Legal services:

Comprehensive legal solutions for contracts, disputes, and compliance. Our expert team ensures legal protection and strategic guidance for your business.

AML consulting:

Specialised AML consulting to develop and maintain robust anti-money laundering policies. We assess risks, offer ongoing support and provide tailored AML services.

Obtaining a crypto license:

We offer licensing and ongoing support for your crypto-business. We also offer licences in the most popular jurisdictions.

Registration of legal entities:

Efficient legal entity registration support. We manage documentation and interaction with the authorities, ensuring a seamless process for establishing your business.

Opening bank accounts:

We facilitate the opening of bank accounts through our extensive network of partners (European banks). Hassle-free process, tailored to your business needs.

COREDO TEAM

Nikita Veremeev
Nikita Veremeev
CEO
Pavel Kos
Pavel Kos
Head of the legal department
Grigorii Lutcenko
Grigorii Lutcenko
Head of AML department
Annet Abdurzakova
Annet Abdurzakova
Head of the Customer Success Department
Basang Ungunov
Basang Ungunov
Lawyer at Legal Department
Egor Pykalev
Egor Pykalev
AML consultant
Yulia Zhidikhanova
Yulia Zhidikhanova
Customer Success Associate
Pavel Batsulin
Pavel Batsulin
AML consultant
Diana Alchaeva
Diana Alchaeva
Customer Success Associate
Johann Schneider
Johann Schneider
Lawyer
Daniil Saprykin
Daniil Saprykin
Customer Success Associate

Our clients

COREDO’s clients are manufacturers, traders and financial companies, as well as wealthy clients from European and CIS countries.

Effective communication and fast project realisation guarantee satisfaction of our customers.

Exactly
Unitpay
Grispay
Newreality
Chicrypto
Xchanger
CONVERTIQ
Crypto Engine
Pion

In 2025, more than 70% of new fintech companies in Europe and Asia face licensing delays, losing up to 18 months of operational time and hundreds of thousands of euros on additional approvals and repeated reviews. Behind this dry statistic lies a fundamental problem: most entrepreneurs and finance directors do not understand how a bank license in the EU fundamentally differs from a financial license, what opportunities and restrictions they bring to a business, and how to choose the optimal scaling path amid strict regulation and growing competition.

Why can obtaining a license in Luxembourg take twice as long as in Lithuania? What minimum capital is required for an EMI, PI or a universal bank? What risks and AML compliance costs should be budgeted to avoid sanctions and account freezes? And finally, which type of license will realistically give your fintech startup access to cross-border payments, lending and integration with VISA and MasterCard?

In this article I will outline the strategic differences, practical steps and key nuances of licensing in the EU that determine the success of international financial businesses. If you want to avoid mistakes, accelerate your market entry and choose the optimal jurisdiction, read to the end. Here you will find not only an in-depth analysis, but also practical recommendations based on COREDO‘s experience supporting dozens of projects in the EU, the UK, Singapore and Dubai.

Banking license in the EU: key features

Illustration for the section «Banking license in the EU: key features» in the article «Banking license vs financial license in the EU»
A banking license in the EU is an authorization issued by a national regulator or the European Central Bank (ECB) that allows carrying out classic banking activities: accepting deposits, lending, opening accounts for individuals and legal entities, issuing bank cards and integrating with international payment systems.

Main requirements for a banking license

  • Minimum share capital: for a universal bank: from EUR 5 million; for specialized banks (for example, in Lithuania), from EUR 1 million. Capital must be supported by transparent sources of funding and comply with capital structure requirements.
  • Top management qualifications: members of the board of directors and executives are required to have experience in the banking sector, a proven reputation and no conflicts of interest. At COREDO we always recommend preparing a separate dossier for each candidate, including certificates of good standing and references from previous employers.
  • Office and residency requirements: the bank must have a physical office in the licensing country, and key persons must be residents or hold long-term visas. For example, in the United Kingdom at least one director must be a resident of the country, and in Luxembourg: having a real office and staff is a mandatory requirement.
  • Internal audit and control systems: mandatory presence of departments for internal audit, AML compliance, risk management and disclosure of accepted risks.

Regulatory bodies and supervision

  • European Central Bank (ECB): supervises systemically important banks and coordinates the Single Supervisory Mechanism (SSM) within the EU.
  • National regulators: in Germany – BaFin, in the United Kingdom, FCA and PRA, in Luxembourg – CSSF. Each authority applies its own requirements to capital structure, management qualifications and Due Diligence procedures.
  • Single banking license in the EEA: allows, after obtaining a license in one EU country, to open branches and provide services in all countries of the European Economic Area without re-licensing.

Examples of countries with banking licenses

  • United Kingdom: a flexible system for digital banks, but strict residency and capital requirements.
  • Germany: a high capital threshold, strict BaFin supervision, popular for large international banks.
  • Luxembourg: developed infrastructure for private banking and wealth management, but a lengthy licensing process and strict physical presence requirements.

