Obtain a MiCA licence in Lithuania

All business entities whose operations are related to the issuance, placement, and exchange of crypto-assets are obliged to obtain a MiCA licence in Lithuania. Since 2020, Lithuania has demonstrated steady growth towards the formation of a modern legal environment for the fintech sector. State authorities, including the Central Bank, continue to promote digital transformation. This has enabled the country to take a leading position among European and global crypto hubs.

Lithuania remains a country with a progressive approach to digital finance, demonstrating a willingness to support innovation, and investment in the cryptocurrency economy. For those seeking a reliable entry point into the EU market and looking to build a long-term development strategy, obtaining a crypto licence in Lithuania is a sound choice.

As a practicing lawyer with extensive experience in FinTech and the cryptosphere, in this article, I explain in detail how to obtain a CASP crypto licence in Lithuania under MiCA. In the publication, I go step-by-step through all the conditions and mandatory criteria that need to be fulfilled to successfully obtain the status of a crypto provider. In addition, special attention will be paid to key legal and technical aspects that play an important role in ensuring the company's compliance with the new European regulations.

Obtaining a MiCA licence in Lithuania: what justifies the choice of this country

The Republic of Lithuania holds a leading position among European countries offering favourable conditions for regulating and licensing crypto activities. Low start-up costs, proactive legislation, and digitalisation of public services have made Lithuania attractive for foreign investors seeking to legalise activities in the field of digital assets.

Before the MiCA Regulation came into force, Lithuanian lawmakers had already established a legal infrastructure to control crypto service providers at an institutional level. This has significantly increased the level of legal certainty, and differentiated the responsibilities of various participants in the crypto market. Lithuania's legal regime for cryptocurrency companies is closely linked to compliance with AML/CFT requirements. All entities applying for a MiCA licence in Lithuania must adhere to mandatory procedures arising from both national and EU-wide legislation:

1. Registration of a legal entity in the Trade Register.
2. Appointment of an AML Officer.
3. Implementation of internal KYC procedures.
4. Reporting to the financial intelligence unit in case of suspicious transactions.

As of January 2025, Lithuania has moved to fully integrate the provisions of the MiCA Regulation, which means a transition from domestic regulation to a pan-European supervisory system. The main advantage for entrepreneurs is that obtaining a MiCA cryptocurrency licence in Lithuania automatically entitles them to provide services throughout the EU without the need for re-accreditation in other states. This is made possible thanks to EU passporting - an end-to-end system of licence recognition between member states.

• Significant reduction in re-licensing costs when expanding geographically.
• Easy access to a wide range of customers across Europe.
• Increased transparency and legal continuity of cross-border operations.

One of the elements significantly speeding up administrative procedures was the implementation of the ‘single window’ concept, based on a digital platform that unites all necessary state bodies. Electronic interaction is carried out through interfaces integrated with databases:

• Lietuvos Bankas regulates the financial and payment infrastructure.
• Financial Crime Investigation Service (FNTT) provides administrative supervision in the field of anti-corruption and financial regulation.
• Lietuvos Respublikos finansų ministerija involved in checking the compliance of documents and financial data.

The high level of digitalisation makes it possible to obtain a MiCA licence in Lithuania without physical presence and minimise administrative barriers when entering the market. In addition to regulatory advantages, Lithuania offers an attractive tax regime for cryptocurrency companies. The basic income tax rate is 15% and undistributed profits are exempt from taxation. Preferential tax regimes are available for small businesses and startups, and if certain conditions are met, a company can take advantage of tax optimisation schemes following European directives.

Which services require a MiCA licence in Lithuania

Lithuania, as a jurisdiction with a developed infrastructure for fintech businesses, was among the first to adapt its national legislation to the new European norms. Lietuvos bankas is responsible for controlling compliance with MiCA requirements, licensing CASPs (Crypto-Asset Service Providers), and monitoring transactions conducted by cryptocurrency companies.

The regulator engages with key European bodies, including:

• ESMA responsible for common market standards.
• EBA deals with financial sustainability issues.
• ECB shapes EU macro-financial policy.

Obtaining a CASP licence in Lithuania has become a key prerequisite for operating in the digital asset sector, covering four main categories of services.

Cryptocurrency operations and development of exchange platforms

This category of services includes:

• buying and selling of digital assets on behalf of clients or for their own account;
• creation and technical support of cryptocurrency exchanges and trading platforms.

