LIECHTENSTEIN Trends and Developments Contributed by: Christian Inmann and Markus Stelzl, Inmann Stelzl & Partner Attorneys at Law Partnership
and oversight of critical third-party providers. Under DORA, technology choices, such as cloud arrange - ments, become subjects of regulatory scrutiny, emphasising governance and continuity planning rather than merely technical compliance. This aligns closely with supervisory expectations in Liechtenstein, where the FMA already emphasises operational soundness and risk governance as part of ongoing supervision, reflecting DORA’s broader regulatory direction. PSD3: modernising the payments regime The Third Payment Services Directive (PSD3) will replace the current PSD2 framework and is intended to strengthen consumer protection, enhance security and ensure fair competition among payment service providers (PSPs) across the EEA. In late 2025, nego - tiators for the European Parliament and the Coun - cil reached a provisional agreement on PSD3 and its companion Payment Services Regulation (PSR), encompassing fraud prevention, supervisory powers and competitive access for non-bank PSPs. PSD3 aims to address shortcomings identified under PSD2, including cybersecurity challenges, uneven implementation across jurisdictions and the evolving nature of digital payment services. Among other ele - ments, this modernisation effort seeks to harmonise strong customer authentication requirements and balance competitive conditions between banks and non-bank providers. Though the directive is still being finalised and will require transposition into EEA member state law, its direction is clear: payments regulation is moving toward more consistent, secure and competition- friendly frameworks across the EEA. The EU Listing Act The EU Listing Act is a reform package of the Europe - an Union designed to make access to capital markets easier and more attractive for companies. Its main objective is to simplify listing and capital-raising pro - cesses, especially for small and medium-sized enter - prises (SMEs), by reducing administrative burdens, streamlining disclosure requirements, and lowering costs. At the same time, it aims to maintain investor
protection and strengthen the competitiveness of EU capital markets. Together with the above changes, prospectus regula - tion has been amended significantly by the EU List - ing Act. The amendments include new regulations for exceptions from the prospectus obligation, more standardisation of format and content for prospec - tuses, ESG-related content being obligatory under certain circumstances, and new rules for EU follow- on prospectus and EU growth prospectus. This new regulation is, in particular, important for issu - ers of security tokens, which may be advantaged by the new rules. Digital Services Act (DSA): horizontal regulation with broad reach The Digital Services Act (DSA, Regulation (EU) 2022/2065) establishes a comprehensive legal frame - work for digital services operating within the European internal market. It applies broadly to online interme - diary services and platforms that make information, goods or services available to end users, with gradu - ated obligations based on the type and size of the service. While primarily designed to regulate digital content, platform governance and intermediary responsibility, the DSA has practical implications for certain fintech business models, in particular those that operate online platforms or facilitate interactions between mul - tiple user groups (eg, marketplaces or crowdfunding platforms). Obligations under the DSA encompass transparency, risk mitigation and co-operation with supervisory authorities, and are proportionate to the size, reach and potential risks associated with the pro - vider’s services. From a compliance perspective, the DSA reinforces the need for an integrated approach that encompass - es financial compliance, digital governance and user protection, reflecting the European regulatory shift toward holistic oversight. The AI Act and regulation of data-driven finance The EU’s Artificial Intelligence Act (the “AI Act”) estab - lishes the first comprehensive legal framework for the
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