MiCAR in Lithuania
Under Lithuania’s Crypto-Asset Markets Act (11 July 2024), the Bank of Lithuania is the sole supervisory authority for all MiCA-related crypto-asset activities. A startup must be formed as a public (AB) or private (UAB) limited company and may obtain either an asset-referenced-token issuer licence or a crypto-asset service-provider licence. Its dossier must mirror MiCA annex requirements—business plan, governance, capital and risk data—with any follow-up information supplied within 20 working days of the supervisor’s request. All directors need prior “fit-and-proper” clearance, and the Bank rules within 30 working days of receiving a complete file. Post-licensing, the firm must keep Lithuanian-standard accounts, file prudential reports, and undergo an annual external audit that also confirms MiCA capital compliance; resolve customer complaints within 15 business days (exceptionally 35); and ensure client-facing staff continually meet knowledge benchmarks set by the supervisor.
Competent authority. All licensing and ongoing supervision are carried out by the Bank of Lithuania.
The Lithuanian Crypto‑Asset Markets Act of 11 July 2024 transposes EU Regulation 2023/1114 (MiCA) and applies in parallel with it. Key licensing provisions start applying on 30 December 2024; accounting and audit rules apply from 1 August 2024.
-
Asset‑referenced token issuer licence – allows public issuance of tokens that reference a pool of assets.
-
Crypto‑asset service provider licence – covers custody, exchange, brokerage, order execution, placement, portfolio management and other MiCA services.
-
A licence applicant must be incorporated as either:
-
a public limited company (Akcinė bendrovė, “AB”), or
-
a private limited company (Uždaroji akcinė bendrovė, “UAB”).
No other legal forms are accepted for MiCA licensing in Lithuania.
-
If the applying company already conducts, or intends to conduct, any business other than crypto‑asset services, the Bank of Lithuania may refuse the licence until those activities are transferred to a separate company, whenever they could adversely affect the applicant’s financial soundness or supervisory transparency.
The company must file the full set of information required by MiCA (notably the data listed for token issuers and service providers) together with any national forms. If the supervisor requests clarifications, they must be delivered within 20 working days.
Typical contents include:
-
constitutional documents and proof of legal form;
-
programme of operations and business model description;
-
organisational structure and governance arrangements;
-
policies on internal control, risk management, AML/CTF and outsourcing;
-
evidence of own‑fund resources and prudential calculations;
-
white paper for the tokens (for issuers);
-
list of managers, beneficial owners and key function holders, with supporting fit‑and‑proper documentation.
All documents must meet Lithuanian archival and document‑management standards; incomplete or inaccurate files are grounds for refusal.
-
Governance bodies required: shareholders’ meeting, board and chief executive. Each director or senior manager needs prior individual approval from the Bank of Lithuania. Assessment focuses on impeccable reputation, relevant education, professional experience and absence of conflicts of interest.
Decision deadline: 30 working days after the complete request is received; the clock stops if the supervisor asks for additional data. The supervisor can refuse or later revoke an approval for misrepresentation or loss of fitness and propriety.
Any employee who provides advice on crypto‑assets or related services must possess – and keep up‑to‑date – knowledge and skills set out in a competence list issued by the Bank of Lithuania. The supervisor also defines the assessment criteria.
-
Compliance with MiCA and the Lithuanian Act at all times (own funds, reserve assets, conduct of business, disclosure, white‑paper maintenance).
-
Regular prudential and statistical reports in formats and deadlines set by the Bank of Lithuania.
-
Statutory accounting under Lithuanian Financial Accounting Law and annual financial statements under the Corporate Reporting Law; financial year equals the calendar year.
-
Mandatory external audit every year; the auditor must report any breaches or going‑concern doubts to the supervisor within three working days.
-
Complaints handling – every customer complaint must receive a reasoned reply within 15 working days (exceptionally 35 days). Procedures must be free of charge.
-
Employee knowledge upkeep and timely notification of changes in directors or key functions for fresh approval.
-
-
Choose the legal form (AB or UAB) and incorporate in Lithuania.
-
Prepare the application package strictly following MiCA annexes and the Bank of Lithuania’s templates; factor in translation of all materials into Lithuanian.
-
Screen and pre‑approve directors and senior managers; collect evidence of reputation and experience early to avoid delays.
-
File the complete dossier and be ready to answer information requests within 20 working days.
-
Set up internal policies and IT systems so that they already comply with MiCA when the licence is granted.
-
Plan for annual audits and reporting cycles from day one; select an audit firm experienced in regulated financial entities.
-
Implement a customer‑complaint process that meets the 15‑day response standard.
-
Establish a training programme aligned with the supervisor’s competence list for all client‑facing staff.
-
Monitor supervisory communications and be prepared for on‑site inspections or data calls.
-
Behind Licentium
Our Edge
Licentium is a specialized platform that connects crypto-asset issuers and service providers with an international network of lawyers, regulatory consultants, and former supervisors. Projects can map applicable rules in key jurisdictions through a single interface, obtain jurisdiction-specific launch advice, arrange the drafting of white papers and licensing applications, and schedule ongoing compliance health-checks. The platform’s curated expert pool spans financial services, data protection, and corporate law, enabling founders to address cross-border requirements—from MiCA in the EU to securities, AML, and consumer-protection regimes elsewhere—within coherent project timelines and budgets.
