Lithuania

Crypto Licensing

Lithuania's pre-MiCA national crypto-asset registration regime ended its transitional period on 31 December 2025, and from 1 January 2026 only crypto-asset service providers holding a Markets in Crypto-Assets Regulation authorisation may lawfully provide crypto-asset services in the jurisdiction. This wind-down occurred ahead of the EU-wide outer transitional limit set at 1 July 2026 under MiCA Article 143(3), making Lithuania one of the jurisdictions that closed its legacy national track early relative to the bloc-wide deadline.

Against this backdrop, Lietuvos bankas authorised Micar assets, UAB as a crypto-asset service provider, the fourth such MiCA authorisation granted in Lithuania. The authorisation covers custody and administration of clients' crypto-assets, exchange services, and order execution for both retail and professional clients. This is a concrete, dated, Tier-1-sourced licensing event directly from the supervisory authority, Lietuvos bankas.

The combination of a cleanly completed legacy-regime wind-down and continued authorisation activity under the new regime indicates a licensing module that is functioning as designed: no parallel unregulated track remains open, and the authorisation pipeline continues to process new applicants. Lithuania's own national implementing legislation citation for MiCA, sometimes referred to as a Law on Markets in Crypto-Assets, was not independently confirmed from the Seimas legal-acts register this cycle, which leaves a gap in the precise statutory citation underpinning the national supervisory framework even though the regulatory outcome itself is well evidenced through Lietuvos bankas's own publications.

Outlook

Further CASP authorisations at a similar pace are the expected trajectory for this module. Confirmation of the precise national implementing legislation citation, if retrieved in a future cycle, would close the current sourcing gap without changing the substantive finding that Lithuania's crypto-licensing regime is now fully MiCA-based.

Stablecoin Regime

From 2 March 2026 the Bank of Lithuania has communicated guidance addressing the interface between MiCA's electronic money token framework and Lithuania's payment-services licensing regime. The guidance holds that where a crypto-asset service provider's electronic money token-related activity, examined in substance, qualifies as a payment service, the provider needs an additional payment-services authorisation or must restructure its licensing arrangement accordingly. This sits atop, and does not replace, the directly-applicable MiCA rule permitting an electronic money institution to issue electronic money tokens and to provide custody and transfer services exclusively for the tokens it itself issues, subject to the institution notifying its home competent authority at least 40 working days before first providing those services.

The guidance is best understood as a functional look-through test: a CASP cannot rely solely on its MiCA authorisation as a complete answer to its licensing position if the specific services it provides around its electronic money tokens, in substance, constitute a payment service as separately regulated. This is an active and, as yet, untested overlay, in the sense that no supervisory action or enforcement decision has been identified that applies the guidance to a specific Lithuania-licensed CASP's EMT product line. The communication itself was not independently retrieved from a Bank of Lithuania primary source this cycle; the finding rests on secondary legal-commentary reporting, and the degree of enforcement rigor the Bank of Lithuania will apply to this interface question remains to be seen.

For CASPs operating in Lithuania with electronic money token issuance or custody/transfer lines, the practical consequence is a need to assess, product by product, whether any given EMT-related service function crosses into payment-service territory as a matter of substance rather than labelling. The underlying MiCA notification mechanism for EMT issuance and custody/transfer services remains unchanged and continues to operate as the baseline authorisation route; the guidance adds a second licensing question rather than displacing the first.

Outlook

Whether the Bank of Lithuania moves from guidance to an actual supervisory test of a specific CASP's EMT-related payment-service functionality is the development most worth tracking in this module going forward. Firms with EMT product lines that include features resembling payment initiation, account-information access, or funds transfer beyond pure custody should expect closer supervisory attention to the substance-over-form question the guidance raises. Independent confirmation of the guidance against Bank of Lithuania primary material would also materially improve confidence in its precise scope and legal status.

Tax Treatment

Lithuania, as an EU member state, falls within the scope of the DAC8/CARF cross-border tax-reporting framework for crypto-asset service providers, which brings such providers into an information-reporting obligation beginning with the 2026 data year. Based on the pattern observed in other EU jurisdictions, including Ireland, the first DAC8/CARF reporting deadline for the 2026 data year would fall on 31 May 2027. This date is inferred from the cross-jurisdictional pattern of DAC8 implementation rather than confirmed directly against a Lithuanian national transposition instrument, which was not independently retrieved this cycle.

The practical effect of this emerging reporting obligation is that crypto-asset service providers operating under a Lithuanian MiCA authorisation, including entities such as Micar assets, UAB authorised this cycle, will need to prepare for CARF-aligned reporting on transactions and holdings for their 2026 activity, with the first returns due in mid-2027. This is a structural, EU-wide development rather than a Lithuania-specific one, but its application to Lithuanian-authorised CASPs is a direct consequence of the jurisdiction's MiCA licensing activity.

Outlook

Confirmation of Lithuania's own national DAC8/CARF transposition instrument, not yet independently retrieved this cycle, would allow this finding to move from probable to confirmed confidence and would clarify whether Lithuania's domestic implementation introduces any jurisdiction-specific variation on the general EU timeline.

Commercial Activity

Bank of Lithuania's authorisation of Micar assets, UAB as a crypto-asset service provider under MiCA on 3 March 2026 is a concrete, dated commercial event: a licensing agreement between Micar assets, UAB as licensee and Lietuvos bankas as the authorising authority, completed on that date, resulting in regulatory clearance for custody, exchange and order execution services. Micar assets, UAB is majority-owned by Myriad Capital FMĮ UAB, a ten-year-old Lithuanian finance brokerage, meaning the new CASP enters the market with an established domestic financial-sector parent rather than as an entirely new entrant. No financial terms were disclosed in connection with the authorisation, which is consistent with its character as a regulatory licensing clearance rather than an investment or acquisition transaction with a disclosed value.

This is the fourth MiCA CASP authorisation granted in Lithuania, continuing a steady commercial build-out of the jurisdiction's licensed crypto-asset-service-provider base. The event is Tier-1 sourced directly to Lietuvos bankas's own publication of the authorisation.

Outlook

Further commercial licensing events of this kind, involving either new market entrants or established domestic financial firms extending into crypto-asset services, are a plausible continuation of the current pace of Lithuania's CASP authorisation activity.