Transition to CASP in Lithuania: Key MiCA Requirements by 2026
The implementation of the European MiCA regulation is actively changing the rules of the game for the crypto industry. Lithuania, as one of the most popular jurisdictions for crypto companies, is at the forefront of these changes. The Lithuanian Financial Crime Investigation Service (FNTT) has officially issued a reminder: the transition period for virtual asset service providers (VASPs) will end on December 31, 2025. Starting January 1, 2026, all companies working with crypto assets will be required to hold a CASP (Crypto-Asset Service Provider) license.
Obligations Continuing After Termination
Even if a company decides to cease operating as a VASP, its obligations to regulators do not completely cease.
The organization must:
- retain client data and transaction records;
- ensure the correct transfer of necessary documents;
- be prepared for inquiries from the FNTT even after closure.
This is due to the overall tightening of MiCA requirements and the desire to increase transparency in the crypto market.
Strict reporting deadlines
The Lithuanian regulator emphasizes the importance of timely submission of STR and CTR reports related to activities until the end of 2025.
Important points to remember:
- All reports must be submitted before the end of the transition period;
- After January 1, 2026, an additional three-month deadline applies for completing mandatory reporting;
- After these three months, access to the FNTT system will be blocked, and late reports will be considered only on a case-by-case basis.
Failure to meet deadlines may result in regulatory consequences, including fines or difficulties with subsequent licensing.
Responsible Contact Persons
FNTT recommends that companies retain a designated responsible contact person for at least three months after MiCA comes into force. This person is necessary for prompt communication with Lithuanian financial monitoring and other foreign authorities. It ensures the timely transfer of information, responds to regulators' requests, and helps complete the transition period without disruption. This ensures that communication between the company and the FIU remains transparent and stable, even if the business ceases operations or is in the licensing process.
Strix Questionnaire: A Step Toward Streamlining Data
Starting December 15, 2025, all VASPs are required to complete the Strix questionnaire. It is designed to determine the company's status: whether it is ceasing operations or planning to apply for a CASP. The questionnaire is an important element in the regulator's preparation for the full implementation of MiCA.
If you need assistance preparing for MiCA requirements or applying for a CASP license in Lithuania, IT-OFFSHORE specialists are ready to support you every step of the way.
