RE: Interview out20 Nov 2025 12:43
Application submitted pending approval or Application in progress.......... Sounds like from Shayne we are still at stage 1.
The Bank of Lithuania (BoL) handles Crypto-Asset Service Provider (CASP) authorisations under the EU's MiCA Regulation (fully applicable for CASPs since 30 December 2024). The process splits into two main phases: completeness review (administrative check) and substantive/merits assessment (full evaluation).1. Completeness Review (First Stage)What it is: BoL checks if your application package is administratively complete — i.e., all required documents, forms, and information are submitted and properly formatted. This is not a deep dive into the quality or substance yet; it's just "do we have everything to start reviewing?"
Timeline: BoL must respond within 25 working days of receiving the application.
If something is missing or unclear, they send a request for additional info/clarifications.
You then have time to respond, and each new request can add another 25 working days (no limit on how many rounds — this is where delays often happen if the initial filing is sloppy).
Common issues that trigger requests: Missing proof of capital, incomplete AML policies, unclear shareholder/UBO details, or documents not translated into Lithuanian where required.
Outcome: Once BoL is satisfied everything is there → the application is declared complete, and the clock officially starts on the next phase.
2. The Stage After Completeness Review: Substantive Assessment (Merits Review)What happens: This is the real evaluation. BoL conducts an in-depth review of whether your company actually meets all MiCA requirements, including:Governance & organisation (fit & proper management, no conflicts of interest)
Prudential safeguards (minimum capital — €50k–€150k depending on services, proof of own funds)
Operational resilience (IT security, business continuity, outsourcing arrangements)
Conduct of business rules (fair treatment, complaints handling, marketing)
AML/CTF framework
Safeguarding of client assets
Overall business model viability and risk management
They often ask follow-up questions, request interviews with key personnel, or even on-site visits.
Timeline: 40–65 working days from the date the application is declared complete (sources vary slightly: some say 40, others 65; BoL guidance points to around 3 months in practice).
In reality, total time from submission to decision is often 90–180 days because of the back-and-forth in both stages.
Outcome:Approval → You get the CASP authorisation, are added to BoL’s public register (and ESMA’s EU-wide register), and can passport services across the entire EU/EEA.
Refusal → Written reasons given; you can re-apply after fixing issues (or appeal).