LIECHTENSTEIN Trends and Developments Contributed by: Christian Inmann and Markus Stelzl, Inmann Stelzl & Partner Attorneys at Law Partnership
Security tokens, which represent equity, debt or other tradable financial instruments, are still actively issued in Liechtenstein. These require adherence to existing securities laws (including prospectus requirements and licensing) when they qualify as financial instru - ments. Ongoing activity in this space demonstrates that Liechtenstein remains open to both traditional and emerging digital asset classes. The time of AI Artificial intelligence is becoming an increasingly important part of Liechtenstein’s financial services landscape. Over recent years, AI technologies have moved from experimental pilots to real operational tools across the fintech sector and traditional finan - cial industry alike. Across the financial industry, AI increasingly deter - mines operational efficiency, risk management qual - ity and customer satisfaction. Liechtenstein fintech providers and financial institutions are, in particular, actively integrating AI into areas such as data man - agement, compliance monitoring, transaction analy - sis, client onboarding, fraud detection and advisory support. Routine and repetitive processes are steadily migrating into the digital domain. This, in turn, allows highly regulated institutions to free up resources for complex advisory services, where human expertise, trust and proximity remain essential. Legal Developments The TVTG: foundation of Liechtenstein’s tokenisation framework The Token and TT Service Provider Act (TVTG), often referred to as Liechtenstein’s “Blockchain Act”, pro - vides one of the most advanced national frameworks for tokenised digital assets and services. It establishes legal certainty for token containers from a civil point of view, defines trusted technology systems (such as most blockchains) and requires service providers (for blockchain assets that fall outside the scope of MiCAR, such as NFTs) to comply with registration and ongoing supervision by the FMA. Importantly, the TVTG remains structurally relevant even after the adoption of supranational European frameworks like the Markets in Crypto-Assets Regula - tion. While MiCAR harmonises many aspects of cryp -
to-asset regimes at the EEA level, the TVTG continues to govern those areas which it does not cover, for instance, legal issues surrounding token ownership or transfer, enforcement of rights, or non-fungible tokens (NFTs) that fall outside MiCAR’s scope. Liechtenstein’s dual regime means that MiCAR and the TVTG operate alongside each other, with TVTG still playing an important role where EU law leaves space for national law. MiCAR: European harmonisation of crypto-asset regulation MiCAR represents Europe’s first comprehensive reg - ulatory framework for crypto-assets. It was formally incorporated into the EEA Agreement on 24 June 2025, at which point it became directly applicable in Liechtenstein under international law. MiCAR introduces harmonised rules governing the issuance, admission to trading and service provision for crypto-assets. It requires firms engaged in crypto- asset services to obtain authorisation and meet gov - ernance, capital and conduct requirements akin to other regulated financial services. The transition from the national framework of the TVTG to MiCAR is a significant operational change for firms that have been operating under Liechtenstein’s token regime. The FMA has already issued MiCAR-based authori - sations for crypto-asset service providers in Liech - tenstein, illustrating the implementation of this new regime in practice. DORA: operational resilience as a regulatory imperative The Digital Operational Resilience Act (DORA) was adopted as Regulation (EU) 2022/2554 and came into force in 2025. It establishes a cross-sectoral frame - work to manage and govern information and com - munication technology (ICT) risks across financial entities, including fintechs. DORA’s core objective is to ensure that digital operational disruptions, includ - ing cyber threats, do not undermine the stability of financial markets. DORA requires firms to implement robust ICT risk management, incident reporting, resilience testing
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