Lithuania Crypto Licence Requirements in 2026

A Lithuania crypto (CASP) licence requires a Lithuanian company — typically a UAB — with genuine local substance and the class-based MiCA capital (€50,000–€150,000). Lithuania is the EU’s most-used gateway for a crypto licence — but the requirements file behind a CASP authorisation is a full financial-services file, not the light-touch registration Lithuania was known for before MiCA. Where the old VASP regime asked for little, the Bank of Lithuania now asks for a real business: a Lithuanian company with substance, funded capital, vetted people and a working AML and ICT-resilience programme.

This guide is the requirements checklist we work from on our own desk. It covers exactly what the 2026 Lithuania CASP regime demands — a UAB with genuine local presence, initial capital by service class, fit-and-proper management assessed by the regulator, an MLRO, and a DORA-compliant ICT framework — so you can price the licence on what it actually takes. This is a full EU financial-services regime, and we scope it as one.

The company and local substance

Everything starts with a Lithuanian company. The Bank of Lithuania licenses a Lithuanian legal entity — in practice a UAB — with genuine substance behind it. There is no remote-only route: the applicant is incorporated in Lithuania, keeps a registered office there, and runs a real operating presence, not a virtual address. This is the first hard difference from an offshore VASP, and it is the requirement operators most often underestimate.

Substance is assessed in the round. The regulator wants to see that the business is directed and administered from Lithuania, with the right people performing the core functions locally. A company that exists only on paper, with management and operations sitting elsewhere, does not clear the substance test. For the full picture of what a CASP authorisation buys and how it sits within MiCA, our flagship Lithuania crypto licence overview maps the regime end to end.

Capital by service class

This is the requirement that catches operators pricing Lithuania on the state fee alone. MiCA sets a minimum capital floor by the service class you run, and Lithuania applies it directly. At application you must fund the initial capital and hold it in a bank or e-money account within the EEA — it is working capital of the business, not a fee.

These figures are identical in every EU member state — they come from MiCA, not from national law — so the capital tier is not something you optimise by choosing Lithuania over another EU jurisdiction. What Lithuania offers is speed and a deep fintech ecosystem around the same requirement. Costs sit outside scope here; for the full year-one build, the state fee and running costs, see the Lithuania crypto licence cost guide, and for the capital rules across all three classes our CASP capital requirements primer breaks each one down.

People, governance and fit-and-proper vetting

Under MiCA, the people behind the company are assessed as rigorously as the business itself, and the Bank of Lithuania runs the vetting. This is not a formality — an unresolved file on any one person holds the whole application.

Fit-and-proper management. The people running the CASP are assessed for competence, integrity and relevant experience. The regulator expects a board and senior management with genuine financial-services or crypto backgrounds — not a founder team with no regulated-industry track record. Directors must demonstrate they can actually run a licensed EU financial-services business.

A dedicated MLRO and governance structure. A money-laundering reporting officer is a condition of the licence, backed by a clear governance structure with defined responsibilities and board-level compliance oversight. The MLRO is accountable for the AML programme, transaction monitoring and reporting — and must be a real, appointable person, not a name on an org chart.

Suitability and source-of-funds on shareholders and UBOs. Every ultimate beneficial owner and significant shareholder faces suitability checks and a source-of-funds assessment. You must show not only that the business is funded, but where the money comes from and how the beneficial owners built their wealth. Vague or undocumented wealth is one of the most common reasons a file stalls — the same standard a tier-1 bank applies.

Because these checks take the longest to assemble, especially source-of-funds evidence and documents from multiple jurisdictions, start them on day one rather than treating them as a closing step.

The documents and programme

Alongside people and capital, the Bank of Lithuania reviews a defined set of documents and policies. Filing with any of these missing, or written for a different business model, is what turns a three-month approval into a six-month one. The core pack is:

Three elements deserve emphasis. The AML/CFT policies must be operable documents aligned to the EU’s 5th and 6th anti-money-laundering directives and the Travel Rule — the EU Transfer of Funds Regulation obligation to attach originator and beneficiary data to crypto transfers — because the MLRO is expected to actually run them. The DORA ICT framework covers ICT risk management, incident reporting, resilience testing and third-party ICT oversight, and it applies to every CASP. And where you issue or admit tokens to trading, a MiCA white paper meeting the regulation’s disclosure standard is required on top of the service authorisation. Custody, safeguarding and complaints-handling policies round out the pack, with strict client-asset segregation for any class that touches custody.

Transition, passporting and the VASP deadline

Two dates frame the requirements. First, the VASP-to-CASP transition: under MiCA the national VASP registration is being retired, and the transitional window for previously registered Lithuanian VASPs closes by 1 July 2026 (MiCA Article 143(3)). Existing VASPs must transition to a full CASP authorisation or wind down before then, and new entrants apply directly for CASP — there is no VASP shortcut left. If you hold an old Lithuanian registration, our VASP-to-CASP transition guide walks through the upgrade path and the deadline mechanics.

Second, the reward for meeting the full requirements: passporting. Once the Bank of Lithuania grants the CASP licence, it lets you offer crypto services across all 27 EU member states on a notification basis under MiCA Article 65 — one licence, the single largest regulated crypto market in the world, without applying jurisdiction by jurisdiction. That EU-wide reach is precisely what the substance, capital and DORA requirements are the price of. For how the CASP authorisation itself is structured, see our Lithuania CASP licence explainer.

Assembling the file in the right order

Requirements are one thing; sequence is another. The order that avoids rework is: fix your CASP service classes and the matching capital tier first, then incorporate the Lithuanian UAB, fund the capital in an EEA account and stand up the local office and roles. Assemble every UBO and management fit-and-proper file — source of funds, suitability, experience evidence — in parallel, because they take the longest. Draft the programme of operations, AML/CFT and DORA policies against your actual operating model, not off a template. Only then does the Bank of Lithuania application go in.

None of this is the light registration Lithuania offered before 2025 — and that is the point. The CASP regime asks for a real Lithuanian company, real capital, vetted people and operable AML and ICT programmes, and in exchange gives you a full EU financial-services credential that passports across 27 markets and carries weight with banks, PSPs and institutional partners. Get the file complete and internally consistent the first time and the three-to-six-month window is achievable; file with gaps and it drifts.

Ready to assemble your CASP requirements pack, or want a second opinion on a file you have already started? Our team handles the full Lithuanian substance, fit-and-proper, AML and DORA build end to end and will review any application against the Bank of Lithuania’s expectations before you submit. Book a free consultation and we will tell you exactly what is missing.

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