Lithuania CASP Application Process 2026
Lithuania CASP authorization under MiCA takes 4–8 months end-to-end. Bank of Lithuania has a 3-month completeness check plus an extended substantive review under MiCA Article 62 — typically 20–25 weeks total once the application is submitted. Here's the full month-by-month process.
The 7-stage Lithuania CASP authorization process
Stages run mostly sequential, with some parallelization possible (UAB formation + AML program build can overlap). The Bank of Lithuania review is the longest stage and is purely waiting time.
Stage 1: Strategy + class selection (Week 1)
You contribute: 30-minute call. Describe your crypto activity, target customers, expected volumes, and current corporate structure (existing entity elsewhere? VASP transitioning? completely greenfield?).
We deliver: Honest recommendation on whether Lithuania CASP is the right fit. CASP class recommendation (Class 1, 2, or 3 based on services). Engagement letter, fixed-fee quote, project timeline.
Honest framing: If you only need to serve non-EU customers, Lithuania CASP's $50K–$120K cost + €125K capital is overkill — Panama or Canada MSB would serve you better. Lithuania CASP makes economic sense when EU retail customers are a genuine target market.
Stage 2: Lithuanian UAB formation (Week 1–2)
We deliver: Lithuanian UAB incorporation with €2,500 share capital. Notary execution. Registration with Centre of Registers (Lithuanian companies house). Registered office in Vilnius. 1–2 weeks.
You contribute: Provide founder/director identification documents (passports, proof of address). Sign incorporation documents (can be done remotely with apostilled signatures).
Stage 3: Capital deposit (Week 2–6)
We deliver: Open Lithuanian bank account for the UAB at one of the crypto-friendly Lithuanian banks/EMIs (Paysera, Verse, ConnectPay, Genome, Citadele, SEB). Coordinate auditor confirmation of capital deposit.
You contribute: Wire €50K–€150K (depending on CASP class) to the UAB's Lithuanian bank account. Source-of-funds documentation for the wire.
Banking is the bottleneck here. Lithuanian banks have tightened KYC for crypto-adjacent businesses; opening a bank account for a new UAB intended to become a CASP can take 2–4 weeks. Some EMIs (Paysera, Verse) are faster — 1–2 weeks. Plan accordingly.
Stage 4: Application package preparation (Week 4–14, parallel with Stages 2–3)
This is the deliverable Bank of Lithuania actually reviews. Quality matters enormously.
We deliver (in collaboration with Lithuanian counsel):
- Business plan with 3-year financial projections (30–80 pages)
- AML/KYC program (5AMLD/6AMLD compliant, 60–120 pages)
- IT and security framework (20–60 pages)
- Business continuity plan
- Outsourcing arrangements documentation
- Service descriptions for each crypto-asset service
- Customer-facing terms of service, white papers (where applicable), risk disclosures
- Conflicts of interest policy
- Complaint handling procedure
You contribute:
- Business model details, expected volumes, customer geographies
- Identify all key personnel (board members, MLRO, IT officer)
- Each key person completes fit-and-proper questionnaire (~15-20 pages each)
- Each key person provides: CV, criminal record check (apostilled), 2 professional references, photo ID
- Source-of-funds documentation for capital deposit
- UBO disclosure for all owners ≥10%
Stage 5: CASP application submission (Week 14–15)
We deliver: Submit complete application package to Bank of Lithuania via the supervisory portal. Pay the €5,000–€10,000 application fee. Receive acknowledgement within 5 business days.
Stage 6: Bank of Lithuania review (Week 15–40)
Under MiCA Article 62, Bank of Lithuania has a structured review process:
- Completeness check (3 months): Bank of Lithuania confirms the application is complete. If incomplete, requests additional information with response deadlines.
- Substantive review (extended): Detailed review of business plan, AML program, IT framework, fit-and-proper, capital adequacy. May involve interviews with key personnel.
- Decision: Authorize, conditionally authorize, or refuse. Authorization is published on Bank of Lithuania's register and ESMA's central register of CASPs.
Typical end-to-end review: 20–25 weeks. Faster for simple Class 1 applications; slower for Class 3 trading platforms.
What you can do during review: Wait actively. Bank of Lithuania may issue requests for information (RFIs) at any point. Respond within 7-14 days; slow responses extend the timeline. Use the waiting period to onboard MLRO, finalize IT systems, build customer pipeline.
