MiCA CASP Authorisation in Liechtenstein
A CASP licence is a MiCAR authorisation granted by the FMA. We collect your documents and coordinate the application; a licensed trustee or lawyer advises and submits.
- Decided by: the FMA
- TVTG registrations for MiCAR services expired 2 July 2026
- Advice on the application: a licensed trustee or lawyer
A CASP authorisation from the FMA, prepared with licensed partners
A CASP licence in Liechtenstein is an authorisation under Art. 63 MiCAR, granted by the FMA; a TVTG registration no longer covers these services. LFF Heritage Trusts collects your documents and coordinates the work. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and submits a licence application prepared for the Financial Market Authority.
This page covers crypto-asset services only. Investment funds follow a different regime, with their own page.
What's included
Route intake
We collect your business description and hand it to the licensed trustee or lawyer, who settles with you whether Art. 63 or Art. 60 applies.
Crypto exchange models
The FMA's list of services names a trading platform and two exchange services. The adviser maps your model and classifies the tokens.
Documents for the FMA
Group chart, financials, origin of funds, business model and management CVs, gathered for the questionnaire and the informal discussion.
The applicant entity
A licensed trustee forms and registers it; we prepare the draft. For the AG route, see forming an AG with a qualified board member.
The application file
We coordinate the file with the licensed adviser, including optional legal questions to the FMA. LFT never submits as agent.
After authorisation
We coordinate around the audit firm, notices, the annual report and AML duties. The MiCA institute carries those duties itself.
Who it is for
New crypto-asset businesses
Firms planning a new Art. 63 application to provide crypto-asset services from Liechtenstein.
Entities the FMA already licenses
Banks, investment firms, e-money institutions and fund managers considering an Art. 60 notification.
Founders and their advisers
Teams who want a prepared file before the FMA's informal preliminary discussion.
Looking for an exchange to use?
This page is for businesses seeking authorisation. The FMA points to the ESMA register for authorised providers.
Which route applies: Art. 63 authorisation, Art. 60 notification or TVTG
Three routes, three groups of users. The licensed adviser settles which one is yours.
The three routes for crypto-asset businesses in Liechtenstein
| Route | Who can use it | What the law or the FMA sets | Example or source |
|---|---|---|---|
| Art. 63 MiCAR authorisation | New entrants: a legal person or other undertaking in Liechtenstein | Authorisation by the FMA, possibly with conditions; passporting once held | Bitcoin Suisse (Europe) AG, 22 June 2026 (FMA news); Sygnum Europe AG, 26 June 2026 |
| Art. 60 MiCAR notification | Credit institutions, CSDs, investment firms, e-money institutions, UCITS management companies, AIFMs, market operators | Notification to the FMA; no crypto-asset services while it is incomplete | ZEUS Anstalt für Vermögensverwaltung, portfolio management under Art. 60(3), 1 December 2025 |
| TVTG registration | VT services outside MiCA only | Registration before the first service; for MiCAR activities expired 2 July 2026 | TVTG Art. 12(1); FMA news on the end of the transition |
Source: EWR-MiCA-DG; FMA MiCAR page and news; TVTG.
MiCA in Liechtenstein, June 2024 to July 2026
Months from June 2024
- June 2024FMA informal discussions begin
- 1 Feb 2025EWR-MiCA-DG in force
- 1 Dec 2025ZEUS Anstalt
- 1 Jan 2026Amendment in force
- 22 Jun 2026Bitcoin Suisse (Europe) AG
- 26 Jun 2026Sygnum Europe AG
- 1 Jul 2026Transition ends
- 2 Jul 2026TVTG registrations for MiCAR activities expire
From the first FMA discussions to the end of the transition
How the application runs
The FMA publishes no day count for its decision. We promise no period.
Eight steps of a CASP application
Settle the route
Who acts: Client, with a licensed adviser
Optional legal questions to the FMA
Answers are not binding
Who acts: Adviser drafts
Questionnaire and informal discussion
Who acts: Client and FMA; LFT coordinates
Set up the entity
Who acts: Licensed trustee; LFT prepares the draft
Submit the application
Who acts: Licensed trustee or lawyer
FMA decision
Appeal possible after six months without a decision
Who acts: FMA
Audit firm and ongoing duties
Who acts: MiCA institute
Passporting
After authorisation
Who acts: Licensed entity
Settle the route
You and the licensed adviser decide between Art. 63 and Art. 60 and, for an exchange model, which listed services apply and how the tokens are classified.
