Crypto Exchange License in Lithuania: CASP Classes

Lithuania closed its door earlier than almost anyone else. The transitional period under the Law on Markets in Crypto-assets, which let nationally registered providers keep operating under Financial Crime Investigation Service (FNTT) supervision, ended on 31 December 2025. Since then there has been no grandfathered right to serve clients while an application sits with the regulator — a firm without a Bank of Lithuania authorisation has lost the right to operate.

That single fact changes how a crypto exchange in Lithuania is scoped in 2026. You are no longer converting an existing business on a running clock; you are applying cold, with no revenue permitted until the licence is granted. Below is what that means for the class you pick, the payments authorisation most exchanges miss, and what the Bank of Lithuania actually reviews.

Which class you need — and why it is not a Lithuanian question

MiCA lists ten crypto-asset services. An exchange normally touches three, and two of them set the capital floor.

If the customer transacts with you at your quoted price, that is the exchange service. If users post orders and your engine matches them against each other, you are operating a trading platform and MiCA treats you as market infrastructure rather than a shop — which is why it sits a tier higher and carries market-integrity duties. Most exchanges do both and authorise at the higher tier.

None of that is specific to Lithuania: the classes and the capital floors come straight from the regulation and apply identically in Dublin, Vilnius or Valletta. We keep the mechanics in one place rather than repeating them per country — the full tier table, the own-funds override and the fixed-overheads calculation are in CASP capital requirements, and the regime overview is in MiCA explained. What follows is what is actually Lithuanian.

The EMT trap: your exchange may need a payments licence too

This is the detail that catches exchange operators, and it is a genuinely local supervisory position rather than a MiCA universal.

The Bank of Lithuania has taken the view that crypto-asset services involving e-money tokens constitute payment services. Providers offering them were required to obtain an additional payment institution authorisation by 1 March 2026, or to transfer those services to an entity that already holds the relevant authorisation.

For a trading venue this is not an edge case. If your book quotes pairs against a euro-denominated e-money token, if you offer EMT transfers between users, or if your on-ramp routes customer euros through an EMT leg, you are potentially running a payment service alongside your CASP activity. The consequences are structural, not cosmetic: a second authorisation, a second set of prudential requirements, and a different supervisory relationship — or a group structure that puts the payments leg in a licensed entity and the trading leg in the CASP.

What the Bank of Lithuania reviews, and on what clock

The Bank of Lithuania is the competent authority for CASP authorisation, and it distinguishes between two routes in. A legal person that is not one of the financial institutions listed in MiCA Article 60 needs a licence. An existing credit institution, investment firm, e-money institution, CSD, UCITS/AIF manager or market operator instead operates under an exemption for defined services, subject to approval of the new business plan — a credit institution may provide any crypto-asset service, while an e-money institution is limited to custody and transfers for the e-money tokens it issues. If you already hold a Lithuanian EMI or investment-firm licence, check that table before assuming you need a full CASP file.

The statutory timetable is the same everywhere in the EU, and worth stating plainly because the market is full of claims to the contrary:

• 25 working days from receipt for the regulator to assess whether the application is complete against the information listed in MiCA Article 62(2). If it is not, the regulator sets a deadline for the missing information — and may refuse to review an application that is still incomplete when that deadline passes.
• 40 working days from receipt of a complete application to assess whether the applicant complies with Title V.

Read those two together and the practical lesson is clear. The only lever you control is completeness. An exchange file is heavier than most because it stacks trading-venue documentation on top of the standard CASP pack: platform operating rules, orderly-trading and halt mechanisms, market-abuse detection, pre- and post-trade transparency, plus custody segregation, a client position register, DORA ICT resilience and the AML framework with a named MLRO.

Substance in Lithuania is a real test

The applicant is a Lithuanian UAB with genuine operations. In practice that means a real office, management that is fit and proper and demonstrably experienced in the activity being licensed, and the people performing the regulated functions actually located in Lithuania. A registered address and a non-resident director do not survive the review.

This matters more now than during the transitional era. The old FNTT-supervised regime was an AML registration; the number of registered providers ran into the hundreds and the bar for entry was low. The Bank of Lithuania authorisation is a financial-services licence, assessed as one — and the firms that struggled after 31 December 2025 were largely those that had built for the registration standard rather than the licensing one.

Why Lithuania, honestly

The case for Lithuania is not a faster regulator — the clock is MiCA’s and it is identical across the union. The case is the ecosystem around the licence. Lithuania hosts one of the EU’s deepest benches of EMI and payment institutions, which matters enormously for an exchange, because the hardest part of launching a venue is rarely the authorisation itself: it is the fiat rails, the banking relationships and the auditors who understand the model. In a country where crypto-adjacent financial firms are ordinary rather than exotic, those relationships are realistically available to a licensed CASP.

The flip side is the one stated at the top. Lithuania closed its transitional window before most of the EU and applied a payments overlay to e-money-token activity that several other member states have not. It is a jurisdiction that rewards a well-prepared file and punishes an improvised one.

If you are scoping a Lithuanian exchange, the two questions to answer before anything else are which services actually sit inside your model and whether any of them touch e-money tokens. Book a free consultation and we will map the licence perimeter, the payments question and the capital plan to what you are really building.

Christina S.

Crypto Licensing · Vantegris

Part of the Vantegris desk that runs these licences end to end — writing from live applications across 40+ jurisdictions, not recycled marketing. Reviewed by Vladyslav S. (Compliance & Legal).

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This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.