MiCA in Lithuania

The Lithuanian Ministry of Finance, in close cooperation with the Bank of Lithuania, has developed and presented a package of draft laws aimed at systematically transforming the legal regime for providers of crypto-asset services.

These initiatives aim to establish new standards for operational activities and harmonise licensing procedures in line with the provisions of the pan-European regulations MiCA and TRF. The proposed changes concern not only the supervisory mechanism itself, but also the transition period to full compliance with the new regulations and the procedure for interacting with the regulator.

According to the position of the Ministry of Finance of Lithuania, the proposed measures will bring the legal regime applicable to crypto service operators closer to that applicable to traditional financial institutions. This, in turn, will strengthen consumer protection, increase trust in the sector and create a level playing field for the sustainable development of the fintech ecosystem. Deputy Minister of Finance Vaida Česnulevičytė-Markavičienė emphasises that the current version of the draft laws takes into account the views of market participants and provides additional time for adaptation compared to the stricter conditions announced earlier.

The MiCA Regulation, which entered into force at the European Union level on 30 December 2024, provides for the introduction of uniform requirements for all crypto-asset service providers in EU countries, including mandatory licensing, consumer protection, risk management and information disclosure. In parallel, the Transfer of Funds Regulation (TRF) is in force, aimed at tracking cryptocurrency transactions and preventing financial offences, including money laundering and terrorist financing.

The proposed Lithuanian amendments place particular emphasis on the transition period: crypto service providers will have until 1 June 2025 to submit documents to the Bank of Lithuania and obtain a licence. By that date, companies must provide all information required by MiCA and, where necessary, consult with the regulator on enforcement issues. This decision was taken on the basis of consultations with market participants and reflects the need to allow time for companies to prepare technically, organisationally and legally for the new regulatory regime.

At the same time, the draft legislative amendments provide for certain exemptions for cross-border payments for goods and services made through e-commerce platforms. If the TRF requirements are met, such transactions may be exempted from certain regulatory barriers, creating additional incentives for fintech platforms to locate in Lithuania.

According to the proposed changes, oversight of compliance with the new regulations will be carried out by the Bank of Lithuania, which is being granted the authority to register, inspect, and supervise the activities of crypto service providers. In turn, functions in the area of AML/CFT (anti-money laundering and countering the financing of terrorism) will be performed jointly by the Bank of Lithuania and the Financial Crime Investigation Service (FNTT), in accordance with the division of functional responsibilities.

The deadline for discussing the draft laws is limited — the relevant authorities and stakeholders must submit their comments by 28 March 2025. Once the consultation process is complete, the amendments will be submitted to the Seimas for consideration. The implementation of these initiatives will create a legally stable environment for the development of cryptocurrency activities in Lithuania and allow bona fide market participants to prepare for the new pan-European standards in a timely manner.

The legal team at Regulated United Europe provides comprehensive support to crypto companies preparing for licensing under MiCA. We accompany our clients at all stages, from strategic assessment of legal risks and preparation of internal policies to representation before the Bank of Lithuania and interaction with the FNTT.

Lithuania’s Crypto Regulatory Requirements Under MiCA & TRF

The future of the cryptocurrency sector in Lithuania

From the end of 2024, European Union Regulation No. 2023/1114 on markets in crypto assets (MiCA) will apply in Lithuania, marking the starting point for the transition to a new stage in the development of digital finance. This regulatory act introduces strict requirements for transparency of operations, risk management, consumer protection and the responsibility of crypto service providers. In this regard, there is active discussion in Lithuania as to whether the country can use this moment to consolidate its status as one of the key players on the European and, possibly, global crypto map.

According to experts, the current redistribution of influence in the international financial system provides Lithuania with a unique window of opportunity. As noted by Mykolas Majauskas, president of the Crypto Economy Organisation, in a context of global change accompanied by a weakening of centralised control, Lithuania can contribute to the formation of a new financial market architecture. This is fundamentally different from its role in the post-war period when traditional financial institutions such as the IMF, the World Bank and modern central banks were established.

Strategic Opportunities for Lithuania

• Global Shift: Lithuania can benefit from changes in international financial power dynamics.
• Architect Role: Potential to influence the future architecture of decentralized finance.
• Era Shift: Moving away from post-war centralized financial institutions.

