CASP License Liechtenstein: MiCA Authorisation with a Licensed Local Adviser

ABB does not obtain the licence. Financial and business advice for third parties is a trustee activity (TrHG Art. 2(c)), and legal advice and representation are reserved to lawyers (RAG Art. 8). ABB collects your documents and coordinates; a licensed trustee or lawyer, named in the engagement letter, advises and submits the file to the FMA.

Not for activities that need MiCAR authorisation. The MiCAR transition period ended on 1 July 2026, and TVTG registrations for those activities expired on 2 July 2026. The two regimes are mutually exclusive in scope, so a provider may need authorisations under both. The TVTG still covers VT services outside MiCA.

Providing crypto-asset services without authorisation is an offence under the EWR-MiCA-DG (Art. 26): the court can impose up to three years' imprisonment. An entity notifying under Art. 60 may not provide crypto-asset services while the notification is incomplete. The licensed adviser confirms the position for your model before anything client-facing starts.

The FMA publishes no day count for its decision, and the MiCAR deadlines are not quoted here, so ABB quotes none. By law, if a complete application is undecided after six months, an appeal to the FMA-Beschwerdekommission is open (EWR-MiCA-DG Art. 24(2)). That is an appeal trigger, not a promised duration. The FMA calls complete, high-quality applications an essential prerequisite.

ABB compares no states and cannot say which suits you; that is for you and your licensed adviser. What the sources show: the FMA is the competent authority in Liechtenstein, passporting to other EEA states is possible only once an authorisation is held, and the FMA questionnaire asks whether other EEA states have been or will be approached.

The FMA fee for granting or refusing an Art. 63 authorisation is CHF 30,000 if at least one service under Art. 3(1)(16)(a) to (d) MiCAR is included, and CHF 10,000 for services under (e) to (j) only (FMAG annex, 2026 text). Adviser, trustee and entity costs are separate. ABB pricing is on request.

A CASP licence is the Art. 63 MiCAR authorisation to offer crypto-asset services. The Liechtenstein act calls the holder a MiCA institute, a term that also covers issuers of asset-referenced tokens authorised under Art. 21, so MiCA licence is the wider phrase. VASP is a search label here; the acts speak of MiCA institutes and VT service providers.

The FMA lists ten crypto-asset services, including custody, operating a trading platform and exchange of crypto-assets for funds or for other crypto-assets. An exchange is part of the CASP regime, not a separate licence. The licensed adviser first decides which services your model amounts to and whether the tokens are MiFID II financial instruments.

Art. 60 is open to financial entities the FMA already licenses: credit institutions, central securities depositories, investment firms, e-money institutions, UCITS management companies, AIFMs and market operators. A new entrant applies for an Art. 63 authorisation. An Art. 60 notifier is also a CASP but holds no Art. 63 licence.

FMA news names Bitcoin Suisse (Europe) AG, authorised under Art. 63 since 22 June 2026, and Sygnum Europe AG, since 26 June 2026, both in Vaduz. ZEUS Anstalt was authorised on 1 December 2025 for portfolio management under Art. 60(3), not Art. 63. The FMA points to the ESMA register for the current overview.

The FMA questionnaire asks for the planned substance in Liechtenstein and the expected number of employees after the licence. We found no CASP-specific staff minimum. Company law adds a board rule: PGR Art. 180a(1) requires a board member who holds a Trustee Act licence or an Art. 180a licence treated as equal, with exceptions in Art. 180a(3).

Cross-border activity within the EEA (passporting) is possible only once a CASP authorisation has been obtained. It is not available at the application stage, and ABB promises none. Whether and how it works for your business model, and which host states apply, is for your licensed adviser and the FMA to confirm.

The audit firm needs the FMA's prior approval, and a change of seat or address, or outsourcing of important tasks, needs prior notice. The annual report goes to the FMA within four months of year-end, with a yearly audit. CASPs are obliged entities under the Due Diligence Act; the Travel Rule applies and self-hosted address risk must be assessed.

Yes. An FMA decision can be appealed to the FMA-Beschwerdekommission within 14 days of service. If a complete application is undecided after six months, an appeal is also open. A further appeal lies to the Verwaltungsgerichtshof within 14 days. A licensed lawyer may represent you in an appeal (RAG Art. 8).