🇱🇹 Lithuania vs 🇬🇧 United Kingdom: crypto licensing compared
On paper, Lithuania's MiCA Crypto-Asset Service Provider (CASP) authorisation under Title V of Reg (EU) 2023/1114; replaced the national VASP registration. Single passportable licence covering the services applied for. and United Kingdom's Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. answer the same question; in practice the detail decides it. The two regimes differ on 8 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Lithuania: verified 2026-07-01 · United Kingdom: verified 2026-07-03
| Dimension |
🇱🇹 Lithuania
partly open
Verified 2026-07-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| Licence type | MiCA Crypto-Asset Service Provider (CASP) authorisation under Title V of Reg (EU) 2023/1114; replaced the national VASP registration. Single passportable licence covering the services applied for. | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. |
| Regulator | Bank of Lithuania (Lietuvos bankas) - single competent authority. Publicly selective stance: wants few, solid firms rather than the ~370-strong legacy VASP pool. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Lithuania capital requirement is locked. Unlock with the £349 pass. | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). |
| Timeline to authorisation | Lithuania timeline to authorisation is locked. Unlock with the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | Lithuania local substance is locked. Unlock with the £349 pass. | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. |
| Application cost | Lithuania application cost is locked. Unlock with the £349 pass. | FCA application fee GBP 11,150 (Category 6, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Lithuania ongoing cost is locked. Unlock with the £349 pass. | Annual FCA periodic fee under fee-block G.30 (renumbered from G.23): minimum GBP 2,229 for 2025/26 plus GBP 15.13 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. |
| Passporting | Lithuania passporting is locked. Unlock with the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | Lithuania mica casps approved is locked. Unlock with the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Lithuania key restrictions is locked. Unlock with the £349 pass. | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. |
| Recent changes | Lithuania used a shortened 12-month grandfathering - legacy VASP cover ended 1 Jan 2026 (vs the EU 1 Jul 2026 backstop). First CASP: Robinhood Europe (29 May 2025); only ~4 CASPs authorised by Mar 2026. | SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. |
| Difficulty rating | Lithuania difficulty rating is locked. Unlock with the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
The two regimes differ on 8 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇱🇹 Lithuania (verified 2026-07-01): Lithuania used a shortened 12-month grandfathering - legacy VASP cover ended 1 Jan 2026 (vs the EU 1 Jul 2026 backstop). First CASP: Robinhood Europe (29 May 2025); only ~4 CASPs authorised by Mar 2026.
🇬🇧 United Kingdom (verified 2026-07-03): SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027.
Quick answers
Who regulates crypto licensing in Lithuania and United Kingdom?
Lithuania: Bank of Lithuania (Lietuvos bankas) - single competent authority. Publicly selective stance: wants few, solid firms rather than the ~370-strong legacy VASP pool.. United Kingdom: Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers..
What licence do you need in Lithuania compared with United Kingdom?
In Lithuania the authorisation route is MiCA Crypto-Asset Service Provider (CASP) authorisation under Title V of Reg (EU) 2023/1114; replaced the national VASP registration. Single passportable licence covering the services applied for.; in United Kingdom it is Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Lithuania vs United Kingdom comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/lithuania-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.