Lithuania was among the first in the European Union to regulate the crypto market, and it remains one of the strictest environments — but this page's main story is different: Lithuania closed its MiCA transition far earlier than the Union's maximum. In the Bank of Lithuania's own words, the transitional period for obtaining a crypto-asset service provider licence ended in Lithuania on 31 December 2025 — and since then, unlicensed operation reaches into criminal exposure.
Label discipline matters here too: the CASP authority in Lithuania is the Bank of Lithuania — use exactly that name in documents — while AML/CFT supervision stays with the Financial Crime Investigation Service (FCIS/FNTT). And no euro figure appears on this page: the current lb.lt pages publish no state-levy amount, so we write — the state levy is set by Government Resolution No 1458; confirm the amount with the regulator (lb.lt).
The EU Frame: MiCA and the Route for a Georgian-Owned Group
As across the Union, MiCA ((EU) 2023/1114) Article 59(2) requires a registered office in a Member State, effective management in the Union and at least one EU-resident director. The Bank of Lithuania's own page confirms directly that licensed providers must have their registered office in a Member State — for a Georgian group this means a Lithuanian company (UAB) with local substance. A third-country firm serves Union clients only at the client's own exclusive initiative (Article 61(1)).
The clock: a completeness check within 25 working days, a decision within 40 working days, a possible suspension of up to 20 further working days (Article 63). Own funds follow Article 67 and the Annex IV classes (the higher of the class minimum or one quarter of the preceding year's fixed overheads; confirm your class amount in Annex IV). Among refusal grounds, the Bank of Lithuania names members of the management body failing the Article 68(1) criteria.
The Regulator Split: Who Licences and Who Supervises
The Lithuanian Law on Crypto-Asset Markets (No. XIV-2879, adopted 11 July 2024) implements MiCA Title V nationally: authorisation and supervision belong to the Bank of Lithuania, while AML/CFT supervision remains with the Financial Crime Investigation Service (FCIS/FNTT). Applications go to the Bank's Legal and Licensing Department, and the Licensing Rules were set by a Bank Board resolution of 17 December 2024, in force since 30 December 2024.
The Timing Catch: a Window Closed Early, and Criminal Law
MiCA Article 143(3) allowed Member States to shorten the transition below 1 July 2026 — Lithuania used that option. The Bank of Lithuania's notices of 18 and 21 July 2025 both confirm the same fact: the transitional period ended in Lithuania on 31 December 2025. After that, unlicensed provision counts as "illegal financial activities": under the Criminal Code, providing financial services without a licence carries up to 4 years' imprisonment, and the Bank of Lithuania may block the websites of illegal providers — and publicises them.
The old register's numbers are telling: over 370 "virtual currency exchange operators and depository wallet operators" were declared on the Centre-of-Registers list, but by the Bank of Lithuania's assessment only around 120 were actually generating revenue. Those not continuing had to wind down in an orderly way — client communication, transfer of assets to licensed CASPs or self-hosted wallets, return of funds — under the Bank's July 2025 guidance.
Process, Current Pipeline and the Legal Basis of the Fee
The current picture: by July 2025 the Bank of Lithuania had roughly 30 applications, ten of them under assessment; the first MiCA licence in Lithuania was granted in May 2025 to Robinhood Europe, UAB, and the list of licensed providers is published on lb.lt. The application content is the MiCA Article 62/63 stack (in the formats of Delegated Regulation 2025/305 and Implementing Regulation 2025/306), and the Licensing Rules repeat the 25-working-day completeness deadline nationally, with notification of missing documents.
On fees: the state levy is set by Government Resolution No 1458 — confirm the amount with the regulator (lb.lt). Follow-up resolutions (including No 864 of 16 October 2024) amend the list, but no euro amount appears on the Bank's current pages — and we do not print the figure that circulates in law-firm materials. The annual supervision contribution runs under Bank Board contribution resolutions (current rates under No 03-115 of 14 October 2024); confirm the applicable amounts with the regulator.
The Georgian Layer: What Applies at Home Despite a Lithuanian Licence
A Lithuanian CASP licence is a document for the European market; Georgian requirements do not change underneath it. The organic law on the National Bank of Georgia (No 101044): Article 52-5(2) — the provider registers with the National Bank; Article 52-5(3) — unregistered operation is impermissible; Article 52-5(4) — only the virtual asset service and auxiliary activity; Article 39-1 — a virtual asset is not legal tender; Article 48 — supervision belongs to the National Bank.
The AML law (No 4690334): Article 3(1) makes VASPs accountable persons; Article 4 assigns AML supervision to the National Bank; Article 11(1) sets the crypto KYC trigger at USD 1 000 / EUR 1 000 / GEL 3 000; Article 17¹ is the Travel Rule, its accompanying-information content defined by a National Bank act (Article 52-5(1) of the organic law). A Lithuanian licence cancels none of this: Georgia-facing activity requires its own registration.
Frequently Asked Questions
What is the Lithuanian application fee?
No euro figure is published on the current lb.lt pages. The state levy is set by Government Resolution No 1458 — confirm the amount with the regulator (lb.lt). The number circulating in intermediary materials is not official and does not appear on this page.
Which regulator is competent in Lithuania?
The Bank of Lithuania — authorisation and supervision; AML/CFT supervision sits with the FCIS/FNTT. Any other institutional name in a Lithuanian context is an error: Latvia's former regulator's name is routinely mixed into materials by mistake.
Can we operate first and authorise later?
No. The transition ended on 31 December 2025 — in the FNTT's wording, a licence has been mandatory since 1 January 2026. Unlicensed provision is "illegal financial activity" carrying criminal liability of up to 4 years' imprisonment, and the Bank blocks websites.
Does a Lithuanian licence change Georgian requirements?
No — Georgia-facing services still require National Bank registration under Article 52-5(2), and the USD 1 000 / EUR 1 000 / GEL 3 000 KYC trigger and the Travel Rule remain part of the Georgian AML layer.
How We Help on Legal.ge
Legal.ge builds the Lithuanian route on the Bank of Lithuania's own materials: we set up the UAB with Article 59(2) substance, deliver the Article 62/63 stack in the 2025/305-306 formats, track the 25-working-day completeness clock and the FCIS/FNTT AML expectations, and in parallel build the Georgian ring — National Bank registration and AML compliance. The levy amount we confirm on lb.lt before filing — not in blogs. Contact us: let us start the Lithuanian route from your service list, with the post-31-December-2025 reality priced in.