FMA Licensing for Financial Services

We coordinate your licence application; a licensed Liechtenstein trustee or lawyer advises and submits it.

  • Regimes mapped act by act
  • Official FMA fees shown
  • Licensed partner submits
  • No licence promised
Aerial view of a snow-dusted city in a wide mountain valley

How FMA licensing works with VCS

A financial services license in Liechtenstein comes from the FMA, which licenses banks, investment firms, asset managers, insurers, fund managers and payment and e-money institutions. The applicant is a Liechtenstein company set up and administered from Vaduz, formed by a licensed trustee. Advice on the application is a trustee or lawyer activity under the Trustee Act (TrHG).

We collect, prepare and coordinate. We do not promise a licence, a date, a bank account or an EEA passport, and we run no regulated activity for you. Crypto-asset services, payment institutions and funds have their own pages, linked below.

What is included

  • Intake of your business description, routed to a licensed trustee or lawyer who settles the regime with you
  • The applicant company in the form the act requires, drafted by us, formed by a licensed trustee; for the board, see a resident board member provided by a licensed trustee
  • Collection of the documents: business plan, management evidence, qualifying shareholders, capital evidence
  • Coordination of the file with the licensed trustee or lawyer, who prepares and submits it
  • Coordination with the audit firm to be appointed or named
  • After the licence: conditions, notices and approvals tracked with the licensed partner

Not included: choosing the regime, signing for the applicant, acting as its agent before the FMA, or any promise of a licence or date.

An application folder and a laptop on an office desk
One file, kept in order from intake to decision.

Who needs an FMA licence

Banks and investment firms

Both need an FMA licence before they start. A bank must be an AG or SE with its seat and head office in Liechtenstein.

Asset managers and insurers

Each needs the licence before business starts, with its seat and head office in Liechtenstein.

Fund managers

AIFM, UCITS and IUG management companies are authorised or licensed and appear in public FMA registers. For the fund itself, see how an investment fund is established in Liechtenstein and who administers it.

Payment, e-money and token projects

A payment institution license Liechtenstein and our token issuance service have their own pages and their own conditions.

Financial regimes and the act behind each

  • Activity: Bank
    Act: BankG
    Rule: FMA licence or authorisation before business starts
  • Activity: Investment firm
    Act: WPFG
    Rule: FMA licence or authorisation before business starts
  • Activity: Asset management company
    Act: VVG
    Rule: FMA licence or authorisation before business starts
  • Activity: Insurance undertaking
    Act: VersAG
    Rule: FMA licence or authorisation before business starts
  • Activity: AIFM
    Act: AIFMG
    Rule: FMA licence or authorisation before business starts
  • Activity: UCITS management company
    Act: UCITSG
    Rule: FMA licence or authorisation before business starts
  • Activity: IUG management company
    Act: IUG
    Rule: FMA licence or authorisation before business starts
  • Activity: Payment institution
    Act: ZDG
    Rule: FMA licence or authorisation before business starts
  • Activity: E-money institution
    Act: EGG
    Rule: FMA licence or authorisation before business starts
  • Activity: Crypto-asset services
    Act:
    Rule: See the CASP page
Nine regimes, one supervisor.

How the licensing file runs

The acts we read do not fix the order of these steps. The periods below are legal maximums, counted from a complete application.

Who acts at each step of an FMA licence file

Client and shareholders

Licensed trustee or lawyer, VCS coordinating

FMA

1Intake and regime
Client and shareholders to Licensed trustee or lawyer, VCS coordinatingIntake and regime
2Applicant company
Licensed trustee or lawyer, VCS coordinatingApplicant company
3People and auditor
Licensed trustee or lawyer, VCS coordinatingPeople and auditor
4Capital paid in
Client and shareholdersCapital paid in
5Written application
Licensed trustee or lawyer, VCS coordinatingWritten application
6FMA fee
Client and shareholdersFMA fee
7FMA decision
FMAFMA decision
8Conditions kept
Licensed trustee or lawyer, VCS coordinatingConditions kept
Who acts at each step of the file.
  1. Intake

    We collect your business description. A licensed trustee or lawyer decides with you which regime applies.

  2. Applicant company

    The company takes the form the act requires: an AG or SE for a bank, see Liechtenstein AG formation. We draft; a licensed trustee forms it.

  3. People and auditor

    Management and board must offer the guarantee of proper business conduct, and an FMA-recognised audit firm is appointed or named. Managers who are moving can read our guide to settling in Liechtenstein as a founder or investor.

  4. Capital paid in

    The shareholders pay in the initial capital: a bank before business starts, an asset manager when the licence is granted.

