Liechtenstein is a particularly crypto-friendly jurisdiction in Europe: as early as 2020, Liechtenstein enacted comprehensive regulation of the token economy with the TVTG aka "Blockchain Act", thereby creating legal certainty. The country in the heart of Europe is home to a vibrant crypto scene: more than 28 companies are now registered for a total of almost 60 service provider roles. These include 4 major crypto exchanges. MiCAR provides for transitional provisions and simplifications for service providers registered under national laws. Exchanges that are registered in Liechtenstein under the Blockchain Act by the end of 2024 can benefit from this.

The MiCAR Regulation is intended to end the existing patchwork and ensure maximum harmonisation in the crypto sector: as an EU regulation, MiCAR is binding for all member states and applies directly in all EU member states to all crypto assets that do not fall within the scope of the existing EU financial regulations. The central aim of this regulation is to create legal certainty throughout Europe. The regulation is also intended to control the financial risk posed by crypto assets (e.g. risk to market integrity and financial stability). Innovation and further development are also to be promoted. MiCAR will have a major impact on the European crypto sector as a whole and beyond.

In order to maintain its pioneering role in the crypto sector, the government has submitted a proposal to amend the TVTG at an early stage in preparation for MiCAR: The aim is to integrate certain MiCAR-CASP service providers into the TVTG before it becomes applicable in the EU and to create legal certainty in the transition from the Blockchain Act to MiCAR. In this respect, the introduction of a new service provider role for lending and staking is also envisaged. Liechtenstein thus offers added legal certainty and more than just MiCAR.

1. When does MiCAR apply in Liechtenstein?

The MiCAR regulations on value-referenced tokens and e-money tokens have been in force in the EU since June 2024. The regulations for all other crypto assets will come into force from December 2024.

In the EEA area, and therefore also in Liechtenstein, the regulation is expected to be adopted at the end of February or beginning of March 2025. From this date, MiCAR will apply in full in Liechtenstein, allowing the country to further consolidate its role as a leading location for crypto service providers.

There are transitional provisions for service providers who currently have a TVTG registration as a TT service provider. You can continue to carry out your registered activity until 31 December 2025. However, as with all national laws within the EU, cross-border provision of the service is not possible as there is no provision for a "passporting" mechanism. This corresponds to the general principle that national regulations do not permit an EU-wide passporting approach and is therefore not a specific feature of Liechtenstein as a business location. In order to benefit from the advantages of passporting a MiCAR licence, service providers must therefore apply to the Liechtenstein Financial Market Authority ("FMA") for a MiCAR licence from 1 January 2026. The FMA published an application template for MiCAR pre-applications in October 2024. The aim is to speed up the authorisation process for crypto asset service providers (CASP) and facilitate processing

It should be noted that MiCAR and TVTG will apply in parallel in future, but with different scopes of application. NFTs are therefore exclusively subject to the TVTG, as they are exempt from its provisions in accordance with Art. 2 para. 3 MiCAR. Depending on their business model, service providers may have to hold licences for both legal acts.

2. What advantages does Liechtenstein offer?

In addition to the regulatory provisions, the Blockchain Act also contains civil law provisions, particularly with regard to tokens, the representation of rights by tokens and their transfer: In Liechtenstein, classic property rights, including those to physically indivisible objects of value and to fungible objects, can be made digitally divisible and transferable into any number of token units by means of tokenisation. This creates legal certainty and new opportunities for commercialisation and the creation of liquidity.

In addition to its EEA access, Liechtenstein also has open access to the Swiss market thanks to its integration into the Swiss franc currency area with customs union. A remarkable blockchain ecosystem has developed in Liechtenstein in recent years. Liechtenstein's government and authorities are open to innovation and new technologies. Together, they are in constant dialogue with market participants. In order to promote the competitiveness and future viability of the financial centre, the government of the Principality has set up the Financial Centre Innovation and Digitalisation Unit: it supports financial service providers and financial market-related companies in their private innovation process. The Liechtenstein Financial Market Authority has also opened up to the token economy with the creation of the "Regulatory Laboratory".

3. how you should act now

If you are aiming for a MiCAR licence, we recommend that you take a close look at the licensing requirements now, as the application process is complex. We will be happy to support you with individual advice and help you find the ideal route to a MiCAR licence.

We will be happy to provide you with an initial consultation to plan the next steps together. With our expertise and prepared documents, we simplify the application process and provide you with reliable support on the way to MiCAR authorisation.

Please feel free to contact us in person, by phone or by e-mail.

We will gladly assist you by phone, email, or in person.