Passporting a Lithuanian CASP licence across the EU: how notification works
Lithuania has become a popular home base for crypto firms seeking an EU foothold, but a Lithuanian CASP licence does not automatically open every market. Passporting a Lithuanian CASP means using the freedom of establishment or freedom to provide services to reach clients across the EEA, and the process runs through your national regulator rather than a separate EU application.
What passporting actually means for a Lithuanian CASP
Under MiCA, which is fully in force across the EU in 2026, a crypto-asset service provider authorised in one member state can provide services in other member states without obtaining a separate licence in each country. The Lithuanian licence becomes the home-state authorisation, and the Bank of Lithuania acts as the competent authority. Passporting a Lithuanian CASP is therefore a notification exercise, not a new licensing exercise.
Two legal bases exist. The freedom to provide services allows a firm to serve clients in another member state on a cross-border basis without a physical presence there. The freedom of establishment allows a firm to open a branch or use tied agents in another member state. The choice affects supervisory expectations, local presence costs, and how clients perceive your operation.
The scope of the passport is limited to the services covered by your Lithuanian authorisation. If your licence covers custody and exchange but not portfolio management, you cannot passport portfolio management. Any expansion of activities generally requires an update to the home-state authorisation first.
The notification procedure step by step
The process starts with the home-state regulator. You submit a notification to the Bank of Lithuania setting out the member states where you intend to operate, the services you will provide, and the legal basis you are relying on. For freedom of establishment, you also provide details of the branch or agent, including governance, premises, and the individuals responsible.
The Bank of Lithuania reviews the notification for completeness and then transmits it to the host-state competent authority. Under the MiCA framework, the host authority has a defined period to assess the information and may request clarification. In practice, timelines vary by host state and by the complexity of the notification, so firms should plan for a period of weeks rather than days.
Once the notification is accepted, the host state is informed and the firm can begin providing the notified services. You do not receive a new licence document from the host state. Instead, the passport operates through the home-state authorisation, and the host state supervises conduct and certain local requirements within its territory.
Documents and information you will need
A complete notification package typically includes your corporate details, your Lithuanian authorisation reference, a description of the services to be passported, and the member states concerned. For a branch, you will need information on the branch manager, the organisational structure, and the address where records will be kept.
Regulators also expect a programme of operations. This should explain the target client base, the marketing approach, the complaints handling route, and how you will comply with host-state rules on matters such as language and consumer disclosure. Vague plans tend to attract follow-up questions and delay the process.
Because MiCA is still bedding in across national markets, some host authorities apply additional local expectations around AML supervision, payment arrangements, and client onboarding. It is prudent to prepare a short annex addressing these points rather than waiting for a request.
Home-state versus host-state supervision
The passporting model splits supervision. The Bank of Lithuania remains responsible for prudential matters, including capital adequacy, governance, and the core authorisation. The host-state authority supervises how you conduct business locally, including marketing, complaints, and compliance with local conduct rules.
This split matters for capital. MiCA sets minimum capital requirements for CASPs in three tiers, commonly described as EUR 50,000, EUR 125,000, and EUR 150,000 depending on the class of services provided. A firm passported into multiple states still meets these requirements at home-state level, but the home regulator will expect the capital position to reflect the expanded footprint.
Host states can also require firms to report locally and to cooperate with local investigations. Ignoring host-state correspondence is a common mistake. Even where the home regulator is your primary point of contact, host authorities can escalate concerns that ultimately affect your Lithuanian licence.
Practical pitfalls and how to avoid them
One frequent error is treating passporting as a formality. In reality, the notification must match your actual business model. If you notify exchange services but then launch a lending product, you are operating outside the passport and may face enforcement in the host state.
Another pitfall is inconsistent disclosure. Clients in different member states may see different terms, fee schedules, or risk warnings. Regulators increasingly compare marketing materials across borders, so a single coherent client-facing framework reduces risk.
Finally, firms often underestimate the operational work behind a passport. Local bank accounts, language support, complaints handling, and tax registrations all need attention. Building a checklist before notification helps avoid a scramble after approval.
