Token Issuance Liechtenstein: MiCA White Paper or TVTG Route with a Licensed Local Partner
We collect the token facts and coordinate; a licensed Liechtenstein trustee or lawyer classifies, drafts and files; the FMA decides. No price, no time promise.
- MiCAR white paper or TVTG Basisinformationen
- TVTG registrations for MiCAR activities expired 2 July 2026
- Offer made too early: up to 3 years
- FMA white-paper transmission CHF 500
Token issuance in Liechtenstein: who does what
MiCAR governs the public offer of asset-referenced tokens, e-money tokens and other crypto-assets. The TVTG defines token issuance only for tokens outside MiCAR, and the two scopes exclude each other. An ICO or token offering therefore starts with the question of which regime applies, much as with any financial services license Liechtenstein route.
We collect the token facts and coordinate. The licensed trustee or lawyer, named in the engagement letter, classifies the token, drafts the document and files it. The FMA is the competent authority. Offering a token to the public without meeting the MiCAR conditions is a criminal offence.
What's included
Token facts and routing
We collect what the token is, who gets it, its rights and the offer size. The licensed partner classifies it; ABB does not decide the class.
Other crypto-asset under MiCAR
The licensed partner drafts the crypto-asset white paper and transmits it to the FMA. The issuer answers for it as offeror; ABB coordinates.
Token outside MiCAR
The Basisinformationen (basic information document) is prepared by the licensed partner, and the issuance is notified to the FMA before the issue.
ART route, licensed institutions only
For a credit institution or an Art. 21 authorisation holder: the partner prepares, the issuer applies. The EMT route is for licensed institutions and ABB does not offer it.
The issuing entity
Where you want a Liechtenstein legal person, a licensed trustee forms it and files the registration. We explain how the transfer of a ready-made Liechtenstein company is completed.
After the issue we coordinate supplements, disclosure and levies. Custody and trading need a different licence: our CASP licence service. ABB never classifies, files as agent, issues, holds or trades tokens.
Who it is for
Founders and Web3 projects
Offering an other crypto-asset to the public: the MiCAR white paper route, drafted and transmitted by the licensed partner.
Issuers outside MiCAR
A token outside MiCAR, offered in your own name or for a client: the Basisinformationen and the notification to the FMA.
Corporates and banks
Weighing an asset-referenced or e-money token: both are reserved to licensed institutions, and the partner confirms which applies. The e-money institution route: payment institution licences in Liechtenstein.
Fund sponsors
A token project that needs a fund structure with an FMA-licensed manager alongside the issue.
How the process works
Steps 3 to 6 are alternatives by route. Any period named is the statute's; ABB states no time of its own.
Collect the token facts
Rights, holders, offer size and the VT system. Who acts: you supply, ABB collects. No official time applies.
Classify the token
MiFID II instrument, ART, EMT, other crypto-asset or outside MiCAR. Who acts: the licensed trustee or lawyer.
Other crypto-asset: white paper
The white paper is drafted and transmitted to the FMA. Who acts: the licensed partner files, the issuer answers, ABB coordinates.
ART: authorisation
Application under MiCAR Art. 16 and 21 with an ART white paper. Who acts: the issuer applies, the FMA decides. An appeal opens after six months without a decision; that is a trigger, not a processing time.
Outside MiCAR: Basisinformationen
Publish the Basisinformationen and notify the issuance to the FMA before the issue. Who acts: the licensed partner prepares and files.
Registration, only when issuing for a client
The FMA decides a complete application within three months; no service starts before the entry in the register.
After the issue
Supplements, the annual FMA levy and, for a registered issuer, disclosure for ten years. Who acts: the issuer; ABB coordinates.
