The Fastest EU Entry Point for Custodial Providers and VASPs with a Defined Path to MiCA

From 1 November 2022, amendments to the Lithuanian AML law increased the minimum registered share capital for virtual currency exchange and depository wallet operators to EUR 125,000 and introduced tighter governance and fit and proper requirements for shareholders and managers.

From 2025, Lithuania is aligning its regime with the EU Markets in Crypto Assets Regulation (MiCA). National legislation provides a transitional period: existing and new providers can still register as VASPs under the pre MiCA rules, but must move to the MiCA based crypto asset service provider (CASP) regime by 31 December 2025.

The standard legal form is a private limited liability company (UAB). Minimum share capital for an ordinary UAB is EUR 2,500, but for a VASP the registered share capital must be at least EUR 125,000. There is no statutory requirement for a Lithuanian resident director for a VASP, but at least one dedicated AML officer must be a Lithuanian tax resident and must be employed by the company.

Corporate income tax is currently 16% for most companies. From 1 January 2026, the standard rate will increase to 17% and the reduced rate for qualifying small companies will increase from 6% to 7%. Certain small companies (for example with fewer than 10 employees and annual revenue under EUR 300,000) can still benefit from reduced corporate rates under specific conditions. Dividends to individuals are generally taxed at 15% personal income tax.

The standard VAT rate is 21%. As in the rest of the EU, exchange of cryptocurrencies that function as a means of payment against fiat or between each other is treated as an exempt financial service following the CJEU Hedqvist judgment, so no VAT applies on the exchange margin. Ordinary goods and services billed in crypto are still subject to VAT, calculated on the euro value.

Until 31 December 2025, Lithuania still allows registration as a VASP with FCIS under the AML law. A Lithuanian UAB that meets the EUR 125,000 share capital requirement and AML governance conditions can register to provide virtual currency exchange and depository wallet services. There is no state fee for the registration itself and there is no annual supervision fee under the VASP regime.

– Appointment of a Lithuanian resident AML officer as a senior employee responsible for AML and sanctions compliance, including reporting to FCIS.
– Implementation of written AML, CFT and sanctions policies, customer due diligence procedures, risk assessment, and transaction monitoring.
– Reporting of suspicious activity and certain threshold based operations to FCIS, and maintenance of records for at least eight years under local AML rules.

From 2025, Lithuania is introducing a MiCA based CASP regime that will be supervised by the Bank of Lithuania. CASP authorisation will be mandatory for Lithuanian crypto businesses that want to continue regulated activities after 31 December 2025 or use MiCA passporting across the EU. CASP capital tiers and service categories follow MiCA and use initial capital levels of EUR 50,000, EUR 125,000 and EUR 150,000 depending on the services provided.

There is no automatic conversion from VASP registration to CASP authorisation. Existing Lithuanian VASPs that want to continue operating must file a CASP application and demonstrate compliance with MiCA level requirements on capital, governance, IT security and customer asset protection before the end of the transition period.

– Want an EU based operating company that can start under a relatively simple VASP registration in 2025, with a clear path into full MiCA CASP authorisation.
– Are comfortable with a EUR 125,000 registered share capital and the cost of a full time Lithuanian AML officer, but prefer not to maintain a full local board or a large physical office.
– Plan to offer straightforward exchange and custodial services and do not need banking or investment firm permissions.

This combination makes Lithuania relevant for early and mid stage exchanges, custodial wallet operators and payment style projects that want an EU footprint and are ready to invest in compliance, but prefer a lighter supervisory cost structure in the VASP phase before moving into MiCA CASP.