How Consulting24 supports passporting
Consulting24, operated by X24Consulting OU in Estonia and led by founder Mardo Soo, works with crypto founders on Lithuanian CASP authorisation and the subsequent passporting notifications. The team prepares the notification package, coordinates with the Bank of Lithuania, and helps firms plan their host-state footprint.
For founders considering alternatives, it is worth noting that some jurisdictions outside the EU do not offer a comparable passport. Panama, for example, has no dedicated crypto licence; firms typically incorporate a Sociedad Anonima, which can be set up in around two to three weeks and generally benefits from a 0% tax on foreign-source income. That structure does not provide EU market access, so the choice depends on where your clients are.
If your priority is serving EU clients from a regulated base, the Lithuanian route combined with passporting is one of the more established paths. You can review the relevant service page at https://www.consulting24.co/lithuania-crypto-license/ for an overview of the licensing process.
How to Choose the Right Jurisdiction
Work the decision in this order: customers first, everything else second:
- Who are your customers? EU retail means you need a MiCA passport (Lithuania, Malta or another EU CASP). US customers mean state-by-state money-transmitter licensing or a FinCEN MSB, so consider a Canada MSB or a US setup. Latin America, Asia or HNW clients mean an offshore or territorial base such as Panama is usually the better fit.
- Do you need a regulator badge? A public-facing exchange chasing institutional partners and fundraising often needs the reputational lift of an EU, Swiss or VARA licence. An OTC desk or token treasury usually does not.
- What is your budget and timeline? Offshore and territorial routes set up in weeks for tens of thousands; premium onshore licences take many months and six figures.
- What about tax? Territorial-tax jurisdictions like Panama charge 0% on foreign-source income; EU jurisdictions apply standard corporate tax. Factor total cost of ownership, not just setup fees.
For many offshore-first founders, Panama lands at the intersection of fast incorporation, low cost and 0% tax on foreign-source income, which is why it features so heavily in our work. But the honest answer is that the “best” jurisdiction is the one that matches the four answers above, and that is a conversation worth having before you spend a cent. See our cost breakdown and application process to ground the decision in real numbers.
Banking and Compliance: Where Most Setups Actually Stall
Incorporation is the easy part of any crypto project. Banking is where timelines slip and where under-prepared founders lose months. Since 2023, banks and payment processors worldwide have tightened their onboarding of crypto-adjacent businesses, and they now expect a genuinely professional application , not a one-page business summary. A thin file is simply rejected, and re-applying with the same bank is far harder than getting it right the first time.
Three documents do the heavy lifting. The first is a written AML/KYC compliance program: your customer-onboarding flow, transaction-monitoring rules, sanctions and PEP screening, a named compliance officer, and record-keeping policies. The second is a clear, evidenced source-of-funds file for both the company and its beneficial owners. The third is a coherent business description that explains who your customers are, how money moves, and what volumes you project. Banks approve businesses they understand; ambiguity reads as risk.
Sequencing matters as much as substance. The correct order is: incorporate the operating entity, build the compliance program, assemble the source-of-funds package, and only then approach banking, ideally through a warm introduction rather than a cold application. Founders who approach banks mid-setup, before their file is complete, create the very delays they are trying to avoid. We make direct introductions to banks and crypto-friendly payment rails as part of every engagement, but the introduction only works if the file behind it is ready.
None of this is optional, and none of it changes much from one jurisdiction to the next, the compliance bar is now broadly global. What changes is the appetite of local banks and the speed of onboarding. Our requirements checklist sets out exactly what you need to assemble before you approach a bank.
Crypto Licensing in 2026: The Bigger Picture
Choosing where to license a crypto business in 2026 is no longer a simple cost calculation. The regulatory map has hardened considerably over the last three years. In the European Union, the Markets in Crypto-Assets Regulation (MiCA) has replaced the patchwork of national VASP registers with a single Crypto-Asset Service Provider (CASP) authorisation that passports across all 27 member states. That passport is powerful, but it comes with capital requirements, governance obligations and a multi-month authorisation process that smaller projects often underestimate.