An example of progressive presence in the cryptocurrency market is the activity of the largest international platforms. According to Mayauskas, Binance’s turnover is comparable to that of the New York Stock Exchange, and its operations in Lithuania generate significant fiscal returns: in the first nine months of 2023, the country’s budget received approximately €25 million in taxes from this crypto exchange alone. The presence of such players strengthens Lithuania’s position as a promising jurisdiction in the digital asset sector. Lithuania’s success in the field of cryptocurrencies is due not so much to a targeted state strategy as to a combination of external circumstances. The mass migration of crypto companies to the country began after the tightening of legislation in neighbouring Estonia, which had previously served as an informal hub for the crypto sector but subsequently introduced strict rules, driving away a significant portion of players. As a result, it is estimated that there are now around 300 crypto service providers registered in Lithuania, mainly due to the ‘relocation’ of existing structures.

This context creates a dual situation: on the one hand, a significant base of crypto-active companies has formed in the country, but on the other hand, there has been no clear long-term state strategy for attracting and regulating them. With the introduction of MiCA, the situation is changing radically. The state is gaining a real tool to control the activities of companies operating in Lithuania, including the obligation to obtain a licence in accordance with European standards.

Now is the time for Lithuania to turn its temporary advantage into a sustainable competitive position. This will require not only the implementation of MiCA, but also the development of an additional regulatory framework at the national level that combines legal certainty with favourable conditions for innovative businesses. The focus should be on AML/CTF regulatory mechanisms, due diligence procedures, and institutional interaction between licensing authorities and market participants.

The Regulated United Europe team is ready to support crypto projects operating in Lithuania or planning to enter the EU market at all stages of adaptation to the new MiCA requirements: from compliance analysis and documentation preparation to obtaining a licence and implementing internal control mechanisms in accordance with European standards.

MiCA as a tool for systemic transformation of the crypto market in Lithuania

The expert community agrees that, until now, the crypto asset market in Lithuania and throughout the European Union has operated under fragmented regulation and, in terms of its structure and control mechanisms, resembled a ‘wild’ market with a high degree of tolerance.

Despite the existence of common rules, for example, in the area of anti-money laundering (AML), actual supervision of many crypto market participants remained superficial.

With the adoption and implementation of the MiCA Regulation, this situation is changing dramatically. The new regulatory regime not only provides for the legalisation of cryptocurrencies as an investment instrument, but also significantly strengthens the requirements for operators. It emphasises the need for market access to be restricted to participants who meet the highest standards of reliability and transparency, such as licensed credit institutions, payment and electronic money institutions managed by professional and trustworthy persons.

Cryptocurrency is a high-risk asset, both for private investors and at the macro level. It indicates that international institutions, including those responsible for combating money laundering, have officially recognised crypto assets as a high-risk instrument. This recognition has laid the foundation for the development of new rules aimed at preventing abuse and increasing trust in the digital asset sector.

One of the most important innovations of MiCA is that cryptocurrency will finally be integrated into the financial system as a recognised regulatory object, alongside stocks, bonds and funds. This means that investments in digital assets will no longer be perceived as speculative activities on the periphery of the system, but will acquire institutional legitimacy. At the same time, as Govina notes, this is not a complete guarantee of security, but rather the ability to assess the likelihood of the stability and security of such investments within a clearly defined regulatory framework.

The Regulated United Europe team is ready to provide comprehensive support to cryptocurrency companies adapting to the new realities of MiCA, including preparation for licensing, development of internal AML/CTF policies, and implementation of effective customer asset and risk management structures.

MiCA regulations in Lithuania

MiCA introduces not only fundamentally new standards to the crypto services sector, but also comprehensive requirements for organisations wishing to maintain their market presence. These include the mandatory implementation of internal policies on money laundering prevention, customer asset protection, corporate governance, as well as enhanced internal controls and reporting. These measures are aimed at institutionalising the sector, transforming it from a risky and fragmented segment into a fully-fledged part of the regulated financial infrastructure.

The establishment of clear rules and appropriate obligations will signal to traditional financial institutions — banks, EMIs and payment organisations — that the digital asset market is moving towards a civilised state. This will increase trust in crypto services and create conditions for sustainable cooperation between crypto service providers and institutions working with fiat currencies. Without this synergy, he said, the industry cannot function properly, because ultimately users need to be able to convert their assets into traditional currencies controlled by traditional financial institutions.