Financial license and its types in Europe

Illustration for the section «Financial license and its types in Europe» in the article «Banking license vs financial license in the EU»
Financial license covers activities not related to classic banking: electronic payments, issuance of electronic money, mobile wallets, integration with VISA and MasterCard, processing payments and settlements.

Main types of financial licenses

  • EMI license (Electronic Money Institution): allows issuing electronic money, opening accounts for clients, integrating payment cards, but does not allow accepting deposits or granting loans.
  • PI license (Payment Institution): permits providing payment services (transfers, acquiring, payments via mobile and digital wallets), but not issuing electronic money or opening full-fledged accounts.

EMI and PI licenses: differences

Parameter EMI license PI license
Minimum capital 350,000 euros 20,000–125,000 euros
Opening accounts Yes (but not bank deposits) No
Issuance of electronic money Yes No
Lending No No
Integration with VISA/MC Yes Limited
AML compliance Strict Standard

Licensing in EU countries

  • Lithuania: one of the fastest and most accessible jurisdictions for obtaining EMI and PI licenses, minimum capital 350,000 euros, review times from 3 to 6 months. A solution developed by COREDO for a fintech startup in Vilnius allowed the client to enter the market in 4.5 months, integrate payments with VISA and MasterCard and scale to 7 EEA countries.
  • United Kingdom: strict requirements for physical presence, mandatory office and residency of key persons, but a developed infrastructure for integration with international payment systems.
  • Luxembourg: high entry threshold, lengthy due diligence process, but a prestigious jurisdiction for large fintech companies.

Banking license vs financial license in the EU

Parameter Banking license Financial license (EMI, PI)
Minimum capital from €5 million and above EMI: from €350,000; PI — lower
Lending capabilities Yes No
Deposit-taking Yes No
Account opening Yes Limited
Regulation and supervision ECB + national regulators National regulators
International expansion Single license in the EEA Passporting in the EEA
E-money services Yes Yes
PSD2 applicability Yes Yes

Key differences and business impact

Functionality: A banking license provides access to lending, deposits and full settlement and cash services, which is critical for universal banks and large fintech platforms. EMI and PI licenses are suitable for payment services, mobile wallets, issuing electronic money and integration with international payment systems.
Capital expenditures: obtaining a banking license requires significant investments in capital, infrastructure, personnel and compliance. EMI and PI licenses allow starting with less capital, entering the market faster and testing the business model.
COREDO’s practice confirms: for a fintech startup focused on payments and e-wallets, the optimal choice is an EMI license, while for projects with ambitions in lending and deposits — a banking license followed by expansion through the EU’s Single Supervisory Mechanism.

How can I obtain a license in the EU?

Illustration for the section 'How to obtain a license in the EU?' in the article 'Banking license vs financial license in the EU'
licensing process in the EU: a step-by-step guide — a set of formal and practical stages that companies must go through to operate legally in the European market. At each step there are a number of general requirements for the applicant that directly affect the likelihood of license approval and further interaction with the regulator.

General requirements for the applicant

  • Documents: founding documents, business plan, capital structure, information on beneficiaries, resumes and references for the management.
  • Company structure: transparent corporate structure, presence of qualified directors and shareholders, absence of offshore elements.
  • Management qualifications: proven experience in the financial sector, references, no criminal convictions and no conflicts of interest.

Specifics of obtaining a banking license

  • Verification of funding sources: the regulator requires disclosure of all sources of capital, proof of the legality of the origin of funds, analysis of capital structure and financing plans.
  • Due diligence: comprehensive check of all participants, internal control procedures, AML systems and risk management.
  • Internal audit: mandatory internal audit department, regular checks and reports for the regulator.

Obtaining EMI and PI licenses

  • Minimum capital: for EMI, €350,000; for PI, from €20,000 to €125,000, depending on the volume of operations.
  • Office and physical presence: mandatory office in the licensing country, presence of staff, residency of key persons.
  • Review timelines: in Lithuania, from 3 to 6 months; in the United Kingdom: from 6 to 12 months; in Luxembourg, up to 18 months.
  • Documents: application, business plan, financial forecasts, description of IT infrastructure, AML procedures and internal control.

Which jurisdictions should I choose?

  • Luxembourg: high entry threshold, lengthy due diligence, strict requirements for physical presence, prestigious for private banking.
  • Lithuania: fast process, minimal capital, popular for fintech startups.
  • United Kingdom: developed infrastructure, strict supervision, mandatory office and residency.
The COREDO team implemented an EMI licensing project in Lithuania for a startup that obtained the license in 4.5 months, integrated payments with VISA and MasterCard and scaled the business to 7 EEA countries.

Regulation and compliance: AML, financial monitoring, risks

Illustration for the section «Regulation and compliance: AML, financial monitoring, risks» in the article «Banking license vs financial license in the EU»
Regulation and compliance in the field of AML, financial monitoring and risk management are becoming key tasks for financial organizations amid tightening legislative requirements and the constant complication of money laundering schemes. Effective implementation of core requirements allows not only to minimize legal and reputational risks, but also to build transparent internal control processes.

