MiCA CASP Authorisation in Liechtenstein

A CASP license in Liechtenstein, route by route: authorisation or notification, the FMA's 2026 fees and the dates that matter. We prepare the file; a licensed trustee or lawyer advises and files.

  • FMA decides the authorisation
  • Transition ended 1 July 2026
  • Licensed trustee or lawyer named in your engagement letter
A town in an Alpine valley below the mountains

CASP authorisation in Liechtenstein with a licensed partner

Liechtenstein applies MiCA through the EWR-MiCA-DG, in force since 1 February 2025, and the FMA is the competent authority. The transition period ended on 1 July 2026, so crypto-asset services now need an Art. 63 authorisation or an Art. 60 notification. For the wider picture, see which financial services need a licence from the FMA in Liechtenstein.

Advice on the application is reserved: licensed trustees under the Trustee Act (TrHG) and lawyers under the RAG give it. We collect your business description and documents, prepare the data sheet and coordinate the file. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises, forms the entity and submits.

What is included

Five deliverables, each naming the party that acts. We never advise on the route and never file as your agent.

A woman in a beige jacket looking through papers in a folder
The CASP file is a set of real documents.

Route intake

We collect your business description and hand it to the licensed adviser, who settles with you whether the case is an Art. 63 application or an Art. 60 notification.

Questionnaire and discussion pack

We gather what the FMA questionnaire and the informal preliminary discussion ask for: group chart, origin of funds, business model, outsourcing and ICT, management CVs.

The applicant entity

The authorised party is a legal person or other undertaking in Liechtenstein, for example an Aktiengesellschaft with its seat in Vaduz. The licensed trustee forms it; we prepare the draft.

The application file

We coordinate the documents with the licensed trustee or lawyer, who prepares and submits the file and puts any legal questions to the FMA beforehand.

After the decision

We coordinate around the audit firm the FMA approves before business starts, and around the notices, the annual report and the AML duties the MiCA institute carries.

How the route runs

The FMA publishes no day count for these steps. Each one names who acts, and the appeal periods are the periods the sources state.

The CASP route in Liechtenstein

  1. Settle the route, Art. 63 or Art. 60

    Who acts: Client with licensed adviser; VCS collects

  2. Optional legal questions to the FMA

    Answers not binding

    Who acts: Licensed adviser

  3. FMA questionnaire and informal preliminary discussion

    Who acts: Client, VCS, FMA

  4. Applicant entity formed

    Who acts: Licensed trustee; VCS drafts

  5. Submission

    Who acts: Licensed trustee or lawyer

  6. FMA decision

    Appeal within 14 days, also after six months without a decision on a complete application

    Who acts: FMA; client

  7. Audit firm approved before business starts, then ongoing duties

    Who acts: MiCA institute

  8. Passporting once authorised

    Who acts: MiCA institute

Under steps 1 to 6: no FMA day count published.

Eight steps and who owns each. The FMA publishes no day count.
  1. Settle the route

    Art. 63 application or Art. 60 notification. For an exchange model, the licensed adviser settles which listed services it amounts to; we collect the business description.

  2. Optional questions to the FMA

    The licensed adviser may put legal questions to the FMA before filing, with analysis and a reasoned conclusion. The answers are not legally binding.

  3. Questionnaire and preliminary discussion

    New applicants answer the FMA questionnaire, then hold the informal preliminary discussion. The FMA then supplies the documents for the application or notification.

  4. Set up the applicant entity

    The licensed trustee forms and registers the legal person, by public deed where the law requires it; we prepare the draft. Whether a shelf company Liechtenstein suits your plan is for your adviser.

  5. Submit

    The licensed trustee or lawyer submits the application or notification for you. We coordinate the documents only and never file as your agent.

  6. FMA decision

    Appeal to the FMA-Beschwerdekommission within 14 days of service, or once a complete application is undecided after six months; then 14 days to the Verwaltungsgerichtshof.