However, the implementation of the new requirements in Lithuania is accompanied by significant restrictions, primarily the tight timeframe for the transition period. Although the MiCA Regulation allows EU member states to set a transition period of up to 18 months, Lithuania has opted for a strict approach — existing service providers are required to apply for a licence by 1 June 2025, leaving only five months to prepare and submit documentation.

Lithuania now faces a strategic choice: either the country becomes a regional centre for digital finance or it misses the boat, ceding leadership to more flexible jurisdictions. However, the actions of the Bank of Lithuania indicate that its priority is control rather than development. The financial supervisory authority has stated that it is ready to process applications, has the necessary human resources and intends to grant licences only to mature and well-managed companies. Nevertheless, there are reasonable doubts as to whether it will be possible to review dozens, if not hundreds, of applications in such a short period of time.

The main problem is not only the high demand for licensing and the workload of consultants. The key difficulty lies in the lack of qualified personnel needed to meet MiCA requirements. For example, each company is required to form a board of at least three members with a good reputation, relevant experience and the ability to supervise management. In addition, specialists in AML/CTF, internal control and compliance are needed, and the market is facing an acute shortage of such resources. This puts additional pressure on companies that are trying to adapt their processes, conduct their operations and prepare for licensing at the same time.

The chosen strategy reflects the state’s desire for consistent and strict regulation. At the same time, it expresses doubts that the Bank of Lithuania will be able to conduct an objective review of even half of the approximately 300 active crypto companies in the remaining months. Even if some companies do not apply, the burden on the regulator will be unprecedented. This could affect both the quality of decision-making and the investment climate in the sector.

Faced with tight deadlines, high requirements and institutional pressure, market participants are increasingly turning to professional consultants for support. The Regulated United Europe team provides comprehensive support for MiCA: from document preparation and selection of management personnel to the implementation of internal control procedures and communication with the Bank of Lithuania. Our experience and resources enable us to ensure compliance with all requirements and complete the licensing process in Lithuania within the specified time frame.

According to a number of experts, Lithuania’s current regulatory strategy towards the crypto industry is a clear signal that the country is consciously rejecting the role of an international crypto hub. As a financial analyst points out, the Lithuanian authorities have never positioned themselves as supporters of the development of the cryptocurrency sector. The goal has always been to support fintech — innovative financial technology solutions — with the exception of crypto, which has remained on the periphery of this agenda.

Against this backdrop, a fundamental question arises: does Lithuania intend to extend the MiCA transition period and retain existing market participants, while creating favourable conditions for attracting new international players? Or has the state chosen a course of restraint, prioritising control over growth?

The challenge is not so much for crypto companies as it is for government agencies. Large international providers have the financial resources to pay for consultants, assemble compliance teams, and successfully navigate the licensing process. However, how quickly and efficiently will the Bank of Lithuania and other agencies be able to process dozens of applications within a limited five-month period? Will international companies pass the filter, while promising local start-ups do not?

Historically, Lithuanian state institutions, including the Ministry of Finance, the Presidency and the Ministry of Economy, have been actively involved in establishing the country as a fintech hub. The Bank of Lithuania, despite its traditionally supervisory role, has also been involved in this process. Today, however, the situation is changing: institutional coordination is weakening, and the Bank of Lithuania is effectively left alone at the forefront of MiCA implementation. At the same time, other authorities are demonstrating different priorities, and responsibility for the future of the market is becoming blurred.

Lithuania has most likely chosen a safer and shorter-term strategy: to limit risks through strict selection. Given the global nature of crypto services and the potential for scandals accompanied by accusations against politicians and supervisory authorities, the authorities are keen to minimise potential reputational damage. This leads to a conservative approach: better to restrict the sector than face high-profile failures.

Nevertheless, the key question remains one of political will. Is the state prepared to recognise that regulation is not a guarantee of complete security, but rather a system for managing residual risks? Are political leaders capable of giving supervisory authorities a mandate to work actively and responsibly in conditions of uncertainty and the risk of bankruptcies, which are normal for any developing industry?

The solution can and should be pragmatic. An effective assessment model should take into account not only the risks, but also the potential economic benefits of crypto companies’ activities. The potential is clear: major international exchanges such as Binance generate significant contributions to the economy through taxes, employment, rent and contracts with local lawyers and specialists. These figures can be expressed in numbers and compared with the state’s costs of supervision — such a cost-benefit analysis will help to make an informed decision.

If a company plans to hire only one employee in Lithuania and conduct all its main operations outside the country, such a model may not make sense for the country. However, if the company’s presence brings significant economic benefits, the state may reasonably accept the regulatory risk, knowing that this is an investment in the development of a new industry.

