Blockchain & Crypto-Assets 2026 Comparisons

The key Lithuanian regulators are as follows.

• Bank of Lithuania (Lietuvos bankas) – Supervisor of banks, EMIs, payment institutions and CASPs. The Bank of Lithuania issues CASP licences and supervises their activities.
• Financial Crime Investigation Service (Finansinių nusikaltimų tyrimo tarnyba) – Receives, analyses and disseminates reports of suspicious financial activity to combat AML/CFT and related crimes. Monitors compliance with AML/CFT obligations for certain non‑bank obliged entities, issues guidance, can initiate administrative measures and refers serious cases for prosecution.
• State Tax Inspectorate (Valstybinė mokesčių inspekcija) – Responsible for tax assessment, reporting and enforcement in relation to crypto transactions (including income tax, corporate tax and VAT). It issues guidance, conducts audits and enforces tax‑reporting obligations.
• State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) – Enforces GDPR compliance where personal data is processed in blockchain/crypto contexts.

Classification of Crypto-Assets

Regulators in Lithuania classify crypto‑assets by function and by existing EU categories.

MiCAR categories (directly applicable in Lithuania):

• electronic money tokens (EMT) – a type of crypto-asset that purports to maintain a stable value by referencing the value of one official currency;
• asset-referenced tokens (ART) – a type of crypto-asset that is not an electronic money token and that purports to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies; and
• utility tokens – a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer.

Financial instrument/security classification:

• tokens that meet the legal test of transferable securities or other regulated financial instruments fall under securities/financial‑instruments law (MiFID, Prospectus Regulation) and are regulated as such.

Regulated Activities

Crypto‑assets in Lithuania sit within existing regulatory frameworks (AML, tax, securities, payments, data protection, consumer protection and insolvency). The MiCAR regime applies directly, and Lithuania has adopted the Law on Crypto‑Asset Markets to ensure the fair, open and efficient functioning of crypto‑asset markets.

Under MiCAR in Lithuania, the following activities are regulated.

• CASP activities – custody and administration of crypto-assets on behalf of clients; operation of a trading platform for crypto-assets; exchange of crypto-assets for funds; exchange of crypto-assets for other crypto-assets; execution of orders for crypto-assets on behalf of clients; placing of crypto-assets; reception and transmission of orders for crypto-assets on behalf of clients; providing advice on crypto-assets; portfolio management on crypto-assets; transfer services for crypto-assets on behalf of clients.
• Issuance and offering of EMTs and ARTs: public offerings of EMTs and ARTs require white papers and disclosures; specific requirements for EMTs and ARTs apply (eg, capital and consumer‑protection rules).

Tokenised financial instruments that qualify as transferable securities, e‑money or other regulated instruments remain subject to existing sectoral laws.

Prohibited Activities

Lithuanian law does not prohibit crypto‑asset activities or products per se, but unlawful or high‑risk conduct is prohibited (eg, unlicensed provision of regulated services (CASP activities), offerings that evade AML/sanctions, and non‑compliant issuance of asset‑referenced/e‑money tokens or tokenised securities).

Legislative Regulatory Developments

No major new crypto-asset regulations are expected in the next 12 months for Lithuania, but further national implementing measures and supervisory guidance may impose additional practical requirements on CASPs.

If an investor invests in a fund whose strategy includes investing in crypto‑assets or in the capital of firms providing crypto‑related services, they are investing in the fund itself and subscribing for its units. Depending on the fund, the investor may benefit from stronger protections or, conversely, may be ineligible to invest (for example, where the fund is restricted to professional investors). The tax treatment of such investments may also differ when they are made via a fund.

Lithuania is a viable jurisdiction for token issuance, but issuers must comply with MiCAR and other applicable regimes (securities law, AML, tax, GDPR).

Under MiCAR (directly applicable in Lithuania), any offer to the public or application for admission to trading of crypto‑assets requires the offeror or person seeking admission to draw up, notify to the competent authority and publish an information document (white paper), unless an exemption applies. The procedure varies slightly depending on whether the token is an ART, EMT or a crypto‑asset other than an ART or EMT.

