Data-Driven Insights on the Lithuanian VASP Industry: A 2025 Snapshot

Introduction

This report provides a snapshot of the Virtual Asset Service Provider (VASP) industry in Lithuania as of 2025-01-17. Its purpose is to present key data and observations about the sector, focusing on registration trends, employee distribution, and financial performance. This report aims to serve as an informational resource, offering a high-level overview of the industry without drawing conclusions or providing recommendations. As MiCA came into force on 2025-01-01 and the grandfathering period ends on 2025-06-01, Lithuanian VASP market is now at a pivotal point.

The data used in this report was retrieved on 2025-01-17 from Registrų Centras, leveraging the public VASP registry. The dataset contains fundamental information about companies, including incorporation dates, the timing of their last financial submissions to Registrų Centras, employee counts, and other relevant operational and financial metrics.

Overview of the Lithuanian VASP Industry

By combining two (dvvpo and vvko) VASP registries from Registrų Centras a total of 379 unique Virtual Asset Service Providers (VASPs) were identified as operating in Lithuania as of 2025-01-17. Combination of these datasets allowed us to eliminate duplicates among those databases and present a more comprehensive view of the industry.

Registration Trends

Out of the total 379 VASPs that are operating in Lithuania as of 2025-01-17, 155 were registered in 2024, with 38% of VASPs being registered in the final months:

• 29 companies registered in November.

• 30 companies registered in December.

Starting from 2025-01-01, MiCA (Markets in Crypto-Assets Regulation) is being enforced in Lithuania. However, during the five-month grandfathering period, companies with only a VASP registration are permitted to offer their services without obtaining a

MiCA license. This transitional period has encouraged companies to take advantage of the relatively lenient regulatory environment to provide VASP services before full MiCA compliance becomes mandatory. The influx of registrations may signal a strategic move by VASPs to only temporarily operate in Lithuania under lenient regulatory conditions, until a permanent headquarters is established under the new MiCA regime.

Employee Distribution

The dataset reveals significant disparities in company sizes based on employee count:

• 247 VASPs (65%) operate with one or fewer employees.

• 114 VASPs (30%) employ between 2 and 5 individuals.

• 11 VASPs (3%) fall in the 6–10 employee range.

• 7 VASPs (2%) employ more than 10 individuals.

The majority of companies in Lithuania's VASP sector operate with minimal staffing, reporting one or fewer employees. These solo operators are unlikely to meet the staffing requirements for MiCA licensing, making it improbable that they will apply. Consequently, many of these companies are expected to cease operations in Lithuania.

In contrast, 114 micro VASPs, which are actively investing in their employee headcount, could potentially meet MiCA requirements with additional effort. These companies have a better chance of continuing their operations in Lithuania under the new regulatory framework.

Furthermore, 19 VASPs with more than six employees are the most likely candidates to successfully apply for a MiCA license. If these companies have adequately prepared for the regulatory requirements, they are well-positioned to secure the license and continue operating in compliance with MiCA.

Financial Performance

Revenue Overview

Of the 379 VASPs, 236 submitted their financial reports for 2023, collectively reporting a total revenue of €1.152 billion. The revenue distribution is highly concentrated:

• Cypher Trading contributed 46% of the total revenue.

• Bitfinity ranked second, accounting for 20% of the total revenue.

• Top 10 VASPs generated more than 90% of the sector's total revenue.

Due to the lack of standardized accounting practices among VASPs, comparing companies based on their reported revenue is challenging, the discrepancy in reporting practices complicates regulatory oversight and investor decision-making. Some VASPs include not only the revenue generated from their commissions but also the flow of client funds through the company. Essentially, these VASPs report their total transaction volume rather than the revenue directly attributable to their operations. This inconsistency makes it difficult to draw meaningful comparisons between companies or accurately assess their financial performance.

Conclusion

Regardless of the lack of standardized reporting among VASPs, the data still provides valuable insights that can form the basis for deeper analysis. For instance, identifying companies unlikely to obtain a MiCA license—such as solo VASPs—reveals a potential market of approximately €96 million - a lucrative opportunity for well-prepared VASPs to expand their market share. This represents a conservative estimate of the market share that could become available for licensed VASPs to capture.

Moreover, the data allows us to pinpoint underperforming companies, presenting opportunities for market consolidation through acquisitions. By targeting these companies, larger VASPs can strengthen their position in the evolving regulatory landscape.

As Lithuania continues to enforce MiCA, the VASP sector’s adaptability will be pivotal in shaping the region’s digital asset ecosystem. Have a different perspective, need assistance in mitigating risks, or looking to capitalize on emerging opportunities? Write to us at info@asdlabs.io