Crypto Exchange License in Lithuania: MiCA CASP Classes (2026)

If you want to run a crypto exchange in Lithuania, the first thing to get right is not the paperwork — it is which service you are actually providing. “Crypto exchange license lithuania” is one search term, but MiCA splits the activity into two different CASP service classes with two different capital floors, and picking the wrong one means either overpaying on capital or, worse, operating outside your authorisation. In our practice the exchanges that stall are the ones that treated “exchange” and “trading platform” as the same thing.

They are not. Below is exactly which class an exchange needs, the difference between an exchange service and a platform under MiCA, and the extra obligations a platform operator carries — so you scope the Bank of Lithuania file correctly the first time.

Which CASP class does an exchange actually need?

MiCA lists ten crypto-asset services, and an exchange touches three of them. The two that decide your capital tier are the exchange service and the trading-platform service; custody is the third, and almost every exchange triggers it too.

If your model is a simple buy/sell desk — the customer converts euros to bitcoin at your quoted price, or swaps one token for another — that is the exchange of crypto-assets service and it sits at Class 2, €125,000. If you run an order book where users post bids and asks and your engine matches them, you are operating a trading platform and that is Class 3, €150,000. Because a real exchange usually does both — a matching venue plus instant convert and fiat on/off-ramps — most applicants authorise at Class 3 and add the exchange and custody services under the same CASP. That is the standard shape of a Lithuanian exchange file, and it is the one we scope by default in the Lithuania crypto licence engagement.

Exchange service vs trading platform under MiCA

The distinction is not cosmetic — it changes who bears risk and what the Bank of Lithuania expects to see.

An exchange service makes you the counterparty to the trade. The client transacts with you: you quote a price, you take the other side, and the deal is bilateral. Your obligations centre on a firm, non-discriminatory commercial policy and clear pricing.

Operating a trading platform makes you a venue operator. Third parties trade against each other; you provide the order book and the matching engine, but you are not the counterparty to each fill. Because you now set the rules of a market and multiple users interact inside it, MiCA loads the platform with market-integrity duties that an exchange desk does not carry. This is why Class 3 exists as a separate, higher tier — you are running market infrastructure, not just a shop.

The extra obligations a platform operator carries

Where an exchange desk mainly proves fair pricing and clean AML, a trading-platform operator has to demonstrate it can run an orderly market. In practice the Bank of Lithuania will want to see, at minimum:

• Operating rules for the platform — the crypto-assets admitted to trading, the fee structure, and the objective criteria for access, all published and applied without discrimination.
• Orderly-trading systems — resilient matching infrastructure with capacity limits, the ability to reject or cancel orders, and mechanisms to suspend or halt trading in disorderly conditions.
• Market-abuse prevention — arrangements to detect, prevent and report insider dealing and market manipulation, with records kept and suspicious activity escalated.
• Transparency — public quotes and depth on the order book (pre-trade) and prompt publication of executed prices and volumes (post-trade).
• No prohibited self-dealing — MiCA restricts a platform operator from dealing on own account against its own book, so your governance has to keep the venue and any proprietary activity properly separated.

None of this replaces the general MiCA conduct duties every CASP owes — acting honestly and in clients’ best interests, managing conflicts, honest marketing, and complaints handling. A platform operator carries the general conduct rules and the venue-specific ones.

Custody and asset segregation

The moment your exchange holds client crypto — and virtually every exchange does, because users keep balances on the platform — you are also providing the custody and administration service (Class 2). That brings its own hard obligations:

• Client crypto-assets held segregated from the firm’s own assets, so client holdings are never commingled with company funds.
• A position register per client, kept accurate and reconciled, so ownership is provable at any time.
• Liability for loss of client crypto attributable to an incident within your control, which is exactly why key management, wallet architecture and the DORA ICT-resilience programme sit at the centre of the review.

Because custody, exchange and platform operation stack together in a live exchange, the capital floor that governs is the highest class you hold — €150,000 for a Class 3 operator — and the Bank of Lithuania can require own funds equal to one-quarter of your prior-year fixed overheads if that produces a larger number. We model the real figure against your service mix before you commit; the detail sits in the Lithuania crypto licence cost breakdown.

EU-27 passporting, DORA and AML

The reason to license an exchange in Lithuania rather than offshore is reach. A CASP authorisation passports across all 27 EU member states by notification under MiCA Article 65 — you file once with the Bank of Lithuania and notify the host states you intend to serve, instead of applying licence-by-licence. For an exchange that wants the single market, that is the whole game, and it is the core difference explored in what a crypto exchange licence actually is.

Two horizontal regimes apply on top of the class-specific rules. DORA has been in force since 17 January 2025 and requires a full ICT risk-management framework, incident reporting, resilience testing and oversight of third-party technology providers — non-negotiable for a venue running a matching engine. And AML/CFT to the EU’s directives, with a dedicated MLRO and the Transfer of Funds Regulation (the Travel Rule) on crypto transfers, underpins the whole authorisation. The applicant itself is a Lithuanian UAB with genuine substance — a local office, qualified and fit-and-proper management, and real operations in Lithuania — not an offshore shell.

Why Lithuania for an exchange

Lithuania has become the EU’s most-used CASP gateway for one practical reason: it pairs speed with a deep fintech ecosystem. The Bank of Lithuania runs one of the shorter CASP review queues in the EU — realistically three to six months on a complete file — and the country already hosts a large bench of EMI, PI and crypto firms, which means crypto-aware banking neighbours, specialist talent and auditors who understand the model. Corporate tax is a competitive 15%, with a reduced 5% band for qualifying small companies in their early years.

For a trading-platform operator, that ecosystem matters as much as the timeline: the hardest part of launching an exchange is rarely the licence itself but the fiat rails and banking around it, and Lithuania is one of the few EU jurisdictions where those relationships are realistically available to a licensed CASP. We build the application, the market-integrity and custody controls, the DORA and AML frameworks, and the banking together — because for an exchange they only work as one package.

If you are scoping a Lithuanian exchange and need to fix the right CASP class before you spend on capital, book a free consultation and we will map the services, the tier and the timeline to your model.

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