In these circumstances, the Regulated United Europe team is a key partner for companies wishing to maintain their presence in Lithuania. We provide comprehensive legal and operational support in obtaining a MiCA licence, including economic feasibility analysis, assistance in selecting qualified advisors, developing AML/CTF policies and interacting with supervisory authorities.

MiCA transition period restrictions: position of the Bank of Lithuania

The Bank of Lithuania has officially confirmed that the transition period provided for in European Union Regulation 2023/1114 on markets in crypto-assets (MiCA) applies in the territory of the Republic of Lithuania with significant restrictions.

Cryptocurrency market participants and relevant service providers must strictly comply with the applicable legal framework at both national and European level.

In accordance with the transitional provisions recognised by Lithuanian law, crypto service providers included in the Lithuanian register of legal entities are entitled to continue their activities exclusively in Lithuania. National registration does not automatically grant the right to provide services in other EU countries. For cross-border activities, full licensing under MiCA and obtaining the relevant authorisation are required.

It should also be noted that, starting from 30 June 2024, key provisions of MiCA regulating the issuance, public offering and secondary trading of asset-backed tokens (ART) and electronic money tokens (EMT) will come into force. Crypto service providers are prohibited from offering such tokens to customers if they do not comply with MiCA requirements. Failure to comply with these rules constitutes a violation of the law and may result in administrative or criminal liability.

On 17 January 2025, the European Securities and Markets Authority (ESMA) issued a special notice emphasising the inadmissibility of providing services in relation to ART and EMT that do not comply with MiCA. ESMA also strongly recommends that providers ensure that investors are informed of the risks associated with such instruments and take measures to withdraw non-compliant tokens from the market or convert them into compliant assets.

Although the MiCA Regulation itself will apply from 30 December 2024, Lithuania, like a number of other EU Member States, has introduced a transitional regime. It is implemented on the basis of the Lithuanian Law on Cryptoasset Markets, which provides a temporary opportunity for operators already registered in Lithuania to continue their activities until 1 June 2025. However, the continued provision of services after that date will only be possible if a MiCA licence has been issued in accordance with the established procedure.

The legal team at Regulated United Europe provides comprehensive support at all stages of preparation for licensing in Lithuania, including analysis of the business model’s compliance with MiCA requirements, preparation of documentation, interaction with supervisory authorities, and post-licensing support.

The Bank of Lithuania’s regulatory strategy: how the country is shaping its approach to the cryptocurrency market

In recent years, cryptocurrencies have gained a firm foothold in the global financial market architecture, and their regulation has become a key task for supervisory authorities around the world.

As a member state of the European Union, Lithuania is actively adapting its regulatory mechanisms to the realities of a rapidly developing industry, while striving to ensure the stability of the financial system and protect the interests of investors.

The Bank of Lithuania, which acts as the central bank and chief financial regulator, began to develop a regulatory framework for the crypto market even before the introduction of European legislation, focusing on compliance with the principles of transparency, accountability and prevention of abuse. However, a fundamental question arises today: to what extent does this approach promote innovation in the field of virtual assets, or, conversely, serve as a deterrent to the crypto ecosystem in the country?

With the adoption of Regulation (EU) No 2023/1114 of the European Parliament and of the Council on markets in crypto assets (MiCA), which entered into force on 30 December 2024, the Lithuanian regulator has stepped up its efforts to create a regulatory environment that meets EU standards. Among the priorities is the transition from fragmented control to comprehensive regulation covering the issuance of crypto assets, their public offering, the secondary market, and the activities of service providers working with digital assets.

The interpretation and practical implementation of MiCA in Lithuania is of particular importance. The Bank of Lithuania has committed to ensuring the timely adaptation of the national legal framework by incorporating the provisions of MiCA into the Law on Cryptoasset Markets. At the same time, the Lithuanian regulator’s approach is conservative: the country has set one of the shortest transition periods in the EU — until 1 June 2025 — which requires existing market participants to urgently prepare for licensing under the new conditions.

On the one hand, this approach strengthens confidence in the jurisdiction and confirms the state’s readiness to ensure reliable financial supervision. On the other hand, it raises concerns among businesses about the accessibility of the regulatory environment and whether there will be enough time for comprehensive adaptation. Some industry participants believe that excessive regulation could reduce the country’s attractiveness as a location for international crypto projects.