Seven steps to a token offering
Collect the token facts
Who acts: Client supplies, ABB collects
Classify the token
Who acts: Licensed trustee or lawyer
Route by token type, one of three: other crypto-asset: white paper transmitted to the FMA (licensed partner files, issuer answers); ART: authorisation under MiCAR Art. 16 and 21 (issuer applies, FMA decides; appeal possible after six months without a decision); outside MiCAR: Basisinformationen published, issuance notified (licensed partner)
Who acts: Licensed partner, issuer, FMA
Registration, only when issuing for a client
Decision within three months of a complete application
Who acts: FMA
After the issue: supplements, annual levy, ten-year disclosure for a registered issuer
Who acts: Issuer
Sources: TVTG, EWR-MiCA-DG, MiCAR Art. 16, 21.
Not sure which regime your token falls under?
Describe the token. We return the route, the documents and who acts at each step.
What we ask you to supply first
- What the token represents, its rights, who may acquire it, planned total value
- Issuer identity, corporate documents, beneficial owners, any Liechtenstein issuing entity
- Who answers for technical and legal functionality, and the VT system
- For a token representing rights in things, proof of ownership
- Declaration of the persons responsible for the document content
The exact documents the FMA asks for come from the licensed partner and the FMA, not from this list.
Which route fits which token
TVTG registrations for MiCAR-authorisable activities expired on 2 July 2026. The licensed partner classifies your token, not this table.
Which regime a token falls under
Question: Is it a MiFID II financial instrument? Tested in order, top to bottom
The licensed partner decides
Condition: Yes
Outcome: Security token: outside MiCAR, securities rules, a licensed lawyer confirms
Condition: No, asset-referenced or e-money token
Outcome: ART: credit institution or Art. 21 holder only / EMT: credit or e-money institution only
Condition: No, other crypto-asset under MiCAR
Outcome: MiCAR white paper, transmitted to the FMA
Condition: No, none of the above
Outcome: Outside MiCAR: TVTG Basisinformationen and notification
Sources: FMA MiCAR page, TVTG.
Route by token type (FMA MiCAR page and TVTG, read 2026-10-26).
| token | regime | what goes to the FMA | who may offer |
|---|---|---|---|
| Other crypto-asset | MiCAR | the crypto-asset white paper is transmitted | may be offered without authorisation if MiCAR Art. 4 ff. are met |
| Asset-referenced token (ART) | MiCAR | authorisation under Art. 21 and a white paper | licensed credit institutions and Art. 21 holders only |
| E-money token (EMT) | MiCAR | (route not offered by ABB) | licensed credit or e-money institutions only |
| Token outside MiCAR | TVTG | Basisinformationen published, issuance notified | an own-name issuer is not subject to registration but follows TVTG Art. 30 to 38; an issuer acting for a client registers |
| Security token (MiFID II instrument) | outside MiCAR | the MiFID II question is settled first | a licensed lawyer confirms the securities rules; no prospectus route stated here |
Sources: FMA MiCAR page; FMA notice on the end of the MiCAR transition; Token and VT Service Provider Act (TVTG).
The MiCAR and TVTG scopes exclude each other since the EWR-MiCA-DG took effect on 1 February 2025.
Official fees, levies and the cost of a wrong route
Fees and levies below are the FMA's official ones. No fee of ABB, the partner, a trustee or an adviser appears.
Official FMA fees and levies for token issuers (FMAG Annex 1 and 2, read 2026-10-26).
| item | amount |
|---|---|
| Transmission of a white paper or an amended white paper | CHF 500 |
| Approval or refusal of a white paper and the Art. 17 examination | CHF 20,000 |
| Check of MiCAR Art. 16(2) after receipt of the white paper | CHF 2,500 |
| Granting or refusing an ART authorisation under Art. 21 | CHF 30,000, expert costs charged separately |
| ART issuer annual levy | basic CHF 20,000 a year plus 0.1 % of the value received in the issue, capped at CHF 100,000 a year |
| Token issuer annual levy | basic CHF 500 a year, plus a supplementary levy on gross revenue from VT services where it applies, capped at CHF 100,000 per supervised person |
Source: FMA Act (FMAG), Annex 1 and Annex 2.