  7. Audit firm and ongoing duties

    The FMA approves the audit firm before business starts. Then come the notices, an annual report within four months of the year end, a yearly audit, AML duties and the Travel Rule under the SPG amendment.

  8. Passporting

    Passporting to other EEA states is possible only once the authorisation is held, as the FMA's MiCAR page states.

Not sure which route applies to your plan?

Send us your business description. A person in our Legal department replies, and the licensed adviser settles the route with you.

Authorisation or notification

Two routes lead to the same supervisor. Payment and e-money work follows its own regime, see our payment licensing service; fund managers use our fund structuring service.

Art. 63 authorisation and Art. 60 notification compared

The two MiCA routes in Liechtenstein, criteria only.

criterionArt. 63 authorisationArt. 60 notification
Who it is forA legal person or other undertaking in Liechtenstein that wants to offer crypto-asset services as a MiCA instituteFinancial entities the FMA already licenses: credit institutions, central securities depositories, investment firms, e-money institutions, UCITS management companies, AIFMs, market operators
Legal basisEWR-MiCA-DG with MiCAR Art. 63EWR-MiCA-DG with MiCAR Art. 60
Who decidesThe FMAThe FMA
ResultAuthorisation as a MiCA institute; this is what "CASP licence" meansThe notifier is a CASP but holds no Art. 63 authorisation; no services while the notification is incomplete
Examples named by the FMABitcoin Suisse (Europe) AG, 22 June 2026; Sygnum Europe AG, 26 June 2026ZEUS Anstalt für Vermögensverwaltung, portfolio management under Art. 60(3), 1 December 2025

Sources: EWR-MiCA-DG, FMA, crypto-asset service providers. Authorisation examples from FMA news.

Documents and official FMA fees

The FMA names a high-level list before the preliminary discussion; the exact application documents follow after it.

  • 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 infrastructure
  • Planned substance and headcount in Liechtenstein
  • Other EEA states approached, now or planned

Official FMA fees for a CASP file

FMA fees under the Financial Market Authority Act, 2026 text. VCS and partner fees are on request.

itemamountbasis
Authorisation with at least one service under Art. 3(1)(16)(a) to (d) MiCAR: custody, trading platform, the two exchange servicesCHF 30,000FMAG Annex 1 to Art. 30, 2026
Authorisation limited to services under Art. 3(1)(16)(e) to (j) MiCAR: the other six listed servicesCHF 10,000FMAG Annex 1 to Art. 30, 2026
TVTG registration, a separate regime and not the MiCA routeCHF 3,500FMAG Annex 1 to Art. 30, 2026
Further costs of the procedure, expert costs includedno figureFMAG Art. 30(6)
Annual supervisory levy for an Art. 63 CASPBase CHF 50,000 a year with a service under (a) to (d), CHF 8,000 for (e) to (j) only; plus 0.1 % of the net turnover of the preceding year; at most CHF 250,000 a yearFMAG Art. 30a, Annex 2 section N

Source: Financial Market Authority Act (FMAG). The fee is charged for granting or refusing. Letters (a) to (d) are custody, operation of a trading platform and the two exchange services, the first four in the FMA's list of ten; (e) to (j) are the other six. The levy's branch and representative-office surcharges are in Annex 2 section N and not shown.

A pink calculator, a phone and sticky notes on a desk
Official fees are set in a statute.

Dates and penalties

The transition is over. These dates and penalties apply to anyone offering crypto-asset services from Liechtenstein today.

MiCA in Liechtenstein, 2024 to 2026

Authorisations

  1. 1 December 2025ZEUS Anstalt, Art. 60(3), portfolio management
  2. 22 June 2026Bitcoin Suisse (Europe) AG, Art. 63
  3. 26 June 2026Sygnum Europe AG, Art. 63

Law and deadlines

  1. June 2024FMA informal discussions begin
  2. 1 February 2025EWR-MiCA-DG in force
  3. 1 January 2026Amendment in force
  4. 1 July 2026Transition period ended
  5. 2 July 2026TVTG registrations for MiCAR activities expired
From the first FMA discussions to the end of the transition.