However, amid growing pressure from the international community in the areas of AML/CTF, cybersecurity and consumer protection, the Bank of Lithuania’s position reflects the general direction of the European Union: legalisation of cryptocurrency activities is acceptable, but only under strict compliance with regulatory requirements.

The Bank of Lithuania’s approach affects not only the domestic market but also the decisions of international investors considering Lithuania as a potential entry point to the European digital asset market. In this context, issues of law enforcement, the speed of processing licence applications, and interaction between the regulator and market participants are particularly relevant.

Amid rapidly growing interest in digital assets, cryptocurrency regulation in Lithuania is becoming a key element of the sustainable development of the financial sector. Against the backdrop of the entry into force of the EU-wide Regulation (EU) No 2023/1114 on markets in crypto assets (MiCA), Lithuania is strengthening legal and institutional measures to ensure transparency, control over operations and investor protection. This requires market participants to have a clear understanding of the regulatory environment and be ready to adapt to the new way of working.

The Bank of Lithuania’s position on cryptocurrencies remains cautious and pragmatic. Since 2014, the regulator has consistently warned about the risks associated with virtual asset transactions, without prohibiting their use. Cryptocurrencies are not officially recognised as legal tender, and financial institutions are prohibited from directly participating in transactions involving them. At the same time, the development of blockchain technology as a basic infrastructure is encouraged, as it is seen as an important component of innovation in the financial sector. Compliance with the principles of good conduct and anti-money laundering and counter-terrorist financing rules remains a key condition.

Strict requirements apply to companies working with cryptocurrencies. Companies are required to register and obtain a licence from the Financial Crime Investigation Service (FNTT), implement KYC and AML procedures, and ensure proper internal reporting. These measures are aimed at minimising abuse, ensuring financial transparency and preventing the use of digital assets in illegal activities.

In terms of taxation, Lithuania’s approach is consistent with the principles of fiscal neutrality and proportionality. Income from cryptocurrency transactions is subject to income tax, especially if the annual income exceeds the established threshold of €20,000. Legal entities are required to pay corporate tax at a rate of 15%, with payments in cryptocurrencies treated as a form of salary and subject to the relevant social security and income taxes.

Particular attention is paid to harmonising Lithuanian legislation with European Union law. The adopted MiCA introduces a uniform legal regime for all EU Member States and significantly expands the list of mandatory requirements for crypto service providers. These changes concern the issuance of tokens, wallet services, public offering of assets and the activities of crypto exchanges. The regulation provides for high standards of corporate governance, minimum capital requirements and mandatory segregation of client funds. In Lithuania, the transition period is set until 1 June 2025, which requires companies to prepare for licensing and restructure their internal processes in a timely manner.

Thus, Lithuania is taking a cautious but consistent position on cryptocurrency regulation. The digital asset sector is perceived as a high-risk area, but also as a source of technological opportunities. The state is committed to creating a stable legal environment in which bona fide participants can operate on an equal footing and consumer interests are reliably protected.

Over the past few years, Lithuania’s regulatory landscape for cryptocurrencies has undergone significant changes. Tighter customer identification requirements, increased oversight by the Financial Crime Investigation Service, and subsequent harmonisation of legislation with European standards have all been part of a systemic transformation. In 2023, stricter AML/KYC mechanisms were introduced, requiring crypto service providers to carry out comprehensive customer checks and ensure the transparency of financial flows. The FNTT was granted expanded supervisory and inspection powers, which increased the level of regulatory pressure on market players.

In 2024, additional licensing requirements came into force, requiring all existing cryptocurrency companies not only to renew their registration but also to confirm that they have a sustainable business model, demonstrate compliance with capital requirements and prove the integrity of their key managers. These provisions have become a kind of filter, separating mature players from non-systemic structures.

The culmination of the process was the implementation of the MiCA (Markets in Crypto-Assets) Regulation, which will become mandatory throughout the European Union from 2025. This regulatory act introduces uniform rules in the field of cryptocurrencies, covering issues such as the licensing of providers, the management of stablecoin projects, consumer protection, and the prevention of market manipulation and insider trading. Companies operating in Lithuania are already preparing for a comprehensive overhaul of their procedures to take account of the new obligations. For investors, MiCA means greater transparency, formalisation of risks and guarantees of good conduct on the part of providers.