Main AML and financial monitoring requirements

  • AML requirements: mandatory implementation of customer identification (KYC) procedures, transaction monitoring, reporting of suspicious operations, and regular staff training.
  • Financial monitoring: automated control systems, integration with national and international registers, disclosure of information about risks and procedures for managing them.
  • Internal audit: regular inspections, reports for the regulator, independent assessment of the effectiveness of AML and risk management procedures.

Impact of PSD2 and other regulatory acts

  • PSD2: an EU directive regulating payment systems, opens access to banks’ APIs, strengthens requirements for security, transparency and protection of customer data.
  • Sanctions and fines: for non-compliance with AML and financial monitoring – fines of up to 10% of annual turnover, account freezes, license revocation, prohibition from operating.
A solution developed by COREDO for a fintech company in Estonia allowed automating AML procedures, reducing compliance costs by 30% and avoiding penalties during a regulator inspection.

Licensing of fintech startups in the EU

Illustration for the section «Licensing of fintech startups in the EU» in the article «Banking license vs financial license in the EU»
choice of license for a fintech startup determines not only the formal framework of the company’s operations but also opens up different scenarios for scaling the business in the EU. The specifics of regulation and licensing requirements in the European Union require startups to carefully choose between a banking license, an EMI and a PI — this choice determines the possible business model, time-to-market and the project’s future development.

Criteria for choosing a banking, EMI or PI license

  • Business model: if the goal is lending and deposits, a banking license is required; for electronic payments, mobile wallets and issuance of electronic money: EMI; for acquiring and payment operations – PI.
  • Capital costs: a banking license requires large investments; EMI and PI: minimal capital and a rapid market entry.
  • Licensing speed: EMI and PI licenses can be obtained in 3–6 months, a banking license: from 12 to 24 months.

Examples of business models and licenses

  • Payment platform: an EMI license is optimal, integration with VISA and MasterCard, issuance of electronic money, opening accounts for customers.
  • Mobile wallet: EMI or PI license, fast launch, minimal capital requirements.
  • Digital bank: banking license, access to lending, deposits, international expansion.

Cross-border expansion opportunities

  • Passporting of licenses: after obtaining a license in one EEA country you can provide services in all countries of the area without re-licensing.
  • Restrictions: for banks – practically none, for EMI and PI: restrictions on types of services and operational limits.

Minimizing costs and risks

COREDO strategy: phased Licensing (first EMI, then a banking license), automation of AML procedures, optimization of capital structure, choice of a jurisdiction with a fast licensing process.

Key findings and recommendations

Practical recommendations and key findings will help draw attention to the most important aspects of website optimization and facilitate the implementation of effective solutions. This section compiles the main differences in approaches and tips to consider for improving the site’s ranking and achieving stable results.

Summary of main differences and tips

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  • Banking license: for large projects with ambitions in lending and deposits, requires significant capital and a lengthy licensing process.
  • EMI license, optimal for fintech startups, payment platforms and mobile wallets, minimal capital, fast time to market.
  • PI license – suitable for acquiring, payment operations, integration with e-wallets.

Recommendations for licensing preparation

  • Prepare a detailed business plan with financial forecasts, a description of IT infrastructure and AML procedures.
  • Ensure a transparent capital structure and qualified management.
  • Choose a jurisdiction with optimal requirements and review timelines.

Advice on AML and risk management

  • Implement automated monitoring systems, train personnel, conduct regular internal audits.
  • Disclose information about risks, integrate risk management procedures into operational activities.

How to choose a jurisdiction?

  • Assess capital requirements, management qualification, review timelines and licensing costs.
  • Lithuania: fast process, minimal capital, popular for startups.
  • United Kingdom, developed infrastructure, strict supervision.
  • Luxembourg – prestige, high entry threshold.

Appendices and FAQ

The “Appendices and FAQ” section was created to gather in one place structured supplementary materials and answers to frequently asked questions on the topic of licensing. Here you will find practical documents such as checklists for applying for an EMI/PI license, as well as clarifications on key stages and nuances of the process.

Document checklist for applying for an EMI/PI license

  • Incorporation documents
  • Business plan
  • Financial forecasts
  • Information on beneficial owners
  • Management resumes
  • Description of IT infrastructure
  • AML and internal control procedures

Frequently Asked Questions

How does a fintech license differ from a universal banking license?
A fintech license (EMI, PI) is limited to payment services and the issuance of electronic money; it does not grant the right to lend or accept deposits. A universal banking license allows conducting the full range of banking operations.
Is it possible to start with a payment license and switch to a banking one?
Yes, COREDO’s practice shows that phased licensing is an effective strategy for scaling a business: first EMI/PI, then a banking license as turnover grows and services expand.
What are the qualification requirements for top management?
Management must have experience working in the financial sector, no criminal record, a proven reputation, and references.
What expenses for AML and compliance should be taken into account?
On average, expenses for AML systems and internal audit amount to 15–25% of a fintech company’s annual budget, but automation and integration of modern solutions can reduce costs by 30–40%.
COREDO’s expertise in international licensing, AML consulting and comprehensive business support is confirmed by dozens of completed projects in the EU, the United Kingdom, Singapore and Dubai. If you are looking for a reliable partner to register a company, obtain a financial license or enter new markets, the COREDO team is ready to offer strategic solutions tailored to your goals and regulatory requirements.