Key dates and penalties for crypto-asset services

Dates, penalties and the annual-report duty under the EWR-MiCA-DG and the Trustee Act.

itemrule
MiCAR transitionEnded on 1 July 2026
TVTG registrations for MiCAR activitiesExpired on 2 July 2026
Services without authorisationEWR-MiCA-DG Art. 26(e): imprisonment of up to three years, a court offence
Other breaches of MiCAR and the ActFMA administrative fine, Art. 31(1) and (2)(a): up to CHF 1,000,000 for legal persons; higher for serious, repeated or systematic breaches, Art. 31(3)
Unauthorised trustee activityTrHG Art. 80(1): imprisonment of up to one year or up to 360 daily rates; Art. 81(1)(k): fine of up to CHF 100,000
Annual report (a duty, not a penalty)Filed with the FMA within four months of the financial year end

Sources: FMA, end of the MiCAR transition, EWR-MiCA-DG, TrHG.

Problems we solve

Five questions that come up before most CASP files start, answered from the statute and the FMA's own pages.

"My TVTG registration covers it"

Not for MiCAR activities: those registrations expired on 2 July 2026. MiCAR and the TVTG do not overlap in scope, and some providers need both.

"Who is already authorised?"

Bitcoin Suisse (Europe) AG and Sygnum Europe AG hold Art. 63 authorisations from June 2026. ZEUS Anstalt holds an Art. 60(3) one. The ESMA register gives an overview of authorised providers.

"What will the FMA charge?"

CHF 30,000 or CHF 10,000 under the 2026 tiers, plus further costs and a yearly levy. Adviser fees are separate and on request.

"How long will it take?"

The FMA publishes no day count. Six months is only the point at which an appeal opens. We promise no date and build the file for completeness.

"Who may advise me?"

Advice on the application is reserved to licensed trustees and lawyers. We coordinate; the licensed adviser named in your engagement letter advises and files.

Is your CASP file ready for the FMA questionnaire?

We check what you have against the FMA's list and tell you what is missing, before the preliminary discussion.

Who prepares your CASP file

From our practice

Katrin collects the business description, group chart and capital evidence and keeps the document list for the licensed adviser, who drafts the business plan and the application, in German, English or Italian. The questionnaire and the preliminary discussion come before any filing. The licensed trustee or lawyer, named in your engagement letter, advises, forms the entity and submits.

A quiet street in a small European town
The file is kept in Vaduz.

Frequently asked questions about CASP authorisation in Liechtenstein

Can VCS obtain the CASP licence for me, or do I need a licensed trustee or lawyer?

VCS does not obtain it for you. The FMA is the competent authority and decides the authorisation. Advice on the application is reserved to licensed trustees (TrHG Art. 2(c)) and lawyers (RAG Art. 8). VCS collects your documents and coordinates the file; a licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises and submits it.

Is it worth applying in Liechtenstein when other EEA states also issue CASP licences?

This page does not compare jurisdictions or advise where to apply; that question belongs to your licensed adviser. Two facts apply: an authorisation obtained in Liechtenstein can be passported within the EEA once it is held, and the FMA questionnaire asks whether other EEA states have been or will be approached.

Does the FMA take too long, and can I rely on a fixed timeline?

The FMA publishes no day count for its decision, and VCS quotes no processing time. Six months from receipt of a complete application is only the point at which an appeal opens, not a promised duration. The FMA calls complete, high-quality applications an essential prerequisite, so the file is built for completeness first.

Is a TVTG registration still enough to run crypto services in Liechtenstein?

Not for activities that need MiCAR authorisation. The transition period ended on 1 July 2026, and TVTG registrations for those activities expired on 2 July 2026. MiCAR and the TVTG are mutually exclusive in scope, so some services, NFTs for example, can still fall under the TVTG, and a provider may need authorisations under both.

What happens if I start trading before the licence is granted?