At the same time, cryptocurrencies remain legal in Lithuania, but are strictly regulated. Individuals are free to invest, acquire and hold digital assets without the need for special permits. However, income received is subject to mandatory declaration and taxation under personal income tax. The vigilance of regulators means that large transactions are subject to enhanced monitoring, particularly with regard to the source of funds.

Difficulties may arise when interacting with traditional financial institutions. Banks in Lithuania take a conservative stance and often restrict transactions related to crypto exchanges, as well as refuse to open settlement accounts for cryptocurrency companies. These restrictions, caused by AML requirements and reputational risks, force many market participants to turn to foreign financial partners and alternative payment systems.

From a business perspective, the use of cryptocurrencies in Lithuania is possible but comes with obligations: companies are required to declare income received in digital assets, calculate income tax, and transactions in cryptocurrencies are treated as barter rather than payment. Exchanges and custodial providers are required to obtain licences, implement compliance policies, conduct internal audits, and report suspicious transactions to the FNTT.

The future of the crypto industry in Lithuania will largely be determined by the balance between regulation and innovation. The impact of MiCA, as well as possible tax innovations aimed at strengthening fiscal control over digital assets, may increase pressure on participants. At the same time, central banks are becoming more involved in the design of digital currencies. The Bank of Lithuania has already conducted an experiment with LBCoin and is participating in the European discussion on the digital euro.

The potential introduction of CBDCs could change the structure of payment solutions, but is unlikely to replace decentralised cryptocurrencies. Against the backdrop of these changes, companies wishing to operate legally in the Lithuanian and EU cryptocurrency markets must adapt to the new requirements in advance.

The Regulated United Europe team provides comprehensive legal support on MiCA licensing, tax planning, internal control, AML/CTF compliance, and strategic engagement with financial institutions. We will ensure that your business is ready for the new phase of regulation and minimise the risks associated with the transition to a pan-European enforcement model in the virtual asset sector.

MiCA in Lithuania – documents required for application

From 2025, all companies providing services related to crypto assets in Lithuania will be required to obtain a licence or approval from the Bank of Lithuania. This is due to the entry into force of EU Regulation No. 2023/1114 (MiCAR), which radically changes the way crypto service providers operate in the European market. Lithuania has established a six-month transition period during which providers must complete the adaptation process, submit documents and obtain the appropriate authorisation. According to the regulator, there are currently around 500 companies operating in this sector in the country, but only those planning to continue their activities after 1 June 2025 will require a licence.

Companies subject to the new regulations will be classified into two groups: those exempt from the licence requirement and those for which a licence is mandatory. Exceptions are provided for certain categories of financial institutions, such as banks, investment companies, fund managers, infrastructure platform operators and electronic money institutions. Despite the absence of a licensing requirement, these organisations are required to submit an application and provide the Bank of Lithuania with a comprehensive set of documentation, including a programme of activities, internal control procedures, ICT procedures, risk management policies, AML/CTF documents and mechanisms for the segregation of client assets.

Applications in this category will be reviewed within 40–60 business days. Companies that do not fall under the exemptions are required to undergo full licensing. The applicant must confirm that it has a legal address in an EU country and ensure that at least one of its directors resides in the EU.

A licence will not be granted without proof of compliance with the minimum authorised capital requirements (between €50,000 and €150,000 depending on the type of services provided), a transparent organisational structure, sound corporate governance and internal control systems.

The criteria for assessing applications will be identical to those applied to other financial institutions. Applicants are required to have a competent management team with an impeccable reputation, the necessary professional skills and experience, and a proven ability to perform management duties effectively. Investors seeking a stake of more than 25% in CASP’s authorised capital are required to notify the Commission for the Coordination of the Protection of Facilities of National Importance.

To obtain a licence, companies must submit an extensive set of documents, including their articles of association, business plan, three-year financial forecasts, risk management procedures, measures to protect client assets, complaints and accounting policies, and technical specifications for their IT infrastructure. All information submitted is thoroughly reviewed within 65 working days. If necessary, the Bank of Lithuania may request additional clarifications or documents and suspend the review period until they are provided.

Reasons for refusing a licence may include a lack of effective control and management, an opaque ownership structure, weak anti-money laundering mechanisms, low capitalisation, and a negative reputation of shareholders or managers, including criminal convictions or lack of qualifications. Any of these factors may be considered a threat to the financial stability of the company and grounds for refusal.

