Crypto license in Lithuania

Obtaining a crypto license in Lithuania has become a strategic move for blockchain companies aiming to operate within the European Union. Known for its efficient regulatory procedures and business-friendly environment, Lithuania offers one of the most accessible paths for securing legal status as a virtual asset service provider in Lithuania. The framework allows firms to engage in activities such as cryptocurrency exchange, wallet custody, and token transfers — all under a compliant structure that aligns with both national and EU-wide standards.

The appeal of the Lithuania cryptocurrency license lies in its balance of legal clarity, speed of registration, and low entry thresholds. Startups and international firms alike benefit from a streamlined process that includes registering a local entity, appointing a compliance officer. With the upcoming implementation of MiCA in Lithuania, businesses licensed today are positioning themselves for long-term success in a harmonized EU crypto environment. The crypto license in Lithuania not only ensures current regulatory compliance — it also future-proofs operations in an industry defined by constant legal evolution.

Why Lithuania is a Premier Crypto Jurisdiction

Lithuania has earned a solid reputation as a top destination for crypto entrepreneurs due to its streamlined regulations and clear government stance on digital assets. 

A major advantage of pursuing a Lithuania crypto license is the speed and simplicity of the process. The process includes company registration, document submission, and appointment of AML-compliant personnel, but avoids excessive bureaucracy — making it ideal for first-time applicants and experienced crypto firms alike.

Moreover, Lithuania’s regulatory infrastructure is closely aligned with the upcoming MiCA in Lithuania framework. This ensures that entities operating under the Lithuanian crypto regulation today will not face major restructuring once EU-wide rules come into effect. By combining legal clarity, cost-effectiveness, and future-proof compliance, Lithuania has positioned itself as one of the most strategic jurisdictions for launching a fully compliant crypto business in Lithuania in the EU.

Lithuania Crypto License Types and MiCA Transition

Lithuania previously operated with two separate VASP authorisations — crypto-exchange operator and custodian wallet operator — but regulatory updates have merged these into a single VASP registration where firms simply select the activities they plan to provide. The exchange license permits businesses to operate digital asset trading platforms, offering fiat-to-crypto and crypto-to-crypto transactions. Meanwhile, the wallet license authorizes companies to provide custodial services for client crypto assets, including the management of private keys. Together, these form the backbone of the Lithuania cryptocurrency license framework, allowing firms to launch end-to-end crypto operations in full legal compliance.

As the EU’s MiCA in Lithuania regulation approaches enforcement, existing VASP structures will evolve into a unified crypto asset service provider in Lithuania regime. This transition will require enhanced risk disclosures, increased capital thresholds, and stricter AML oversight. However, Lithuania is already well-aligned with MiCA’s core principles, making it one of the easiest jurisdictions to adapt to the new rules. For businesses that secure their crypto license in Lithuania today, the shift toward EU-wide compliance is not a disruption — it’s a natural progression.

Pre-MiCA License Types

Before MiCA comes into full force, Lithuania’s regulatory framework distinguishes between two main types of crypto licenses:

• Crypto Exchange License — Grants authorization to operate a digital currency trading platform. Licensed entities can facilitate the buying, selling, and exchanging of cryptocurrencies for fiat or other digital assets.
• Crypto Wallet License — Permits the custody and management of users’ cryptocurrency wallets, including holding and securing private keys. This license is essential for firms offering custodial or safekeeping services.

Both licenses fall under the broader umbrella of the VASP license in Lithuania regime, regulated by the Financial Crime Investigation Service (FCIS). They offer the foundational compliance structure for any crypto business in Lithuania looking to operate legally and sustainably prior to full MiCA in Lithuania implementation.

Post-MiCA CASP Registration

The change is already under way: Lithuania’s new crypto law has been signed by the President and entered into force, granting firms a transitional window to 31 December 2025 to secure a CASP registration. This business-friendly update cements Lithuania’s reputation as one of the most attractive EU jurisdictions for crypto companies preparing for MiCA.

Under the new model, businesses will be able to register for the following CASP roles:

• Custody Services — Holding and safeguarding crypto assets or private keys for clients.
• Exchange Services — Facilitating transactions between crypto assets and fiat currencies or between different crypto assets.
• Execution of Orders — Acting on behalf of clients to execute crypto transactions.
• Placement of Crypto Assets — Assisting in the distribution of new tokens, such as through ICOs or other offerings.
• Crypto Portfolio Management — Making investment decisions on behalf of clients within a crypto portfolio.
• Crypto Advice and Brokerage — Providing personalized investment recommendations or brokering deals between buyers and sellers.