Providing crypto-asset services without authorisation is a court offence under EWR-MiCA-DG Art. 26, with imprisonment of up to three years. Other breaches of MiCAR and the Act can draw an FMA fine of up to CHF 1,000,000 for legal persons, higher for serious, repeated or systematic breaches. An Art. 60 notifier may not start while its notification is incomplete.

What is the difference between a CASP licence, a MiCA licence and a VASP licence?

A CASP licence is the Art. 63 authorisation as a MiCA institute. "MiCA licence" is the wider term: it also covers issuers of asset-referenced tokens authorised under Art. 21 MiCAR. An Art. 60 notifier is a CASP too but holds no Art. 63 licence. The sources we work from define no VASP licence; the TVTG speaks of VT service providers.

What does the FMA officially charge for a CASP authorisation?

Under the 2026 text of the FMAG, the fee is CHF 30,000 for an authorisation with at least one service under Art. 3(1)(16)(a) to (d) MiCAR and CHF 10,000 for one limited to services under (e) to (j). The FMA can charge further costs, and an annual supervisory levy applies. VCS and partner fees are on request.

Which services can a CASP licence cover?

The FMA lists ten crypto-asset services: custody and administration, operating a trading platform, exchange for funds, exchange for other crypto-assets, executing orders, placing, receiving and transmitting orders, advice, portfolio management and transfer services. Which of them a model amounts to, and whether a token is a MiFID II financial instrument outside MiCAR, is settled first with the licensed adviser.

Is a crypto exchange licence a separate licence, or part of the CASP regime?

The sources name no separate exchange licence. A business that wants to run an exchange needs an Art. 63 authorisation or, if it is an Art. 59(1)(b) financial entity, an Art. 60 notification, for the services its model amounts to. The FMA lists operating a trading platform and the two kinds of exchange as separate services.

Who is already authorised in Liechtenstein, and for which services?

Bitcoin Suisse (Europe) AG has held an Art. 63 authorisation since 22 June 2026, covering custody, both exchange services, order execution, reception and transmission, and transfers. Sygnum Europe AG has held one since 26 June 2026. ZEUS Anstalt für Vermögensverwaltung was authorised on 1 December 2025 for portfolio management under Art. 60(3). The ESMA register gives the overview.

Do I need real substance and staff in Liechtenstein?

The FMA questionnaire covers planned substance and expected headcount; we found no CASP-specific staff minimum. Under PGR Art. 180a, at least one board member authorised to manage and represent must hold a Trustee Act licence or a licence treated as equal (paragraph 2); paragraph 3 exempts entities needing a managing director under the Trade Act or another special act.

What is the difference between an Art. 60 notification and an Art. 63 authorisation?

Art. 60 is open only to financial entities the FMA already licenses: credit institutions, central securities depositories, investment firms, electronic money institutions, UCITS management companies, AIFMs and market operators. They notify the FMA and hold no Art. 63 licence. Every other undertaking that wants to offer crypto-asset services needs an Art. 63 authorisation.

Can I passport the licence to other EEA countries?

Only once a CASP authorisation has been obtained. The sources we work from give no procedure, timeline or outcome in another state, so this page states none and promises none. Whether to passport the authorisation, and to which states, is a question for your licensed adviser, who can assess the plan for each market.

What ongoing duties and AML rules come with the licence?

The FMA approves the audit firm in advance, and any later change. A change of seat or address and outsourcing of important tasks need prior notice. The annual report is due within four months of the year end, with a yearly audit. CASPs are obliged entities under the Due Diligence Act, with Travel Rule and self-hosted address checks.

Can I appeal if the FMA refuses or does not decide?

Yes. An appeal to the FMA-Beschwerdekommission is open within 14 days of service of the decision, and also when a complete application is still undecided six months after receipt. The Commission's decision can then go to the Verwaltungsgerichtshof within 14 days. A licensed lawyer may represent you in the appeal; VCS keeps the file in order.

Start your CASP file

Send us your business description and group chart; we prepare the file for the licensed adviser.

+423 210 0003 (Legal department) · Monday to Friday 10:00-18:00 · Rietstrasse 42, 9490 Vaduz · info@company-in-liechtenstein.com