Given the scale of the reform and the complexity of the procedure, all existing and potential CASPs in Lithuania are strongly advised to start preparations now. It is necessary to conduct a preliminary audit of the business structure, verify the compliance of key persons with the requirements, assess the readiness of IT systems, develop internal policies and reserve sufficient capital. Taking into account the standard practice of the regulator, which provides for additional requests and clarifications, it is advisable to allow at least six months for the licensing process.

It is already clear that crypto asset service providers will have to submit the following to the competent authority together with their application for a licence to provide crypto asset services:

a) a programme of operations setting out the types of crypto asset services that the crypto asset service provider intends to provide, including information on where and how these services will be offered on the market;

b) evidence that

the crypto asset service provider complies with the prudential security measures specified in the MiCA Regulation; c) a description of the organisational structure and internal control measures of the crypto asset service provider;

d) evidence that the members of the management body of the crypto asset service provider are of sufficiently good repute and have the appropriate knowledge, skills and experience to manage the service provider;

e) information on the identity and size of shareholdings of shareholders, direct or indirect, who have a qualifying holding in the crypto asset service provider, as well as evidence that these persons have a sufficiently good reputation;

f) a description of the internal control mechanisms, strategies and procedures of the crypto asset service provider for identifying, assessing and managing risks, including money laundering and terrorist financing risks;

g) a business continuity plan;

h) technical documentation of IT systems and security measures and their description in non-technical language;

i) a description of the procedure for separating crypto assets and client funds;

j) a description of the crypto asset service provider’s complaint handling procedures;

q) information on the types of crypto assets to which the crypto asset service will relate.

Additional information required to obtain an operating licence in accordance with MiCA

Depending on the type of crypto asset services provided, the following additional information will be requested:

a) if the crypto asset service provider intends to provide custody and administration of crypto assets on behalf of clients — a description of the custody and administration policy;

b) if the crypto asset service provider intends to administer a crypto asset trading platform — a description of the rules for administering the trading platform, as well as the procedure and system for detecting market abuse;

c) if the crypto asset service provider intends to exchange crypto assets for cash or other crypto assets — a description of the non-discriminatory trading policy governing relations with clients, as well as a description of the methodology for determining the price of crypto assets that the crypto asset service provider offers to exchange for cash or other crypto assets;

d) if the crypto asset service provider intends to execute orders related to crypto assets on behalf of third parties — a description of the execution policy;

(e) if the crypto asset service provider intends to provide advisory services or portfolio management services for crypto assets, evidence that the individuals providing recommendations on behalf of the crypto asset service provider or managing portfolios on behalf of the crypto asset service provider have the necessary knowledge and experience to perform their duties;

(f) where the crypto asset service provider intends to provide crypto asset transfer services on behalf of clients, information on how such transfer services will be provided.

The Regulated United Europe team provides professional support to companies subject to licensing under MiCAR. We will provide full legal support, including strategic analysis of the company structure, preparation of the entire set of documents, support in interactions with the Bank of Lithuania, and minimisation of risks at all stages of obtaining a licence. Start preparing now, and your company will be ready for the new rules without losing time and competitive position in the EU crypto services market.

The Lithuanian Seimas will decide on extending the validity of crypto company licences until the end of 2025

Lithuania is continuing to review its approach to licensing companies that provide services related to crypto assets. The Seimas is considering amendments to the Law on Crypto Asset Markets, which would extend the transition period until the end of 2025. Currently, the regulations set the deadline for submitting licence applications as 1 June 2025. The initiative to extend the deadline was supported by 69 MPs, with two abstentions and no votes against the proposed measure. The final consideration of the amendments is scheduled for 29 April.

The initiative was put forward by Algirdas Sisas, Chairman of the Committee on Budget and Finance. He stressed that Lithuania had initially chosen the minimum period allowed under MiCA for obtaining licences – six months – while other EU Member States had used the options provided for in the Regulation to extend the transition period to one year or even 18 months. According to Sisas, the extension will give market participants additional time to comply with the new requirements and submit documents, and will allow supervisory authorities to assess the applications received in a thorough manner.

The Bank of Lithuania confirmed that 23 companies have applied for licences to date, 14 of which are currently being reviewed. No licences have been issued yet. This situation is due to the need for a thorough legal and operational assessment of applicants, especially in light of the requirements of the European Regulation on crypto asset markets, which came into force in the EU on 30 December 2024.

