Lithuania Updates Crypto-Asset User Reporting Rules Under DAC8 and CARF

By Order No. VA-63 of September 24, 2026 (effective September 25, 2026), the Head of the State Tax Inspectorate (VMI) amended the Description of the Procedure for Submitting Data on Reportable Crypto-Asset Users to the VMI, previously established by Order No. VA-119 on December 10, 2025. On September 28, 2026, VMI published official explanatory note No. R-2618 outlining the practical implications of these regulatory updates.

The amendments correct linguistic discrepancies found in the official Lithuanian translation of Council Directive (EU) 2023/2226 (DAC8) and establish a direct legal obligation to follow the OECD Crypto-Asset Reporting Framework (CARF) rules and official commentaries for interpretation and undefined terms.

The revised description formally segments crypto-asset users based on the onboarding timeline. Under sub-clauses 3.18 and 3.19, an "existing individual crypto-asset user" and an "existing entity crypto-asset user" are defined as persons or entities whose business relationship with the reporting provider was established prior to December 31, 2025. Relationships established on or after this date fall under new-user onboarding protocols. The definitions of reportable persons (clause 3.37) and reportable users (clause 3.40) have also been clarified to cover tax residents of both EU Member States and third-country jurisdictions.

Crypto-asset service providers (CASPs under MiCA Regulation (EU) 2023/1114) and crypto-asset operators registered in Lithuania must align their KYC and due diligence workflows with the revised terminology. Entities must maintain technical controls to confirm the reliability of client self-certifications, accurately record the inception of business relationships, and ensure information systems record all mandatory transaction and identity data fields specified in clause 27 of the Procedure.

Reporting crypto-asset operators must register with the VMI by May 31 of the calendar year following the reportable period. The initial reporting period covers the 2026 calendar year, establishing May 31, 2027, as the mandatory deadline for both initial operator registration and the first annual CARF/DAC8 data submission. Final XML/XSD file schemas and the list of participating non-EU partner jurisdictions under CARF will be released by the tax authority in subsequent technical specifications.