Payment Institution and E-Money Licences in Liechtenstein
The FMA grants the licence. We prepare and coordinate the file; a licensed Liechtenstein trustee or lawyer advises and files.
- Decided by: the FMA
- Applicant: an AG or SE seated in Liechtenstein
- Valid across the EEA once granted
A payment or e-money licence from the FMA, prepared with licensed partners
A payment institution licence allows payment services on a professional basis, and an e-money institution licence allows issuing e-money; the FMA grants both (ZDG Art. 7(1), EGG Art. 4). Through our financial licensing service we collect documents and prepare the file. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and files.
The page covers the payment institution, the e-money institution and the account-information route, which needs registration only. Crypto-asset services go through our CASP licensing service and funds through fund setup Liechtenstein. Providing payment services without FMA authorisation is a criminal offence, punishable by up to three years (ZDG Art. 109(1)(b)).
What's included
The applicant entity
An AG or SE with seat and head office in Liechtenstein, such as an Aktiengesellschaft with its seat in Liechtenstein. The licensed trustee forms and files it; we prepare the draft.
Route intake
We hand your business description to the licensed trustee or lawyer, who advises you on the payment tier, the e-money route or registration; you decide with them. We do not advise on the choice.
Board and management
We gather the roles and evidence for the licensed partner. The FMA approves each person before they take office.
The German application file
The application and the business plan, with the attachments from the FMA checklist, compiled with you; the licensed partner files the signed application, by qualified electronic signature or by hand and post.
Audit firm mandate declaration
Requested from an FMA-recognised audit firm, which declares that it accepts the audit mandate; the application must contain it.
After the decision
Start of business, agents, passport notices, the yearly audit and the AML duties are the licensed company's own; the licensed partner files the notices, and we coordinate the documents.
Who it is for
Businesses planning payment services
Money remittance, payment initiation or other payment services; each sits in its own capital tier.
Businesses planning to issue e-money
Issuing e-money professionally needs the e-money institution licence, subject to the reservations in EGG Art. 24, 26 and 30, with its own capital rule.
Firms seated outside the EEA
A firm seated outside the EEA that wants to offer payment services in Liechtenstein needs FMA authorisation, or registration if it provides account information services only (ZDG Art. 29, Art. 11).
Token or crypto-asset businesses
A different regime, with its own page and its own guide: our token issuance service and what the Liechtenstein token act requires from a crypto business.
Which licence fits: payment institution tiers, e-money institution, account information
Facts, not a recommendation: the licensed partner advises on the choice.
Payment and e-money routes in Liechtenstein: capital and conditions
| Route | Who it is for | Capital or condition | Notes |
|---|---|---|---|
| Payment institution, money remittance only | money transfer businesses | at least CHF 20 000 or the euro equivalent (ZDG Art. 10(2)(a)) | AG or SE only; capital unencumbered; valid across the EEA |
| Payment institution, payment initiation only | payment initiation providers | at least CHF 50 000 or the euro equivalent (Art. 10(2)(b)) | AG or SE only; also needs professional indemnity insurance or an equivalent guarantee (Art. 8(u)); valid across the EEA |
| Payment institution, all other payment services | providers of the other payment services | at least CHF 125 000 or the euro equivalent (Art. 10(2)(c)) | AG or SE only; valid across the EEA |
| E-money institution | issuers of e-money | at least EUR 350 000 or the CHF equivalent (EGG Art. 8) | AG or SE only; also covers the payment services of ZDG Art. 2(2)(a) to (h); valid across the EEA |
| Account information service | providers of account information only | registration with the FMA, no full licence (ZDG Art. 11) |
How the application runs
The FMA decides within three months of a complete application; no other period is promised.
Eight steps to a payment licence application
Settle the route
Who acts: You with the licensed partner
Optional informal pre-application
Who acts: LFT compiles
Form the AG or SE, capital paid in
Who acts: Licensed trustee
Board of three, one independent; management of two or more outside the board, 200 per cent in total; FMA approval
Who acts: You, the FMA
Audit firm mandate declaration
Who acts: Audit firm
File in German: application and business plan
Who acts: LFT coordinates
Signed application filed
Who acts: Licensed partner
FMA decision and register entry
Who acts: FMA
Every step names who acts; only statutory periods are given, none is a project time.
Settle the route
Payment tier, e-money or registration, decided by you with the licensed partner. Who: you and the partner.
Informal pre-application, if wanted
A draft file without original documents, checked by the FMA only for red flags on the main points; we compile the documents (FMA-WL 2019/8 section 3). Who: LFT, the partner.
