MiCA in Lithuania: How to Prepare

MiCA in Lithuania: How to Prepare

Lithuania is steadily establishing itself as one of the leading jurisdictions for VASPs seeking to comply with the new MiCA regulation. And although the transitional period will last until December 31, 2025, action must be taken now. Delaying may cost companies not only time but also the right to operate in the EU.

What this means: companies have less than six months left to submit their application and pass the two-stage review by the Bank of Lithuania.

Moreover, from March 2, 2026, CASPs carrying out certain electronic money token transactions will be required to hold an additional authorisation to provide payment services.

Are there any precedents?

The Lithuanian financial regulator has officially issued a licence under the MiCA regulation. The right to provide services throughout the EU was granted to Robinhood Europe UAB, which submitted its application earlier this year.

This step confirms that Lithuania is not only ready for the new regulatory landscape, but is becoming one of the key gateways for business entry to the European market. Over 370 companies are currently registered locally as VASP, but far from all are actively preparing documentation to transition to the new regime.

Four Key Requirements from the Bank of Lithuania for CASPs

1. Share Capital:
   The capital must be registered. In the case of a cash contribution, this means a real amount either blocked in a bank account or confirmed by a bank statement. It must be confirmed that the balance meets the required amount on the date of application submission.
2. Management Bodies:
   Two directors with proven experience in finance and impeccable reputation are required.
3. AML:
   A certified MLRO, internal KYC procedures, transaction monitoring, and proper client verification must be in place.
4. Operational Resilience:
   Business continuity plan, key management policy, internal audit, and cybersecurity structure must be clearly defined.

How to Prepare: Step-by-Step Plan

Step 1: Define the service class your company falls under

This determines the minimum capital requirements. Remember, the capital must be actually deposited in the company’s account before the application is submitted.

Step 2: Build a qualified team

At least two directors with relevant financial experience, legal clarity, and confirmed competence are mandatory. You will also need:

• MLRO — a money laundering reporting officer
• Information Security Officer — responsible for cybersecurity
• Auditor / Internal Controller — for compliance monitoring

Step 3: Prepare your documentation

MiCA requires a full set of internal policies, including:

• AML/KYC framework
• IT architecture and custody mechanism description
• Business continuity plan
• 3-year business plan
• Cyber risk strategy and asset protection plan

Note: this is an indicative, not exhaustive, list of required documentation.

Step 4: Ensure your IT infrastructure is ready

The website must function properly, contain all necessary client information, present clear marketing offers, and ensure technical compliance with operational requirements.

Step 5: Submit your application to the Bank of Lithuania

The regulator will assess the submitted documentation, may request additional information, or conduct an on-site interview. Review timelines vary from 2 to 6 months, depending on the completeness of your application.

How FINANCEIQ HUB LTD Supports You

We guide businesses through all stages of preparation and submission for a MiCA licence in Lithuania:

✔ Registration of a UAB (if required)
✔ Opening of a capital deposit account
✔ Preparation of a complete set of documents
✔ Review of management team and support with additional required documentation
✔ Full project management and communication with the regulator
✔ Connections to payment partners for a complete infrastructure setup (accounts, acquiring, liquidity provider, on/off ramp, KYT/KYC providers)

✔ Additionally, we can assist in obtaining an MSB licence in Canada or the USA for expanding to new markets.

📩 Contact us to request a company audit and receive consultation on the optimal structure for your business.