MiCA CASP licence in the Baltics: Estonia, Latvia or Lithuania?

Licensing5 min readMAXCORP legal team

Which one we recommend

Clients often ask which Baltic regulator is "easiest". The legal test is the same everywhere, because MiCA is an EU regulation. What differs is what each country adds on top and how your team fits it:

• Choose Latvia if your team works in English and you want the fewest national additions. The fees are written into the law, and Latvijas Banka offers a free consultation before you apply.
• Choose Lithuania if you plan a real team in Vilnius. Part of the key management is expected to live in Lithuania, and the business plan and client documents are prepared in Lithuanian.
• Choose Estonia if you already have people in Estonia. The law asks for two board members and a compliance officer who works permanently in the country, so it suits an operation that is genuinely run from Tallinn.

Where your management actually sits, and which market you serve first, usually decides it. Whichever country grants it, the licence lets you passport to the rest of the EU.

Estonia, Latvia and Lithuania side by side

The key national differences for a crypto-asset service provider (CASP) under MiCA:

MiCA CASP licensing in Estonia, Latvia and Lithuania compared

Factor	Estonia	Latvia	Lithuania
Regulator	Finantsinspektsioon	Latvijas Banka	Bank of Lithuania
Company form	OÜ or AS only	Not limited by the crypto law	UAB or AB only
Application fee	€3,000	€2,500	€2,425 state fee
Annual supervision fee	Capital share plus a volume share, rate set each year	Up to 0.6% of crypto income, at least €3,000	Share of income, rate set each year
Application language	Estonian; English documents if declared	No rule in law; English used in practice	Business plan and client documents in Lithuanian
National additions	Board of at least 2; compliance officer working permanently in Estonia	None beyond MiCA	Managers need prior approval; local key management expected
Own funds (MiCA)	€50,000 to €150,000 by class	€50,000 to €150,000 by class	€50,000 to €150,000 by class
Legal decision time (MiCA)	25 + 40 working days	25 + 40 working days	25 + 40 working days

Legal decision time: 25 working days to confirm the application is complete, then 40 working days to decide; requests for information stop the clock for up to 20 working days. Estonia has no separate country page yet, so its column links to our EU overview.

What MiCA sets the same in every country

Most of the work is identical in all three, because it comes straight from the EU regulation:

• Own funds: €50,000 for class 1 services (such as advice or order transmission), €125,000 for class 2 (including exchange and custody), €150,000 for class 3 (a trading platform), or a quarter of last year’s fixed overheads if that is higher.
• Substance: a registered office in the country that grants the licence, where at least part of the services are provided, effective management in the EU and at least one director resident in the EU.
• Passport: to serve other EU countries you notify your own regulator, which forwards the notice; you can start at the latest on the 15th calendar day after notifying.
• Travel Rule: sender and recipient details travel with every crypto transfer under Regulation (EU) 2023/1113.

The old national regimes are closed in all three countries: the Estonian FIU licences, the Latvian registration with the State Revenue Service and the Lithuanian VASP register no longer allow a firm to operate. Firms that held them needed a MiCA authorisation to continue.

Local staff: what the law requires and what regulators expect

This is where the three countries differ most, and where marketing claims often mix law with practice:

• Estonia (law): the AML compliance officer must be a person who works permanently in Estonia, appointed in agreement with the Financial Intelligence Unit, and a management board member is put in charge of AML. The board needs at least two members. e-Residency does not meet any of these requirements.
• Latvia (law): the AML law requires a responsible person both in senior management and in the internal control unit, with no residency rule. In practice, Latvijas Banka looks for key functions that are really run, and we plan for local roles.
• Lithuania (law and expectation): a board member and senior employees organise AML, with no residency rule in the AML law. The Bank of Lithuania approves managers in advance and expects part of the key management to live in Lithuania.

Whatever the law says, the regulator has to see that the company is really run from where it is licensed. We plan the local roles before filing, not after the regulator asks.

Timeline and cost

The legal clock is the same in all three countries: 25 working days for the completeness check and 40 working days for the decision, with pauses while the regulator waits for answers. Our planning figure, including the time to prepare policies, hire key people and answer questions, is 6 to 10 months from start to licence.

The regulator fees are small next to the real costs: own funds, salaries for the local roles, audit and ICT security. Our MiCA readiness audit costs €15,000 and is credited towards the full application, which starts from €80,000. Displayed prices are indicative professional fees excluding VAT; own funds, company formation and regulator fees are separate.

How MAXCORP helps

MAXCORP prepares MiCA CASP applications in Estonia, Latvia and Lithuania and across the EU: business model and CASP class, policies, AML and ICT frameworks, the local team and the filing itself.

Not sure which Baltic country fits? Tell us which services you will offer, where your management and clients are, and when you want to launch. The readiness audit ends with a written jurisdiction recommendation.

Official sources (12)

1. MiCA, Regulation (EU) 2023/1114 (Arts 59, 63, 65, 67, Annex IV)
2. ESMA: statement on the end of transitional periods under MiCA
3. Estonia: Market in Crypto-Assets Act (KrüTS), English translation (§ 5, § 7)
4. Finantsinspektsioon: the operating licence in markets of crypto-assets (fee, language, deadlines)
5. Estonia: Money Laundering and Terrorist Financing Prevention Act, English translation (§ 17)
6. Latvia: Crypto-Asset Services Law (s.4, s.6)
7. Latvijas Banka: crypto‑asset service providers
8. Latvia: AML/CTF law (s.10)
9. Lithuania: Law on Markets in Crypto‑Assets No XIV‑2879
10. Bank of Lithuania: authorisation of crypto‑asset service providers
11. Lithuania: Government Resolution No 1458 on state fees (point 3.157)
12. Lithuania: Law on the Prevention of Money Laundering and Terrorist Financing (Art 22)

General information only, not legal or tax advice. Rules change; ask us about your case.

• MiCA CASP licence in Latvia

  Authorisation from Latvijas Banka, with policies, local roles and the filing prepared.

  View the service

• MiCA CASP licence in Lithuania

  Authorisation from the Bank of Lithuania, with Lithuanian documents and local roles.

  View the service

• MiCA CASP licence (EU)

  Readiness audit, CASP class and the right EU country for your crypto business.

  View the service

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