CASP Licence in Lithuania: The 2026 Guide
The Bank of Lithuania CASP licence explained — what a MiCA Crypto-Asset Service Provider authorisation is, the three capital classes.
Contents
If you want a full EU crypto licence and you want it quickly, the phrase you keep hitting is “CASP in Lithuania”. The phrase names a real authorisation: a crypto-asset service provider licence issued by the Bank of Lithuania under MiCA. This guide sets out exactly what a Lithuanian CASP licence is, which services fall into which capital class, and how the EU passport actually works so you can plan the application around the parts that matter.
Lithuania’s 12-month transitional window for registered VASPs closed at the turn of 2026, and a CASP here is a financial-services licence with substance, capital and a technology-resilience programme. Budgets built for the light-touch registration Lithuania was known for before 2025 do not survive contact with it. Below is the version we scope from.
- A CASP is the MiCA licence for firms providing crypto services; the Bank of Lithuania issues it, and it replaced the old Lithuanian VASP registration.
- Capital is €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3) by service class — set by MiCA, identical in every EU country.
- One CASP passports across all 27 EU states by notification under MiCA Article 65, so you license once for the whole bloc.
- Lithuania offers a ≈3–6 month process on a complete file plus a deep fintech ecosystem; substance, an MLRO and a DORA ICT framework are mandatory.
What a CASP authorisation actually is
CASP stands for Crypto-Asset Service Provider. It is the single licence created by MiCA, the EU’s Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), for any business that provides crypto-asset services to third parties. Before MiCA, each EU country ran its own registration, and Lithuania’s was a national VASP (Virtual Asset Service Provider) registration that became famous for being fast and light. MiCA swept that away and put one harmonised authorisation in its place.
The Bank of Lithuania (Lietuvos bankas) is the competent authority that issues and supervises CASPs in Lithuania. That matters: a CASP is a supervised financial-services licence in the same family as an e-money or investment-firm authorisation, a different order of thing from a company registration or an AML notice. You apply to a central bank, you are assessed on fit-and-proper management and capital, and you report to that regulator for the life of the licence. For the wider picture of how these terms fit together, our explainer on VASP, CASP and MiCA unpacks the vocabulary in full.
The three Lithuania service classes and their capital
MiCA does not charge one flat capital figure. It bundles the ten regulated crypto services into three capital classes, and your minimum own-funds requirement is fixed by the highest-class service you provide. Because these thresholds live in the regulation itself, they are the same in Lithuania as in every other EU state — you do not shop between EU countries for cheaper capital.
| Class | Min. capital | Services covered | Who needs it |
|---|---|---|---|
| Class 1 | €50,000 | Reception & transmission of orders, advice on crypto-assets, execution of orders, placing of crypto-assets, transfer services | Brokers, advisers, order-routers, OTC intermediaries |
| Class 2 | €125,000 | Everything in Class 1 plus custody & administration of crypto-assets and exchange of crypto for funds or other crypto | Custodians, wallet providers, exchange & fiat-to-crypto services |
| Class 3 | €150,000 | Everything in Classes 1–2 plus operating a trading platform for crypto-assets | Exchanges and marketplaces running an order book |
The dividing lines are worth reading carefully. Holding client assets (custody, wallets, safeguarding) or running an exchange desk puts you in Class 2 at €125,000. Operating the matching venue itself, in other words a trading platform with an order book, puts you in Class 3 at €150,000. A pure advisory or order-routing model that never touches client crypto can sit in Class 1 at €50,000. Most exchange businesses that people casually call “a crypto exchange” are Class 2 or Class 3 once you map what they really do; our crypto exchange licence guide walks through that classification for Lithuania specifically, and our CASP capital requirements piece breaks the tiers down further.
The €50k–€150k is a prudential floor, held as own funds or insurance, and none of it goes to the regulator. MiCA Article 67 sets the requirement at the higher of your class floor or one quarter of the prior year’s fixed overheads, so a larger operation may need more. We model the real figure against your class and cost base in the requirements review before you commit.
How EU-27 passporting works from Lithuania
This is the reason to license in the EU at all. Under MiCA Article 65, an authorised CASP that wants to provide services in other member states does not re-apply anywhere. It notifies the Bank of Lithuania of the host states and services it intends to offer; the Bank of Lithuania forwards that notification to the competent authorities in those states; and after a short notice period the firm can operate there. In this way one authorisation reaches up to 27 markets by notification alone.
In practice that turns a single Lithuanian CASP into a passport for the entire European single market. You still respect each host country’s local marketing and consumer rules, and you still geo-block jurisdictions you are not authorised in, but you are not filing 27 licence applications or funding 27 lots of capital. That single-licence economics is the whole case for the EU route, and it is what our Lithuania crypto licence pillar covers end to end.
Why operators choose Lithuania for a CASP
If the capital and the passport are identical EU-wide, why choose Lithuania? Two things: a predictable process and the ecosystem.
