RESEARCH: Source "FMA Liechtenstein — Blockchain Act" content changed at https://www.fma-li.li/en/su

# RESEARCH: Liechtenstein Blockchain Act

Executive Summary

Crypto is legal in Liechtenstein, regulated under the Token and TT Service Provider Act (TVTG) 2019 and now incorporated into EU MiCA via EEA law. The Financial Market Authority (FMA) issues CASP authorisations, granting passporting rights across the full EEA (30 jurisdictions). In 2026, the FMA has issued licences to a handful of entities, reflecting practical market access for crypto-asset service providers. The practical reality is favourable for regulated operators due to established banking infrastructure and institutional credibility, though licensing involves substantial capital requirements (EUR 150k for trading platforms) and thorough AML/KYC obligations.

Regulatory Framework

Regulatory Bodies:

• Financial Market Authority (FMA Liechtenstein), https://www.fma-li.li

Primary Laws:

• Token and TT Service Provider Act (TVTG), enacted 2019, establishes licensing for crypto‑asset service providers.
• EWR‑MiCA‑DG (EEA MiCA Implementing Decree), effective 2026, incorporates MiCA into Liechtenstein law.

International Standing:

• Member of the European Economic Area (EEA) but not the EU; participates in FATF/Moneyval standards through EEA alignment.

Licensing Requirements

Who Needs a License: Providers of crypto‑asset services such as custody, exchange, trading platforms, and portfolio management. Activities Requiring Licensing: Custody, exchange, trading platform operation, transfer services, brokerage, portfolio management. Capital Requirements (EUR):

• Trading platform: Minimum EUR 150,000.
• Other categories: EUR 50,000 minimum. Application Process & Timeline: Pre‑application consultation with FMA → submission of detailed documentation → review (~3–6 months). No specific public timeline disclosed beyond typical EU/EEA processing periods. Structural Requirements: Must operate as a legal entity in Liechtenstein, maintain adequate risk management systems, and comply with AML/KYC obligations. Licensed Entities (as of 2026): A limited number have been granted CASP authorisation; exact names not publicly disclosed beyond FMA announcements.

AML/KYC Requirements

• CDD & EDD: Customer due diligence for all clients; enhanced due diligence for high‑risk categories.
• STR Reporting: Suspicious transaction reporting to FMA within 5 days of detection.
• Record Retention: Minimum 5 years of KYC and transaction records.
• Beneficial Ownership: Disclosure of beneficial ownership information as per EEA regulations.
• PEP Screening: Mandatory screening against PEP/adverse media lists.

Enforcement Actions

No specific enforcement actions reported for Liechtenstein’s crypto licensing regime in the provided sources. Regulatory focus remains on compliance and supervisory oversight rather than punitive measures.

Tax Treatment

Liechtenstein has not issued explicit tax guidance on virtual asset gains as of 2026. Income from crypto activities is taxed under general income tax rules, but specific treatment for capital gains or VAT on crypto transactions remains undefined.

Key Gaps & Risks

• Implementation Gaps: While MiCA is incorporated, practical guidance on certain MiCA provisions (e.g., stablecoin issuance) may lag.
• Regulatory Uncertainty: The evolving nature of global crypto regulation could introduce compliance challenges post‑MiCA alignment.
• Operational Risk: High capital thresholds and rigorous AML/KYC requirements may limit market entry for smaller operators.

Sources

• Liechtenstein - Franchising & Licensing [Brill]

• MiCA License in Liechtenstein 2026: CASP Authorisation, FMA... [LinkedIn]

• Atomic Safety and Licensing Board Panel annual report, Fiscal year 1992 [OSTI]

• The New Environmental Licensing Framework After the Veto Override: Regulatory Rationality, Institutional Capacity, and Systemic Adjustments [SSRN]

• Licensing 2.0 – Licensing Platforms for the Knowledge Economy [SSRN]

• Liechtenstein - Franchising & Licensing [Brill]

• Should a Licensing Market Require Licensing? [OSF]

• Content Licensing (Media for licensing) [Elsevier ScienceDirect]

• Compare - Panoramic - Lexology Lexology

• Claim: Crypto is legal in Liechtenstein, regulated under the Token and TT Service Provider Act (TVTG) 2019 and now incorporated into EU MiCA via EEA law. Liechtenstein - Franchising & Licensing

• Claim: The Financial Market Authority (FMA) issues CASP authorisations, granting passporting rights across the full EEA (30 jurisdictions). MiCA License in Liechtenstein 2026: CASP Authorisation, FMA...

• Claim: Minimum capital requirement for a trading platform is EUR 150,000. MiCA License in Liechtenstein 2026: CASP Authorisation, FMA...

• Claim: AML/KYC obligations include customer due diligence, enhanced due diligence for high‑risk clients, and beneficial ownership disclosure. MiCA License in Liechtenstein 2026: CASP Authorisation, FMA...

• Claim: No explicit tax guidance on crypto gains has been issued by Liechtenstein as of 2026. Compare - Panoramic - Lexology