Optional legal questions
The adviser drafts questions to the FMA with an analysis and a reasoned conclusion. The FMA's answers at this stage are not binding.
Questionnaire and discussion
New parties answer the FMA questionnaire, then meet the FMA informally. The FMA then supplies the application documents.
Set up the entity
A licensed trustee forms and registers the Liechtenstein entity; we prepare the draft. Whether the detailed ready-made companies page offers a fit is for your adviser.
Submit
The licensed trustee or lawyer submits the application or notification. We coordinate the documents only.
FMA decision
A complete application undecided after six months can be appealed to the FMA Complaints Commission, then within 14 days to the Administrative Court.
Audit firm and duties
The FMA approves the audit firm before business starts. Then come notices, the annual report, the yearly audit and AML duties.
Passporting
Services in other EEA states, only once the authorisation is held.
Not sure which route fits your business?
Send us a short description of the business. We set out the route question, the documents and who acts.
Documents, official fees and duties after authorisation
What you supply for the FMA's questionnaire. The FMA names the exact application documents after the discussion.
- Group chart with shares and voting rights
- Annual financial statements and evidence of financial soundness
- Origin of the funds for capital and operations
- CVs of the planned management
- Business model: services, clients, outsourcing, ICT
- Planned substance and headcount in Liechtenstein
- Other EEA states approached or planned
- A business description for the route question
The fees below are the FMA's statutory charges. Adviser, trustee and entity costs are separate.
FMA fees and duties of an authorised CASP in Liechtenstein
| Item | What the law or the FMA sets | Source |
|---|---|---|
| Authorisation fee, at least one service under Art. 3(1)(16)(a)-(d) MiCAR | CHF 30,000 | FMAG Annex 1, 2026 |
| Authorisation fee, services under (e)-(j) only | CHF 10,000 | FMAG Annex 1, 2026 |
| Annual supervisory levy, base | CHF 50,000 with a service under (a)-(d); CHF 8,000 for (e)-(j) only | FMAG Annex 2 section N.1, 2026 |
| Levy add-on and cap | 0.1% of the prior year's net turnover; whole levy at most CHF 250,000 a year | FMAG Annex 2 section N.2, N.6 |
| Audit firm | Approved by the FMA before business starts; also for Art. 60 notifiers | EWR-MiCA-DG |
| Notices | Prior notice of a change of seat or address and of outsourcing important tasks | EWR-MiCA-DG Art. 6(2)(b), (c) |
| Annual report and audit | Report to the FMA within four months after year-end; yearly audit by an FMA-recognised firm | EWR-MiCA-DG |
| AML duties | Obliged entity under the SPG; Travel Rule; risk of self-hosted addresses; risk-based history checks | SPG Art. 3(1)(r), 9b(2a), 12, 12a |
| Administrative fines | Up to CHF 1,000,000 for legal persons; higher for serious, repeated or systematic breaches | EWR-MiCA-DG Art. 31 |
| Conciliation body | Customer disputes may go to the financial services conciliation body | EWR-MiCA-DG |
Source: FMAG Annex 1 and 2 (2026 text); EWR-MiCA-DG; SPG. The FMA can charge further costs, expert costs included.
Problems we solve
"Our TVTG registration covers us"
Not for MiCAR services: those registrations expired on 2 July 2026. TVTG still covers VT services outside MiCA; see the blockchain act guide.
Who may advise on the application
Financial advice is a trustee activity (TrHG Art. 2(c)); legal advice is reserved to lawyers (RAG Art. 8). LFT coordinates; the licensed adviser advises.
Duties that start after the licence
Audit firm, annual report within four months, AML checks and the Travel Rule. The licensed adviser plans these into the file from the start; we coordinate.
Which service is an exchange
The FMA separates a trading platform from exchange for funds and for other crypto-assets. MiFID II instruments sit outside MiCAR; the adviser classifies.
"The FMA takes too long"
The FMA publishes no day count and asks for complete, high-quality applications. The six months are an appeal trigger, not a processing time.
Ready to scope your CASP application?
One plan: the route, the documents, the FMA's fees and who acts. Pricing on request.
Why work with us
Corinne Sele, our tax, accounting and licensing lead in Vaduz, keeps the file on one desk. We collect the documents and coordinate; a licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and submits; the FMA decides.
Frequently asked questions
Can LFT obtain the CASP licence for me, or do I need a licensed trustee or lawyer?
