BLOCONS

Lithuania closed its VASP regime on 1 January 2026 — six months before the EU deadline required. The cheap Lithuanian crypto company is gone. What exists now is a CASP authorisation from the Bank of Lithuania under MiCA: the same rulebook, the same capital and the same file as anywhere else in the Union.

What actually happened

For years Lithuania was the volume jurisdiction. A registered company, a resident AML officer, a modest fee, and several hundred VASPs appeared on the register. That model rested on a national regime, and MiCA replaced national regimes with one European authorisation. Lithuania ended its transitional period on 31 December 2025 — earlier than the 1 July 2026 backstop most member states used. Since 1 January 2026, providing crypto services in Lithuania without a MiCA authorisation is simply unlawful.

If you are reading an offer for a «Lithuanian crypto licence in three weeks for a few thousand euro», it is describing a product that no longer exists. Ask the seller for the authorisation number in the Bank of Lithuania's public register.

What replaced it

A CASP authorisation issued by the Bank of Lithuania. It covers custody, exchange of crypto-assets for funds or other crypto-assets, operating a trading platform, execution, reception and transmission of orders, placement, transfers, portfolio management and advice — and it passports to the whole European Economic Area by notification.

  • Own funds — € 50 000 for advice and order execution, € 125 000 for custody or exchange, € 150 000 for a trading platform; or one quarter of the previous year's fixed overheads, whichever is higher.
  • Timeline — the regulator has 25 working days to confirm completeness and 60 working days to decide; preparation takes three to six months. Four to twelve months in total.
  • Substance — management resident in Lithuania, real premises, staff, decisions taken locally.

Does Lithuania still make sense?

Sometimes, and for reasons that have nothing to do with the old price list. The Bank of Lithuania supervises a large fintech population, its e-money and payment licensing practice is one of the most active in the Union, and if your model combines crypto with payment services that concentration of expertise in one regulator is genuinely useful. Costs are lower than in western Europe, correspondence is workable in English, and the country is inside the euro area.

It stops making sense if you were choosing Lithuania because it was easy. That reason has expired everywhere in the Union at once, and choosing on price now leads to a rejected file rather than a cheap licence.

What the Bank of Lithuania checks

  • fit and proper assessment of managers and beneficial owners, including source of funds;
  • substance: local management, premises, key functions performed in the country;
  • AML/CFT programme, MLRO, transaction monitoring, sanctions screening, Travel Rule;
  • ICT and operational resilience under DORA, outsourcing, incident reporting;
  • segregation and safekeeping of client assets, custody policy, key management;
  • governance, conflicts of interest, complaints, marketing communications;
  • capital, prudential safeguards and a wind-down plan.

If you hold an old Lithuanian VASP registration

It stopped being a permission on 1 January 2026. There is no conversion. Three practical routes exist: file for a CASP authorisation in Lithuania, file in another member state whose regulator fits your model better, or wind down the regulated activity in an orderly way while you decide. We will tell you which of the three your file actually supports before you pay us anything.

How we work on it

1. Model review, free

What you do, which MiCA service classes it maps to, and whether Lithuania is the right regulator for it.

2. Structure and substance

Company, resident management, office, staffing, budget, capital.

3. The application file

Programme of operations, AML/CFT framework, ICT and security, custody and safeguarding, business continuity, wind-down plan, financial projections.

4. Filing and correspondence

We file with the Bank of Lithuania and carry the questions through to a decision.

5. After authorisation

Reporting, MLRO support, passporting notifications, changes of control and service classes.

Frequently asked questions

Can I still buy a Lithuanian VASP company?
You can buy the company, but not a permission — the VASP register stopped conferring rights on 1 January 2026. Any offer presenting it as an operating licence is misdescribing what is being sold.
Is Lithuania cheaper than Estonia or Malta?
Capital and documentation are set by MiCA and identical. Local costs differ modestly. The old price gap disappeared with the national regimes.
Why did Lithuania close earlier than other countries?
Member states could choose how long to run the transitional period. Lithuania ended it on 31 December 2025; several others ran to 1 July 2026.
Can a Lithuanian CASP serve clients across the EU?
Yes, through passporting notification — one authorisation, all member states.
We are outside the EU and only have EU customers. Do we need this?
Yes, unless the client approached you entirely on their own initiative. Soliciting EU clients without authorisation counts as unauthorised activity.

Reviewed: August 2026, against Lithuanian transitional legislation ending 31 December 2025 and Regulation (EU) 2023/1114 (MiCA).

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