Crypto Regulations in Lithuania (2026): Licensing and Compliance After the MiCA Transition

For years, Lithuania was one of the easiest places in the EU to start a crypto business: firms just needed to register with the national registry. Those times are over. Since January 1, 2026, only providers authorized under the EU's Markets in Crypto-Assets Regulation (MiCA) may offer crypto-asset services in the country.

The end of the transition period

MiCA has applied since December 30, 2024. Like most member states, Lithuania let existing providers keep operating for a transitional period. That period ended on December 31, 2025. From then on, onboarding clients, holding crypto-assets in custody, or providing any other crypto-asset service without a MiCA license counts as illegal financial activity. 

The penalties are serious. Under the Criminal Code, providing financial services without a required license can lead to fines, restriction of liberty, or up to four years' imprisonment. The Bank of Lithuania can also block websites it suspects of offering illegal financial services.

The EU-wide transition then ended on July 1, 2026, so across the EU only MiCA-authorized CASPs may now provide crypto-asset services, which influenced the market. In mid-2025, over 370 companies were registered to provide crypto services, but only about 120 were actually operating and filing financial statements. Licensing has been slow and selective. The Bank of Lithuania received 102 MiCA license applications from 55 companies in 2025, with around 30% submitted in October and November, just before the deadline. In March 2026, UAB Micar Assets became the fourth company in Lithuania licensed under MiCA, after Robinhood Europe, CoinGate (UAB "Decentralized"), and Nuvei Liquidity.

Suggested read: MiCA Regulation and EU Crypto Rules: What Changes in 2026

Who regulates crypto in Lithuania?

• Bank of Lithuania (Lietuvos bankas): The competent authority under MiCA. It grants CASP licenses, supervises licensed firms, and enforces the rules. It has set up a new Investment and Crypto-Asset Firms Supervision Division within its Prudential Supervision Department.
• Financial Crime Investigation Service (FCIS): Lithuania's financial intelligence unit, which receives suspicious transaction reports. The FCIS and the Bank of Lithuania have agreed to share expertise, run joint inspections, and assist each other in supervising crypto firms.
• Ministry of Finance: Drafts national legislation and aligns it with EU law.

Key legal frameworks

• MiCA (Regulation (EU) 2023/1114): The EU-wide rulebook for crypto-asset issuers and service providers.
• Law on Markets in Crypto-Assets (No. XIV-2879): Lithuania's implementing law. It sets sanctions, including fines that can reach EUR 15 million or 15% of annual gross income for legal persons for certain market-abuse infringements.
• Transfer of Funds Regulation (Regulation (EU) 2023/1113), TFR: Brings the Travel Rule to crypto transfers.
• Law on the Prevention of Money Laundering and Terrorist Financing: Sets the national AML/CFT obligations that apply to CASPs.

Getting a CASP license in Lithuania

Applications go to the Bank of Lithuania. Completeness is checked within 25 working days of receipt, and a decision follows within 40 working days after the application is deemed complete. Minimum capital depends on the services provided:

• Class 1 (€50,000): order execution, placing, transfer services, reception and transmission of orders, advice, and portfolio management
• Class 2 (€125,000): any Class 1 services plus custody and exchange of crypto-assets for funds or other crypto-assets
• Class 3 (€150,000): any Class 2 services plus operating a trading platform

Applicants must show sound governance, fit-and-proper management, a risk management framework, and AML/CFT controls. CASPs must also meet the ICT resilience requirements of DORA.

The regulator said applicants were unprepared, and many applications filed in the final weeks didn't meet even the minimum requirements.

A license carries EU passporting rights, so a Lithuanian CASP can serve clients in other member states after a notification process.

E-money tokens and payment licenses

CASPs dealing in EMTs may need a second license. Because transferring EMTs on a client's behalf, or holding them in custody, can count as a payment service, the EBA's No-Action Letter gave these firms until March 1, 2026, to obtain a payment institution authorization or hand the services to an entity that already has one. The Bank of Lithuania relayed that to the Lithuanian market in June 2025, and the requirement has applied since March 2, 2026. Missing the date is not automatically fatal: in February 2026 the EBA set out the conditions under which national regulators may let a CASP keep providing EMT payment services while its application is pending, and advised them to make firms outside those conditions stop. Both CoinGate and Nuvei Liquidity obtained a payment institution license alongside their CASP authorization.

AML and Travel Rule obligations

Licensed CASPs are obliged entities under Lithuanian AML law. They must:

• carry out customer due diligence before providing services
• apply enhanced due diligence to high-risk customers
• monitor transactions on a risk-based basis
• report suspicious activity to the FCIS
• keep customer due diligence and transaction records
• screen customers against sanctions lists

Under the TFR, CASPs must attach originator and beneficiary information to every crypto-asset transfer, whatever its size. For transfers above €1,000 involving a self-hosted wallet, they must also check that the customer owns or controls that wallet.

Suggested read: Crypto Travel Rule Explained: FATF Requirements for VASPs

Firms that did not get licensed

Unlicensed firms must wind down. The Bank of Lithuania and ESMA say these firms should stop accepting new clients and marketing, offer only the services needed to sell or transfer crypto-assets or close positions, and keep clients clearly and repeatedly informed. The obligations continue after clients move. A licensed CASP that takes on transferred clients must promptly carry out full customer due diligence, and custody may not be outsourced to providers without MiCA authorization.

What's next for crypto in Lithuania?

• Possible move to EU-level supervision. On December 4, 2025, the European Commission published the Market Integration and Supervision Package, which proposes transferring direct supervision of all CASPs to ESMA. The European Parliament may soften this. The ECON rapporteur's draft keeps small CASPs under national supervision and moves only significant ones to ESMA. The proposal is still going through the legislative process.
• DAC8. CASPs have had to collect tax-reporting data on EU clients' crypto transactions since January 1, 2026, with the first reports due in 2027.
• EU AML package. The AML Regulation (AMLR) applies from July 10, 2027, and will replace much of the national AML rulebook with directly applicable EU rules. The new EU AML Authority (AMLA) is expected to begin directly supervising selected high-risk cross-border financial entities from 2028.

Conclusion

Lithuania still works as a base, but the entry price has changed. Registering with the Centre of Registers took weeks. Under MiCA, the Bank of Lithuania has received applications from 55 companies and issued four licenses. Firms that get through hold something they can passport across the EU and that banks and payment partners will recognize. Firms that skipped the process now risk criminal liability, not just regulatory action. Anyone starting now should plan around the next two dates as well: the AMLR from July 10, 2027, and the first DAC8 reports, due by September 30 of the same year.