Crypto‑Assets Other Than ARTs or EMTs

Offerors and persons seeking to offer to the public a crypto-asset other than an ART or EMT, or seeking admission to trading, shall draft and notify the white paper to the Bank of Lithuania. The obligation to publish a white paper for crypto-assets other than ARTs or EMTs does not apply in the following cases:

• the offer is made to fewer than 150 persons per EU member state;
• the offer is addressed solely to qualified investors, who alone may hold the tokens;
• total consideration does not exceed EUR1 million over 12 months;
• the crypto‑asset is offered for free;
• the crypto‑asset is automatically created as a reward for maintaining the ledger or validating transactions;
• the offer concerns a utility token giving access to an existing good or service; and
• the crypto‑asset can be used only within a limited network of merchants under contractual arrangements with the offeror.

ARTs and EMTs

Offerors and persons seeking admission to trading of ARTs or EMTs must always prepare and submit a white paper for the relevant crypto‑assets to the Bank of Lithuania. The exemptions that apply to crypto‑assets other than ARTs or EMTs do not apply.

For ARTs, the white paper must, as a rule, be approved by the Bank of Lithuania before publication. Prior approval is not required if one of the following conditions is met:

• over any 12‑month period the average outstanding value of the ART never exceeds EUR5 million; or
• the offer is addressed solely to qualified investors and only they may hold the ART.

Lithuania enforces the market‑abuse rules of the EU Market Abuse Regulation (MAR), which apply directly. These rules cover financial instruments, including security tokens and other tokens classified as financial instruments. MiCAR adds market‑integrity protections for crypto‑asset markets that are aligned with the MAR. Key prohibited behaviours include:

• insider dealing – trading crypto‑assets while in possession of material, non‑public inside information;
• unlawful disclosure – disclosing inside information except in the normal exercise of employment or duties;
• market manipulation – any behaviour that gives false or misleading signals about supply, demand or price, or secures an artificial price; and
• attempting, aiding or abetting the above (including organising or facilitating manipulation).

MiCAR incorporates a market abuse regime for crypto-assets, essentially applying principles similar to the MAR. This means that market abuse, such as insider dealing or manipulating the price of crypto-assets, is prohibited under MiCAR, mirroring the MAR’s application to traditional securities.

Operators of virtual‑currency exchanges and custodial virtual‑currency wallet providers listed in the Register of Legal Entities that provided services in accordance with applicable law before 30 December 2024 were permitted to continue doing so until 1 January 2026. To date, no systemic breaches have been identified publicly. However, businesses and individuals intending to provide crypto‑asset services must pay close attention to the new regime and must not provide such services without authorisation from the Bank of Lithuania, as non‑compliance can lead to refusal of authorisation and financial sanctions.

MiCAR is directly applicable in Lithuania. Accordingly, an authorisation under the MiCAR framework is required whenever a firm provides regulated crypto‑asset services, irrespective of the underlying technology. The crypto‑asset services requiring an authorisation are listed in 2.2 Crypto-Asset Regulatory Frameworks. Issuers of ARTs and EMTs are subject to separate MiCAR issuer authorisation/registration, capital and consumer‑protection requirements.

An authorisation is required for firms “established in Lithuania” that perform licensable CASP activities. Establishment is typically shown by having a branch in Lithuania, or by having a legally constituted entity subject to Lithuanian law. Firms domiciled abroad can also fall within Lithuanian supervisory reach if they actively offer services to Lithuanian clients (marketing, soliciting, onboarding clients in Lithuania) – regulators look at the target market and commercial activity, not only corporate domicile.

Transitional (grandfathering) provisions applied in Lithuania. Operators of virtual‑currency exchanges and custodial virtual‑currency wallet providers listed in the Register of Legal Entities that lawfully provided services before 30 December 2024 were permitted to continue operating until 1 January 2026. Those operators lost the right to carry out the respective activities from 1 January 2026 if they had not obtained a licence under MiCAR by that date.

CASP authorisation in Lithuania is granted in accordance with MiCAR and applicable national law. Firms intending to provide crypto-asset services must apply to the Bank of Lithuania. The application must include all information required by Article 62(2) of MiCAR (for example: identity and address of the applicant; programme of operations; articles of association; identity of shareholders/members with qualifying holdings; description of internal control arrangements; a robust AML/KYC framework; ICT technical documentation and security measures; complaints-handling procedures; procedures for segregation of clients’ crypto-assets and funds).

