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Liechtenstein

Retail_Trading_Status

Allowed-Regulated High Confidence
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Analysis ID
#712
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Created
2025-12-12 04:44
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Executive Summary

Retail cryptocurrency trading is fully legal and regulated in Liechtenstein under a comprehensive dual framework comprising the national 'Blockchain Act' (TVTG) and the EU's Markets in Crypto-Assets Regulation (MiCA). The Financial Market Authority (FMA) actively supervises the sector, requiring service providers to register and comply with strict AML/KYC standards. While MiCA governs most crypto-asset services as of 2025, the TVTG remains in force for civil law aspects and assets outside MiCA's scope, such as NFTs.

Key Pillars

Financial Market Authority (FMA) Liechtenstein (Primary Regulator)
Token and TT Service Provider Act (TVTG) for civil law and non-MiCA assets
EEA MiCA Implementation Act (EWR-MiCA-DG) for harmonized EU crypto services
Due Diligence Act (SPG) for AML/CFT compliance
Mandatory registration/licensing for TT Service Providers (exchanges, custodians)

Landmark Laws

Token and TT Service Provider Act (TVTG) (TVTG) - Enacted: 2020-01-01
- Also known as the 'Blockchain Act,' this pioneering law created a comprehensive civil law framework for tokens ('Token Container Model') and established registration requirements for 'Trustworthy Technology' (TT) service providers.
- Source

EEA MiCA Implementation Act (EWR-MiCA-DG) - Enacted: 2025-02-01
- Implements the EU Markets in Crypto-Assets Regulation (MiCA) into national law, establishing the authorization regime for Crypto-Asset Service Providers (CASPs) and issuers of asset-referenced tokens.
- Source

Due Diligence Act (SPG) - Enacted: 2008-12-11
- Applies strict anti-money laundering (AML) and counter-terrorist financing (CFT) obligations to crypto service providers, requiring customer identification (KYC) and transaction monitoring.
- Source

Considerations

Dual regulatory regime: MiCA covers standard crypto services, while TVTG covers NFTs and civil law token rights.
Transitional period: Entities registered under TVTG have until December 31, 2025, to obtain full MiCA authorization.
Taxation: Crypto is generally treated as foreign currency; capital gains are tax-free for private investors (wealth tax applies).
Government acceptance: Bitcoin and Ether are accepted for payment of certain government fees.
Strict AML enforcement: All VASPs/CASPs must comply with FATF travel rule standards.

Notes

Liechtenstein's 'Token Container Model' is unique because it separates the 'token' (the container) from the 'right' (the asset inside), allowing for the tokenization of virtually any right, not just financial instruments. This provides a legal basis for token ownership that many other jurisdictions lack.

Remaining Uncertainties

  • Specifics of the final transition for all TVTG-registered entities to MiCA licenses before the Dec 31, 2025 deadline.
  • Future interaction between TVTG civil law definitions and potential new EU-level definitions for NFTs.

Detailed Explanation

Retail cryptocurrency trading is fully legal and regulated in Liechtenstein. The country operates under a sophisticated dual regulatory framework that combines its pioneering national legislation with harmonized European Union rules. The primary national law is the Token and TT Service Provider Act (TVTG), also known as the 'Blockchain Act,' which came into force on January 1, 2020. This law established a comprehensive civil law framework for tokens, notably the unique 'Token Container Model,' and created a registration regime for 'Trustworthy Technology' (TT) service providers like exchanges and custodians. This national framework is now complemented by the EEA MiCA Implementation Act (EWR-MiCA-DG), enacted on February 1, 2025, which transposes the EU's Markets in Crypto-Assets Regulation (MiCA) into Liechtenstein law, establishing an authorization system for Crypto-Asset Service Providers (CASPs). The Financial Market Authority (FMA) Liechtenstein serves as the primary regulator, actively supervising the sector and enforcing compliance. All service providers must register or obtain a license and adhere to strict anti-money laundering and counter-terrorist financing obligations under the Due Diligence Act (SPG), which mandates customer identification (KYC) and transaction monitoring, including compliance with FATF travel rule standards. A transitional period is in effect until December 31, 2025, during which entities registered under the TVTG must obtain full MiCA authorization. Notably, the TVTG remains in force for civil law aspects and for assets outside MiCA's scope, such as NFTs, creating a layered regulatory approach. There are no bans on retail trading, and the government even accepts Bitcoin and Ether for payment of certain fees. For taxation, cryptocurrencies are generally treated as foreign currency, with capital gains being tax-free for private investors, though a wealth tax may apply.

Summary Points

I. Regulatory Status
* Retail cryptocurrency trading is fully legal and regulated.
* Operates under a dual regulatory regime: the national TVTG (Blockchain Act) and the EU's MiCA framework.
* No bans on retail trading or ownership.

II. Key Regulatory Bodies
* Financial Market Authority (FMA) Liechtenstein: The primary regulator supervising the sector, responsible for registration, licensing, and enforcement.