  5. Written application

    The licensed trustee or lawyer submits the application with the proof of the conditions; we coordinate. A bank reports any change in the facts without delay.

  6. Statutory FMA fee

    The applicant pays the fee from the FMAG annex. A proceeding closed without a ruling can be charged too.

  7. FMA decision

    The FMA decides within the act's maximum. A bank licence can carry conditions, and a bank application still incomplete after twelve months is rejected.

  8. After the licence

    The conditions apply permanently. A bank's changes to its statutes need FMA approval.

Which licence does your activity need?

Send us the business description; the licensed partner settles the regime and we build the file.

Documents you will need

  • Business description: activities, client types, markets, custody of client assets
  • Group chart and the qualifying shareholders and beneficial owners
  • CVs of the management and board members
  • Evidence of each member's guarantee of proper business conduct
  • Business plan, or an activity plan for an insurer
  • Capital evidence for the regime
  • Name and details of the audit firm to be appointed or named
  • Prompt notice of any change in the facts while a bank proceeding runs
  • Document language, confirmed by the licensed partner against the FMA's instruction
A modern glass office building facade
The documents come before the application.

FMA licence requirements and fees by type

Capital from each act, fees from the FMAG annex (2026 state), periods as statutory maximums.

Capital, FMA fee and decision period by regime

FMA licence requirements by regime, from the acts and the FMAG annex, 2026 state.

regimeinitial capitalFMA fee (FMAG annex, 2026 state)decision period (maximum, from a complete application)act
Bankat least EUR 10 million, fully paid in before business starts; never below EUR 5 million where the FMA prescribes another amountCHF 100 000; CHF 50 000 under the annex item for Art. 16 with Art. 17 BankGsix months; an application still incomplete after twelve months is rejectedBankG Art. 18, 25
Investment firmno figure stated hereCHF 35 000, plus CHF 10 000 with an MTF or OTF; small non-interconnected firm CHF 30 000 with the same add-onno period statedWPFG, FMAG annex
Asset management companyat least EUR 75 000, fully paid in when the licence is granted; the FMA may prescribe moreCHF 15 000 (class 2), CHF 10 000 (class 3)six monthsVVG Art. 6, 8
Insurance undertakingno figure stated hereCHF 80 000; captive CHF 40 000no fixed period; appeal after six monthsVersAG Art. 12, 14, 15
AIFMat least EUR 125 000, or EUR 300 000 if internally managed, plus 0.02% of portfolios above EUR 250 million, capped at EUR 10 millionCHF 20 000; CHF 25 000 if granted with conditionsthree months, extendable to sixAIFMG Art. 31, 32
UCITS management companyat least EUR 125 000 (self-managed investment company EUR 300 000), plus the same add-onno fee figure stated hereone month, extendable to sixUCITSG Art. 16, 17
IUG management companyat least CHF 125 000, plus 0.02% above CHF 250 million, capped at CHF 10 million, never below a quarter of last year's fixed overheadsCHF 20 000three months after the completeness confirmation, up to sixIUG Art. 23, 24
Payment and e-money institutione-money at least EUR 350 000; payment institution no figure stated hereCHF 30 000 eachthree monthsZDG Art. 9, EGG Art. 7, 8

Sources: FMAG, BankG, VVG, VersAG, AIFMG; UCITSG, IUG, ZDG and EGG as cited in the act column.

There is no needs test: the FMA may not refuse a bank licence because the market needs no further bank, but grants it only on a complete application that meets every condition.

Unusually large proceedings can be billed at CHF 100 to 400 an hour, urgent work on request up to 50% more, and experts separately. An annual supervisory levy under FMAG Art. 30a comes on top.

Problems we solve

"Which licence do I need?"

The map above sets activity, act and rule side by side; a licensed trustee or lawyer makes the choice. For tokens, read the Token and TT Service Provider Act and what it regulates.

"What will the FMA really charge?"

For most items the annex fee also applies to a refusal, a closed proceeding can be charged, large proceedings can be billed by time, and the annual levy is a second line.

"Is this firm licensed?"

The FMA keeps public registers of AIFMs, asset managers, UCITS and IUG management companies and payment and e-money institutions, and a register page of licence holders.

"How long will it take?"

The acts give maximums from a complete application, not the FMA's real time. A bank's six months start only when the file is complete.

"May I already say bank?"

No. A firm without a bank licence may not use bank wording in its company name or stated purpose.

What does your licensing file need first?

We list what you have and what is missing, before the licensed partner drafts a line.

Who prepares your licensing file

From our practice

Katrin assembles the business plan, governance and capital evidence of an FMA application, in German, English or Italian, and keeps the file in step with the licensed trustee or lawyer, named in your engagement letter, who advises and submits.

