Payment and E-Money Licences in Liechtenstein
Planning a payment institution licence in Liechtenstein? We set out the form, capital and governance the FMA asks for and coordinate your file; a licensed Liechtenstein partner advises and files.
- AG or SE only
- FMA decides within three months of a complete file
- Licensed partner named in your engagement letter
Payment and e-money licences with a licensed partner
A payment institution or an e-money institution in Liechtenstein needs a licence from the FMA, the Financial Market Authority, and only the FMA grants it. We prepare and coordinate a licence application prepared for the Financial Market Authority; a licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises, forms the company and files.
There are three routes: a payment institution licence, an e-money institution licence, or registration only for account information services. Providing payment services without a licence or registration is a criminal offence under the Payment Services Act (ZDG), so the route is settled with the licensed partner first.
What is included
Route material
The three routes set out as criteria and facts: legal form, capital, governance, fee. You choose the route with the licensed partner.
The German-language file
We coordinate the documents. The application and the business plan go in German, signed and filed by the licensed partner.
The applicant company
An AG or SE with its seat and head office in Liechtenstein, formed by the licensed trustee, who also files the registry entry.
Board and management
The applicant is the share company that international groups register in Liechtenstein, or an SE. You appoint; the partner submits each person for FMA approval.
Filing and after the licence
The partner files and the FMA fee is paid. Afterwards: the annual audit, agent registration and passport notices for other EEA states.
How the licence route runs
No official time is published for steps 1 to 7. The statutory clocks are the FMA's three months from a complete file and the twelve months after which an incomplete file is rejected.
Eight steps to a payment or e-money licence
Choose the route
Who acts: Client with licensed partner
Informal pre-application, optional
Who acts: Client; partner reviews; VCS compiles
Form the AG or SE, capital paid in
Who acts: Licensed trustee
Appoint board and management, FMA approval
Who acts: Client appoints; partner submits
Audit firm mandate declaration
Who acts: Client
Application and business plan in German
Who acts: Client with partner; VCS coordinates
File and pay the FMA fee
Who acts: Licensed partner
Decision and register entry
Three months from a complete file
Who acts: FMA
Steps 1 to 7: no official time is published.
Choose the route
Payment institution tier, e-money institution or account-information registration. You decide with the licensed partner.
Informal pre-application
Optional and not binding: an informal pre-application to the FMA surfaces red flags early. We compile the documents; the partner reviews.
Form the AG or SE
The licensed trustee forms the company and files; the capital is paid in and unencumbered. If you look at an existing company on the ready-made companies page, note that no licence comes with it, so the FMA application is still needed.
Appoint board and management
At least three board members, one independent, and management of at least 200 per cent in total. The FMA approves each person before they start.
Engage the audit firm
You engage an FMA-recognised audit firm. Its declaration that it accepts the mandate goes into the application.
Prepare the file
Application and business plan in German; other documents in the original, German or certified translation. We coordinate; the partner drafts with you.
File and pay
The partner files the signed application with the FMA checklist, and the FMA fee is paid. It is owed even if the application is refused.
Decision and register
The FMA decides within three months of a complete file and enters the licence in its register. Business must start within one year.
Not sure which licence route applies?
The licensed partner settles the route with you. Send us your business model and we set up the file.
Requirements at a glance
Payment institution and e-money institution side by side, as the acts set them. Account information services alone need FMA registration, not a licence.