Applicants must be legal entities established in Lithuania. MiCAR sets minimum own-funds requirements for CASPs depending on activity:

• Class 1 – EUR50,000 (execution of orders, transfer services, reception/transmission, advisory services, portfolio management, placing of crypto-assets);
• Class 2 – EUR125,000 (custody/administration of crypto-assets on behalf of clients, exchange between crypto and funds/other crypto-assets); and
• Class 3 – EUR150,000 (operation of a trading venue for crypto-assets).

These requirements ensure firms hold sufficient resources to cover operational risks.

The Law on Crypto-Asset Markets of the Republic of Lithuania requires authorised entities to have at least the following corporate bodies: a general meeting of shareholders, a board of directors and a manager.

MiCAR does not prescribe specific headcount requirements, but a CASP must maintain an organisational structure and sufficient staff to ensure compliance with Title V of MiCAR, taking into account the scale, nature and complexity of the services (eg, compliance officer/money laundering reporting officer, risk officer, IT/security lead).

Applicants should ensure that at least some of the CASP’s senior managers with authority to make decisions related to the supervised entity’s activities reside in Lithuania or otherwise provide for adequate governance, availability and conditions enabling Bank of Lithuania to effectively supervise the entity.

The Bank of Lithuania shall, within 25 working days of receiving an application, assess its completeness and verify that all information required by Article 62(2) of MiCAR has been provided. If incomplete, the Bank of Lithuania will set a deadline for submission of missing information and may refuse to consider the application if the information is not supplied. Within 40 working days of receiving a complete application, the Bank of Lithuania will assess whether the applicant meets the statutory requirements and will issue a reasoned decision to grant or refuse the licence.

During the assessment, and no later than the 20th day of the assessment period, the Bank of Lithuania may request additional information; the assessment period is suspended from the date of such a request until the applicant’s reply is received, for a suspension not exceeding 20 working days. The Bank of Lithuania may request further clarifications at its discretion, but further requests will not extend the suspension. The overall duration of the assessment depends on the scope and quality of the application; the Bank of Lithuania co-operates with applicants throughout the process and may organise meetings as needed.

Any person who decides to – or becomes aware he or she will – directly or indirectly acquire a qualifying holding in a CASP must immediately notify the Bank of Lithuania using the prescribed form and annexes, attaching required documents and related‑party tables.

A qualifying holding is defined as a direct or indirect share in a CASP’s share capital and/or voting rights that amounts to 10% or more of the CASP’s share capital and/or voting rights, or that otherwise gives the ability to exercise a significant influence over the CASP’s management.

The acquirer must disclose their identity, shareholders (including beneficial owners), corporate documents and other information needed to assess the suitability of a person acquiring a qualifying holding in a CASP.

The Bank of Lithuania may request additional documents and submitters must certify the accuracy of their information. The Bank of Lithuania can require any further information it deems necessary.

Persons transferring or reducing qualifying holdings must notify the Bank of Lithuania immediately.

The Bank of Lithuania assesses suitability and reputation under applicable laws and its fit‑and‑proper rules; submitters may submit preliminary notices, and the Bank of Lithuania will co-operate and advise during assessment.

If the Bank of Lithuania does not object and the transaction is completed, the acquirer must notify the Bank in writing within two business days.

Licences granted in Lithuania under MiCAR can be passported across the EU. An authorised CASP in Lithuania that intends to provide crypto-asset services in more than one EU member state shall submit the notification to the Bank of Lithuania (home national competent authority or NCA), which then notifies the host NCA(s).

There is no automatic passporting to non-EU markets. Access to non-EU markets requires local authorisation or local partner arrangements.

Crypto-Asset Services

Marketing of crypto-assets in Lithuania is regulated by MiCAR. Public offers of crypto-assets to Lithuanian investors require a white paper or a prospectus if the token is classified a security.

Cross‑border provision of crypto-asset services into Lithuania is permitted under MiCAR rules for authorised EU firms but is restricted for unauthorised or non‑EU firms. A CASP that intends to provide crypto-asset services in more than one EU member state shall submit the following information to the competent authority of the home EU member state (home NCA).

• a list of the member states in which the CASP intends to provide crypto-asset services;
• the crypto-asset services that the CASP intends to provide on a cross-border basis;
• the starting date of the intended provision of the crypto-asset services; and
• a list of all other activities provided by the CASP not covered by MiCAR.