The modern market offers entrepreneurs and investors a wide range of legal structures for investment funds. The most in demand are SPV (Special Purpose Vehicle), unit investment funds (PIF), closed-end investment funds (ZPIF) and specialized forms, such as ZISIF. The choice of structure determines not only the tax burden and level of asset protection, but also the possibilities for scaling, attracting investors, risk management and compliance with international standards.

What is an SPV and why is it needed?

An SPV is a legal entity created to implement a specific investment task or to structure a transaction. In COREDO’s practice COREDO SPVs are often used to isolate risks for individual projects, to raise financing secured by specific assets or to create a platform for venture investments.

This structure allows effective risk management: the obligations of an SPV do not extend to the parent company, and assets are protected from creditors’ claims related to other lines of business. In international practice, SPVs are used in bond issuance, securitization, real estate management and venture deals.
At the same time, SPVs have limitations: insufficient flexibility in long-term asset management, difficulties in attracting a large number of investors, as well as the need to strictly comply with AML and KYC requirements in some jurisdictions. A solution developed by COREDO for one European client made it possible to integrate an SPV into a holding structure, providing transparency for regulators and optimizing the tax burden.

PIF and ZPIF: differences and types of funds

A unit investment fund (PIF) is an asset pool held in trust management by a management company.

In a PIF, unit holders acquire a share (unit) in the overall asset pool, and management is carried out based on rules of trust management (PDU). Open PIFs provide high liquidity — a unit can be sold at any time and the entry threshold is minimal. For long-term and complex investment strategies, a closed-end investment fund (ZPIF) becomes the optimal instrument.

A ZPIF is characterized by a fixed term, a limited number of unit holders and the ability to invest in less liquid assets, real estate, venture projects, private companies and non-publicly traded securities. The entry threshold into a ZPIF is usually higher, and the liquidity of investment units is limited: they can be realized only at the end of the fund’s term or on the secondary market.

In some jurisdictions it is allowed to create a ZPIF for a single founder, which opens new opportunities for structuring private capital. COREDO’s practice confirms: a ZPIF is an effective tool for long-term investments, tax optimization and asset protection.
Legislative regulation of PIFs and ZPIFs requires mandatory registration of the investment fund, approval of the rules of trust management, engagement of a specialized depositary and a registrar. In the EU, for example, the UCITS and AIFMD directives apply, and in the UK: the FCA rules for alternative investment funds.

ZISIF and other forms of investment funds

ZISIF (Specialized Investment Fund) is a specialized form of fund intended for qualified investors and complex investment strategies.

Such structures are widespread in Luxembourg, Cyprus, Estonia and the Czech Republic. They allow flexible asset management, the use of mixed investment strategies and minimizing the tax burden through special regimes.

An example from COREDO’s practice: the registration of a ZISIF for a venture fund in Estonia allowed a client to combine investments in startups and real estate, as well as to provide a transparent legal structuring of capital for international investors.

SPV or ZPIF: how to choose a structure?

Parameter SPV ZPIF
Legal status Legal entity Asset complex under trust management
Liquidity Limited Limited (exit at maturity or on the secondary market)
Term Flexibly determined by the founder Fixed, with possibility of extension
Taxation Depends on the jurisdiction Often a preferential regime, tax optimization through ZPIF
asset management Managed by the founder or the board of directors Management company, specialized depositary, appraiser
Risks Isolation of project risks Diversification, capital protection, regulator oversight
The advantages of ZPIF for business are clear when long-term investment structuring, trust management of assets, creating a platform for qualified investors, and tax optimization are required.

ZPIF allows implementing complex investment strategies, integrating management of real estate, venture projects, and private companies. An SPV, on the other hand, is suitable for one-off transactions, securitization, managing individual assets, or time-limited projects.

In one of COREDO’s cases for an international development group a combined structure was implemented: an SPV was used to acquire and manage individual real estate properties, while a ZPIF was used to pool investments and distribute income among unitholders taking tax benefits into account.

Registration and support of an investment fund

Illustration for the section «Registration and support of an investment fund» in the article «Legal structure of an investment fund - from SPV to ZISIF»
The procedure for registering an investment fund varies significantly depending on the jurisdiction. In EU countries (for example, Luxembourg, Cyprus, Estonia) registering a fund requires approval of constitutional documents, trust management rules, engaging licensed management companies, a specialized depositary and a registrar of investment funds. In the United Kingdom there is an FCA licensing system, and in Singapore: MAS licences for management companies and funds.