On process, the Bank of Lithuania built capacity for fintech authorisations well before MiCA, and we plan for three to six months on a complete file. It has not been a volume route under MiCA so far: ESMA’s register listed 6 Lithuanian CASPs out of 352 in our 20 September 2026 snapshot, against 94 in Germany. On ecosystem, Lithuania already hosts one of Europe’s deepest benches of e-money institutions, payment firms and crypto companies, which means crypto-aware banking and EMI/PI partners, specialist compliance talent and auditors who have done this before are all on the ground. Add a 17% corporate tax rate from 2026 (7% for qualifying small companies) and modest state fees, with the Bank of Lithuania application fee starting from around €2,300, and the total picture beats most alternatives on time-to-market rather than on any single line item.
The practical trade-off is substance. A Lithuanian CASP applicant is a Lithuanian company, typically a UAB (uždaroji akcinė bendrovė), with a real registered office, genuine local operating presence, fit-and-proper management the regulator can assess, and a resident-anchored AML function. This is not an offshore shell with a nameplate; the Bank of Lithuania tests for real substance, and thin structures get sent back. If you are weighing this against the neighbouring Baltic option, our Estonia vs Lithuania comparison sets the two side by side.
DORA, AML and the compliance backbone in Lithuania
A CASP is a supervised licence, so the obligations run past day one. Two frameworks sit underneath every Lithuanian CASP.
AML/CFT. You need a dedicated money-laundering reporting officer (MLRO), customer due-diligence, transaction monitoring and suspicious-activity reporting aligned to the EU’s 5th and 6th AML directives, plus the Travel Rule — originator and beneficiary data attached to crypto transfers under the EU Transfer of Funds Regulation. This is the operational heart of the licence and the part regulators scrutinise hardest.
DORA. The Digital Operational Resilience Act, Regulation (EU) 2022/2554, has applied to CASPs since 17 January 2025. It requires an ICT risk-management framework, incident classification and reporting, resilience testing, and oversight of your third-party technology providers. A CASP file submitted without a credible DORA programme is incomplete, and this is one of the most common reasons applications stall. On top of both sit MiCA’s own conduct rules: client-asset safeguarding and segregation, conflict-of-interest management, disclosures and complaints handling.
From the old VASP registration to CASP
For years, Lithuania’s draw was a fast national VASP registration with light requirements. MiCA ended that model. The national VASP regime has been retired: under MiCA Article 143(3) Lithuania chose a 12-month transitional window for previously registered VASPs, which closed at the turn of 2026 (the EU-wide outer limit was 1 July 2026). Since then CASP authorisation has been the only route, and firms that leaned on the old registration need full MiCA authorisation to keep operating.
Firms that held a legacy registration needed to scope their service classes and capital, stand up the substance and the DORA and AML programmes, and file for CASP well before that date. Our VASP-to-CASP transition guide maps that migration step by step. New entrants skip the legacy stage entirely and apply for CASP directly.
The upside for the extra rigour is real. A Bank of Lithuania CASP carries weight with banks, PSPs, auditors and institutional counterparties in a way an offshore registration never did, and it opens the whole EU by notification. It costs more in substance and capital than the old world, and what it buys is a durable, passportable EU credential.
If you are deciding between service classes, weighing Lithuania against another EU or offshore home, or working out where a legacy VASP stands after the July 2026 deadline, we will map it to where your users and your capital actually sit and quote the real number. Book a free consultation and we will scope your CASP file end to end.
Frequently asked questions
What is a CASP licence in Lithuania?
A Crypto-Asset Service Provider authorisation issued by the Bank of Lithuania under MiCA (Regulation (EU) 2023/1114). It replaced the old Lithuanian VASP registration and, once granted, lets you provide crypto services across all 27 EU member states on a notification basis under MiCA Article 65 — one licence for the whole single market.
How much capital does a Lithuania CASP need?
It depends on your service class: €50,000 for Class 1, which covers reception/transmission, advice, execution and placing; €125,000 for Class 2, which adds custody and exchange; or €150,000 for Class 3, which covers operating a trading platform. These tiers are set by MiCA and are identical in every EU country. The ongoing requirement is the higher of that tier or a quarter of the previous year's fixed overheads, met with own funds, an insurance policy or a mix.
How long does a CASP licence take in Lithuania?
Typically three to six months on a complete, well-prepared file. The Bank of Lithuania runs one of the shorter CASP review queues in the EU, but the real timeline depends on your service classes, documentation quality and how quickly you answer the regulator's review questions.
Can a Lithuania CASP passport into the rest of the EU?
Yes. Under MiCA Article 65, an authorised CASP notifies the Bank of Lithuania of the host states it wants to serve, the regulator passes that notification to those states, and you can then provide services there without a separate application. That single authorisation covering the EU-27 is the main argument for licensing in the EU rather than offshore.
Do I need a Lithuanian company and DORA compliance?
Yes to both. MiCA requires genuine local substance in the form of a Lithuanian company (usually a UAB), qualified management and an MLRO. Since 17 January 2025 it has also required a DORA-compliant ICT risk-management and incident-reporting framework. An offshore shell will not pass the Bank of Lithuania's fit-and-proper and substance assessment.
Is a Lithuanian VASP registration still available?
No. MiCA replaced national VASP registrations with the CASP licence. The transitional window for previously registered VASPs closed on 1 July 2026 (MiCA Article 143(3)). New entrants apply directly for CASP authorisation, and there is no faster legacy VASP route left.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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