Payment institution and e-money institution requirements in Liechtenstein, by criterion
| criterion | payment institution | e-money institution |
|---|---|---|
| Legal form | AG or SE (ZDG Art. 9(1)(a)) | AG or SE (EGG Art. 7(1)(a)) |
| Seat and head office | In Liechtenstein (ZDG Art. 9(1)(b)) | In Liechtenstein (EGG Art. 7(1)(b)) |
| Board | At least three members (ZDG Art. 9(1)(i)) | Set by EGG Art. 7(1)(i); the licensed partner confirms the composition |
| Management | At least 200 per cent of working time in total (ZDG Art. 9(1)(i)) | May not sit on the board at the same time (EGG Art. 7(1)(i)) |
| Independent board member | At least one (ZDG Art. 17f(6)) | At least one (EGG Art. 9f(6)) |
| Initial capital | CHF 20 000 money remittance only; CHF 50 000 payment initiation only; CHF 125 000 all other services; or the euro equivalent (ZDG Art. 10(2)) | EUR 350 000 or the CHF equivalent, also the permanent minimum (EGG Art. 8(2), (4)) |
| Safeguarding | Customer funds kept apart, or covered by insurance or a guarantee, for the services in ZDG Art. 2(2)(a) to (c) and (f) to (h) (ZDG Art. 20(1)) | ZDG Art. 20 applies (EGG Art. 11(1)) |
| FMA fee | CHF 30 000, owed even if refused (FMAG Annex 1) | CHF 30 000 (FMAG Annex 1) |
| EEA validity | All EEA states (ZDG Art. 7(2)) | All EEA states (EGG Art. 5(1)) |
| FMA decision | Within three months of a complete application (ZDG Art. 9(4)) | Within three months; may be limited to some services or carry conditions (EGG Art. 7(3), (4)) |
Source: Payment Services Act (ZDG); E-Money Act (EGG); FMA Act (FMAG), Annex 1.
Documents and official FMA fees
- Business model and programme of operations
- Three-year business plan, in German
- Governance, risk, security and AML controls
- Safeguarding measures for customer funds
- Ownership chart and qualifying holders
- Evidence on each board and management member
- Audit firm mandate declaration and proof of paid-in capital
The FMA's own fees, as the statute and its guidance set them. Our fee and the partner's are on request and never appear in this table.
Official FMA fees for payment and e-money licences in Liechtenstein, FMAG Annex 1 text read 2026
| item | FMA fee | source |
|---|---|---|
| Grant or refusal of a payment institution licence | CHF 30 000, owed even when refused | FMAG Annex 1 Part A item 1(d) |
| Grant or refusal of an e-money institution licence | CHF 30 000 | FMAG Annex 1 Part A item 1(c) |
| Registration as an account information service provider | CHF 15 000 | FMAG Annex 1 Part A item 4(a); FMA-WL 2019/8 section 5.2 |
Source: FMA Act (FMAG), Annex 1; FMA guidance FMA-WL 2019/8.
Deadlines and penalties
The statutory clocks, and the penalties for acting without a licence. No other FMA processing time is published, so we quote none.
Statutory periods for a payment institution
Application
- within three monthsFMA decision
- twelve months of receiptGaps not filled: application rejected
After the licence
- one yearBusiness started, or the licence is withdrawn
Agent registration
- within two monthsFMA answers
Statutory periods and penalties for payment and e-money institutions in Liechtenstein
| event | period or penalty | source |
|---|---|---|
| FMA decision | Within three months of a complete application | ZDG Art. 9(4); EGG Art. 7(3) |
| Application left incomplete | Rejected if not complete within twelve months of receipt | ZDG Art. 9(4) |
| Start of business | Within one year of the licence taking effect, or the licence is withdrawn | ZDG Art. 14(1)(a) |
| Agent registration | The FMA answers within two months | ZDG Art. 25(2) |
| Payment services without licence or registration | Imprisonment of up to three years | ZDG Art. 109(1)(b) |
| Issuing e-money without a licence | Imprisonment of up to three years, by the Landgericht | EGG Art. 48(1) |
Source: Payment Services Act (ZDG); E-Money Act (EGG).
Problems we solve
"I want a GmbH or an Anstalt"
Neither can apply. A payment or e-money institution must be an AG or SE, and the act names no exception.
"I want to run it from abroad with nominees"
Seat and head office must be in Liechtenstein, with a board of at least three and management of at least 200 per cent in total, each person approved by the FMA.
"CHF 20 000 is my budget"
That tier covers money remittance alone. Payment initiation alone needs CHF 50 000, other payment services CHF 125 000, and own funds can rise above the initial capital.
"I need a date"
The three-month clock starts only with a complete file. We keep the document list and the dates; the licensed partner confirms the file is complete before filing. No one can promise the FMA's date.
"My team does not write German"
Only the application and the business plan must be in German. Other documents may stay in the original or a certified translation.
Is your licence file ready for the FMA?
We compile your documents against the FMA's list; the licensed partner reviews them and files.