A bright open-plan office with empty desks
The file is reviewed before it goes out.

Frequently asked questions about FMA licensing in Liechtenstein

Can VCS submit the FMA application for me?

No. VCS coordinates the file: it collects the business description and the documents and keeps the timetable with your licensed Liechtenstein trustee or lawyer, named in your engagement letter, who prepares and submits the application to the FMA. VCS does not sign for the applicant and does not act as its agent before the FMA.

Can I use the word bank in my company name before I hold a licence?

No. A firm without a bank licence may not use a name that suggests it is a bank, either in its company name or in its stated purpose. A planned bank waits for the licence before it uses bank wording. The rule sits in the Banking Act of 5 December 2024, LGBl. 2025 Nr. 085.

Will the FMA refuse a bank licence because the market needs no further bank?

No, the FMA may not refuse on that ground. That does not make the licence a formality: it is granted only if a complete application was submitted and all conditions of Art. 18 to 23 BankG are met, and the FMA may attach conditions and requirements to it.

What does the FMA charge, and is the fee refunded if the application fails?

The fee comes from the FMAG annex, 2026 state: for example CHF 100 000 for a bank licence and CHF 30 000 for a payment institution. For most items the annex fee applies to a refusal as well as a grant, and a proceeding closed without a ruling can also be charged. The table above lists every type.

How long does the FMA take to decide?

The acts set maximums counted from a complete application, not the time the FMA needs: six months for banks and asset managers, three months for payment and e-money institutions, three months for an AIFM and one month for a UCITS management company, both extendable to six. Insurers have no fixed period. No date is promised.

Why can VCS not advise on the application itself?

Advice on a licence application is financial and business advice, a trustee activity under TrHG Art. 2(c). Where it applies the law, it is legal advice reserved to lawyers under RAG Art. 8(1)(a). Practising trustee activities without a licence is an offence under TrHG Art. 80(1), so VCS coordinates and the licensed partner advises.

Which FMA licence does my activity need?

It depends on the activity: bank (BankG), investment firm (WPFG), asset management company (VVG), insurer (VersAG), AIFM (AIFMG), UCITS management company (UCITSG), IUG management company (IUG), payment institution (ZDG) or e-money institution (EGG). The licensed trustee or lawyer decides this with you; this page maps the regimes and does not advise.

How much initial capital must I show?

It depends on the act. A bank needs at least EUR 10 million, fully paid in before business starts, never below EUR 5 million where the FMA prescribes another amount. An asset manager needs EUR 75 000, an AIFM EUR 125 000 (EUR 300 000 if internally managed), an e-money institution EUR 350 000, each at least.

Can the FMA bill more than the annex fee?

In defined cases. Unusually large or difficult proceedings can be billed by time at CHF 100 to 400 an hour, urgent work done on request can cost up to 50% more, and expert costs are billed separately. Licensed firms also pay an annual supervisory levy under FMAG Art. 30a; this page states no amount for it.

Does a ready-made company shorten the licensing process?

No source says so. The FMA grants the licence to the applicant only after testing the conditions, and a bank must be an AG or SE with its seat and head office in Liechtenstein. A ready-made company does not replace or shorten the licence; the licensed partner confirms whether it can be the applicant. No licence or date is promised.

What does an insurance licence cost and what does it require?

The FMA fee is CHF 80 000, or CHF 40 000 for a captive insurer. The insurer must be an AG, SE, cooperative or SCE with its seat and head office in Liechtenstein. The application names the eligible capital, the qualifying shareholders, the management, the external auditor and an activity plan. This page states no capital figure.

What does an investment firm licence require?

An investment firm is licensed under the WPFG and pays an FMA fee of CHF 35 000, plus CHF 10 000 if the licence includes an MTF or OTF. This page states no capital figure and no decision period for it: the licensed trustee or lawyer confirms both against the act before the file is built.

Is there a forex or CFD licence in Liechtenstein?

This page names no act, article or licence for forex or CFD business and does not promise that one exists. The licensed trustee or lawyer, named in your engagement letter, assesses which regime the activity falls under. Operating without FMA authorisation is a criminal offence, so that assessment comes before any business starts.

How do I check that a firm is licensed in Liechtenstein?

The FMA keeps public registers, updated monthly, of AIFMs, asset management companies, UCITS management companies and IUG management companies, and public registers of payment and e-money institutions. It also publishes a register page of licence holders for the other regimes, where a firm's name can be checked before you deal with it.

Start your FMA licensing file

Tell us the activity; we prepare the file for the licensed trustee or lawyer who submits it.

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