Stage 7: Authorization + EU passport activation (Week 40–42)
Bank of Lithuania delivers: CASP authorization decision. Your CASP is added to the public Bank of Lithuania CASP register and ESMA's central CASP register.
EU passport activation: To passport into other EU member states, file passport notifications via Bank of Lithuania. Receiving competent authority is informed; 30-day period after which you can provide services in that member state. Process is simple but requires individual notifications per member state.
Realistic timeline scenarios
| Scenario | Total time | Bottleneck |
|---|---|---|
| Best case — Class 1 (advice/portfolio), single founder, existing AML program from another EU jurisdiction | 4–5 months | Bank of Lithuania review |
| Typical Class 2 — exchange/custody, 2-3 founders, fresh AML program, Lithuanian MLRO hire | 6–7 months | Bank of Lithuania review + RFI cycles |
| Class 3 — trading platform, market-abuse surveillance setup, complex IT framework | 7–9 months | Application complexity + Bank of Lithuania review |
| VASP-to-CASP transition — existing Lithuanian VASP, AML program already in place | 4–6 months | Updated documentation + Bank of Lithuania review |
What can speed up the process
- Existing AML program from another EU jurisdiction — saves 4–6 weeks of program build.
- Pre-vetted Lithuanian MLRO — having the MLRO already identified before kick-off saves 2–4 weeks of recruitment.
- Class 1 vs Class 2 vs Class 3 — Class 1 reviews are 4–6 weeks faster than Class 3.
- Capital available immediately — €125K+ already in Lithuanian bank account at kick-off saves 2–4 weeks.
- VASP-to-CASP transition — existing VASPs typically 2–4 weeks faster than greenfield.
What slows the process
- Incomplete fit-and-proper documentation — most common cause of RFI cycles. Get criminal record checks apostilled in week 1.
- Generic AML program — Bank of Lithuania reviewers spot generic templates immediately, triggering deficiency findings.
- Insufficient local substance — purely foreign management triggers Bank of Lithuania substance concerns. Add Lithuanian-resident MLRO + at least one substantive Lithuanian board member or operations head.
- Capital deposit delays — Lithuanian bank account opening can take 2–4 weeks for new UABs intended to become CASPs.
- RFI delays — slow responses to Bank of Lithuania RFIs add 2–6 weeks per cycle.
FAQ — Lithuania CASP application process
How long does Lithuania CASP authorization take in 2026?
Lithuania CASP authorization takes 4–8 months end-to-end. Pre-submission stages (UAB formation, capital deposit, AML program, application package) take 2–3 months. Bank of Lithuania review under MiCA Article 62 takes 20–25 weeks (3-month completeness check + extended substantive review). Class 1 is faster (~4–5 months); Class 3 is slower (7–9 months) due to complexity.
Do I need to travel to Lithuania for the CASP application?
No travel is strictly required for the application itself. UAB formation, document signing, and CASP submission can be done remotely with apostilled signatures. However, Bank of Lithuania may request key personnel interviews — these can be done by video. Most successful CASP holders eventually establish some Lithuanian presence (MLRO, operations staff, occasional in-person meetings) for substance reasons.
What's the EU passport notification process?
To passport into another EU member state, file a notification with Bank of Lithuania specifying the receiving country and services. Bank of Lithuania forwards to the receiving competent authority within 1 month. After a 30-day waiting period from receipt by the receiving authority, you can provide services in that country. Each member state requires a separate notification, but the underlying authorization is a single Lithuanian CASP authorization.
Can I start operations before authorization is granted?
No. You cannot provide regulated CASP services to EU customers before authorization is granted — doing so violates MiCA and triggers enforcement. You CAN provide non-EU services from another jurisdiction (Panama, Canada) during the wait, and use the wait period to build technology, recruit, and prepare for launch.
What happens if Bank of Lithuania refuses authorization?
If Bank of Lithuania refuses authorization, you receive a written decision with reasons. You can appeal to the Vilnius Regional Administrative Court within 30 days, or address the deficiencies and re-apply. Most refusals can be addressed with corrected documentation; full re-applications take another 4–8 months. Better to invest in a high-quality first application than to expect to refile.
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