launch faster.
• Single-scope license. A single Lithuanian license covers all major crypto verticals. A new company can launch a basic crypto exchange or wallet service and later add others (staking, NFTs, crypto lending, etc.) without applying for separate permits. This flexibility is ideal for startups that want to iterate products under one regulatory umbrella.
• Favorable tax and EU access. Nearly all of gross revenues can be reinvested since crypto transactions are not taxed. Only profits incur ~15% tax, meaning young companies retain more funds for growth. And because Lithuania is in the EU, a license grants access to the entire single market (no EU customer limits). This EU passporting advantage is hard to replicate outside the union.
• Industry credibility. Lithuania’s license is well-recognized in the global crypto community. Being regulated under EU law (MiCA) adds legitimacy to a startup. It signals to investors, payment providers and clients that the company follows high standards.
• Supportive ecosystem. Lithuania has a growing fintech ecosystem with crypto-friendly banks and service providers. The government and Bank of Lithuania have actively courted blockchain businesses, offering clear guidance and consultation. For small teams, finding local partners (legal firms, tech vendors) is straightforward.

Official Sources & Primary Legislation (MiCA / BoL / FNTT)

Primary Acts

• Regulation (EU) 2023/1114 (MiCA) — full text
• Regulation (EU) 2023/1114 (MiCA) — PDF
• Regulation (EU) 2023/1113 (EU Travel Rule for funds & certain crypto-assets) — full text
• Regulation (EU) 2023/1113 — PDF
• Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing (VIII-275) — official text

Bank of Lithuania — Competent Authority for CASPs

• Authorisation of crypto-asset service providers (CASP licensing)
• Public list of financial market participants — CASPs
• Legal framework and AML/CFT guidance

FNTT — Financial Crime Investigation Service (AML/FIU)

• Information for virtual currency exchange and/or wallet operators (legacy obligations)
• FNTT main page (AML supervision and reporting)

EU Supervisory Registers — ESMA (Regulatory touchpoints)

• ESMA MiCA overview and central registers
• ESMA Databases and Registers