EU/EEA PassportingMiCA CASP authorisation

CASP Authorisation in Lithuania

Lithuania is a Baltic/EU CASP route under Bank of Lithuania supervision. It fits teams seeking a credible MiCA authorisation and EU/EEA passporting potential, but the file must support real local substance, governance, AML, safeguarding and banking readiness.

Processing time
From 6 months
Service price
17 300 EUR
Required share capital
From 50 000 EUR
State fee
2,500 EUR
Annual supervision fee
From 3 000 EUR
Banking difficulty
Medium to high
RegulatorBank of Lithuania

Confirm current Bank of Lithuania licensing rules, fee schedule, review process and MiCA implementation guidance before using this page for client advice.

Regulatory status should be confirmed by local counsel before relying on this route.

What is Lithuania CASP authorisation?

Lithuania CASP authorisation is the Bank of Lithuania-supervised route for crypto-asset service providers under MiCA. It is a Baltic/EU option for regulated operations that need EU/EEA market access planning, not a light offshore setup.

CASP
Jurisdiction
Lithuania
Regulator
Bank of Lithuania
Regime
CASP
Legal basis
Legal basis: MiCA CASP authorisation supervised by the Bank of Lithuania.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

CASP service scope in Lithuania

The Lithuania application should start with a narrow and defensible CASP service perimeter. Exchange, custody, brokerage, wallet, advisory, staking and payment-adjacent models can change the governance, safeguarding, AML and banking evidence expected in the file.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Conditional

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Included

    EU/EEA passporting available.

  • Startups

    Excluded

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

EU/EEA passporting from Lithuania

Lithuania can be positioned for EU/EEA passporting under MiCA once the authorisation and notification path match the actual services. The commercial plan should define target markets, client categories and operating responsibilities before submission.

  • Map target EU/EEA countries to each CASP service rather than relying on a generic passporting statement.

  • Prepare a Lithuania-based operating model that can supervise outsourced technology, group functions and cross-border client flows.

  • Treat Turkey and other non-EU routes as market-specific alternatives, not substitutes for EU/EEA passporting.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Capital, governance and audit expectations

The CSV snapshot positions Lithuania as a high-complexity route with share capital from 50,000 EUR, state fee of 2,500 EUR, annual supervision fee from 3000 EUR, required local staff, physical office and audit. The real budget must also cover governance, AML, safeguarding and banking preparation.

  • Board, senior management, compliance, AML and technology owners should be named and credible.high
  • Capital planning should match the authorised service scope, especially for exchange, custody and fiat-heavy operations.high
  • Audit, reporting, outsourcing oversight, safeguarding and incident-management workflows should be budgeted as recurring obligations.high

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Lithuania CASP application bottlenecks

Most Lithuania CASP blockers are operating-model issues. The application is easier to defend when service scope, local substance, governance, AML, safeguarding and banking are solved before the timeline is sold to stakeholders.

  • Unclear CASP service perimeter or EU/EEA passporting plan

    High

  • Local office or staffing model that does not support real Lithuania substance

    High

  • Weak custody, safeguarding, wallet or technology-control evidence

    High

  • Generic AML policies that do not match clients, tokens, geography and fiat flows

    High

  • Banking, EMI, PI or PSP package prepared too late

    High

  • Route selection driven by a low-budget or fast offshore objective rather than regulated EU CASP operations

    High

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Conditional

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Suitable

EU/EEA passporting available.

Startups
Not suitable

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Is Lithuania CASP authorisation right for your project?

Best for

  • EU passporting and regulated CASP operations
  • EU/EEA market access

Not suitable for

  • Low-budget or fast offshore setup
  • Projects without a prepared banking strategy

Banking difficulty is high for this route. Prepare a banking strategy before committing to the Lithuania route.

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalFrom 50 000 EUR
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local substance in Lithuania

Local staff and physical office should be treated as operating requirements. A nominal Lithuanian address is not enough if governance, compliance and technology accountability are not supported by a defensible control model.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Planning notes

  • Define which decisions, controls and regulator-facing responsibilities sit in Lithuania.
  • Document outsourced group functions, technology providers and board oversight before filing.
  • Budget local staffing, office, audit and ongoing compliance separately from the application advisory fee.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
17 300 EUR EURFixed
State fee
2,500 EURFrom
Annual supervision feeRecurring annual cost after authorisation.
From 3 000 EURFrom
Required share capitalMust be held, not an expenditure.
From 50 000 EURFrom
High ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Lithuania

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€17,300
State fee€2,500
Required share capitalMust be held, not an expenditure.€50,000

Summary

One-off costs
€69,800
Annual (year 1)
€0
Total year 1
€69,800

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Lithuania — From 6 months.

Total timelineFrom 6 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Lithuania

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Bank of Lithuania

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 6 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

High setup complexity
High

Setup complexity is rated high for Lithuania. Company setup, governance and documentation take longer than average.

