Token Issuance in Liechtenstein under TVTG and MiCA
Your token's regime decides the document and who may issue it. We collect the facts and coordinate; a licensed trustee or lawyer classifies and files.
- Two regimes: MiCAR white paper or TVTG Basisinformationen
- Advice and filing: a licensed trustee or lawyer
- TVTG registrations for MiCAR activities expired 2 July 2026
Token issuance in Liechtenstein, prepared with licensed partners
A token offer in Liechtenstein falls under MiCAR or, if the token is outside MiCAR, under the TVTG, and the two regimes have mutually exclusive scopes. A token that is a MiFID II financial instrument is classified first and is outside MiCAR. As part of which financial services need a licence from the FMA in Liechtenstein, we collect your token facts and coordinate the file. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, classifies the token, drafts and files.
This page covers the public offer of a token by its issuer. Trading a token or holding it for others is a separate authorisation, set out under related services below. Which document you need follows from the route table further down.
What's included
Token facts and routing
We collect what the token is, who may acquire it, its rights and the planned size, and hand them to the licensed partner, who classifies it.
MiCAR white paper
For an other crypto-asset, the licensed partner drafts the white paper and transmits it to the FMA. The issuer answers for it as offeror.
TVTG Basisinformationen
For a token outside MiCAR, the licensed partner prepares the Basisinformationen and the notification of the issuance to the FMA.
Asset-referenced token path
The licensed partner prepares the file for a credit institution or an authorisation holder. The e-money token path is not offered.
The issuing entity
Where you want a Liechtenstein legal person as issuer, the licensed trustee forms and registers it; we prepare the draft.
After the issue
Supplements, disclosure and the annual levies where they apply. Liability for the Basisinformationen cannot be excluded or limited in advance.
The project name
If the token's name matters to you, ask about a mark filed through a licensed Liechtenstein representative before the launch.
Who it is for
Founders and companies
Planning a public token offer and wanting a prepared file before the licensed partner drafts and files.
Advisers
Whose client plans a token issue and needs the classification and filing done by a licensed partner.
Issuers for clients
Liechtenstein entities that would issue tokens for a client and need to know whether a registration applies.
Holding the issuer or the proceeds
If a family's foundation, trust or family office would hold the issuer, start with the foundation that holds a family's wealth from Vaduz and ask the licensed adviser.
Which route applies to your token
The Token and TT Service Provider Act and what it regulates has its own guide; the routes are below.
Token classes and the route that applies in Liechtenstein
| Token class | What applies | Who can use it | Source |
|---|---|---|---|
| Other crypto-asset | MiCAR white paper; offered without authorisation if the requirements of Art. 4 et seq. MiCAR are met | the issuer as offeror | FMA MiCAR page |
| Asset-referenced token (ART) | Art. 21 authorisation | a licensed credit institution or an Art. 21 holder | FMA MiCAR page, FMAG |
| E-money token (EMT) | reserved to licensed institutions | licensed credit or e-money institutions only; LFT does not offer this path | FMA MiCAR page |
| Token outside MiCAR | TVTG Basisinformationen and notification to the FMA; registration only if issuing for a client | own-name issuers and issuers acting for a client | TVTG Art. 30 ff., Art. 12 |
| Security token | a MiFID II financial instrument, outside MiCAR | a licensed lawyer confirms the rules that apply | FMA MiCAR page, RAG Art. 8 |
From the TVTG to MiCAR in Liechtenstein
Months from 1 February 2025
- 1 Feb 2025EWR-MiCA-DG in force; MiCAR and TVTG scopes exclusive
- 31 Dec 2025LGBl. 2025 Nr. 596 in force
- 1 and 2 Jul 2026MiCAR transition ended; TVTG registrations lapsed for MiCAR-authorisable activities
How the offer is prepared
Two clocks are fixed in our sources: three months for a registration decision and six months without a decision before an ART appeal. Other periods are not stated in our sources.
Eight steps of a token issue
Collect the token facts
Who acts: Client with LFT
Classify the token, MiFID II first
Who acts: Licensed trustee or lawyer
Issuing entity, if wanted
Who acts: Licensed trustee; draft by LFT
Route A, other crypto-asset: white paper to the FMA
Who acts: Licensed partner; issuer answers
Route B, ART: application and ART white paper
Who acts: Licensed partner prepares, issuer applies, FMA decides
Term: six months with no decision: appeal possible
Route C, outside MiCAR: basic information published, issuance notified
Who acts: Licensed partner
Registration, only if issuing for a client
Term: three months from a complete application
After the issue: supplements, disclosure, levies
Who acts: Issuer
Steps 4 to 6 are alternative routes; the licensed adviser picks one.
Collect the token facts
You and we gather the rights, the holders, the planned size, the VT system and who answers for its function. Period not stated in our sources.
Classify the token
The licensed trustee or lawyer checks first whether it is a MiFID II financial instrument, then which regime applies. Period not stated in our sources.