Outside the EU, the picture is more varied. Offshore and territorial-tax jurisdictions compete on speed, cost and privacy, while major financial centres such as Switzerland, the UAE and Singapore compete on credibility and institutional access. The Financial Action Task Force (FATF) sits over all of them: its “travel rule” and AML standards now apply, in some form, almost everywhere a serious crypto business would consider basing itself. Jurisdictions that ignore FATF expectations end up grey-listed, which quietly closes correspondent-banking doors for every company registered there.
This is why the question behind Passporting a Lithuanian CASP is rarely “which licence is cheapest?” It is “which regime matches my customers, my risk appetite and my banking needs?” An EU-retail exchange and an offshore OTC desk serving high-net-worth clients in Latin America have almost nothing in common in terms of the right base. Getting this decision right at the start saves you from the single most expensive mistake in the industry: licensing in the wrong place and having to re-domicile a live business.
Consulting24 has guided more than 200 crypto company setups across 15+ jurisdictions since 2017, which means we have seen how each of these regimes behaves in practice rather than just on paper. The summary below is the same framework we use with clients, and we are always happy to map it to your specific model. Start with our Panama vs Lithuania comparison to see how the trade-offs play out between an offshore base and an EU-passported one.
Common Mistakes to Avoid
The failures we see when founders research Passporting a Lithuanian CASP on their own are remarkably consistent, and almost all of them are avoidable. The first is licensing to the headline tax rate. A 0% jurisdiction is worthless if your customers legally require a regulated provider you cannot become there, and you will simply have to start again. Decide who you are allowed to serve first, then optimise for tax.
The second is treating the compliance program as paperwork. The AML/KYC program is not a formality to satisfy a regulator; it is the document your bank reads most closely. A generic template downloaded from the internet is transparent to any compliance officer and will sink your banking application. It needs to reflect your actual product, customer base and risk profile.
The third is underestimating banking lead time. Founders routinely budget for incorporation and forget that the bank account, the thing that actually lets the business operate, can take longer than the licence itself. Build banking into your launch timeline from day one, not as an afterthought.
The fourth is ignoring personal tax residency. A company in a low-tax jurisdiction does not erase your obligations where you personally live. Many founders create unexpected liabilities by structuring the company perfectly and ignoring themselves. We introduce qualified tax advisors precisely to close this gap.
The fifth and most expensive is choosing a provider on price alone. The cheapest setup that results in a rejected bank application or a re-domiciliation is far more expensive than doing it properly once. Ask any provider to itemise their fee and explain their banking track record before you commit.
What Happens After You Are Licensed
Getting licensed and banked is the start, not the finish. Every regulated or registered crypto business carries ongoing obligations, and letting them lapse is how companies lose their standing, and their banking. At minimum you will maintain a registered agent or local presence, file annual renewals or supervision fees, keep accounting records, and keep your compliance program live with periodic reviews and updated sanctions and PEP screening lists.
Most jurisdictions also expect you to keep your beneficial-ownership information current and to report material changes, new directors, new shareholders, a pivot in business activity, promptly. Transaction monitoring is not a one-time setup either; screening rules need tuning as your volumes and customer mix evolve. Banks may request periodic refreshes of your KYC and source-of-funds documentation, particularly after a year of trading or a significant change in activity.
This is why we offer ongoing maintenance on an annual retainer rather than treating setup as a one-off transaction. The cost of staying compliant is a fraction of the cost of losing a banking relationship and having to rebuild one from scratch. Plan for it in your year-two budget from the outset, and treat your compliance function as a living part of the business rather than a box you ticked at launch.