Who prepares your licence file
Katrin Imhof leads our tax, accounting and licensing files and works in German, English and Italian. We compile the business description, governance, safeguarding and ownership documents and keep the document list and the dates; the licensed partner advises and files. Unlicensed trustee work is an offence under the Trustee Act (TrHG), Art. 80.
Frequently asked questions about payment and e-money licences
Do I really need an AG, can I not use a GmbH or an Anstalt?
No. A payment institution must be an AG or a European company (SE), and an e-money institution likewise; the act names no exception. Its seat and head office must both be in Liechtenstein. Forming the company for a client is a trustee activity, so the licensed trustee named in your engagement letter does it.
Why does the FMA application have to be in German?
The FMA requires the application and the business plan in German. Other documents may be filed in the original, in German or in a certified translation, and some in English after consulting the FMA. The application is signed with a qualified electronic signature, or by hand and sent in the original by post.
Is CHF 20 000 really enough, or is the real capital higher?
CHF 20 000 applies to money remittance alone. Payment initiation alone needs CHF 50 000, and all other payment services CHF 125 000, each or the euro equivalent. Ongoing own funds may never fall below the initial capital and can be higher. An e-money institution needs EUR 350 000.
Do I need both a payment institution licence and an e-money licence?
As a rule, issuing e-money professionally needs the e-money institution licence; EGG Art. 4 reserves Art. 24, 26 and 30, which the licensed partner checks. That licence also covers the payment services listed in ZDG Art. 2(2)(a) to (h), so an issuer needs no second licence for them. The licensed partner decides which route fits your model.
Can I get a licence without a local board and local management?
The law asks for a seat and head office in Liechtenstein, a board of at least three with at least one independent member, and management of at least 200 per cent of working time in total. The FMA approves each person before they take office. The licensed partner confirms what this means for where your members live.
What is the minimum capital for a payment institution in Liechtenstein?
There are three tiers by the services offered: CHF 20 000, CHF 50 000 and CHF 125 000, or the euro equivalent. The capital must be freely available and unencumbered. Own funds never fall below it; under method A they are at least 10 per cent of the previous year's fixed overheads.
How long does the FMA take to decide?
The FMA decides within three months of a complete application, and the e-money rule is the same. An application still incomplete twelve months after receipt is rejected. No other processing time is published, so we promise none. Business must start within one year of the licence, or it is withdrawn.
Can a Liechtenstein payment institution serve clients across the EEA?
The payment institution licence is valid in all EEA states, and the e-money licence likewise. Before providing services in another state, the institution must notify the FMA in writing first. Any wider reach is for the licensed partner to confirm.
What is the difference between a payment institution and an e-money institution?
Both must be an AG or SE. Capital differs: CHF 20 000, CHF 50 000 or CHF 125 000 for a payment institution against EUR 350 000 for an e-money institution. Safeguarding follows the same ZDG rule, and the FMA fee is CHF 30 000 for each. Which applies depends on the activity.
Which payment services need a licence and which are excluded?
Providing payment services professionally in Liechtenstein needs an FMA licence, and doing so without a licence or registration is a criminal offence. Account information services alone need registration only. The licensed partner checks the statutory exclusions (ZDG Art. 3) first.
Which parts of the work are done by the licensed Liechtenstein partner?
We compile your documents against the FMA checklist and coordinate the file. A licensed Liechtenstein trustee or lawyer, named in your engagement letter, advises, reviews the documents, forms the AG and files. You appoint the board and engage the audit firm. The FMA alone decides on the licence.
What does the FMA charge for the licence, and is it refunded if the application is refused?
The FMA fee for a payment institution licence is CHF 30 000 and is owed even when the application is refused. For an e-money institution it is also CHF 30 000. Registration as an account information service provider costs CHF 15 000. Our fee and the partner's are on request.
Does an account information service need a full licence?
No. A provider of account information services alone needs registration with the FMA, not a licence. The FMA fee for the registration is CHF 15 000. Whether your model is account information only, with no other payment service, is for the licensed partner to confirm.
Start your licence file
Send us your business model; we set up the file and the licensed partner takes the route from there. Price on request.
+423 210 0003 (Legal department) · Monday to Friday 10:00-18:00 · Rietstrasse 42, 9490 Vaduz · info@company-in-liechtenstein.com