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European UnionLithuania requires MiCA entitlement for crypto-asset services following the end of its transition in December 2025. Lietuvos bankas assesses each CASP applicant’s organisation, resources and service scope. Domestic security token guidance provides classification and record-keeping criteria, but service licensing does not replace issuance rules or additional payment obligations.
For a business planning tokenization or services in Lithuania, the former virtual-currency register is no longer the destination. The project must identify the provider’s current authorisation and distinguish MiCA crypto-assets from shares, bonds or other financial instruments represented on a network.
Both routes can be observed in Lithuania: the Bank of Lithuania processes service authorisations and records permissions for DLT infrastructures. These are different entitlements, with organisational, client-protection and asset-control requirements that must be reflected in the operating model.
What changed when the VASP regime ended
MiCA governs services and assets within its scope in Lithuania, alongside domestic implementation measures. Financial instruments are not brought within MiCA merely by tokenization. Initial assessment must distinguish service provision, asset issuance and any investment or payment services associated with the business model.
FNTT's December 2025 notice confirms that transition ended on 31 December. From 1 January 2026, former VASP registration no longer permits services without the required entitlement. Closure also does not remove obligations to retain client and transaction records for the applicable statutory periods.
The roles of the Bank of Lithuania and FNTT
Lietuvos bankas handles CASP authorisations and publishes entry requirements. Financial supervision must be distinguished from FNTT's financial crime prevention and investigation functions. Previous registration under the anti-money laundering framework does not establish equivalent prudential assessment or convert automatically into a MiCA licence.
The bank also distinguishes requirements for ART and EMT issuers. Asset-referenced tokens and e-money tokens are separate categories. The issuer, its entitlement and the relevant disclosure document must be checked; authorisation of a distributing platform does not itself establish compliance of the issuance.
The organisation an applicant must demonstrate
A CASP application must define services, governance, shareholders and necessary resources. The August 2024 supervisory letter requires a transparent structure and rejects outsourcing that turns the company into an empty shell. It guides application preparation rather than promising approval or a fixed commercial timetable.
The published procedure distinguishes Article 63 authorisation from Article 60 notifications for certain financial entities. An electronic money institution, for example, has a limited route for custody and transfer of its own EMTs. Cross-border access also requires the applicable procedure; another group company cannot use the licence as its own.
Issuing and recording securities using DLT
Lithuania's 2019 security token offering guidelines examine economic functions and incorporated rights. Where a token has financial instrument characteristics, applicable securities, investment and public offering rules follow. The issuer's chosen name or execution through a smart contract does not displace that classification.
The guidelines condition recognition of DLT entries as financial instrument accounts on system integrity, reconciliation and legal compliance. They must be read alongside the later European DLT Pilot Regime, which provides specific permissions and exemptions. Each issuance still needs analysis of entitlement, transfer, custody and correspondence between the technology register and enforceable rights.
Lietuvos bankas' register records an investment firm licence and specific DLT trading and settlement system permission for UAB Axiology DLT from 9 July 2025. This establishes an authorised domestic infrastructure. It neither authorises other platforms nor proves that every proposed asset can be admitted to that system.
When payments and custody add requirements
DORA and MiCA require continuity, ICT security and external provider oversight. Custody requires separation of proprietary and client assets, access controls and arrangements for returning assets. A technology contract neither transfers regulatory responsibility nor independently establishes insolvency protection.
The bank's June 2025 notice explains that certain EMT operations can constitute payment services. The EBA's February 2026 Opinion sets out conditions for continuity pending a PSD2 authorisation decision after 2 March. This is not a general exemption: the specific activity and competent authority's treatment need verification.
Preparing to operate or issue from Lithuania
Preparation begins by classifying the asset and checking permission for the entity contracting with the client. A firm coming from the VASP regime must also review record retention and other duties surviving closure of its former business.
For securities issuance, define holder records, reconciliation and transfer rules before selecting infrastructure. If a service uses EMTs for payments, also assess PSD2 and applicable conditions; crypto-asset authorisation does not automatically settle that additional perimeter.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Former VASP registration ceased to permit continuity in January 2026.
- Authorisation requires effective resources and management as well as documentation.
- Security token classification depends on the token’s rights and functions.
- EMT payment services require assessment separate from CASP authorisation.
Blockchain development in Lithuania
Regulatory milestones
Security token offering guidelines
Lietuvos bankas approves classification, offering and record-keeping criteria through Resolution 03-188.
Domestic crypto-asset markets law
The domestic law supplementing application of the MiCA Regulation is adopted.
EBA Opinion on EMTs and payments
The EBA clarifies supervisory conditions at the end of its PSD2/MiCA No-Action Letter transition.
Frequently asked questions
No. Transition ended on 31 December 2025. MiCA authorisation or an applicable notification route must be verified, including its scope and any cross-border procedure.
Not by itself. Financial instruments fall outside MiCA. Issuance and related services must be assessed under securities, investment and, where relevant, DLT Pilot Regime rules.
No. FNTT states that documents must be retained for the applicable statutory periods, including when services end or the company is liquidated. FNTT · End of transition.
Yes. The Bank of Lithuania register identifies UAB Axiology DLT with an investment firm licence and specific DLT TSS permission valid from 9 July 2025. That permission belongs to that entity and has its own scope. Lietuvos bankas · Axiology DLT register.
No. Assess whether the activity is also a payment service. EBA’s February 2026 opinion sets conditions for continuation by certain PSD2 applicants; it is not a general exemption. EBA · 2026 PSD2/MiCA opinion.