In Asia, based on COREDO’s experience, special attention is paid to AML procedures and disclosure of beneficiary information. In Singapore, for example, since 2025 all companies are required to maintain a register of controllers and confirm the data annually. Failure to comply with these requirements can result in substantial fines and even criminal liability.

Therefore, when registering an investment fund it is critically important to ensure the legal structuring of capital taking into account AML, KYC and the international standards of FATF.

Trust management and a specialized depositary are key elements of a fund’s infrastructure. They provide protection of investors’ interests, operational transparency and compliance with regulatory requirements.

Solutions implemented by the COREDO team in the Czech Republic and Estonia have shown: the integration of a professional depositary and an independent asset valuer minimizes risks and increases confidence from investors and regulators.

Asset management through ZPIF

Illustration for the section \
Organizing asset management in a ZPIF requires a clearly structured governance framework: a management company, a specialized depository, a registrar, and an independent asset appraiser. Each element plays its role: the management company is responsible for the investment strategy, the depository for safekeeping and accounting of assets, the registrar for maintaining the unit-holders’ register, and the appraiser for regular valuation of assets.

A ZPIF allows investing in a wide range of assets: real estate as an asset, venture projects, private companies, and non-tradable securities. In COREDO’s practice, mixed investment funds are often implemented, combining several asset classes to diversify and increase the ROI of investments through a ZPIF.

Interval PIFs (IPIFs) provide additional flexibility: unit-holders can exit the fund at specified intervals, which increases the liquidity of investment instruments.
risk management in a ZPIF is built on a multi-level control system: internal policies, independent asset valuation, regular audits, and compliance with trust management rules (PDU). This approach ensures transparency, reduces the likelihood of conflicts of interest, and protects the interests of all participants.

How do closed-end unit investment funds (PIFs) work?

Illustration for the section «How do closed-end PIFs work?» in the article «Legal structure of an investment fund — from SPV to ZISIF»
The entry threshold for a closed-end PIF is usually higher than for open-ended funds, which is due to the focus on qualified investors. Nevertheless, for certain strategies it is allowed to create a closed-end PIF for a single founder, which is in demand when structuring private capital or family offices.

The participation of qualified investors makes it possible to implement more complex and profitable strategies.
Liquidity of units is limited: the secondary market for closed-end PIF units is developing, but still lags behind the stock and bond markets in volume.

Transfer of units to third parties is possible only with the consent of the management company or within the established rules. The fund’s term is fixed, but an extension of the closed-end PIF’s term or early liquidation of the closed-end PIF is possible upon the occurrence of certain conditions specified in the Trust Management Rules (PDU).

Trust Management Rules (PDU): the fundamental document that defines the rights and obligations of unitholders, the procedure for valuing assets, income distribution, extension and liquidation of the fund.

COREDO’s practice shows: well-drafted PDU allows avoiding most disputes and ensures the fund’s stability in the long term.

Tax optimization and investment protection through ZPIF

Illustration for the section «Tax optimization and investment protection through ZPIF» in the article «Legal structure of an investment fund - from SPV to ZISIF»

One of the key advantages of ZPIF is tax optimization. In many jurisdictions the fund’s income is exempt from corporate income tax, and taxation arises only at the unit-holders’ level when income is distributed.

This allows structuring transactions through a ZPIF effectively, minimizing tax risks and providing legal protection for investments.

The COREDO team has repeatedly executed projects to structure transactions through ZPIFs for investments in private companies, real estate and venture projects.

This approach ensures transparency for regulators, protection of investors’ interests and compliance with international AML and KYC standards. Legal protection of investments is achieved through a multi-level control system: a specialized depositary, an independent registrar, regular asset valuation and clearly defined trust management rules.

Investment risks through a ZPIF are minimized thanks to asset diversification, independent valuation and strict oversight by the management company and regulators. An example from COREDO’s practice: for a fund investing in unlisted securities and startups, an internal compliance system and regular audits were established, which made it possible to attract institutional investors and reduce the cost of borrowed capital.

Key findings and recommendations for investors and entrepreneurs

Illustration for the section 'Key findings and recommendations for investors and entrepreneurs' in the article 'Legal structure of an investment fund — from SPV to ZISIF'

  • SPV – optimal for one-off transactions, securitization, and managing individual assets. ZPIF: a tool for long-term investments, trust management, tax optimization and capital protection.
  • The choice of fund structure depends on investment goals, asset composition, liquidity requirements, investor makeup, and jurisdiction.
  • Registering an investment fund requires careful legal packaging of capital, compliance with AML and KYC, and the engagement of professional management companies and a specialized depository.
  • To minimize risks, it is important to develop rules of trust management, ensure regular asset valuation and operational transparency.
  • When choosing a legal partner, pay attention to experience in international projects, knowledge of jurisdictional specifics, and the availability of comprehensive solutions for the registration, licensing, and support of investment funds.

