Crypto license in Lithuania

Disadvantages of the сrypto license in Lithuania

There are still some drawbacks to consider, and here they are below.

High regulatory requirements

MiCA rules, which also apply in Lithuania, establish fairly strict requirements for crypto-companies.

Among the main conditions:

• the presence of an authorized capital from 125,000 euros (depending on the type of activity);
• implementation of full-fledged AML/KYC procedures;
• creation of a local corporate governance system.

After obtaining the crypto exchange license in Lithuania, the company must also regularly submit reporting, undergo audits, maintain compliance processes, and retain qualified personnel. For small companies, this can become a significant financial burden.

In addition, the legislation requires the appointment of local managers, in particular a CEO, MLRO, and the person responsible for AML, which also increases costs.

Limited global recognition

Even though the Lithuanian CASP license is very prestigious, non-EU markets like the US, UK, China etc. do not accept it because 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 in 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 exchange license

Today in Lithuania, a single crypto-license actually operates — CASP in accordance with MiCA requirements. However, historically several separate types of permits existed.

Virtual Currency Exchange Operator License (VCESP)

This license allows companies to open crypto-exchanges, carry out the exchange of cryptocurrencies among themselves or for fiat currencies, and perform operations on behalf of clients.

Crypto-Wallet Provider License (VCWSP)

Such a permit was obtained by companies that stored clients’ crypto-assets, managed their wallets and private keys.

CASP License

Starting from 2025, Lithuania issues only the CASP license in accordance with MiCA requirements.

It covers all types of activities with crypto-assets that previously required separate licenses. Regardless of whether a company works as a crypto-exchange, custodian, broker, or manager of crypto-portfolios, to conduct activity it is necessary to obtain specifically the CASP license.

In the Lithuanian system, a white-label model or sub-licensing is not provided — each company receives a license directly from the regulator.

Requirements for obtaining a crypto exchange license in Lithuania

Companies that plan to obtain the status of a virtual asset service provider (VASP) must meet a number of requirements.

Corporate structure and authorized capital

The applicant must be registered as a legal entity in Lithuania (most often in the form of a UAB — an analogue of an LLC). One of the main requirements is a sufficient capital size: previously, €125,000 was required for a crypto exchange, and according to MiCA rules, this amount is from €50,000 to €150,000 depending on the list of services. Funds must be actually available and confirmed by bank statements or audit reports.

Local presence and team

According to MiCA, the company must have at least one director working in the EU, as well as an official office on the territory of the European Union. Lithuanian legislation also requires the appointment of key officers, including a chief executive officer (CEO), a chief compliance officer (CCO), and a money laundering reporting officer (MLRO). In small companies, individual functions can be combined, however, the regulator expects that qualified specialists will be responsible for them. The minimum requirement is the appointment of a competent AML/KYC officer.

Verification of owners and management

All owners, directors, and managers undergo a comprehensive check of business reputation. The package of documents includes certificates of no criminal record, confirmation of financial solvency, and resumes. The Bank of Lithuania may refuse to issue a license if it detects criminal records, serious financial problems, or other risks. Also, ultimate beneficial owners (UBOs) must be disclosed, especially those who own 10% or more of the company.

Business plan and documents

The company must submit a detailed business plan with a description of future activities. To the application are usually attached constituent documents, organizational structure, internal policies (AML/CFT, KYC, corporate governance), main agreements, accounting documents, and confirmation of the presence of capital. Special attention is paid to how the company plans to conduct customer identification, transaction monitoring, and risk management.

Technical infrastructure in accordance with the DORA regulation

The crypto platform must be reliable, secure, and resilient to cyber threats. As a rule, IT infrastructure must be located in the EU (and in separate cases — directly in Lithuania), use modern encryption tools, SSL protection, backup, and other cybersecurity mechanisms. Although the law does not detail all technical requirements, in practice the regulator expects that the company will be able to prove the stability and continuity of the work of its IT systems.

AML/KYC and risk management system

The company must implement a full-fledged system for countering money laundering and terrorist financing in accordance with EU standards. This includes customer verification (KYC), ongoing monitoring of operations, reporting of suspicious transactions, checking of sanctions lists and politically exposed persons (PEPs). Before obtaining a сrypto license in Lithuania, all internal policies, procedures, and staff training programs must be ready. It is also necessary to implement a risk management system, business continuity plans, audit logs, and conflict of interest policies.

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

During budget planning, it is worth considering several main cost items.

State fees and fee to the regulator

In Lithuania, a significant state fee for submitting an application is absent. At the same time, the Bank of Lithuania charges a fee for issuing a license — approximately €2,425. It is paid after preliminary approval of the application, before the final processing of the license. An annual fixed payment for maintaining the license is not provided.

Authorized capital

The biggest financial requirement is providing the necessary authorized capital (for example, €125,000). These funds are not necessarily used in operational activities, however, they must be contributed as capital of the company and remain available until the completion of the licensing process.

Corporate and other taxes

Lithuania’s corporate income tax is 17% 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 17%. Overall, the tax burden is considered light compared to many jurisdictions.

Compliance and professional support

In addition to payments to the regulator, the company must budget for legal support, audit of AML procedures, checking of IT systems, accounting services, and consulting services. For example, an independent audit of compliance or cybersecurity systems can cost several thousand euros per year. Preparation of documents and licensing support by specialized consultants or lawyers usually costs from €3,000–5,000 and more.

Estimated budget for the first year

Depending on the scale of the business, starting costs may include:

• authorized capital — about €125,000;
• license fee — approximately €2,400;
• launch of the company (legal, accounting, and IT services) — about €40,000;
• annual costs for compliance, audit, and consultations — from €5,000–10,000.

The actual budget depends on the structure of the company, business model, and list of services.

Maintaining a crypto license after obtaining

Obtaining a license is only the first stage. In the future, the company must constantly comply with the requirements of the regulator.

Regulatory reporting

Licensed CASPs regularly submit reports to the Bank of Lithuania. Usually, these are annual financial statements, AML reports, information on transaction volumes, and notifications of changes in corporate governance. In order not to miss the established deadlines, companies are recommended to keep a separate compliance calendar.

Continuous fulfillment of AML/KYC requirements

Control over customers does not end after their registration. The company must continuously verify customers, monitor transactions, and report suspicious operations. In case of detecting atypical activity, information must be transferred to the financial intelligence unit (FIU), as a rule, within 24 hours. Data on customers and executed transactions must be stored for at least five years. The Bank of Lithuania or other competent authorities can check these procedures at any moment.

Audit and regular checks

Although special mandatory crypto audits do not exist in Lithuania, in practice, licensed companies regularly undergo independent checks of AML systems, information security, and internal control. Financial statements must also be checked every year by an authorized auditor.

Notification of changes

Any significant changes in the company’s activity (for example, a change of owners, CEO, or MLRO) must be coordinated in advance with the Bank of Lithuania. The company must continue to correspond to that structure and model of work that were approved during licensing.

Customer protection

Although there are no separate special rules regarding the protection of crypto service users in Lithuania, licensed companies are obliged to comply with MiCA requirements regarding transparency, honest provision of services, and proper management of customer funds. This implies clear conditions for using the service, proper protection of customer assets, and an officially approved procedure for reviewing complaints.