Particular attention is paid to the distinction between centralised (CEX) and decentralised (DEX) exchanges. If developers or other project participants have the ability to modify smart contracts, manage key functions or intervene in the flow of funds, then such a DEX platform equates to a centralised platform. This entails the need for full MiCA compliance: registration, audit, implementation of KYC/AML procedures and reporting to supervisory authorities.

Custodial services: storage and protection of digital assets

The next area is the provision of cryptocurrency storage and digital wallet management services to clients. Companies wishing to obtain a cryptocurrency licence under MiCA in Lithuania and legally engage in custodial activities are required to prove their ability to:

• secure private keys;
• protect assets from hacking and unauthorised access;
• ensure that funds are available to owners at any time;
• maintain accurate and transparent accounting records of transactions;
• provide IFRS reporting.

Moreover, the provision of such services requires the implementation of reliable internal control procedures, risk management systems, and compliance with European GDPR requirements.

Consulting and investment advice in the field of cryptocurrencies

Providing advice and recommendations on digital assets has become a separately licensed area. This includes:

• preparation of analytical reports and research reviews;
• assessment of the investment attractiveness of specific cryptoinstruments;
• development of investment strategies taking into account market and regulatory factors.

However, the legislator strictly separates general information support and personalised advice. The former is allowed under a standard cryptocurrency licence, while the latter requires a separate investment advice authorisation under the EU MiFID II Directive.

Integration of cryptocurrencies into the payments sector

The MiCA licence in Lithuania allows to provide services for:

• acceptance of cryptocurrencies in online commerce and digital business;
• creation of technological gateways to connect crypto-infrastructure with traditional banking systems;
• cross-border settlements using stablecoins and other digital payment instruments;
• issuance of own tokens intended for settlements within the ecosystem (subject to compliance with the provisions of the PSD2 Directive).

At the same time, activities in the payment sector cannot do without compliance with the PSD2 Directive and the implementation of security standards, including two-factor authentication, KYC/AML procedures, and internal financial monitoring systems.

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How to obtain a MiCA licence in Lithuania

The licensing process requires compliance with strict requirements covering transparency, compliance, security and corporate governance. One of the key requirements of the regulator is full and accurate disclosure of the applicant's corporate structure. This includes:

• Identification of all founders and ultimate beneficial owners (UBOs).
• Providing biographies of key individuals: directors, board members, compliance officers and AML specialists.
• Confirmation of the legality of the origin of capital.
• Providing evidence of the participants' sound business reputation - from references to criminal records.

Companies seeking a CASP licence in Lithuania are required to demonstrate a high level of customer and operational data protection. Among the key requirements are multi-factor user authentication, maintenance of up-to-date cryptographic protocols to protect information, constant software updates, regular IT audits, and implementation of control measures for internal information systems. Special attention is paid to the company's ability to respond to cyber-threats and ensure the resilience of business processes.

The successful issuance of a crypto licence in Lithuania is not possible without a fully implemented AML/KYC policy. The regulator requires:

1. Appointment of an AML Officer, preferably with resident status.
2. Compliance with KYC procedures for the entire client base.
3. Implementation of a system of financial controls and internal compliance.
4. Having written policies in place to identify suspicious activity.
5. Implementing internal training programmes and auditing of relevant processes.

Before proceeding to apply for a cryptocurrency licence in Lithuania, it is necessary to register a legal entity. Usually, firms involved in crypto transactions are registered as a private company (UAB) or a joint stock company (AB). The process is as follows:

1. Checking in databases and reserving a unique business name.
2. Preparation of statutory and related documents, their notarisation (if necessary).
3. Submission of the registration form.
4. Receipt of the registration certificate.

The next step is to prepare and approve a full set of internal documents:

• Compliance and AML Policy.
• Regulations on processing and protection of personal data.
• Security and incident response protocols.
• Internal instructions on client intake and identification.
• Documentation describing the management structure and the authority of officials.

Each document must be worked out in detail and adapted to the specifics of the company's activities. The ready package of documents is submitted to the Central Bank of the country. It should include an application for a MiCA licence in Lithuania, a business plan with a description of the strategy, target audience and market analysis, financial forecasts, information about the management and employees, documents confirming the payment of the share capital.

Once the documents are submitted, the verification process begins, during which the regulators may ask for clarifications, interview key players or initiate an audit. After successfully passing all stages and receiving approval from the regulator, a CASP-licence is issued. From that moment on, the company is authorised to officially provide crypto services in Lithuania and other EU countries.