SPV vs PIF vs ZPIF: comparison

Parameter SPV PIF (open-ended) ZPIF (closed-ended)
Legal status Legal entity Asset pool Asset pool
Liquidity Limited High Limited
Term Flexible Indefinite Fixed-term
Taxation Depends on jurisdiction Depends on jurisdiction Often preferential
Management Founder/directors Management company Management company, depository
Minimum entry threshold Low Low Medium/High

Glossary of key terms

  • PDU (Rules of Trust Management): the fund’s primary document defining unitholders’ rights, the procedure for management and liquidation.
  • Trust management: the transfer of assets to the management of a professional company on the basis of the PDU.
  • Specialized depository: an independent organization responsible for the safekeeping and accounting of the fund’s assets.
  • Investment fund registrar: maintains the register of unitholders, ensuring transparency of operations.
  • Qualified investor: an investor who meets the established criteria for experience, capital, and knowledge.
  • Non-tradable securities: instruments not traded on an exchange (e.g., stakes in private companies).
  • Interval mutual fund (IMF): a fund in which a unit can be redeemed only at specific intervals.

Frequently Asked Questions

  1. How to choose the optimal legal structure for an investment fund?

    The choice depends on investment objectives, asset composition, liquidity requirements and tax optimization. For one-off projects an SPV is suitable; for long-term and diversified ones: ZPIF or ZISIF.

  2. What are the requirements for registering a fund in the EU and Asia?

    Registration with the regulator is required, approval of the offering document (PDU), engagement of a management company, a depositary and a registrar, as well as compliance with AML/KYC.

  3. How to ensure legal protection of investments?

    Use a multi-level infrastructure: a management company, a specialized depositary, an independent registrar, regular asset valuation, transparent trust management rules.

  4. What risks are associated with investments through a ZPIF?

    Limited liquidity, the need for strict compliance with regulatory requirements, risks in asset valuation. COREDO’s practice shows that a sound structure and compliance minimize these risks.

  5. What is the minimum entry threshold for a ZPIF?

    Depending on the jurisdiction and the fund’s strategy, the threshold can range from several thousand to hundreds of thousands of euros.

If you are planning to launch an investment fund, structure capital or optimize taxation, the COREDO team is ready to offer comprehensive solutions that take into account the specifics of your business and jurisdiction. A reliable legal infrastructure is the foundation of long-term success in the world of investments.

In 2026 Lithuania found itself at the center of attention in the European crypto market: according to the European Commission, in just the last year the volume of crypto-asset transactions in the country grew by more than 120%. This is not just a statistic: it is a challenge for anyone building or scaling a crypto business in the EU. Why? Because from 2026 cryptocurrency regulation in Lithuania is changing radically: MiCA (Markets in Crypto-Assets) comes into force, and national rules are becoming stricter and more transparent than ever before.

Today entrepreneurs face not only the need to register a crypto company in Lithuania, but also new requirements for licensing, capital, AML and corporate governance. A mistake at any stage, and a business risks losing access to EU markets, facing sanctions or fines, and in the worst case – being excluded from the legal field.

Are you ready for these changes? How can you use the CASP transitional period not only to survive but to gain a competitive advantage? What steps will ensure the transparency and security of crypto-asset operations in Lithuania in 2026?

In this article I, Nikita Veremeev, founder of COREDO, share practical strategies and the experience of our team so that you not only understand the essence of the changes, but also get a step-by-step guide to adapting to the new rules. Read to the end; you will find not only answers to pressing questions, but also tools to grow your crypto business in the new regulatory reality.

Changes in crypto regulation in Lithuania 2026

Illustration for the section «Changes in crypto regulation in Lithuania 2026» in the article «Crypto regulation in Lithuania - what changed in 2026»
The year 2026 became a point of no return for the crypto asset industry in Lithuania. The entry into force of MiCA in Lithuania and national amendments completely reshaped the approach to licensing, registration and supervision of crypto businesses. Key changes affected not only legal entities but all crypto asset service providers (CASP and VASP).

  • MiCA in Lithuania: From 2026 all crypto assets and related services are regulated at the EU level under unified standards. This provides transparency, investor protection and a level playing field for all market participants.
  • Transition period for CASP in Lithuania: Until 1 January 2026 there was a transitional period that allowed operating companies to adapt to the new requirements without the risk of an immediate shutdown.
  • registration of a crypto company in Lithuania 2026: The registration procedure has become stricter – now not only legal formalization is required, but also compliance with new criteria on capital, corporate governance and internal AML policies.

Implementation of MiCA in Lithuania: what’s new?