Set up the issuing entity
If you want a Liechtenstein legal person, the licensed trustee forms it and we prepare the draft. Period not stated in our sources.
Other crypto-asset
The licensed partner drafts the white paper and transmits it to the FMA; the issuer answers for it. Period not stated in our sources.
Asset-referenced token
The licensed partner prepares the Art. 16 and 21 application and the ART white paper; the issuer applies and the FMA decides. If the FMA has not decided a complete application within six months of receipt, an appeal to the FMA-Beschwerdekommission (FMA appeals commission) is possible (EWR-MiCA-DG Art. 24(2)).
Outside MiCAR
The Basisinformationen is published in German or English, and the issuance is notified to the FMA before the issue. Period not stated in our sources.
Registration, only if issuing for a client
The FMA decides a complete application within three months; no service before the entry. An own-name issuer needs none, but Art. 30 to 38 apply.
After the issue
A supplement for important new circumstances, ten years' disclosure for registered issuers, and levies where they apply.
Not sure which route fits your token?
Send us a short token description. We list what the licensed partner needs to classify it.
Documents and official charges
What you supply for the licensed partner:
- Token description: what it represents, rights, eligible buyers, planned value
- The issuer's identity, corporate documents and beneficial owners
- Documents for the issuing entity, if seated in Liechtenstein
- Who answers for the token's function, and the VT system
- For tokens representing things: proof of ownership, such as via a physical validator
- The declaration of the persons responsible for the document that, to the best of their knowledge, the information is correct and no material information is omitted
The FMA's statutory charges are below. Our fee and the partner's are not shown.
FMA charges and statutory requirements for a token issue
| Item | What the law or the FMA sets | Source |
|---|---|---|
| White paper transmission | CHF 500 | FMAG Annex |
| White paper approval or refusal, with the Art. 17 examination | CHF 20 000 | FMAG Annex |
| Amended white paper | CHF 5 000 | FMAG Annex |
| Art. 16(2) check | CHF 2 500 | FMAG Annex |
| ART authorisation under Art. 21 | CHF 30 000, expert costs extra | FMAG Annex |
| ART issuer levy | CHF 20 000 a year plus 0.1 % of the value received in the issue, capped at CHF 100 000 | FMAG Annex |
| Token issuer basic levy | CHF 500 a year for registered issuers; none stated for an own-name issuer | FMAG Annex |
| Minimum capital of a registered token issuer | lowest tier CHF 50 000, up to CHF 5 million issued per calendar year | TVTG |
| Disclosure of the Basisinformationen | during the issue and at least ten years afterwards, for registered issuers | TVTG Art. 17(1) |
Problems we solve
"Is a token launch just paperwork?"
No. Offering without meeting the MiCAR conditions is a criminal offence under the EWR-MiCA-DG, up to three years. The licensed partner settles the route first.
"Small offers are exempt"
Under 150 users or up to CHF 5 million, only the Art. 30 lit. a and b TVTG duties fall away. The notification stays; a breach is fined up to CHF 100 000.
"I need a registration and CHF 50 000 capital"
Not as an own-name issuer. Registration and the capital tier concern an issuer acting for a client; the licensed partner confirms which applies to you.
"Can we issue a stablecoin-type token?"
An asset-referenced token is reserved to licensed credit institutions or Art. 21 holders, an e-money token to licensed institutions. We route the facts accordingly.
Breaches and penalty ceilings for token offers in Liechtenstein
| Breach | What the law sets | Source |
|---|---|---|
| Offer of other crypto-assets without MiCAR Art. 4(1) or 5(1) | up to three years' imprisonment, before the Landgericht | EWR-MiCA-DG |
| ART offer without Art. 16(1) or 17(1), EMT offer without Art. 48(1) | up to three years' imprisonment, before the Landgericht | EWR-MiCA-DG |
| White-paper duty breach, ordinary FMA fine | up to CHF 1 000 000 for legal persons, CHF 500 000 for natural persons | EWR-MiCA-DG |
| Serious, repeated or systematic breach | legal persons up to CHF 4 900 000, 3 % of annual turnover (12.5 % for ART issuers) or twice the benefit; natural persons CHF 700 000 or twice the benefit | EWR-MiCA-DG |
| Breach of Art. 30 ff. TVTG | up to CHF 100 000 | TVTG |
Ready to scope your token issue?
Send us the token's rights and planned size. We set out the next steps; pricing on request.
Why work with us
Corinne Sele, our tax, accounting and licensing lead, coordinates the file. We collect the token facts and coordinate; a licensed Liechtenstein trustee or lawyer, named in your engagement letter, classifies, drafts and files; the FMA supervises.
Token issuance in Liechtenstein: questions
Do I need a licence to issue a token in Liechtenstein?