LFT collects documents and coordinates the application. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and submits it; the FMA decides. Financial and business advice is a trustee activity (TrHG Art. 2(c)), and legal advice and representation are reserved to lawyers (RAG Art. 8).
What does the FMA ask about approaching other EEA states?
The FMA questionnaire asks whether other EEA states have been approached or will be. Answer as the facts stand on the day you file. Whether to approach another state, and in what order, is a strategy question for your licensed adviser, not for LFT.
Does the FMA take too long, and can I rely on a fixed timeline?
The FMA publishes no day count for its decision and says complete, high-quality applications are essential. If a complete application is not decided within six months of receipt, an appeal is open (EWR-MiCA-DG Art. 24(2)). That is an appeal trigger, not a processing time. We promise no period.
Is a TVTG registration still enough for crypto-asset services?
Not for MiCAR services. The transition period ended on 1 July 2026, and TVTG registrations for activities that need MiCAR authorisation expired on 2 July 2026 (FMA). MiCAR and TVTG do not overlap in scope; the TVTG still covers VT services outside MiCA, such as some NFTs.
What happens if I start trading before the authorisation?
Providing crypto-asset services without authorisation is a criminal offence, punishable by up to three years' imprisonment (EWR-MiCA-DG Art. 26(e)). An entity using the Art. 60 route may not provide crypto-asset services while its notification is incomplete. Neither LFT nor the partner runs services for you before authorisation.
Is a CASP licence the same as a MiCA licence or a VASP licence?
A "MiCA institute" (EWR-MiCA-DG Art. 2(1)(a)) is an undertaking authorised under Art. 63 MiCAR to offer crypto-asset services, or under Art. 21 MiCAR in respect of asset-referenced tokens. The CASP licence is the Art. 63 authorisation. The Liechtenstein TVTG term is VT service provider.
What does the FMA officially charge for a CASP authorisation?
CHF 30,000 with at least one service under Art. 3(1)(16)(a)-(d) MiCAR, CHF 10,000 for (e)-(j) only (FMAG Annex 1, 2026). The yearly levy base is CHF 50,000 or CHF 8,000, plus 0.1% of the prior year's net turnover, capped at CHF 250,000. Adviser costs are separate.
Which services can a CASP authorisation cover, and is a crypto exchange a separate licence?
The FMA lists ten services: custody, a trading platform, exchange for funds, exchange for other crypto-assets, order execution, placing, reception and transmission, advice, portfolio management and transfers. An exchange model is one or more of these, in the same regime. Fit and token classification are for your adviser.
Who in Liechtenstein is already authorised under MiCAR?
FMA news names Bitcoin Suisse (Europe) AG, authorised under Art. 63 on 22 June 2026, and Sygnum Europe AG on 26 June 2026. ZEUS Anstalt für Vermögensverwaltung was authorised on 1 December 2025 under Art. 60(3), the notification route. For the full list, the FMA points to the ESMA register.
Do I need real substance and staff in Liechtenstein?
The FMA questionnaire asks for your planned substance in Liechtenstein and the expected number of employees after the licence. We found no CASP-specific staff minimum. The board rule is PGR Art. 180a(1)-(3); your licensed adviser confirms whether the exception in para. 3 applies and which licences count as equal to a Trustee Act licence.
What is the difference between an Art. 63 authorisation and an Art. 60 notification?
Art. 63 is the authorisation for new entrants. Art. 60 is a notification open to entities the FMA already licenses: credit institutions, central securities depositories, investment firms, e-money institutions, UCITS management companies, AIFMs and market operators. The FMA also calls an Art. 60 notifier an authorised CASP.
Can I offer services in other EEA states once I am authorised?
Yes, through passporting, and only once the CASP authorisation has been obtained; not before. The FMA describes the passport as available to authorised CASPs. How and where to use it, and what the host state asks for, is a question for your licensed adviser before you start.
What duties apply after the authorisation, including AML?
The FMA approves the audit firm before business starts. Then: prior notice of a seat or address change and of outsourcing, an annual report within four months, a yearly audit by an FMA-recognised firm, and SPG duties including the Travel Rule and self-hosted address checks. Serious breaches can lead to withdrawal.
Can I appeal if the FMA refuses or does not decide?
Yes. An FMA decision can be appealed to the FMA Complaints Commission within 14 days of service. A complete application undecided after six months can be appealed too (EWR-MiCA-DG Art. 24). From there, 14 days to the Administrative Court. A licensed lawyer may represent you.
Take the next step
Tell us the services you plan. We return a CASP application plan with the route question and who acts.