Lithuania VASP to CASP Transition: 2026 Deadline Guide

For years, Lithuania’s national crypto-asset registration was the pragmatic way into Europe: a light-touch VASP entry with modest requirements and a short queue. That regime is being switched off. Under the Markets in Crypto-Assets Regulation (MiCA), the national VASP registration is replaced by a single EU credential — the Crypto-Asset Service Provider (CASP) licence — issued in Lithuania by the Bank of Lithuania. If you held an old Lithuanian VASP registration, the clock ran out on 1 January 2026 — earlier than the 1 July 2026 outer limit MiCA allowed, because Lithuania chose a shorter transitional period.

In our practice, the VASP holders who come out of this cleanly treat it as a corporate re-authorisation project with a hard deadline, not a renewal. The ones who wait discover the problem the way most compliance problems surface — a banking partner asks for a licence reference that resolves to a regime that no longer exists. This guide is the practical path from a lapsing VASP registration to a full CASP authorisation in 2026.

Why the VASP registration is closing

The old national regime and the new EU one answer to different masters. A VASP registration was a Lithuanian creation, supervised locally, and its authority stopped at the border. MiCA replaced that patchwork of national crypto rules with one directly applicable EU regulation, and one licence type that carries across the whole bloc. There is no mechanism to keep both running in parallel indefinitely — the national regime was always designed to sunset into MiCA.

Article 143(3) of MiCA is the specific provision that matters to you. It grants CASPs that were already providing services under national law before MiCA applied a transitional period in which they may continue on the old basis — and Lithuania did not take the full runway. While MiCA’s outer limit is 1 July 2026, Lithuania legislated a shorter transitional period that closed on 1 January 2026. That date has passed: a legacy Lithuanian VASP registration is no longer a durable legal footing, it is a lapsed permission, and providing crypto-asset services in Lithuania without a CASP authorisation is unlawful financial activity rather than a paperwork gap. You are not being asked to renew a registration. You are being asked to obtain a different, heavier credential in its place. Our MiCA regulation explained guide covers the regime change in full — this article focuses on what a Lithuanian VASP holder specifically has to do about it.

What a VASP holder must actually do now

Converting to a CASP is a substance exercise, not a form. The registration many operators hold today was granted with comparatively little in the way of local presence, governance or capital. A CASP authorisation is a full financial-services licence, and the Bank of Lithuania assesses it as one. The applicant is a Lithuanian UAB with genuine substance — real management in Lithuania, a real office, and a real compliance function, not a nameplate.

The core build looks like this:

• A Lithuanian company (UAB) as the licence applicant, with a registered office and genuine operating presence in Lithuania.
• Class-based initial capital of €50,000, €125,000 or €150,000 depending on the CASP service class, held in an EEA bank or e-money account.
• Fit-and-proper management assessed by the Bank of Lithuania, plus a dedicated MLRO and board-level compliance oversight.
• AML/CFT policies aligned to the EU’s fifth and sixth anti-money-laundering directives and the Travel Rule (originator/beneficiary data on transfers).
• A DORA-compliant ICT framework — risk management, incident reporting, resilience testing and third-party ICT oversight, applicable to CASPs since 17 January 2025.
• A programme of operations, business plan and financial projections, plus custody, safeguarding and complaints-handling policies.

Compared with the registration era, when little of this was asked of you, it is a real project — and the ICT and AML build are the long poles. The full breakdown is in our Lithuania crypto licence requirements guide, and the licence itself is covered end to end in our Lithuania CASP licence explainer. The point here is to start the corporate and compliance work now, because none of it compresses into the weeks before the deadline.

Old VASP registration vs new CASP licence

Lithuania closed early — on 1 January 2026 — and what a lapse costs

VASP holders tend to underestimate this because the registration still “works” today. The exposure is twofold. First, regulatory: now the transitional window has shut, providing crypto-asset services on a lapsed registration is unauthorised activity, and the Bank of Lithuania can act on it. Second — and usually faster — commercial: crypto-friendly banks, EMI and payment-institution partners verify authorisation status directly, and a registration that resolves to a sunset regime simply fails that check. When it fails, settlement holds and account closures follow quickly, and unlike a fine there is no negotiating your way out of a bank’s risk decision.

There is also a scope cost to drifting. A lapsed or national-only permission cannot passport, so any EU expansion you had planned stalls until the CASP is granted. If your registration ever does lapse before the new licence is live, you are looking at a renewal-and-reauthorisation exercise under time pressure — the exact situation our crypto licence renewal in Europe guide exists to help operators avoid. The cheapest version of this transition is the one you start early.

What changes commercially once you hold a Lithuania CASP

The upside of the work is reach. A national VASP registration only ever authorised you in Lithuania; every other EU market was closed to you, or required its own local registration. A CASP authorisation passports across all 27 member states under MiCA Article 65 — you apply once in Lithuania, notify the host states you want to serve, and operate EU-wide from a single licence. For any operator with ambitions beyond one country, that is a step change in addressable market, not a compliance chore.

The credential also carries more weight. A Bank of Lithuania CASP authorisation is a recognised EU financial-services licence, and it opens doors a light-touch registration never did — crypto-friendly banking and EMI/PI partners, institutional counterparties, auditors and listing venues all read a MiCA CASP differently from a national VASP entry. In our experience that shows up as smoother onboarding and a shorter due-diligence cycle when you open new banking or payment relationships. The substance you build for the licence — the UAB, the MLRO, the DORA and AML stack — is the same foundation you reuse to add service classes or scale into new markets later. Our Lithuania crypto licence pillar sets out the full picture of what the authorisation unlocks, and once you are live you will want to keep your public status clean and verifiable — the mechanics of which we cover in the Lithuania crypto licence check guide.

Convert in Lithuania, or relocate?

Not every VASP holder should assume Lithuania is still the answer — but for most already established here, it is. The honest question is where your genuine substance sits. If your management, staff and banking are already in Lithuania, converting the existing UAB into a CASP applicant is the cleanest route: you are adding capital, governance and policy to a business that already exists, and the Bank of Lithuania runs one of the shorter CASP review queues in the EU. Relocation only earns its cost if your real operating centre is somewhere else, in which case it may be more honest to license where your people and controls actually are.

Either way, the decision is a modelling exercise, not a default. The wrong move is to do nothing and let the 1 July 2026 deadline decide for you — because standing still converts a manageable, planned re-authorisation into an outage. Whether you convert in Lithuania or license elsewhere, the one option that isn’t safe is running past the window on a registration that has lapsed. Book a free consultation and we’ll size the CASP conversion against your service classes, capital, banking needs and timeline before the clock runs down.

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).

Full profile Book a free consultation

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