LIECHTENSTEIN Law and Practice Contributed by: Christian Inmann and Markus Stelzl, Inmann Stelzl & Partner Attorneys at Law Partnership
1. Fintech Market 1.1 Evolution of the Fintech Market
Looking ahead, the fintech market in Liechtenstein will be shaped primarily by: • ongoing MiCAR operational compliance and super - visory expectations; • enhanced AML and digital operational resilience requirements under DORA; • rising compliance costs and potential market con - solidation; and • continued demand for specialised legal, compli - ance and IT expertise. Artificial intelligence is increasingly being considered in Liechtenstein’s fintech sector, particularly for AML automation, transaction monitoring and customer onboarding. However, adoption remains cautious, as many fintechs are currently prioritising MiCAR and DORA compliance. Once the regulatory framework has stabilised, broader use of AI in fintech products and services is expected to accelerate. From a legal perspective, key consid - erations will include the AI Act, data protection, model governance and regulatory accountability, all within the existing EU-aligned legal framework. Liechtenstein’s fintech ecosystem is shaped by its role as an EEA financial centre with a strong focus on digi - tal assets, infrastructure services and regulated finan - cial intermediation (such as banks, asset management companies, insurance companies or crypto-asset exchanges). Further, Liechtenstein is well-known for its crypto-foundations, which are used both for DAOs The most prominent fintech business models in Liechtenstein remain crypto-asset services and token-based business models. This includes token issuances, trading platforms, custody solutions and wallet services. The TVTG has historically provided legal certainty for tokenised rights, while MiCAR now governs large parts of this sector from a regulatory as well as for asset protection. Crypto-Assets and Tokenisation 2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
Over the past 12 months, Liechtenstein has further strengthened its position as an attractive EEA jurisdic - tion for fintechs and crypto-asset service providers. Liechtenstein continues to benefit from its early adop - tion of a national blockchain regulation, the Token and Trusted Technology Service Provider Act (TVTG), which provides legal certainty for token-based busi - ness models and complements EU-level regulation (Markets in Crypto-Assets Regulation – MiCAR). Due to the experience with this first-mover piece of leg - islation, fintechs continue to be advantaged by the early regulatory experience of the local regulator, in particular with DLT/blockchain business models. The entry into force of MiCAR and DORA has been the key driver of market development. These frame - works have increased legal clarity and encouraged institutional participation, while at the same time rais - ing regulatory and operational standards. Despite high compliance requirements, Liechtenstein remains appealing to international fintechs seeking EEA pass - porting under a predictable and pragmatic supervisory environment, as it may also be used as a bridge to Switzerland due to its customs and monetary union. The primary focus over the past year has shifted from regulatory assessment to practical implementation of MiCAR and DORA. Regulatory scrutiny in Liechten - stein has intensified, particularly with regard to AML/ CFT compliance, governance structures and cyber - security. Smaller fintechs are increasingly required to adapt decentralised or innovation-driven business models to stricter organisational, reporting, digital operational resilience and risk management requirements. While this presents challenges, it also contributes to the ongoing professionalisation and institutionalisation of the fintech market in Liechtenstein. This has favoured the entrance of established players into the Liechten - stein market, in particular financial institutions with a focus on digital assets.
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