The Token and TT Service Provider Act (TVTG) is Liechtenstein’s in-force statutory framework for tokens and services built on trustworthy technology systems. The Act entered into force on 1 January 2020 and remains part of Liechtenstein’s token-law architecture after the implementation of the EU Markets in Crypto-Assets Regulation (MiCAR) through the EEA MiCA Implementation Act. As of 22 July 2026, the TVTG should be read alongside MiCAR: activities now subject to MiCAR authorization have moved out of the TVTG transition regime, while the TVTG continues to address token civil-law concepts, non-MiCAR roles, tokenisation-specific functions, and selected TT service provider obligations.
What the Liechtenstein TVTG covers
The TVTG establishes a legal framework for transaction systems based on trustworthy technology, including blockchain-based systems. Its core civil-law function is to define how tokens can represent rights, how rights may be transferred by disposing of tokens, and how token-related rights are treated under Liechtenstein law. The Act’s definition of a token is broad: a token is information on a TT system that can represent claims, membership rights, property rights, or other absolute or relative rights, and that is assigned to one or more TT identifiers.
This structure is often described as a technology-neutral “token container” approach. Rather than treating every token as a single asset class, the framework focuses on the right or claim represented by the token and on the legal effect of disposing of that token within a TT system. The Act also includes provisions for token cancellation where a TT key is lost or a token is otherwise non-functional.
Registration and supervision of TT service providers
The TVTG gives the Financial Market Authority Liechtenstein (FMA) responsibility for registration and supervision of TT service providers. Persons with a registered office or residence in Liechtenstein that intend to provide TT services professionally in Liechtenstein must generally apply to be entered in the FMA’s TT Service Provider Register before providing the service for the first time. Registration is tied to requirements such as reliability, technical suitability, organizational structure, internal control mechanisms, and minimum capital where applicable.
The Act also provides a simplified registration route for specified financial institutions already licensed under financial-market legislation, including MiCAR-authorized institutions when they provide TT services covered by the TVTG. The FMA maintains a public register, monitors compliance, may request information or documents, may order or carry out extraordinary audits and on-site inspections, and may temporarily prohibit the exercise of a TT service where necessary.
Token issuance, custody, and user protection
For token issuances outside the scope of MiCAR, the TVTG generally requires token issuers to prepare and publish basic information and notify the FMA before issuing tokens, subject to statutory exceptions. That basic information must be prepared in an understandable form and include information about the tokens, associated rights, the TT system used, purchase and transfer conditions, risks, and responsible persons.
The TVTG also contains safeguards for tokens and TT keys held for customers. Tokens or TT keys held in custody on a fiduciary basis or in the customer’s name are treated as third-party property in specified enforcement and insolvency proceedings and are segregated in favor of the customer. The Act also requires relevant records and supporting documents to be kept for supervisory purposes for at least ten years.
Relationship with MiCAR
MiCAR changed the perimeter of Liechtenstein crypto regulation. The FMA states that MiCAR covers activities previously regulated largely by the TVTG and that Liechtenstein implemented MiCAR through the EEA MiCA Implementation Act, which entered into force on 1 February 2025. The TVTG transitional provisions allowed certain registered TT service providers to continue under the prior regime until an Article 63 MiCAR authorization decision, but no later than 1 July 2026. The FMA announced that TVTG registrations expired as of 2 July 2026 for activities subject to MiCAR authorization.
For editorial classification, the TVTG remains an in-force Liechtenstein Act. Its current profile is best understood as a national token and TT-service framework narrowed by MiCAR, not as a standalone substitute for MiCAR authorization for in-scope crypto-asset services.