The home NCA shall, within ten working days of receipt of the notification, communicate that information to the host NCA.

Non-EU firms must generally establish an EU entity or work with a locally authorised partner; direct cross‑border provision from outside the EU is not permitted without local authorisation.

Reverse solicitation is permitted if a Lithuanian client genuinely and independently initiates contact (unsolicited) and requests services from a foreign provider. The provider must be able to demonstrate the contact was truly unsolicited (clear written evidence: client request, no prior marketing/targeting, no onboarding activities directed at Lithuania). The Bank of Lithuania applies a narrow factual test and may scrutinise attempts to rely on reverse solicitation.

Unregulated Services

Selling blockchain‑based services that do not involve crypto‑asset services does not require authorisation under MiCAR (eg, private DLT implementations, enterprise blockchain applications, or smart‑contract solutions), though such providers must still comply with applicable sectoral rules in Lithuania (data protection, outsourcing, AML/CFT, etc).

MiCAR does not permit a CASP to appoint other legal persons – intermediaries or agents (third parties) – to provide crypto‑asset services on its behalf, for example to accept and transmit client orders. However, it is not explicitly prohibited for firms to use white‑label arrangements to sell into Lithuania by operating under an existing authorised entity’s licence, provided the licensed entity genuinely performs the regulated CASP activities and the arrangement complies with MiCAR.

For example, the non-authorised firm may operate its own website, client base and sales strategy while the licensed CASP:

• provides all regulated services and enters into the client agreements;
• performs AML/KYC monitoring and transaction surveillance; and
• submits regulatory reports and retains regulatory responsibility.

Thus, although white‑label solutions could theoretically be used, in practice one must assess whether the proposed structure would be in compliance with MiCAR and whether the unlicensed firm would be regarded as providing crypto‑asset services that require authorisation under MiCAR.

Lithuanian law does not directly prohibit DeFi (decentralised finance) as an ecosystem of financial applications and services built on top of blockchain technology; however, in practice such activities may be subject to various Lithuanian/EU law and licensing requirements, which can make practical deployment of DeFi more difficult.

Many DeFi use cases will require licensing (eg, crypto-asset service provision, specialised banking, EMI authorisation, crowdfunding service provision), and AML/CFT, prudential and consumer‑protection obligations may apply. Firms must therefore address these specific regulatory requirements before offering DeFi products or services into Lithuania.

DeFi structures are rare in Lithuania.

To date, DeFi has not been widely deployed in Lithuania – activity is largely limited to pilots and tests – so there is insufficient practice or precedent to reliably assess how courts and regulators would treat accountability or liability for harm caused by DeFi.

A payment made in crypto-assets in Lithuania is regarded as a transfer of assets. For tax purposes, it makes no difference whether a company or a self‑employed individual is paid in virtual currency, cash or by bank transfer – such payments must still be recorded in the accounts.

If payment for sold goods and/or services is made in crypto-assets, for corporate income tax purposes the entity is regarded as having acquired an asset (crypto-asset) for the amount recognised as the entity’s income from those goods and services. If an entity pays for purchased assets or services in crypto-assets, the purchase price of these assets or services is the amount corresponding to the selling price of the crypto-assets.

From the point of view of personal income tax, when goods sold or services provided are paid for in crypto-assets, the amount corresponding to the market price of the goods sold or services provided would be considered income from individual activities. When a resident (including those carrying out individual activities) pays for goods and services in crypto-assets, it is considered that they sell crypto-assets, the selling price of which is the market price of the goods or services.

In Lithuania, tokenised assets are regulated primarily by reference to the underlying asset, not the technology used to record it. Blockchain is treated as a record‑keeping/settlement tool. Accordingly, the first step is to ask which legal regime would apply if the asset were not tokenised.

If the token structure meets MiCAR’s definition of an asset‑referenced token (ART) referencing real‑world assets, it will fall under MiCAR and the issuer must comply with the MiCAR rules for ARTs. However, from the perspective of the underlying asset, tokenisation by itself does not change the applicable legal regime.

Some assets are particularly difficult to tokenise in practice. For example, in Lithuania title to real estate must be registered in the Real Estate Register and related transactions must be notarised. In such cases, tokenisation of real estate is theoretically possible but practically challenging to implement.