Payment Institution and E-Money License in Liechtenstein

Yes. A payment institution must be an AG or a European company (SE), and so must an e-money institution. An Anstalt, a GmbH or a foundation cannot apply, and we found no exception. Seat and head office must both be in Liechtenstein. If your group holds another form, the licensed partner advises on a new applicant company.

The FMA requires the application and the business plan in German. Other documents go in the original, in German or as a certified translation, and some may be in English after consulting the FMA. The application is signed with a qualified electronic signature, or signed by hand and posted in the original with the checklist.

CHF 20,000 applies only if money remittance is your sole service. Payment initiation alone needs CHF 50,000, and every other payment service needs CHF 125,000, each or the euro equivalent. Ongoing own funds may not fall below the initial capital and can be higher: method A is 10 per cent of the previous year's fixed overheads.

Not always. Issuing e-money professionally needs an e-money institution licence as a rule, and that licence also covers the payment services in ZDG Art. 2(2)(a) to (h), so an issuer needs no second licence for them. A business that offers payment services only follows the payment institution route. The licensed partner decides which fits your model.

Seat and head office must both be in Liechtenstein, so the institution is run from there. The law asks for a board of at least three members, one of them independent, and a management of at least two persons with 200 per cent of working time in total. The FMA approves each person before they take up the function.

It depends on the services. The initial capital is CHF 20,000 for money remittance only, CHF 50,000 for payment initiation only and CHF 125,000 for all other payment services, each or the euro equivalent. It must be freely available and unencumbered. An e-money institution needs at least EUR 350,000 or the Swiss franc equivalent.

The FMA decides within three months of receiving a complete application. If the applicant has not delivered everything within twelve months of receipt, the FMA rejects it. We quote no further FMA processing time and no project time. The clock starts only when the file is complete.

Yes. The licence is valid in all EEA member states. Before providing services in another EEA state, the institution notifies the FMA in writing first. Agents are registered by the FMA, which tells the institution within two months whether the agent is entered.

Both are an AG or SE with seat and head office in Liechtenstein and a board of at least three, one independent, and the FMA fee is CHF 30,000 for each. Capital differs: CHF 20,000 to CHF 125,000 by service for a payment institution, EUR 350,000 for an e-money institution, which issues electronic money.

Providing payment services on a professional basis in Liechtenstein needs an FMA licence as a payment institution. A provider of account information services only needs registration. The exclusions sit in ZDG Art. 3; we list none here, because whether your model falls under one is for the licensed partner to confirm.

We coordinate the application; the regulatory advice is given by a licensed trustee or lawyer; operating without FMA authorisation is a criminal offence. The licensed trustee forms the AG (TrHG Art. 2(a)) and files the application. ABB collects and prepares your documents. The FMA alone grants the licence.

The FMA fee for granting or refusing a payment institution licence is CHF 30,000, and it is owed even when the application is refused. The fee for an e-money institution licence is also CHF 30,000. Our own fee is quoted on request after we see the business model.

No. A provider of account information services only needs registration by the FMA, not a full payment institution licence. The FMA fee for that registration is CHF 15,000. Whether your model counts as account information only, or also includes other payment services, is checked by the licensed partner at the start.