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Liechtenstein

Liechtenstein was the earliest EEA mover on MiCA, with the FMA (Financial Market Authority) as the competent authority for CASP authorisation; its EEA MiCA Implementation Act (EWR-MiCA-DG) entered into force on 1 February 2025, ahead of MiCAR's incorporation into the EEA Agreement on 24 June 2025, with the transition running to 1 July 2026. Its pioneering TVTG Blockchain Act now runs alongside MiCAR, continuing to govern NFTs and the civil-law aspects of tokens. Payments and e-money follow PSD2 and EMD2 via the EEA, supervised by the FMA, with DORA in force; gambling runs under the Gambling Act, supervised by the Office of Economic Affairs, with a moratorium on new casino permits and online-gambling concessions — and Liechtenstein uses the Swiss franc, levies no capital gains tax on private crypto, and applies a wealth tax instead.

Available licences

Crypto-Asset Service Provider authorisation (FMA under MiCAR via the EEA)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require FMA authorisation under Article 63 MiCAR; an authorisation passports across the EEA.

Asset-Referenced Token (ART) issuer authorisation (FMA)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR, supervised by the FMA.

E-Money Token (EMT) issuer (bank or EMI; FMA)

EMTs (including fiat-backed stablecoins) may be issued only by an authorised credit institution or e-money institution, with redemption at par; the FMA is the prudential supervisor.

Article 60 MiCAR notification route (existing financial entities)

Banks, investment firms, e-money and payment institutions and other authorised entities may provide specified crypto-asset services by notifying the FMA at least 40 working days before starting; Liechtenstein banks have used this simplified route.

TVTG TT-service-provider registration (FMA — non-MiCAR token services)

Registration under the Token and TT Service Provider Act for token-related activities outside MiCAR's scope, such as NFTs and the civil-law aspects of tokens (the Token Container Model); this registration does not, on its own, grant an EEA passport.

Payment Institution authorisation (FMA)

A licence to provide payment services under Liechtenstein's PSD2 implementation, supervised by the FMA and passportable across the EEA.

E-Money Institution authorisation (FMA)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital, supervised by the FMA.

Account Information and Payment Initiation Services (FMA)

Open-banking providers — account information and payment initiation service providers — fall within the payment-services framework, with strong customer authentication.

Banking authorisation (FMA)

Deposit-taking and lending require a banking licence from the FMA; because Liechtenstein is outside the banking union, there is no ECB/SSM role and the FMA is the sole banking supervisor.

Investment firm authorisation (FMA — MiFID II via the EEA)

Investment services in financial instruments (including security tokens) require FMA authorisation under the EEA-aligned MiFID II framework.

Casino permit (Office of Economic Affairs)

A permit to operate a land-based casino under the Gambling Act; new permits are currently suspended by moratorium, and online-gambling concessions are suspended to end-2028.

Detailed overview

Liechtenstein at a glance

Liechtenstein combines the world's first blockchain law, an early MiCA rollout and a wealth-tax model. Crypto is supervised by the FMA; the EWR-MiCA-DG came into force on 1 February 2025 and MiCAR was incorporated into the EEA Agreement on 24 June 2025. Payments follow PSD2 and EMD2 via the EEA, with the FMA as supervisor and DORA in force. Gambling runs under the Gambling Act, supervised by the Office of Economic Affairs, with moratoria in place. The Swiss franc is the currency, and Liechtenstein sits outside the euro area and banking union, so the FMA is the sole financial supervisor.

Crypto regime under MiCA — FMA-led, earliest EEA mover:

  • MiCA via the EEA — Regulation (EU) 2023/1114 (MiCAR) applies through the EEA Agreement; the domestic EWR-MiCA-DG entered into force on 1 February 2025, and MiCAR was incorporated into the EEA Agreement by the EEA Joint Committee on 24 June 2025
  • Competent authority — the FMA, with dedicated fintech and innovation bodies (an Office for Financial Centre Innovation and a regulatory laboratory); a pre-application supervision request (Unterstellungsanfrage) is available
  • Grandfathering — the transition runs to 1 July 2026 (aligned up to the MiCAR maximum from an earlier 12-month setting); TVTG-registered providers performing in-scope activities may continue until then, but EEA passporting requires a MiCAR authorisation
  • Pre-MiCA heritage — the Blockchain Act — the TVTG (in force 1 January 2020) was the world's first comprehensive, technology-neutral token law, with a Token Container Model giving a civil-law basis for ownership, transfer and enforcement of token rights
  • Dual regime — MiCAR supersedes the TVTG's CASP-related provisions, while the TVTG continues to apply outside MiCAR's scope (notably NFTs, which Article 2(3) MiCAR excludes, and the civil-law aspects of tokens that MiCAR does not regulate)
  • Market character — as at late 2025 no Liechtenstein-registered firm had yet obtained a MiCAR CASP authorisation while 29 held TVTG registrations; the first MiCAR CASP authorisations have since begun to be granted, and genuine local substance is non-negotiable
  • AML/CFT — the Due Diligence Act (Sorgfaltspflichtgesetz, SPG) applies, with the Financial Intelligence Unit; the EU AML package and AMLA in Frankfurt apply in the EU from 10 July 2027, with EEA incorporation to follow
  • TFR / DORA — the Travel Rule and DORA apply via the EEA Agreement; CARF crypto-tax reporting is committed
  • Tax — private individuals pay no capital gains tax on crypto (treated like other movable assets), but crypto held as private wealth is included in the wealth tax base at year-end value, integrated into income tax via a notional 4% return ("Sollertrag"); staking, mining and professional trading are taxed as income or business income, and crypto used as a means of payment is VAT-exempt within the Swiss VAT union. Companies pay a flat 12.5% income tax (minimum CHF 1,800), often effectively lower via a 4% notional-interest deduction on equity