The CHF 20,000 approval item and the CHF 2,500 check belong to the ART route, where Art. 16 and 17 sit. How the FMA treats an other-crypto-asset white paper in practice is not in our sources, so we describe no review. Adviser, trustee and issuing-entity costs are not given.
What an offer made the wrong way risks (EWR-MiCA-DG, TVTG, TrHG).
| breach | consequence |
|---|---|
| Offering other crypto-assets to the public without meeting MiCAR Art. 4(1) or 5(1) | imprisonment up to three years, before the Landgericht |
| An ART offer without Art. 16(1) or 17(1), or an EMT offer without Art. 48(1) | imprisonment up to three years |
| Breach of the white-paper duties | FMA fine up to CHF 1,000,000 for a legal person and CHF 500,000 for a natural person; for serious, repeated or systematic breaches a legal person faces up to CHF 4,900,000, a share of annual turnover or twice the benefit gained, even above the cap, and a natural person CHF 700,000 or twice the benefit |
| Breach of the Basisinformationen duties of TVTG Art. 30 ff. | fine up to CHF 100,000 |
| Practising a trustee activity without authority; offering one without authority | up to one year or 360 daily rates; FMA fine up to CHF 100,000 |
Sources: EWR-MiCA-Durchführungsgesetz; TVTG; Trustee Act (TrHG).
Problems we solve
"Is a token launch just paperwork?"
No. An offer made without meeting MiCAR Art. 4(1), 5(1), 16(1), 17(1) or 48(1) is a criminal offence, up to three years. The risk table above sets out the rest.
"Small offers are exempt"
Only the Basisinformationen duties of TVTG Art. 30 lit. a and b fall away, for fewer than 150 users or a total sale price up to CHF 5 million. The notification to the FMA stays; a breach is fined up to CHF 100,000.
"I need a registration and CHF 50,000 capital"
Not as an issuer offering in its own name, who is not subject to registration but follows TVTG Art. 30 to 38. Registration and the capital tiers concern an issuer acting for a client; the lowest tier is CHF 50,000.
"White paper or Basisinformationen?"
Two documents for two token populations: the MiCAR white paper inside MiCAR, the TVTG Basisinformationen outside it. The licensed partner settles which one yours needs.
"A stablecoin or a tokenised share"
An ART is reserved to licensed credit institutions and Art. 21 holders. A security token is a MiFID II case outside MiCAR, and that question is settled first. Neither is a start-up default.
Ready to scope your token offering?
Send the token description. The licensed partner classifies it; we coordinate the file.
Why work with us
Nadine Koller, Schaan; works in German, English and Italian. She assembles the facts, governance and capital evidence of an FMA filing, which the licensed partner reviews and files.
The licensed trustee (TrHG) or lawyer (RAG) classifies and files, the FMA supervises, ABB coordinates.
From our practice
The token is classified by the licensed partner before any document is drafted. whether you issue in your own name or for a client is settled early, because it decides whether a registration is needed. the issuer answers for the document it publishes, so the persons responsible sign their declaration before filing.
Frequently asked questions
Do I need a licence to issue a token in Liechtenstein?
It depends on the token. An other crypto-asset may be offered without authorisation if MiCAR Art. 4 and the following articles are met. An asset-referenced token may be offered only by a licensed credit institution or an Art. 21 authorisation holder. Offering without meeting the conditions is a criminal offence, so the licensed partner classifies your token first.
Is a white paper approved by the FMA, or only notified?
The sources behind this page do not say how the FMA treats an other-crypto-asset white paper in practice. The fee annex lists a CHF 500 item for transmitting a white paper and a CHF 20,000 item for approval and the Art. 17 examination, which sits with the ART route. We promise no review and no time.
Is it true that small offers (under 150 people or CHF 5 million) need nothing at all?
No. For a token outside MiCAR, an offer to fewer than 150 users or with a total sale price up to CHF 5 million drops only the Basisinformationen duties of Art. 30 lit. a and b. The notification of the issuance to the FMA stays, and a breach of Art. 30 ff. is fined up to CHF 100,000.