MiCA is not just another regulation, but a fundamental market overhaul. The main provisions of MiCA that are now mandatory for Lithuania:

  • MiCA requirements for crypto companies in Lithuania: Any company providing crypto asset services (CASP, VASP) is required to obtain a license for crypto activities in Lithuania through the national regulator – the Bank of Lithuania.
  • Licensing of VASP in Lithuania: Service categories (exchange, custody, portfolio management, advisory) are clearly defined for the first time, and each has specific minimum capital requirements and internal control procedure requirements.
  • Unification of rules across the EU: Thanks to MiCA, Lithuania becomes part of the single European market, which simplifies license passporting and entry into the markets of other EU and EEA countries.
COREDO’s practice shows: the implementation of MiCA has raised requirements for corporate governance transparency, mandatory internal controls and liability for non-compliance with AML/CFT standards.

Transition period for CASP and its significance

The CASP transition period in Lithuania: it was a unique window of opportunity that ended on 1 January 2026. During this period companies could continue operating under the old rules while bringing their processes into compliance with MiCA.

  • How to prepare a crypto business for MiCA requirements in Lithuania: The solution developed at COREDO included an audit of internal policies, updating KYC procedures and implementing transaction monitoring systems.
  • Consequences of the end of the transition period: From 2026, lack of a license or non-compliance with new requirements leads to immediate suspension of activities and the risk of large fines.
The COREDO team’s experience confirms: those companies that used the transition period for comprehensive preparation gained not only a license but also a competitive advantage in the EU market.

Crypto Business Licensing in Lithuania under MiCA

Illustration for the section 'Crypto Business Licensing in Lithuania under MiCA' in the article 'Crypto regulation in Lithuania - what changed in 2026'
С 2026 года лицензия крипто Литва стала обязательным условием для всех, кто планирует оказывать криптоуслуги в Литве 2026 и выходить на рынки ЕС. Банк Литвы выступает единым окном для подачи заявок и осуществляет надзор за соответствием компаний новым стандартам.

  • VASP licensing in Lithuania: The process has become digital, transparent and standardized. Now each application undergoes a comprehensive review for compliance with MiCA requirements and national legislation.
  • Capital requirements for crypto business in Lithuania: Minimum capital ranges from €50,000 to €125,000 depending on the type of services provided. This is a tightening compared to previous rules.
  • The role of the Bank of Lithuania in crypto regulation: The regulator not only issues licenses but also conducts regular supervision, including checks of corporate governance, internal controls and compliance.
  • Passporting rights of the license in the EU: A Lithuanian CASP license grants the right to provide services in all EU and EEA countries without the need to obtain additional permits.

How to obtain a crypto license in Lithuania under MiCA?

COREDO’s practice shows that licensing success depends on thorough preparation and understanding of all stages of the process:

  1. Document collection and assessment criteria: You must prepare the incorporation documents, a business plan, descriptions of internal AML policies, information about beneficiaries and the capital structure.
  2. Electronic application submission: All documents are submitted through the Bank of Lithuania’s electronic “single window” system, which speeds up the process and minimizes bureaucracy.
  3. Internal compliance and AML procedures: To obtain a license, it is mandatory to implement compliance standards, appoint a person responsible for AML and develop internal policies for client identification and transaction monitoring.
A completed COREDO case: for one of the clients entering the EU market, the COREDO team not only prepared a full package of documents, but also helped implement an automated KYC system, which made it possible to obtain the license in minimal time.

Capital and corporate governance requirements

MiCA and Lithuania’s national rules of 2026 have tightened capital and corporate governance requirements:

  • Minimum capital thresholds: €50,000 for advisory services, €125,000 for custody of crypto assets and portfolio management.
  • AML responsible manager: Mandatory appointment of a Lithuania-based resident with experience in AML/CFT.
  • corporate governance: Implementation of an internal control system, regular audits, transparent ownership structure.
COREDO’s experience confirms: the implementation of these standards not only reduces regulatory risks but also increases the confidence of investors and partners.

AML and Financial Crimes in Lithuania’s Crypto Sector

Illustration for the section ‘AML and Financial Crimes in Lithuania's Crypto Sector’ in the article ‘Cryptocurrency Regulation in Lithuania - What Changed in 2026’
In 2026, Lithuania’s cryptocurrency AML regime reached a new level. The Anti-Money Laundering and Countering the Financing of Terrorism law (AML/CFT) has been integrated with MiCA, and supervision was strengthened by two bodies at once – the Bank of Lithuania and the Financial Crime Investigation Service of Lithuania (FCIS).

  • Control of financial crimes in Lithuania’s crypto sector: the FCIS now has expanded powers to monitor operations, investigate suspicious transactions and impose fines.
  • Internal AML policies for crypto companies in Lithuania: Every company is required to implement KYC procedures, transaction monitoring and risk assessments.
  • The role of the Bank of Lithuania in crypto regulation: the regulator conducts regular inspections, requires reporting and confirmation of the effectiveness of internal AML policies.
COREDO implementation: for one of Lithuania’s largest VASPs, the COREDO team developed a comprehensive AML policy, including automated scenarios for detecting suspicious transactions and integration with the national reporting system.

