How to operate a crypto business after the introduction of MiCA. CASP licence in Lithuania
With the adoption of the MiCA (Markets in Crypto-Assets) regulation, the European Union has introduced a pan-European framework for regulating the crypto industry for the first time. The document came into force in 2024 and aims to establish uniform standards for working with crypto assets, eliminate regulatory fragmentation and strengthen consumer protection.
MiCA covers a wide range of crypto assets, including stablecoins and tokens. It regulates the activities of service providers in this area, known as Crypto-Asset Service Providers (CASP). The main goal is to legalise the industry, increase transparency and prevent abuse.
The significance of MiCA for the crypto business in the EU and, in particular, in Lithuania
MiCA has been a turning point for the crypto business in Europe. The regulation provides the legal certainty needed by both institutional investors and start-ups. It eliminates differences in national regulatory regimes, ensuring a uniform standard across the EU.
For Lithuania, as one of the leading key EU jurisdictions in the field of fintech and blockchain projects, MiCA means the transformation of the existing registration regime for cryptocurrency companies into full-fledged licensing. The introduction of the CASP licence will enhance the credibility of Lithuanian companies in the international arena and allow them to provide services throughout the EU without hindrance.
What are MiCA and CASP?
Definition of the MiCA Regulation
MiCA (EU Regulation 2023/1114) is a regulatory act adopted by the European Parliament and the Council in June 2023. It aims to regulate the issuance, circulation and storage of crypto assets, with the exception of central bank digital currencies (CBDCs), NFTs and tokenised securities, which are regulated by other acts.
The main principles of MiCA are:
- establishing requirements for issuers of crypto assets and stablecoins (ART — asset-referenced tokens, EMT — e-money tokens);
- ART — pegged to several assets or a basket of assets (fiat, gold, etc.). EMT — strictly to one fiat currency (USDC, USDT, EURe), acts as electronic money;
- introducing mandatory registration and licensing of crypto service providers (CASP);
- principles of governance, capital requirements, cybersecurity, internal control and anti-money laundering;
- obligation to disclose information and protect consumer rights.
Definition of CASP regulations
Crypto-Asset Service Provider (CASP) — a legal entity providing services related to crypto assets. MiCA defines several types of such services:
- storage and management of crypto assets on behalf of third parties;
- exchange of crypto assets between each other and for fiat currencies;
- execution of orders on behalf of clients;
- organisation of trading platforms (exchanges);
- services for the placement of crypto assets;
- acceptance and transmission of orders, consulting on crypto assets, etc.
The role of the CASP licence
The CASP licence grants companies the right to officially operate throughout the EU and ensures a high level of trust from customers, partners and regulators. Without a licence, activities will be considered illegal after the transition period ends.
Transition period and deadlines
MiCA entry into force deadlines MiCA will enter into force in stages, according to the official text of Regulation (EU) 2023/1114:
- from 30 June 2024 — the start of regulation of stablecoins (EMT and ART);
- from 30 December 2024 — the start of application of requirements to all other crypto service providers (CASP).
The full version of the regulation, including its provisions, requirements and effective dates, can be found here. At the EU level, the European Securities and Markets Authority (ESMA) supervises major players. In Lithuania, supervision is carried out by the Central Bank of Lithuania (Lietuvos Bankas).
Transition period in Lithuania
Until the end of 2025, companies already operating as virtual currency operators (VASPs) may continue their activities provided they apply for a licence by 1 January 2026. If the application is not submitted on time:
- the activity will be deemed illegal;
- fines and a ban on providing services may be imposed;
- bank accounts may be blocked and access to the payment infrastructure may be restricted.
Requirements for obtaining a CASP licence in Lithuania
To obtain a CASP licence in Lithuania, you must:
- register a company in Lithuania with a real physical presence (office, local director);
- appoint an MLRO (compliance and AML/CTF specialist);
- provide a business plan, financial model and description of services; prepare AML/KYC policies, risk management and internal control procedures;
- comply with minimum capital requirements (from €50,000 to €150,000 depending on the type of services);
- prove the integrity and qualifications of managers.
The Central Bank of Lithuania reviews applications within 3–6 months, provided that all necessary documentation is submitted.
Main responsibilities of CASPs after obtaining a licence
- compliance with MiCA and national legislation requirements;
- regular reporting to the regulator;
- conducting compliance control and customer verification (KYC);
- ensuring the protection of user assets;
- reporting suspicious transactions;
- complying with capital, risk management and cybersecurity requirements.
Violation of obligations may result in licence revocation and sanctions.
Advantages of obtaining a CASP licence in Lithuania
Lithuania is one of the most popular jurisdictions for crypto companies to operate in the EU. The main advantage of licensing in this country is the lowest cost of maintaining a company's operations. Other advantages include:
- a quick and straightforward registration procedure;
- an adequate and loyal approach by the regulator;
- an advanced fintech ecosystem and an English-speaking business environment;
- the ability to open accounts with European banks and work with payment service providers.
Recommendations for preparing for licensing
Preparing for licensing requires a comprehensive approach. It is recommended to:
- conduct an internal audit for compliance with MiCA requirements;
- evaluate current AML/KYC processes and refine them; prepare a business plan and risk management strategies;
- appoint qualified board members and responsible persons;
- ensure the technical security of the platform;
- consult with lawyers and fintech consultants specialising in MiCA and CASP licensing.
Conclusion
MiCA is not just a regulatory framework, it is a new era for the crypto business in the European Union. Companies wishing to continue operating legally must adapt to the new realities and prepare for licensing in advance.
Obtaining a CASP licence in Lithuania opens up access to the European market, improves reputation and provides competitive advantages. However, it should be remembered that the path to licensing requires thorough preparation, knowledge of legislation and experience in regulatory matters.
It is important to start preparing for CASP licensing today to ensure the stable and legal operation of cryptocurrency businesses in the EU after the MiCA provisions come into force. Companies planning to continue operating in the European market should assess their compliance with the new requirements in a timely manner, adjust their internal processes, and prepare a complete set of documents for submission.
It is recommended to engage specialists with experience in the field of crypto asset regulation. Turning to experienced consultants will not only speed up the process of obtaining a CASP licence, but also minimise the risks of rejection or sanctions. Reliable legal and regulatory partners will ensure the correct adaptation of the business to the new conditions and help build a sustainable strategy for operating in the EU market.
We have experience in solving tasks of varying complexity — from typical situations to non-standard cases with many nuances. First, our specialists study the issue, propose the optimal path and support at each stage, relying on proven solutions and real-life cases.