The MiCA in Lithuania transition brings legal clarity, enhanced consumer protections, and EU-wide passporting rights — elevating the Lithuania crypto license into a powerful tool for continental expansion.

Key Benefits of Lithuanian Crypto License

Lithuania stands out as one of Europe’s most business-friendly environments for crypto ventures. A major advantage of obtaining a crypto license in Lithuania is the speed and efficiency of the registration process.

Finally, Lithuania’s crypto framework is designed to align seamlessly with European regulations. Licensing is now handled directly by the Bank of Lithuania (BoL), allowing companies to operate legally today while positioning themselves for the upcoming CASP transition under MiCA. This forward-compatible model ensures that companies holding a virtual asset service provider in Lithuania registration today are already on track for full EU-wide compliance and future expansion.

Requirements and Capital Structure

To secure a crypto license in Lithuania, companies must first register a legal entity (UAB) with a local office and appoint a Lithuania-based AML officer. The business must have clear KYC/AML procedures and a documented operational plan.

Previously, Lithuania crypto license requirements included no minimum capital, but under MiCA Lithuania, CASPs must meet capital thresholds from €50,000 to €150,000 depending on the services offered. These ensure consumer protection while maintaining market accessibility.

Submit all compliance documentation to the Bank of Lithuania (BoL) — including detailed information on ownership, risk management, and governance. Meeting these requirements ensures legal status and prepares the crypto business Lithuania for future EU-wide operations.

Legal and Financial Requirements

To obtain a crypto license in Lithuania, applicants must meet a combination of legal and financial standards designed to ensure credibility and compliance with both national and EU-wide regulations. Legally, the company must be registered as a Lithuanian private limited liability company (UAB), have a physical presence in the country, and appoint a qualified local AML/CTF compliance officer. Directors and shareholders must pass background checks and demonstrate a clean financial and criminal record.

Financially, while pre-MiCA frameworks had no capital thresholds, the transition toward MiCA in Lithuania introduces stricter financial requirements. Depending on the type of crypto services provided, virtual asset service providers in Lithuania will need to maintain share capital ranging from €50,000 to €150,000. This capital must be verifiable and deposited in a Lithuanian bank account or electronic money institution.

These requirements ensure that companies operating under a Lithuania cryptocurrency license are well-structured, solvent, and equipped to comply with evolving European crypto regulations.

Operational Compliance Framework

To maintain a valid crypto license in Lithuania, businesses must establish a comprehensive operational compliance framework that aligns with both national and EU-wide standards. This begins with the implementation of detailed AML and KYC policies, which outline how the company verifies client identities, monitors transactions, and prevents illicit activity. These procedures must be regularly updated to reflect changing regulations, especially in the context of MiCA in Lithuania.

Appointing a dedicated compliance officer is mandatory. This individual must possess relevant experience and be responsible for ensuring that all internal practices meet Lithuania’s legal expectations. Their role includes overseeing risk management, maintaining up-to-date regulatory knowledge, and serving as the point of contact with local financial authorities.

In addition to personnel, firms must develop strong internal governance protocols. This includes GDPR-compliant data protection policies, internal auditing mechanisms, and a clear reporting system for financial and transactional disclosures. When properly implemented, this compliance structure ensures that a crypto business in Lithuania operates transparently, legally, and with the confidence of clients, regulators, and partners alike.

Step-by-Step Licensing Process

Obtaining a crypto license in Lithuania is a clearly defined legal process that allows crypto firms to operate within a regulated EU environment. The procedure consists of several mandatory phases — each requiring careful attention to legal, technical, and operational details. Below is a breakdown of each stage:

1. Company Incorporation

The process begins with the registration of a Lithuanian legal entity, most commonly a private limited liability company (UAB). This entity will act as the official crypto business operator. Key steps include:

• Selecting and reserving a company name.
• Drafting and notarizing the Articles of Association.
• Appointing a minimum of one director (can be a foreign national).
• Establishing a legal address in Lithuania.
• Registering the company with the Lithuanian Centre of Registers.