Can I issue a token in my own name without registering with the FMA?
Yes, for a token outside MiCAR. An issuer offering in its own name is not subject to registration, but Art. 30 to 38 of the TVTG still apply to the offer. Registration with the FMA, and the capital tiers that come with it, concern an issuer acting for a client. The licensed partner settles which case you are.
What happens if I offer a token to the public without a white paper?
Offering other crypto-assets to the public without meeting MiCAR Art. 4(1) or 5(1) is a criminal offence, up to three years before the Landgericht. The same ceiling applies to ART and EMT offers without Art. 16(1), 17(1) or 48(1). The FMA can also fine white-paper breaches, up to CHF 1,000,000 for a legal person, more if serious, repeated or systematic.
What is the difference between the MiCA white paper and the TVTG Basisinformationen?
They are two documents for two token populations. The crypto-asset white paper belongs to MiCAR and is transmitted to the FMA. The Basisinformationen, the TVTG basic information document, covers tokens outside MiCAR: it is published and the issuance is notified to the FMA before the issue. The two scopes exclude each other.
Which tokens still fall under the TVTG after MiCA?
The TVTG token issuance is defined only for tokens outside MiCAR, and the two scopes exclude each other. TVTG registrations for activities that need a MiCAR authorisation expired on 2 July 2026. Whether a given token is outside MiCAR depends on its facts, so the licensed partner classifies it; this page states no general rule.
Can an NFT be issued under the TVTG?
This page gives no general rule. Whether an NFT falls under the TVTG depends on the token's facts and on what MiCAR leaves out, so the licensed trustee or lawyer classifies it case by case before any document is drafted. ABB collects the facts and does not decide the class.
Who can offer an asset-referenced token or an e-money token?
An asset-referenced token may be offered only by a licensed credit institution or a person holding an authorisation under MiCAR Art. 21. An e-money token is for licensed credit or e-money institutions only. A start-up cannot simply issue a stablecoin-type token, and ABB does not offer the EMT route.
Who is liable to buyers for errors in the white paper or Basisinformationen?
For the Basisinformationen, liability for wrong or missing information cannot be excluded or limited in advance, and an acquirer's claim against an issuer seated in Liechtenstein goes to the Landgericht. The document names those responsible for its content, who declare it correct and complete. For a MiCAR white paper, the issuer answers as offeror.
Is a security token or tokenised share an ICO or a prospectus case?
A token that qualifies as a MiFID II financial instrument is outside MiCAR, and that question is settled first. This page names no prospectus route and no threshold for it. A licensed lawyer confirms which securities rules apply, and ABB collects the facts for that review.
Does issuing a token also allow me to trade or custody it?
No. Issuing a token does not permit custody or trading for others. Those services belong to the CASP regime, covered on our CASP licence page, and operating without FMA authorisation is a criminal offence. ABB does not issue, hold, trade or exchange your tokens.
In which language must the white paper or the Basisinformationen be written?
The Basisinformationen must be created and published in German or English. The language rule for the MiCAR white paper is not stated in the sources behind this page, so we print none. The licensed partner confirms the white-paper language before drafting starts.
Do I need a Liechtenstein company to be the issuer?
The sources behind this page state no seat requirement for an issuer. Where you want a Liechtenstein legal person, a licensed trustee forms it and files the registration; ABB prepares the draft and collects the documents. Registration as a token issuer concerns persons seated in Liechtenstein who act for a client.
How long do I have to keep the document disclosed?
A token issuer registered with the FMA keeps the Basisinformationen disclosed during the issue and for at least ten years afterwards. Whether the same ten-year duty binds an issuer offering in its own name is not verified, so we state none for that case. The licensed partner confirms the period for your route.
Request a token issuance plan
No price and no promised date. One plan with the route, the documents and the actors.
+423 210 0002 · Business Development department · Monday to Friday, 09:30-17:00 (CET/CEST) · Bahnhofstrasse 8, 9495 Schaan