Lithuania vs Poland for a CASP Licence: Which to Choose

Two CEE routes into the EU crypto market

For a firm choosing a Central and Eastern European base for a MiCA CASP authorisation, two names come up most: Lithuania and Poland. Both are EU member states, both run the standard MiCA regime, and a CASP authorisation from either passports across all 27 EU member states.

But they are not interchangeable. They answer different questions — and a founder who picks on the wrong axis ends up optimising for something that does not matter.

Lithuania: the early, high-throughput jurisdiction

Lithuania built its MiCA machine early. The Bank of Lithuania (Lietuvos bankas) had its CASP process running with its domestic Law on Markets in Crypto-Assets in force from 2024, and it has processed CASP files at volume. For founders, Lithuania’s reputation is throughput and predictability — practitioner-reported timelines of 4-6 months for properly prepared, complete applications.

That throughput is not the same as a light touch. The Bank of Lithuania applies a real substance review; the speed comes from a regulator that has built capacity and process, not from a low bar. A thin application still draws information requests.

Lithuania’s profile is strongest for a firm that wants a clean, predictable, relatively fast route to a passportable CASP authorisation and does not need a particular domestic market.

Poland: the largest CEE market, a later mover

Poland is the largest economy in Central and Eastern Europe — a genuine advantage for a business whose strategy involves a strong domestic presence in that market. The Polish Financial Supervision Authority — the KNF, Komisja Nadzoru Finansowego — supervises CASPs.

Poland’s MiCA story, however, has been one of delay. Domestic implementation was held up by political and legislative complications, making Poland one of the slower EU member states to complete its MiCA framework — while Lithuania was already processing files. Practitioner-reported timelines for the KNF route are in the order of 6-9 months, with an application fee around €4,500 and an annual supervisory fee linked to revenue.

Poland’s profile is strongest for a firm whose strategy genuinely centres on the Polish domestic market — where being a Polish-authorised, Polish-present business is a commercial asset, not just a licensing choice.

The comparison, side by side

Dimension	Lithuania	Poland
Regulator	Bank of Lithuania	KNF
MiCA readiness	Early mover, process built	Later mover, delayed implementation
Timeline (practitioner-reported)	~4-6 months for clean files	~6-9 months
Capital	MiCA Annex IV (€50k / €125k / €150k)	MiCA Annex IV (identical)
Domestic market	Smaller	Largest economy in CEE
Passport	EU-wide	EU-wide (identical)
Best fit	Speed, predictability, EU-wide play	Polish-domestic-market strategy

What is identical — and what is not

The honest comparison starts with what does not differ:

• Capital — the MiCA Annex IV floors are set EU-wide. €50,000 / €125,000 / €150,000 by class, identical in Lithuania and Poland. A founder comparing the two on minimum capital is comparing the same number twice.
• The passport — a CASP authorisation from either jurisdiction reaches all 27 EU member states. The home jurisdiction does not limit the market.
• The core MiCA obligations — governance, ICT resilience, conduct, custody, market abuse — all flow from the Regulation and apply the same way in both.

What does differ:

• Timeline and throughput — Lithuania faster and more predictable, on practitioner reports
• Regulator practice — two different supervisors, two different review styles and paces
• Domestic market — Poland materially larger
• Maturity of the MiCA process — Lithuania built early, Poland later

How to decide

The decision rule follows the firm’s actual strategy:

1. Optimising for a fast, predictable, EU-wide passport play, no specific domestic market → Lithuania. The throughput and process maturity are the asset.

2. Building a business genuinely centred on the Polish domestic market → Poland. The largest CEE economy and a Polish-present, Polish-authorised profile are the asset, and the longer timeline is a cost worth paying for that strategic fit.

3. Indifferent to the domestic market, want EU reach → Lithuania is usually the cleaner answer, because the passport is identical and the timeline is not.

The error is choosing Poland because it is bigger when the business has no particular Polish-market strategy — paying the longer timeline for a market-size advantage the firm will not use. Equally, choosing Lithuania for speed when the whole business case is Polish-domestic forces a substance mismatch the firm then has to manage.

Working with counsel on a CEE jurisdiction choice

The diagnostic for counsel: ask them to tie the recommendation to the firm’s actual market strategy, not to a generic “Lithuania is faster” — and to be specific about current regulator practice and timelines in each jurisdiction. Counsel that has filed in both can describe the real difference. The firms in our index with documented Lithuanian and Polish experience are listed below.