LIECHTENSTEIN Law and Practice Contributed by: Alexander Ospelt, Lukas-Florian Gilhofer, Vivianne Auer and Laura Bayer, Ospelt & Partner Attorneys at Law Ltd
such as policies to cover computer and network hack- ing risks, data or identity theft or loss of reputation. That said, Liechtenstein insurance products still show substantial room for development in this area. 12. Developments in Insurance Law 12.1 Significant Legislative or Regulatory Developments The Liechtenstein FMA has made Value for Money (VfM) a core supervisory priority for insurers, embed- ding it into its Product Oversight and Governance (POG) framework. Products with weak customer val- ue, excessive costs, or unfair commission structures will face increased scrutiny and possible intervention. A new POG Guidance (FMA-M 2025/3), effective from 2026, will align Liechtenstein practice with European standards and place strong emphasis on customer benefit, target market definition, cost-benefit balance, and ongoing product monitoring, particularly for unit- linked life insurance.
Insurers must demonstrate transparent pricing, pro- portionate costs, justified commissions, robust prod- uct testing, scenario analysis, and lifecycle monitor- ing, including handling of cancellations, conflicts of interest, and distributor incentives. The FMA expects proactive internal VfM assessments, data-driven monitoring of customer outcomes, and effective, proportionate governance rather than purely formal compliance. For insurers operating in Liechtenstein, this means deeper integration of VfM and POG into governance, customer-centric product design, continuous perfor- mance monitoring, and timely corrective action where products fail to deliver fair value.
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