For full-fledged operational activities, it is necessary to open a corporate account. In Lithuania, it is possible to open different types of accounts adapted to specific needs: C2B accounts, designed to receive payments from individuals and end customers, as well as B2B accounts, which are used for settlements and mutual settlements with business partners and counterparties. It is important to take into account that traditional banks are reluctant to work with non-residents and crypto-business. Fintech platforms and banks operating under an EMI licence with experience in servicing high-risk clients are more loyal in this regard.

Requirements for obtaining a MiCA licence in Lithuania and categories of authorisations

The transition to licensing under the MiCA model is not limited to legal formalities. Candidates for a CASP cryptocurrency licence in Lithuania must meet a number of strict requirements. The separation of corporate funds and client assets is mandatory. This ensures that in the event of a company's financial or legal problems, users' funds will remain at their disposal and will be protected from possible recoveries.

Companies are required to implement clearly regulated information security procedures, including:

• resilience to cyber-attacks;
• assurance of IT system continuity;
• protection of customer data;
• development of internal incident response policies.

In addition to MiCA, cryptocurrencies are required to follow the requirements of EU Regulation 2022/2554 on the Digital Operational Resilience of Financial Institutions (DORA). This act focuses on the technical preparedness of financial market entities to digital risks and cyber threats.

The Lithuanian CASP licensing system is divided into three main categories, which reflect the level of a company's involvement in the digital asset market, and the range of services it provides.

This licence covers basic intermediary activities related to the circulation of cryptoassets. It allows:

• to support client transactions in cryptoassets, including token subscriptions, with mandatory compliance and counterparty verification procedures;
• to coordinate the issuance of tokens on behalf of issuers, including affiliated entities, while ensuring compliance with applicable regulations;
• to organise the execution of client orders on cryptocurrency platforms, complying with the regulations of European regulators;
• to provide analytical and strategic recommendations to clients on crypto operations and investments;
• to provide trust management of funds based on pre-agreed parameters with the client;
• to ensure the secure transfer of digital assets between different accounts.

Category 1 does not grant the right to hold crypto-assets (custodial services) or manage exchange infrastructure.

This category includes all the features of the previous one, supplemented by a number of key functions:

• protecting customer data and cryptographic keys, including using specialised technical solutions to prevent leaks and attacks;
• providing customers with custodial accounts for storing cryptocurrency assets;
• providing a secure infrastructure for exchanging and converting cryptocurrencies into fiat money and back;
• supporting transactions on centralised crypto exchanges with the ability to participate in transactions using national currencies.

This category of licence is required for all companies providing digital asset storage services and managing centralised trading infrastructure, making it mandatory for cryptocurrency wallets and crypto exchanges.

This licence covers all of the above features plus trading platform management. It entitles:

• to act as a platform for transactions between independent participants (P2P and B2C trading);
• to provide stable liquidity and handle large financial flows;
• to support complex architecture of cryptocurrency exchanges and trading systems.

Obtaining a MiCA cryptocurrency licence in Lithuania requires applicants to meet strict financial requirements. For organisations specialising in cryptocurrency consulting, a minimum capital of €50,000 is stipulated. Companies managing custodial wallets, storing digital assets, depositing and withdrawing funds are required to have a capital of EUR 125,000 or more. In the case of crypto trading platform operators, the minimum capital is €150,000.

In addition, legal entities that have obtained a MiCA cryptocurrency licence in Lithuania are required to have a valid professional indemnity insurance policy or other comparable financial guarantee provided, for example, in the form of a bank guarantee or deposit. These measures are aimed at ensuring the financial stability of the provider and protecting the interests of clients in the event of damage arising from improper fulfilment of obligations or breach of regulatory requirements.

Taxes in Lithuania

Licensed cryptocurrency companies pay income tax at the standard rate of 16%. However, small businesses can count on significant tax exemptions - a rate of 6 or even 0% if they fulfil the established conditions. Cryptocurrency exchange and crypto wallet services are not subject to VAT. Other services paid for with crypto are subject to VAT at the basic rate (21%).

Conclusion

Lithuania demonstrates a stable position among the leaders in the implementation of European crypto regulation. Obtaining a Lithuanian MiCA licence opens the way to legal and scalable operations across the EU. However, to go from registration to obtaining a licence, it is important to demonstrate a willingness to invest in compliance and professional legal support at every stage of obtaining a MiCA licence in Lithuania.

Thanks to my knowledge of local and European legislation, I provide professional advice on crypto business licensing. I offer full support at all stages of obtaining a cryptocurrency licence in Lithuania - from document preparation to liaising with regulators.