15/10/25
As Lithuania approaches the end of its transitional licensing period for crypto-asset service providers, the Bank of Lithuania (Lietuvos bankas) has issued a critical directive: firms opting to cease operations must ensure a smooth and compliant winding-down process.
🧾 Legal Framework & Regulatory Expectations
Under the European Union’s Markets in Crypto-Assets (MiCA) Regulation, crypto-asset service providers are required to obtain a license by 31 December 2025. Failure to do so renders the provision of services such as client onboarding, crypto-asset custody, and related activities illegal. Lietuvos bankas has emphasised that entities not pursuing licensure must responsibly wind down operations, safeguarding client assets and fulfilling all legal obligations.
⚖️ Comparative Insights & Sector Implications
This regulatory stance aligns with broader EU financial supervisory practices, where authorities mandate responsible cessation of services to protect consumers and maintain market integrity. For instance, similar directives have been issued in other EU jurisdictions, reinforcing the importance of compliance during operational wind-downs. The Lithuanian approach underscores the need for crypto firms to engage in transparent and orderly exit strategies, ensuring that all stakeholder interests are considered.
🏦 Practical Considerations for Affected Firms
Firms choosing to exit the market must:
• Notify clients promptly, providing clear instructions for asset retrieval.
• Coordinate with financial institutions to manage the closure of accounts and settle outstanding obligations.
• Comply with data protection regulations by securely handling and disposing of customer information.
• Engage with legal and financial advisors to navigate the complexities of the winding-down process.
Entities failing to adhere to these requirements risk facing legal actions, including potential criminal investigations, as indicated by Lietuvos bankas.
📌 Conclusion
As the 31 December 2025 deadline approaches, crypto-asset service providers in Lithuania must make informed decisions regarding their operational futures. Those opting to cease operations must execute a compliant and transparent winding-down process to mitigate legal risks and uphold market trust. For expert legal guidance tailored to the crypto sector, contact NUR Legal. Visit us at NUR-Legal.com or contact us directly at info@nur-legal.com
Kätrin Särap