Recommendations for AML and CFT Compliance

Effective AML and CFT compliance is not only a legal requirement but also the foundation of trust for customers and partners.

  • Organizing KYC and transaction monitoring: Implement multi-level customer identification and regular verification of sources of funds.
  • Risk assessment and reporting systems: Use automated tools to analyze transactions and submit timely reports to the FCIS and the Bank of Lithuania.
  • Liability for non-compliance: Fines for violating AML standards can reach hundreds of thousands of euros, and in cases of systematic violations license revocation and criminal prosecution are possible.
COREDO’s experience shows: implementing modern AML systems and training staff helps reduce risks and minimize the likelihood of sanctions from regulators.

Crypto business in Lithuania and the EU: new rules

Illustration for the section «Crypto business in Lithuania and the EU: new rules» in the article «Crypto regulation in Lithuania - what changed in 2026»
The implementation of MiCA in Lithuania and the national changes has become a catalyst for scaling crypto business in the EU and increasing the sector’s investment attractiveness.

  • Scaling crypto business in the EU: a CASP license obtained in Lithuania opens access to EU markets and the EEA, simplifying expansion into new jurisdictions.
  • Risks and opportunities: strict capital and compliance requirements raise the barrier to entry but at the same time protect the market from bad actors.
  • Comparison of crypto regulation in the EU and Asia: the European approach (MiCA) emphasizes transparency, investor protection and integration with banking infrastructure, while in some Asian countries regulation is less harmonized.
  • Impact of MiCA on Lithuania’s crypto ecosystem: the new rules help form a resilient ecosystem, attract institutional investors and foster innovation.
The COREDO team carried out projects to scale crypto business using the Lithuanian CASP license, which allowed clients not only to enter EU markets but also to attract strategic partners among European banks and fintech companies.

Practical steps for crypto business leaders in Lithuania

Illustration for the section «Practical steps for crypto business leaders in Lithuania» in the article «Crypto regulation in Lithuania - what changed in 2026»
In practice, successful adaptation to the new rules requires a systematic approach and attention to detail.

  • preparation for licensing and audit: Conduct an internal audit of processes, update documentation, implement automated KYC/AML systems.
  • Establishing internal compliance and AML policies: Develop and approve internal control procedures, appoint responsible persons, conduct staff training.
  • Strategy for using the CASP transitional period: Use the remaining time to test new procedures, adjust the business model, and prepare for the Bank of Lithuania’s audit.
  • Ensuring transparency and security of operations: Integrate your business with the payment infrastructure, use modern monitoring and reporting tools.
  • Choosing reliable partners and consultants: COREDO’s experience shows that working with professional consultants can minimize risks and accelerate the licensing process.
COREDO’s management recommends: do not postpone preparation; changes in Lithuania’s crypto legislation in 2026 require time to adapt and implement new standards.

Practical recommendations and key takeaways

The year 2026 was a turning point for cryptocurrency regulation in Lithuania. The implementation of MiCA in Lithuania, tightened licensing and AML requirements, and new corporate governance standards are shaping a new reality for the crypto business.

Checklist for launching and running a crypto business in Lithuania from 2026:

  • Conduct an audit of business processes and internal documentation.
  • Prepare a complete set of documents for CASP licensing.
  • Implement modern KYC/AML systems and internal controls.
  • Appoint compliance and AML officers and ensure their training.
  • Integrate the business with the EU payment infrastructure.
  • Ensure transparency and security of crypto asset operations.
  • Take advantage of the CASP transitional period for adaptation.
  • Work with professional advisors to accelerate the licensing process.

If you are looking for a reliable partner to register a crypto company in Lithuania in 2026, obtain a crypto license in Lithuania, or receive comprehensive support, the COREDO team is ready to offer solutions proven in practice and compliant with the strictest EU standards.

Comparison of MiCA requirements and Lithuania’s 2026 regulations

Parameter MiCA requirements Lithuania’s national rules (2026) Comments
CASP licensing Mandatory for all service providers Process through Lietuvos Bankas, ‘single window’ Transition period extended until 01.01.2026
Minimum capital From €50,000 to €125,000 In line with MiCA requirements Tightening compared to previously applicable rules
AML/KYC Mandatory procedures, monitoring Implementation of internal policies and reporting Supervision by the FCIS and the Bank of Lithuania
Corporate governance Responsible AML manager Mandatory appointment of a resident responsible person Increased transparency and oversight
License passporting rights Access to EU and EEA markets Subject to EU supervision and the national regulator Lithuania: a hub for crypto business in the EU
Cryptocurrency regulation in Lithuania 2026: new opportunities for growth and scaling if the changes are approached strategically and professionally. Solutions implemented by COREDO confirm: a well-prepared business not only weathers regulatory challenges but also becomes a leader in the European crypto-asset market.
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