This step typically takes 3 to 5 business days if all documentation is properly prepared.

2. Compliance Documentation Preparation

After incorporation, the applicant must develop a full set of internal compliance policies to meet local and EU-level AML standards. These include:

• Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) program.
• Know Your Customer (KYC) procedures.
• Internal audit and risk management policies.
• Business continuity plan and data security framework.
• Job descriptions for key roles, particularly for the compliance officer.

These documents are essential for the licensing authority to assess the company’s risk posture and readiness for operation.

3. Appointment of Key Personnel and Local Substance Setup

Before filing the application, the company must:

• Appoint a qualified AML Compliance Officer with relevant education and/or experience.
• Ensure all directors and UBOs pass background checks with no prior financial or criminal offenses.
• Demonstrate operational presence through a local office or representative in Lithuania (a virtual office is not sufficient under current VASP requirements).
• Prove technical infrastructure is in place — such as a functioning platform, user interface, or wallet architecture.

These requirements ensure the business is not a shell company, but a functioning entity ready to operate in the EU market.

4. Submission to the Bank of Lithuania (BoL)

The licensing application is now filed directly with the Bank of Lithuania (BoL), which assumed responsibility for crypto-asset service provider (VASP/CASP) supervision under the 2024 Crypto Assets Law. The application package must include:

• Completed application form (submitted via the BoL’s online LBIS portal).
• Full set of AML/CFT and operational policies.
• Personal identification documents and fit-and-proper evidence for all directors, shareholders, and beneficial owners.
• Detailed description of IT architecture, wallet security, and data-protection practices.

After submission, applicants should be prepared to answer follow-up queries or provide supplementary documentation as part of the BoL’s standard due-diligence process.

5. Post-Approval: Operational & MiCA Passporting Readiness

After authorisation, a Lithuanian-licensed CASP must move from paperwork to real business while also leveraging MiCA’s passporting mechanism:

• Activate EU passporting. File a notification with the Bank of Lithuania specifying the other EU/EEA jurisdictions in which you intend to operate; the BoL then forwards this notice to ESMA, allowing you to serve clients across the Single Market without additional licences.
• Launch client-onboarding and KYC workflows. Verify identities, perform risk scoring and ensure continuous screening against sanctions lists.
• Implement real-time transaction monitoring and travel-rule compliance. Deploy tools that flag suspicious activity and attach originator/beneficiary data to transfers.
• Maintain ongoing reporting. Submit periodic AML, prudential and IT-security reports required by the Bank of Lithuania and—once MiCA is fully live—by ESMA’s CASP register.

Being listed in the register is not the finish line; it is the start of a long-term compliance journey that now includes seamless passporting throughout the EU.

Company Registration and Documentation

Obtaining a crypto license in Lithuania starts with establishing a compliant legal entity — typically a Uždaroji Akcinė Bendrovė (UAB), the Lithuanian equivalent of a private limited company. This structure is essential for firms looking to operate as a virtual asset service provider in Lithuania, and it provides the corporate foundation required for both local and cross-border crypto activities. The company must be incorporated with at least one shareholder and one director, and both can be non-residents. However, to meet regulatory expectations and maintain credibility, many firms appoint local directors and maintain a physical office presence within Lithuania.

Once the legal entity is set up, the next step is to gather and prepare an extensive portfolio of documentation. These documents include the company’s Articles of Association, detailed descriptions of the business model, shareholder registry and identification documents for all key stakeholders. The licensing authority also expects a formal business plan, outlining the scope of virtual asset services to be provided, risk management strategies, and projected financials. This level of detail helps regulators evaluate the firm’s seriousness, sustainability, and legal fitness.

A critical part of the process involves demonstrating the company’s ability to meet ongoing compliance requirements. As part of the crypto license lithuania application, firms must draft and submit an Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) policy tailored to the local legal landscape. This includes detailed client onboarding procedures, internal reporting mechanisms, and risk assessment protocols. Additionally, companies must appoint a qualified Compliance Officer responsible for monitoring transactions and ensuring adherence to both Lithuanian crypto regulation and broader EU standards — especially those evolving under MiCA in Lithuania.