The draft amendments were formulated after consultations between a parliamentary committee, representatives of the Bank of Lithuania and participants in the cryptocurrency sector. Agnė Kazlauskienė, head of the Bank of Lithuania’s licensing department, said that applications have been coming in since the end of 2024, with 22 applications submitted so far, representing more than 20% of the number of companies actually operating in the Lithuanian market. Although there are formally around 400 legal entities registered as providing cryptocurrency-related services, the Bank of Lithuania estimates that no more than 120 are actively operating.

The Governor of the Bank of Lithuania, Gediminas Šimkus, emphasised that no licences have been issued yet, as all submitted documents require detailed analysis. In this regard, the Bank of Lithuania supported the initiative to extend the transition period, which will ensure better supervision and avoid unnecessary administrative pressure on the sector.

If the amendments are approved, from 1 January 2026, companies that have not obtained a licence in the prescribed manner will lose the right to provide services. In this way, Lithuania remains committed to the pan-European regulatory framework, while demonstrating flexibility and readiness to adapt to the real market dynamics and operational capabilities of both crypto companies and the regulator.

The Regulated United Europe team is ready to provide full support in the MiCA licensing process in Lithuania. We provide legal and operational support to companies planning to continue operating in the EU on a legal basis, including document preparation, communication with the regulator, and implementation of appropriate internal procedures in accordance with European standards.

Against the backdrop of active interest from international investors in the Lithuanian cryptocurrency services market and with a view to ensuring the smooth implementation of the provisions of EU Regulation 2023/1114 on markets in crypto assets (MiCA), the Seimas Committee on Budget and Finance held an open discussion with key government and market entities. The discussion was attended by representatives of the Ministry of Finance, the Bank of Lithuania, the Financial Crime Investigation Service (FNTT), as well as delegates from professional associations and participants in the cryptocurrency sector.

The focus was on the issue of the limited transition period. Under MiCA, all service providers working with crypto assets must obtain a licence from the Bank of Lithuania by 1 June 2025 at the latest. By that date, applicants must submit all the documents required by the European regulation. According to the Bank of Lithuania itself, there are currently more than 400 companies registered in the country that are formally operating in the crypto sector, of which about 120 are actually doing business. Despite this, only 22 organisations have applied for a licence, with most of the others still getting ready.

As stated at the committee meeting, the five-month period allocated for licensing from the date of entry into force of the law is excessively short and does not correspond to the practice of other EU countries, where the transition period ranges from 6 to 18 months. Such tight deadlines could pose risks to the stability of the sector: a suspension of investment activity, an outflow of personnel and the possible relocation of businesses to jurisdictions with more favourable regulatory policies.

Business participants in the discussion noted that the cryptocurrency sector is already bringing significant economic returns to the state. In the period from 2023 to 2024 alone, total tax revenues from companies operating in this segment amounted to approximately €90 million. The five largest market players accounted for more than a third of this amount. Industry representatives emphasised that further development is only possible with legal stability in line with international standards and predictability on the part of the regulatory authorities.

Algirdas Sisas, Chair of the Committee on Budget and Finance, confirmed that regulation is necessary but also pointed out the importance of proportional administrative measures and flexibility in the transition process. He emphasised that a transparent regulatory environment in line with EU standards would help build trust among both investors and market participants themselves.

A similar position was expressed by the president of the Crypto Economy Organisation, Mykolas Majauskas. He noted that licensing under MiCA is an inevitable stage in the development of the industry, ensuring a level playing field at EU level and increasing the overall reliability of the infrastructure. However, he said that the transition should be structured in such a way as to avoid sudden shocks, maintain the viability of existing businesses and ensure competitive advantages for Lithuania as a potential leader in the regulation of the crypto industry.

As a result of the discussion, it was decided that the Committee on Budget and Finance would register the relevant amendments to the current legislation, extending the transition period until the end of 2025. This step will allow both market participants and the regulator, the Bank of Lithuania, to fully prepare for the implementation of the new regime and ensure the proper assessment of applications.

The introduction of MiCA opens up an opportunity for Lithuania to establish itself among the leading European jurisdictions in the field of digital assets. However, this requires a balanced approach that combines legal certainty, consumer protection and support for the sustainable development of technology businesses.

The Regulated United Europe team supports crypto companies at all stages of their interaction with regulators: from legal analysis and documentation preparation to strategic licensing in accordance with MiCA. We will ensure not only legal compliance but also the effective integration of your business into the new EU regulatory environment.