Payments and e-money regime (FMA-led):

  • PSD2 / EMD2 via the EEA — transposed into Liechtenstein law and supervised by the FMA, which encourages pre-application dialogue (FMA Guidance 2019/8)
  • Payment Institution licensing — initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services), in CHF equivalents
  • E-Money Institution — EUR 350,000 initial capital; stablecoin (EMT) issuers must be EMIs or credit institutions
  • DORA (Regulation (EU) 2022/2554) — applies via the EEA Agreement
  • PSD3 / PSR — the EU package (political agreement November 2025, compromise texts April 2026, adoption expected during 2026) will repeal PSD2 and EMD2 and fold EMIs into payment institutions; EEA incorporation would follow
  • Banking — Liechtenstein is outside the banking union, so the FMA is the sole banking supervisor and there is no ECB/SSM role; the local banking sector is small, so banking access can be challenging
  • Currency: Swiss franc (CHF), the sole legal tender via the customs and currency union with Switzerland

Gambling regime — permit-based, under moratorium:

  • Gambling Act (Geldspielgesetz, GSG) — passed 2010 (in force 2011), revised in 2016 from a concession model to a permit (Bewilligung) model giving a legal entitlement where statutory criteria are met
  • Regulator — the Office of Economic Affairs (Amt fĂźr Volkswirtschaft), with the FMA as AML supervisor for casinos
  • Casino boom and moratorium — the permit model drew a wave of land-based casinos to the small principality; since 3 November 2022 a moratorium has suspended new casino permits (to end-2025), and a 2023 referendum rejected a proposed casino ban
  • Online moratorium — online-gambling concessions are suspended to 31 December 2028, so there is no lawful online offering; online provision requires a government concession (no legal entitlement)
  • Capital and player protection — a land-based casino requires CHF 5,000,000 minimum share capital plus an ongoing equity ratio; a central player-ban register and cross-border self-exclusion cooperation with Switzerland apply, and casino profits to the state are directed to charitable causes
  • Tax — a gaming levy (Geldspielabgabe) on gross gaming revenue, with an increase introduced from 2025
  • Minimum age — 18
  • No EU passport — gambling is national

Last verified: July 2026. Reference rate: EUR 1 ≈ CHF 0.94; USD 1 ≈ CHF 0.81.

Liechtenstein was the earliest EEA mover on MiCA, supervised by the FMA, with its pioneering TVTG "Blockchain Act" continuing alongside MiCAR for NFTs and token property law — no capital gains tax on private crypto, but a wealth tax, and a casino market under moratorium.

Is there a crypto licence in Liechtenstein?

Yes. Liechtenstein applies MiCAR through the EEA Agreement, with the FMA authorising and supervising CASPs. It was the earliest EEA mover (its implementation act took effect 1 February 2025), and the transition runs to 1 July 2026.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) — applied through the EEA Agreement (incorporated 24 June 2025)
  • EWR-MiCA-DG — the domestic implementing act, in force from 1 February 2025
  • TVTG (Blockchain Act, 2020) — the pre-MiCA token law, continuing outside MiCAR's scope
  • Due Diligence Act (SPG) and the TFR (via the EEA) — AML/CFT and the Travel Rule

Structure:

  • A Liechtenstein entity with genuine substance and fit-and-proper management
  • MiCAR own-funds floors by class — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) — with the higher of the floor or a fixed-overheads measure
  • AML systems, a white paper for in-scope offerings, custody and client-asset segregation, ICT and governance documentation, and a business plan — filed with the FMA via its e-Service portal

Operational reality:

  • The FMA is accessible and technically engaged, and a supervision request lets firms confirm the licence perimeter before applying
  • Firms should map every token and service against MiCAR versus the TVTG; NFTs and token property-law questions remain under the TVTG, while in-scope CASP activity needs a MiCAR authorisation to passport
  • New activity should be structured through an FMA authorisation, a valid EEA passport or an Article 60 notification

Official CASP roadmap: The FMA is the sole CASP authority; the EWR-MiCA-DG took effect on 1 February 2025, MiCAR was incorporated into the EEA Agreement on 24 June 2025, applications run through the FMA e-Service portal, and the transition runs to 1 July 2026. The TVTG continues for matters outside MiCAR (NFTs and token civil law).