Form the AG or SE
Capital paid in and freely available, for a payment institution also unencumbered. Whether a ready-made company suits you is for the adviser: see how a ready-made company in Liechtenstein changes hands; no licence comes with it. Who: the licensed trustee.
Board and management
A board of at least three with one independent member, and a management of at least two members with at least 200 per cent in total, who may not also sit on the board (ZDG Art. 9(1)(i)); the FMA approves each person first. Who: you, the FMA.
Audit firm
Engage an FMA-recognised audit firm and obtain its mandate declaration. Who: the audit firm.
The file in German
The application and the business plan in German; other documents in the original in German or in a certified German translation, and some in English after consulting the FMA (FMA-WL 2019/8 section 4.1). Who: LFT coordinates.
Filing
The licensed partner files the signed application with the checklist, by qualified electronic signature or by hand and post. The FMA fee is owed even if the licence is refused. Who: the partner.
Decision and after
The FMA decides and enters the licence in its register. Business starts within one year; agents and passport notices go through the FMA; the yearly audit begins. Who: the FMA, then you.
The statutory clocks
Application, months from filing
- 3 monthsFMA decision, from a complete file
- 12 monthsMissing documents: rejection after 12 months from receipt
After the licence, months
- 1 yearStart of business, within one year of the licence
Statutory periods, not a project time.
Want the eight steps scoped for your business?
Tell us which services you plan. We list what the licensed partner needs to settle the route.
Documents, requirements and official fees
What you supply; the FMA checklist in FMA-WL 2019/8 sets the exact attachments.
- Business model and programme of operations
- Three-year business plan, in German
- Governance, internal control and risk management
- Security and incident procedures
- Safeguarding measures and AML/CFT controls
- Ownership chart and qualifying holders
- Board and management members, with evidence
- Paid-in initial capital and the audit firm's mandate declaration
- For payment initiation, proof of professional indemnity insurance or an equivalent guarantee
The FMA's statutory fees and the duties that follow the licence are below. Our fee and the partner's are not shown.
FMA fees and the duties of a licensed institution (texts read in 2026)
| Item | What the law or the FMA sets | Source |
|---|---|---|
| FMA fee, payment institution licence | CHF 30 000, owed even when the licence is refused | FMAG Annex 1 Part A item 1(d) |
| FMA fee, e-money institution licence | CHF 30 000 | FMAG Annex 1 Part A item 1(c) |
| FMA fee, account information registration | CHF 15 000 | FMAG Annex 1 Part A item 4(a); FMA-WL 2019/8 section 5.2 |
| FMA fee, lapse of a payment or e-money institution licence | CHF 15 000 each | FMAG Annex 1 Part A item 3(c) and 3(d) |
| FMA fee, withdrawal of a payment or e-money institution licence (for a payment institution, for example no start of business within a year) | CHF 30 000 each | FMAG Annex 1 Part A item 2(c) and 2(d) |
| Own funds | payment institutions: never below the higher of the initial capital and the amount under ZDG Art. 19 (method A, B or C, fixed by the FMA); method A is 10 per cent of the previous year's fixed overheads | ZDG Art. 18(2), 19(1), 19(4) |
| Safeguarding of customer funds | received funds are safeguarded by one of two methods: kept apart and never mixed with other people's funds (method A), or covered by an insurance policy or comparable guarantee (method B); e-money institutions apply the same rules | ZDG Art. 20(1); EGG Art. 11(1) |
| Yearly audit | by an FMA-recognised audit firm | ZDG Art. 22(1) |
| AML duties | the due diligence act and Regulation (EU) 2023/1113 stay applicable | ZDG Art. 2(6) |
| Start of business | within one year of the licence, otherwise the FMA withdraws it | ZDG Art. 14(1)(a); FMA-WL 2019/8 section 6 |
Problems we solve
CHF 20 000 is not the whole story
It is the tier for money remittance alone. Payment initiation alone needs CHF 50 000, other services CHF 125 000, and own funds can exceed the initial capital.
Running it from abroad
Seat and head office in Liechtenstein, a board of at least three with one independent member, a management of at least two members with 200 per cent in total who do not sit on the board, each approved first. We collect the evidence; we promise no nominee arrangement.
The file must be in German
The application and the business plan, in German; other documents in the original in German or a certified German translation, some in English after consulting the FMA. We coordinate the translations.
How long will it take?