III. Important Legislation
* Token and TT Service Provider Act (TVTG) (Blockchain Act): Enacted January 1, 2020.
* Creates a civil law framework for tokens (the 'Token Container Model').
* Establishes registration requirements for 'Trustworthy Technology' (TT) service providers (e.g., exchanges, custodians).
* Remains in force for civil law aspects and assets outside MiCA's scope, such as NFTs.
* EEA MiCA Implementation Act (EWR-MiCA-DG): Enacted February 1, 2025.
* Implements the EU's Markets in Crypto-Assets Regulation (MiCA) into national law.
* Establishes the authorization regime for Crypto-Asset Service Providers (CASPs) and issuers of asset-referenced tokens.
* Due Diligence Act (SPG): Enacted December 11, 2008.
* Applies strict anti-money laundering (AML) and counter-terrorist financing (CFT) obligations to crypto service providers.
* Mandates customer identification (KYC) and transaction monitoring.

IV. Compliance Requirements
* Mandatory registration or licensing for all service providers (TT Service Providers under TVTG, CASPs under MiCA).
* Strict adherence to AML/CFT rules under the SPG, including FATF travel rule compliance.
* Entities registered under the TVTG have a transitional period until December 31, 2025 to obtain full MiCA authorization.
* Service providers must comply with ongoing supervisory requirements set by the FMA.

V. Notable Restrictions or Limitations
* No major restrictions on retail trading. The regulatory focus is on ensuring provider compliance and consumer protection.

VI. Recent Developments or Notes
* The 'Token Container Model' under the TVTG is a unique legal innovation that separates the token (container) from the underlying right (asset), enabling the tokenization of virtually any right.
* Bitcoin and Ether are accepted for payment of certain government fees.
* For taxation, crypto is generally treated as foreign currency; capital gains are tax-free for private investors, though wealth tax applies to holdings.
* The country is implementing a layered approach where MiCA governs most standard crypto-asset services, while the TVTG covers NFTs and provides the foundational civil law token rights.

Full Analysis Report

Liechtenstein is one of the most advanced and crypto-friendly jurisdictions globally, having established a clear legal framework early on with the 'Token and TT Service Provider Act' (TVTG), widely known as the Blockchain Act, which entered into force on January 1, 2020. This legislation provided legal certainty by defining tokens as 'containers' of rights and establishing a registration regime for 'Trustworthy Technology' (TT) service providers, including exchanges and custodians. The Financial Market Authority (FMA) serves as the primary regulator, maintaining a public register of these entities and enforcing strict compliance with the Due Diligence Act (SPG) for anti-money laundering (AML) purposes.

As a member of the European Economic Area (EEA), Liechtenstein has integrated the EU's Markets in Crypto-Assets Regulation (MiCA). The 'EEA MiCA Implementation Act' (EWR-MiCA-DG) came into force on February 1, 2025, aligning local rules with the harmonized EU framework. This created a dual regime: MiCA governs standard crypto-asset services (CASPs), asset-referenced tokens (ARTs), and e-money tokens (EMTs), while the TVTG continues to regulate areas outside MiCA's scope, such as non-fungible tokens (NFTs) and the fundamental civil law aspects of token ownership and transfer. A transitional period allows TVTG-registered entities to operate while seeking full MiCA authorization by the end of 2025.

For retail investors, the environment is highly favorable. Trading and holding cryptocurrencies are fully legal. From a tax perspective, cryptocurrencies are generally treated as foreign currencies. For private individuals, capital gains from crypto trading are typically tax-exempt, provided the activity does not qualify as professional trading. However, crypto holdings are subject to wealth tax, which is calculated based on the asset's value at the end of the tax year. The government itself demonstrates strong support for the sector, accepting Bitcoin and Ether for the payment of certain government services and fees.

Operational risks are low due to the mature regulatory environment. Banks in Liechtenstein are generally open to crypto-related business, unlike in many other jurisdictions where 'de-banking' is a risk. The FMA is proactive in supervision, and the clear distinction between the roles of token issuers, generators, and custodians under the TVTG/MiCA framework provides high levels of consumer protection. The requirement for all service providers to be registered (and now licensed under MiCA) ensures that retail users interact with compliant entities that adhere to robust KYC and AML standards.

Source Evidence

Primary and secondary sources cited in this analysis

2025-02-01

"The necessary implementation into Liechtenstein law is carried out through the Law implementing Regulation (EU) 2023/1114 on Markets in Crypto-Assets (EEA MiCA Implementation Act, EWR-MiCA-DG), which entered into force on 1 February 2025."

2024-01-01

"The Law on Tokens and TT Service Providers (in short TVTG or the Blockchain-Act) provides a comprehensive and technology-neutral approach to regulating the entire token economy."

2024-12-01

"Persons with a registered office or residence in Liechtenstein who wish to provide TT services in Liechtenstein on a professional basis in principle require registration with the FMA."

"As an EEA Member State, Liechtenstein implemented MiCAR domestically through the EEA MiCA Implementation Act... effective since February 2025."

"The Token and TT Service Provider Act (TVTG) represents a significant stride in Liechtenstein's regulatory landscape... ensuring robust consumer protection and financial stability."

Web Sources (3)

Sources discovered via web search grounding

Search queries used (5)
  • Liechtenstein crypto tax laws for individuals
  • Liechtenstein TVTG Act summary and current status
  • Liechtenstein MiCA implementation status
  • FMA Liechtenstein register of TT service providers
  • Liechtenstein cryptocurrency regulation retail trading status 2024 2025
globallegalinsights.com

https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/liechtenstein/

blackmanta.capital

https://blackmanta.capital/liechtensteins-blockchain-act/

finance.li

https://finance.li/en/news/liechtenstein-has-the-clearest-crypto-tax-regulations/

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