It depends on the token. Other crypto-assets are offered under a MiCAR white paper, not under a licence, if the conditions are met. An asset-referenced token needs an Art. 21 authorisation or a licensed credit institution. Tokens outside MiCAR fall under the TVTG, where registration concerns an issuer acting for a client. The licensed adviser classifies the token first.
Is a white paper approved by the FMA, or only notified?
The FMAG fee annex lists both a transmission of the white paper (CHF 500) and an approval or refusal (CHF 20 000, with the Art. 17 examination), and the FMA may require an amendment. How the FMA treats an other-crypto-asset white paper in practice is not stated in our sources, so the licensed adviser confirms the route.
Is it true that small offers (under 150 people or CHF 5 million) need nothing at all?
No. For a token outside MiCAR, an offer to fewer than 150 users or with a total sale price up to CHF 5 million drops only the Basisinformationen duties of Art. 30 lit. a and b. The notification to the FMA stays, and a breach of Art. 30 ff. is fined up to CHF 100 000.
Can I issue a token in my own name without registering with the FMA?
Yes, for a token outside MiCAR. An issuer offering in its own name is not subject to registration, but Art. 30 to 38 TVTG still apply. Registration, with the CHF 50 000 lowest capital tier, concerns an issuer acting for a client; the FMA decides a complete application within three months.
What happens if I offer a token to the public without a white paper?
It can be a criminal offence. Offering other crypto-assets to the public without meeting MiCAR Art. 4(1) or 5(1) is punishable by up to three years' imprisonment before the Landgericht. The same applies to asset-referenced tokens without Art. 16(1) or 17(1) and e-money tokens without Art. 48(1). The FMA can also fine white-paper breaches.
What is the difference between the MiCA white paper and the TVTG Basisinformationen?
They are different documents for different tokens. The MiCAR white paper applies to crypto-assets inside MiCAR and is transmitted to the FMA. The TVTG Basisinformationen applies to tokens outside MiCAR; it is published and the issuance is notified to the FMA. MiCAR and the TVTG have mutually exclusive scopes.
Which tokens still fall under the TVTG after MiCA?
Tokens that are outside MiCAR. The TVTG defines token issuance only for such tokens, and its scope has been exclusive of MiCAR's since 1 February 2025. TVTG registrations lapsed on 2 July 2026 for activities that need a MiCAR authorisation. The licensed adviser decides on the facts which regime fits a given token.
Can an NFT be issued under the TVTG?
The FMA says only that non-fungible tokens, which MiCAR Art. 2(3) excludes from its scope, could fall within the TVTG. There is no general rule: it depends on the facts of the token. The licensed trustee or lawyer gives the verdict for a given token, and the Basisinformationen duties follow from that answer.
Who can offer an asset-referenced token or an e-money token?
An asset-referenced token may be offered only by a licensed credit institution or a person holding an Art. 21 authorisation. An e-money token is reserved to licensed credit or e-money institutions, and LFT does not offer that path. For an asset-referenced token, LFT collects the facts and the licensed trustee or lawyer files the application.
Who is liable to buyers for errors in the white paper or Basisinformationen?
For the Basisinformationen, liability cannot be excluded or limited in advance (Art. 35(3) TVTG), and acquirer claims against an issuer seated in Liechtenstein go to the Landgericht. Liability for a MiCAR white paper is not stated in our sources, so the licensed trustee or lawyer sets out the position for your token before the offer.
Is a security token or tokenised share an ICO or a prospectus case?
A token that is a MiFID II financial instrument is outside MiCAR, and that question is settled first. The securities rules that apply instead, including any prospectus duty, are confirmed by a licensed lawyer, not by LFT. LFT collects the facts about the token and passes them to the licensed lawyer.
Does issuing a token also allow me to trade or custody it?
No. Issuing a token does not allow trading or custody for others. For crypto-assets inside MiCAR, those are services that need a separate CASP authorisation, and TVTG registrations for such activities lapsed on 2 July 2026. For tokens outside MiCAR, custody stays a TVTG registration (Art. 2(1)(n), Art. 12). The CASP page is linked under related services.
In which language must the white paper or the Basisinformationen be written?
The Basisinformationen must be written and published in German or English (Art. 32(4) TVTG). The language rule for the MiCAR white paper is not stated in our sources, so the licensed trustee or lawyer confirms it before drafting begins and the issuer plans the translation work accordingly.
Do I need a Liechtenstein company to be the issuer?
The route decides. Where you want a Liechtenstein legal person as issuer, a licensed Liechtenstein trustee forms and registers it while LFT prepares the draft. Whether another issuer fits your token is for the licensed adviser to confirm. FMA registration concerns an issuer acting for a client, not one offering in its own name.
How long do I have to keep the document disclosed?
For a registered token issuer, the Basisinformationen must stay disclosed during the issue and for at least ten years afterwards (Art. 17(1) TVTG). Anyone issuing in their own name should have the licensed adviser confirm which disclosure period applies to them. Supplements are added for important new circumstances.
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.