The three-month clock starts only with a complete file. No project time and no processing time beyond the statute is stated.
Ready to scope your payment licence file?
Send us your business description and planned services. We set out the next steps; pricing on request.
Why work with us
Corinne Sele, our tax, accounting and licensing lead, prepares the file. We collect and prepare; a licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and files; the FMA decides.
Payment and e-money licences in Liechtenstein: questions
Can a GmbH or an Anstalt hold a payment institution licence?
A payment institution is an AG or SE with its seat and head office in Liechtenstein; an e-money institution licence also goes to an AG or SE (ZDG Art. 9(1); EGG Art. 7(1)(a)). EGG Art. 30 exempts small domestic e-money issuers from the licence; they notify the FMA instead. The licensed trustee or lawyer advises which fits.
Why does the application have to be in German?
Only the application and the business plan must be in German. Other documents go in the original in German or in a certified German translation; some may be filed in English after consulting the FMA (FMA-WL 2019/8 section 4.1). The FMA guidance accepts a hand signature and a posted original instead of the qualified electronic signature. LFT coordinates the translations.
Is CHF 20 000 enough to start a payment institution?
Only for money remittance alone. Payment initiation alone needs CHF 50 000 and all other payment services CHF 125 000, each or the euro equivalent. The capital must be freely available and unencumbered. Own funds stay at or above the higher of that capital and the ZDG Art. 19 amount (method A: 10 per cent of last year's fixed overheads).
Do I need both a payment institution and an e-money licence?
Issuing e-money professionally needs the e-money institution licence (EGG Art. 4), subject to the reservations in EGG Art. 24, 26 and 30. That licence also covers the payment services in ZDG Art. 2(2), so an issuer needs no second licence for them. The licensed adviser chooses the route.
Can I run the company from abroad, without a local board?
The seat and head office must be in Liechtenstein. The board has at least three members, one of them independent, and the management has at least two members, outside the board, with at least 200 per cent in total. The FMA approves each person first. LFT collects the evidence; who may serve is for the licensed adviser.
What minimum capital applies to an e-money institution?
At least EUR 350 000, or the equivalent in Swiss francs, and it is also the permanent minimum equity (EGG Art. 8). That is higher than the payment institution tiers of CHF 20 000, CHF 50 000 and CHF 125 000. The capital must be fully paid in and freely available in Liechtenstein (EGG Art. 7(1)(g), 8(1)).
How long does the FMA take to decide?
The FMA decides within three months of a complete application, and the same three months apply to an e-money institution. If the applicant has not delivered everything within twelve months of receipt, the FMA rejects the application. These are the main statutory periods; no project time is promised.
Does the licence cover the EU, or only the EEA?
The licence is valid in all EEA states, which is wider than the EU. To serve clients in another EEA state you first give the FMA a written notice, and the FMA forwards the details to the host-state authority within one month. The e-money institution licence is likewise valid EEA-wide.
What is the difference between a payment institution and an e-money institution?
A payment institution provides payment services under the ZDG; an e-money institution issues e-money under the EGG. Both are an AG or SE with an independent board member and a separate management. Capital differs: EUR 350 000 for e-money, CHF 20 000, 50 000 or 125 000 for payment tiers. Each carries an FMA fee of CHF 30 000.
Which services need a licence, and which are excluded?
A licence is needed to provide payment services on a professional basis in Liechtenstein (ZDG Art. 7). The exclusions from the act sit in ZDG Art. 3, and this page does not list them. Account information needs registration only. Whether your activity falls inside the licence is for the licensed adviser.
What does the licensed partner do, and what does LFT do?
LFT prepares, collects and coordinates the file. Advice on the application is a trustee activity (TrHG Art. 2) and legal advice is reserved to lawyers (RAG Art. 8). A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and files, and the FMA decides.
What does the FMA charge, and is the fee owed if the application is refused?
The FMA fee for a payment institution licence is CHF 30 000 and is owed even if the licence is refused. An e-money institution licence costs CHF 30 000 and an account-information registration CHF 15 000. The lapse of a licence carries CHF 15 000 each. These are FMA charges under the FMAG.
Does an account-information provider need a full licence?
No. A provider of account information services only needs registration with the FMA, not a full licence. The FMA fee for the registration is CHF 15 000, as set in the FMA guidance. Whether the registration route fits your business is for the licensed adviser to confirm.
Take the next step
Call the Wealth Management department on +423 210 0004, Monday to Friday 09:00-17:30 (CET/CEST), or write to info@foundation-liechtenstein.com.