Self-custodial wallet / non-custodial software in Lithuania
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Lithuania without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML/KYC obligations attach to a self-custodial wallet software publisher because the publisher never holds, controls, or has access to user funds — the definition of 'Custodian Virtual Currency Wallet Operator' (lt.licensing.custodian-virtual-currency-wallet-operator) requires custody, which is absent here.
- The definition of 'Virtual Currency Exchange Operator' (lt.licensing.definition-any-natural-or-legal) covers exchange or transfer of virtual currencies — a software publisher that does not operate an exchange or facilitate transfers on behalf of users does not fall within this scope.
- The registration regime (lt.licensing.registration-regime-fcis-for-virtual) and associated AML requirements (lt.licensing.amlkyc-requirements-robust-internal-procedures through lt.licensing.record-keeping-maintaining-records-of) apply only to registered virtual currency exchange operators and custodian wallet operators — not to non-custodial software publishers.
Key Restrictions
- The software publisher must not provide any custodial services — it must never hold, control, or have access to user private keys or funds, otherwise it may fall under the Custodian Virtual Currency Wallet Operator definition (lt.licensing.custodian-virtual-currency-wallet-operator) and trigger the €125,000 capital requirement and FCIS registration (lt.licensing.a-minimum-125000-registered-share).
- The publisher must not facilitate exchange or transfer of virtual currencies on behalf of users (e.g., no integrated swap/aggregator that routes transactions), or it may fall under the Virtual Currency Exchange Operator definition (lt.licensing.definition-any-natural-or-legal).
- No specific consumer-protection or disclosure rules for non-custodial software were identified in the provided facts — general EU software and consumer law would apply.
Key Risks
- Regulatory creep: FCIS may broaden interpretations of 'custody' or 'transfer' to capture non-custodial tools, especially if wallet software includes integrated DApp browsing or swap features.
- Enforcement risk if the software publisher provides any ancillary services (e.g., fiat on-ramp integration, fee-collection in fiat) that could trigger EMI/PI licensing or VASP registration.
- If users are Lithuanian residents, the regulator may scrutinize whether the publisher's activities constitute 'transfer of virtual currencies' under the broad definition (lt.licensing.definition-any-natural-or-legal).
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Definition: Any natural or legal person that provides services of exchanging virtual currency to fiat currency or vice versa, or virtual currency to another virtual currency, or transfers virtual currencies. This covers most common crypto exchanges.
Custodian Virtual Currency Wallet Operator:
Registration Regime (FCIS): For virtual currency exchange and custodian wallet operators, Lithuania operates a registration model. This means that once an applicant meets the specified criteria (primarily AML/CTF related) and submits the required documentation, they are registered and allowed to operate. It is generally a less intensive process than obtaining a full financial services license.
A minimum €125,000 registered share capital is required for both virtual currency exchange operators and custodian virtual currency wallet operators. This requirement was significantly increased in November 2022 from a previous €2,500.
AML/KYC Requirements: Robust internal procedures are paramount:
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a self-custodial wallet software publisher is not regulated as a VASP or custodian wallet operator in Lithuania provided it never holds, controls, or accesses user private keys/funds, and does not facilitate exchange or transfer of virtual currencies on behalf of users; no AML obligations attach, no license is required, and no local entity is mandated by the regulatory framework for pure software publishing.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?