License Application and Approval

Licence Application and Approval – current procedure (aligned with the Bank of Lithuania’s official guidance)

Once the legal entity is incorporated and the internal policies are in place, the company submits its CASP licence application to the Bank of Lithuania (BoL) via the LBIS e-portal. The file must contain:

• a completed BoL application form;
• a detailed programme of operations, business plan and organisational chart;
• AML/CFT, internal-control and IT-security policies;
• fit-and-proper evidence for managers, shareholders and beneficial owners;
• proof that the required share capital has been fully paid up and is kept in an EU bank account.

The BoL has 65 working days to assess a complete submission, although the clock stops whenever additional information is requested. Throughout the review the supervisor may arrange clarification meetings or require extra documents; applicants should respond promptly, as slow or vague answers extend the timeline.

Supervision is shared with the Financial Crime Investigation Service (FCIS) only for ongoing AML/CFT monitoring, but all licensing powers now rest with the Bank of Lithuania.

Decision and registration

When the BoL issues a positive decision, the company is entered into the Lithuanian CASP register (and, once MiCA passporting goes live, its details will also be forwarded to ESMA’s EU-wide public list). From that moment the firm may lawfully provide its approved crypto-asset services in Lithuania and, after sending the BoL a simple notification, across other EU/EEA states.

A transitional period runs until 31 December 2025: existing Lithuanian VASPs must obtain a CASP licence or cease operations by that date. New applicants, however, are encouraged to apply under the CASP framework immediately, ensuring full MiCA compliance from day one.

Costs and Investment Requirements

Securing a crypto license in Lithuania is considered one of the more cost-effective options within the European Union. However, applicants should still prepare for both upfront and ongoing financial commitments that reflect the jurisdiction’s regulatory expectations. The initial investment includes company incorporation fees, legal and advisory expenses, compliance documentation drafting, and the appointment of qualified personnel such as a local AML officer and directors.

Additional costs include maintaining a local office (physical or virtual), ongoing AML training for employees, annual reporting, and periodic audits. Businesses should also budget for legal updates to keep policies aligned with MiCA in Lithuania directives. Despite these investments, the overall crypto license in Lithuania pathway remains significant.

Common Challenges and Solutions

While Lithuania offers a streamlined process for obtaining a crypto license in Lithuania, applicants often face several practical and regulatory hurdles along the way. One of the most common challenges is ensuring complete and compliant documentation during the application phase. Authorities require precise AML/KYC policies, proof of local presence, and clean records for directors and shareholders. Incomplete or poorly prepared submissions frequently lead to delays or outright rejection. To overcome this, many firms engage legal advisors familiar with Lithuanian crypto regulation and evolving MiCA in Lithuania standards to pre-audit their materials before submission.

Another recurring issue is opening corporate bank accounts for crypto-related businesses. Despite holding a Lithuania crypto license, many local and EU-based banks remain cautious due to perceived risks. To address this, applicants are encouraged to build transparent financial forecasts, demonstrate compliance readiness, and partner with fintech-friendly institutions or electronic money institutions (EMIs) that cater to the blockchain industry.

Lastly, navigating the shift from pre-MiCA to post-MiCA requirements poses long-term planning challenges.

Why Choose SBSB Fintech Lawyers

Obtaining a crypto license in Lithuania is a strategic move — but navigating the legal, procedural, and compliance landscape requires more than just good intentions. That’s where SBSB Fintech Lawyers stand out. With years of hands-on experience in crypto licensing, VASP registration, and fintech legal services across the EU, SBSB offers businesses a full-spectrum solution tailored to the fast-changing regulatory environment.

SBSB provides end-to-end support that begins with jurisdiction selection and entity formation, moves through document drafting and regulatory alignment, and continues post-licensing with full operational compliance. Whether you’re pursuing a Lithuania cryptocurrency license, a crypto wallet license in Lithuania, or preparing for the upcoming CASP MiCA in Lithuania transition, SBSB brings precision, foresight, and deep legal knowledge to each stage of your journey.

What truly sets them apart is their focus on long-term regulatory sustainability. The firm doesn’t just aim to get your license approved — it helps future-proof your crypto business in Lithuania by implementing adaptable legal structures, preparing for EU-wide conformity, and maintaining ongoing dialogue with local regulators. For any firm aiming to build trust, scale operations, and stay compliant, SBSB Fintech Lawyers offer the reliability and legal depth needed to succeed in one of Europe’s most progressive crypto markets.