Payments & E-money (FMA — PSD2 / EMD2 via the EEA)

Best for payment, remittance, acquiring, wallet and e-money operators wanting an EEA base outside the euro area, in the Swiss-franc zone.

What it is: Authorisation as a payment institution or e-money institution under Liechtenstein's PSD2 and EMD2 implementation (via the EEA Agreement), supervised by the FMA and passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers (including stablecoin issuers, who must be EMIs or credit institutions).

Covers: Payment services — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Liechtenstein entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management. The FMA encourages pre-application meetings.

Headline figures

  • Primary instruments: PSD2 and EMD2 via the EEA Agreement; DORA (Regulation (EU) 2022/2554)
  • Regulator: FMA (authorisation and supervision)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000 (CHF equivalents)
  • Banking: outside the banking union — the FMA is the sole banking supervisor, with no ECB/SSM role
  • Reform pipeline: the EU's PSD3 / PSR (adoption expected during 2026) would later be incorporated into the EEA Agreement
  • Currency: Swiss franc (CHF), via the currency union with Switzerland

Is there a gambling licence in Liechtenstein?

Partly. Land-based casinos operate under a permit model in the Gambling Act, but new casino permits are suspended by moratorium, and online-gambling concessions are suspended to end-2028.

The legal foundation:

  • Gambling Act (Geldspielgesetz, GSG) — the core statute, with casino, online and lottery/betting ordinances
  • Office of Economic Affairs (Amt fĂźr Volkswirtschaft) — licensing and enforcement; the FMA supervises casino AML
  • Moratoria — new casino permits suspended (since November 2022); online concessions suspended to 31 December 2028

Structure:

  • Land-based casinos run on a permit model with a legal entitlement where criteria are met — but new permits are currently suspended
  • Online provision requires a government concession, which is suspended by moratorium
  • A central player-ban register and Swiss cross-border self-exclusion apply

Gambling — Casino permit (Office of Economic Affairs)

Best for established land-based operators — though new permits are currently suspended and there is no lawful online route.

What it is: A permit to operate a land-based casino under the Gambling Act, granted by the Office of Economic Affairs.

Who it suits: Well-capitalised operators meeting strict integrity, capital and player-protection criteria — subject to the current moratorium on new permits.

Covers: Land-based casino gaming; online gambling is not lawfully offered while the concession moratorium runs to end-2028.

Operational requirement: CHF 5,000,000 minimum share capital plus an ongoing equity ratio, background checks, a social-protection concept, central player-ban participation and AML/CFT compliance.

Headline figures

  • Primary instruments: Gambling Act (Geldspielgesetz, GSG)
  • Regulator: Office of Economic Affairs (Amt fĂźr Volkswirtschaft); FMA for casino AML
  • Market structure: permit-based casinos under a moratorium on new permits; online concessions suspended to 31 December 2028
  • Tax: a gaming levy (Geldspielabgabe) on gross gaming revenue, increased from 2025
  • Other: minimum age 18; CHF 5,000,000 casino capital; Swiss cross-border self-exclusion

Costs and timelines at a glance

  • Crypto: MiCAR via the EEA Agreement, FMA as competent authority; own-funds floors EUR 50,000 / 125,000 / 150,000 by class; EWR-MiCA-DG in force 1 February 2025; transition to 1 July 2026; TVTG continues for NFTs and token civil law
  • Payments primary instruments: PSD2 and EMD2 via the EEA Agreement; DORA
  • Payments regulator: FMA (sole banking supervisor — no ECB/SSM, outside the banking union)
  • Reform pipeline: the EU's PSD3 / PSR (adoption expected 2026) would follow into the EEA
  • Gambling: permit-based casinos under moratorium; no lawful online offering (concessions suspended to end-2028)
  • Tax: no capital gains tax on private crypto, but a wealth tax applies; corporate income tax 12.5% (often effectively lower)
  • Currency: Swiss franc (CHF); outside the euro area and banking union
  • FX: EUR 1 ≈ CHF 0.94; USD 1 ≈ CHF 0.81

Who Liechtenstein suits and who it does not

Suitable for

  • Crypto exchanges, custodians and token issuers wanting an established, innovation-oriented EEA base with FMA authorisation and full EEA passporting
  • Projects with complex token structures that value the TVTG's civil-law token framework alongside MiCAR
  • NFT and token-property businesses needing the Token Container Model that MiCAR does not provide
  • Private crypto holders — there is no capital gains tax on private wealth (though a wealth tax applies)
  • Payment, e-money and wallet operators wanting a Swiss-franc, EEA base with a hands-on regulator

Not suitable for

  • Firms unable to establish genuine local substance — the FMA does not accept shell arrangements
  • Operators needing easy local banking — the domestic banking sector is small and access can be challenging
  • Cost-sensitive firms wanting a large financial ecosystem — bigger EEA hubs may offer faster standard CASP timelines
  • Online gambling operators — concessions are suspended to end-2028 and there is no lawful online route
  • New casino operators — the moratorium suspends new land-based permits

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