Likely impactAdd 4–8 weeks to the preparation phase.
MitigationStart company setup and governance planning immediately after scope confirmation.
Banking difficulty
High

Banking difficulty is rated high. Opening accounts for crypto businesses in Lithuania requires extensive documentation.

Likely impactBanking can delay or block operations for 3–6 months after authorisation.
MitigationIdentify and pre-qualify banking partners before submitting the application.
High maintenance cost
Medium

Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.

Likely impactRecurring annual cost significantly above the one-time service price.
MitigationModel annual compliance costs before committing to this route.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP strategy

Lithuania has a strong regulated-finance profile, but banking difficulty remains medium to high for crypto. Bank, EMI, PI and PSP readiness should run in parallel with the CASP application, especially for custody, exchange and fiat-heavy models.

Banking difficulty
High

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare ownership, source-of-funds, flow-of-funds, client geography, token policy and transaction monitoring evidence.
  • Explain safeguarding arrangements before approaching banks, EMIs, PIs or PSPs.
  • Do not assume Bank of Lithuania authorisation will automatically solve account opening or payment rail access.

Business model fit — Lithuania

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
6/6
Poor fit
0/6

Lithuania may not cover your primary activities

Consider an alternative route that better matches your activity profile.

Bank of Lithuania application profile

Regulatory authority · Lithuania

Bank of Lithuania

A Lithuania CASP file should read like a regulated financial services application. The Bank of Lithuania route is strongest when the applicant can show clear services, responsible management, Lithuania substance, AML controls, safeguarding and a realistic banking package.

Official regulator website
Likely areas of scrutiny
  • Regulatory reputation is high, but weak substance or generic policies are likely to create review friction.
  • Custody, exchange and cross-border fiat flows need deeper controls than narrow brokerage or advisory models.
  • AML, sanctions, travel rule, transaction monitoring, outsourcing and cybersecurity evidence should be product-specific.
  • Source updates should be checked before relying on exact timelines, fees or document requirements.
Regulatory reputation
High

Strong international recognition and established supervision track record.

Setup complexity
High

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Risk assessment

Main risk dimensions for the Lithuania route.

Banking difficulty
High

Route risk rating — banking difficulty: Medium to high. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
High

Route risk rating — setup complexity: High.

Maintenance cost
High

Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
High

Route risk rating — regulatory reputation: High.

Regulatory risk
Medium

Route risk rating — regulatory risk: Low to medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Lithuania CASP vs alternatives

Compare Lithuania with Malta CASP for another high-reputation EU/MiCA route, Estonia and Poland for Baltic or Central/Eastern European CASP planning, and Turkey CASP as a non-EU local-market contrast with no EU/EEA passporting.

Current

Lithuania

CASP

Price
17 300 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

Malta (CASP)

CASP

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Established EU CASP route with MFSA supervision

− Also demanding on substance, governance, audit and ongoing compliance

View route

Estonia (CASP)

CASP

Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Baltic/EU comparison point for MiCA authorisation planning

− Not a shortcut if the business cannot support MiCA-level controls

View route

Poland (CASP)

CASP

Passporting
EU/EEA
Banking
Medium
Reputation
Medium to high

+ EU alternative for teams comparing Central and Eastern European routes

− Route selection still depends on local substance, regulator expectations and banking

View route

Turkey (CASP)

CASP

Price
52 800 EUR
Timeline
From 3 months
Passporting
No passporting
Banking
High
Reputation
Medium

+ Non-EU contrast for Turkey-facing local market operations

− Does not provide EU/EEA passporting and has a different regulatory perimeter

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Lithuania vs other CASP routes

Compare key parameters across CASP authorisation routes.

Sort by:
LithuaniaCurrent
Price17 300 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh
Turkey
Price52 800 EUR
TimelineFrom 3 months
BankingHigh
ReputationMedium

Check your readiness for Lithuania CASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

From 50 000 EUR minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Lithuania.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

Lithuania CASP authorisation under MiCA can support EU/EEA passporting for approved services, subject to the required notification process. It should not be described as automatic access for every future activity or market.

Lithuania is best suited for teams that need a credible Baltic/EU CASP route, value Bank of Lithuania supervision and can support local substance, governance, AML, safeguarding and banking preparation.

Usually no. The route requires local staff, physical office, audit, capital, compliance ownership and ongoing controls, so it is not a good fit for a fast offshore or low-cost setup.

The main risk is assuming that authorisation alone will unlock banking or payment rails. Banks, EMIs, PIs and PSPs will still review ownership, flows, clients, token policy, AML controls and safeguarding arrangements.

Lithuania is an EU/MiCA route that can support EU/EEA passporting planning. Turkey is a non-EU local-market CASP route and should be treated as a contrast for Turkey-facing operations, not as an EU access route.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

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