It is also worth planning ahead for growth. A structure that suits a pre-revenue startup may not suit the same company once it is processing meaningful volume, adding new product lines, or expanding into new markets. Many of the businesses we work with begin in a fast, low-cost offshore base to validate the model, then add a second regulated entity, an EU CASP, for example, once revenue justifies the cost and the market access genuinely matters. Designing the first structure with that possible second step in mind keeps your options open and avoids a disruptive re-domiciliation later. We map this growth path out with clients during the initial planning stage so the early decisions support, rather than constrain, where the business is heading.
Consulting24 has completed 200+ crypto company setups across 15+ jurisdictions. Talk to our team for a fixed-fee proposal and realistic timeline.
Learn more WhatsApp usEmail mardo@consulting24.co · Phone +372 58155779
About Consulting24 & Mardo Soo
Founder & CEO, Consulting24 · LinkedIn
Consulting24 is an eight-year-old advisory firm that has completed 200+ crypto company setups across 15+ jurisdictions since 2017. Founder and CEO Mardo Soo and the team specialise in crypto, VASP and exchange licensing, from Panama and the EU (MiCA) to Dubai, Canada and the offshore world. We don't push a single “best” jurisdiction; we map your business to the regime that actually fits, then handle incorporation, the AML/KYC compliance program, and banking and payment-processor introductions end to end.
Every engagement begins with an honest conversation about your customers, budget and timeline and ends with a fixed-fee proposal, so you know the all-in number before you commit. We also introduce vetted local lawyers and tax advisors wherever your structure requires them.
Operated by X24Consulting OÜ (Estonian Business Register code 16971898), Põrdi tn 3-63, 10156 Tallinn, Estonia · mardo@consulting24.co · +372 58155779
Frequently Asked Questions
Do I need a separate licence in each EU country to serve clients there?
No. Under MiCA, a CASP authorised in one member state can passport its services into other member states through a notification procedure. You do not apply for a new licence in each country, but you must notify your home regulator and respect host-state conduct rules.
Which regulator handles a Lithuanian CASP passport?
The Bank of Lithuania is the home-state competent authority. It receives your notification, reviews it, and transmits it to the host-state authority. The host authority then supervises conduct matters within its territory.
How long does the passporting notification take?
Timelines vary by host state and by the completeness of your notification. In practice, firms should allow several weeks for review and any follow-up questions. Complex branch notifications can take longer than simple cross-border service notifications.
What is the difference between freedom of services and freedom of establishment?
Freedom of services lets you serve clients in another member state without a local presence. Freedom of establishment involves a branch or tied agent in that member state, which brings additional governance, premises, and reporting expectations.
Does passporting change my MiCA capital requirements?
The capital tiers remain set at home-state level, commonly EUR 50,000, EUR 125,000, or EUR 150,000 depending on the services you provide. However, the Bank of Lithuania will expect your capital and governance to reflect the expanded scope of your activities across the EEA.
Can I passport services that are not in my Lithuanian licence?
No. The passport covers only the services included in your Lithuanian authorisation. If you want to add activities, you generally need to update your home-state licence first, then notify the additional services.
What happens if I start operating in another member state without notifying?
Operating without a valid passport can be treated as unauthorised activity in the host state. That can lead to enforcement action, fines, and damage to your standing with the Bank of Lithuania.
Is Panama a substitute for an EU passport?
No. Panama does not have a dedicated crypto licence and does not provide EU market access. A Panama Sociedad Anonima can be incorporated in roughly two to three weeks and generally benefits from 0% tax on foreign-source income, but it is a different proposition from an EU CASP passport.
Related reading
More crypto-license guides on this blog
- Crypto License in Panama: Cost, Requirements & Setup (2026)
- Crypto Exchange License: How and Where to Get One in 2026
- Crypto License Cost by Jurisdiction: 2026 Comparison
Related crypto licensing routes
A few relevant guides on consulting24.co, each with real cost, timeline and requirements:
This article reflects 2026 market conditions and is general guidance, not legal or tax advice. Regulations change, so confirm specifics with qualified counsel before acting. Consulting24 (X24Consulting OÜ, Estonian reg. 16971898) introduces vetted local lawyers and tax advisors during every engagement.
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