Crypto-asset service providers: Procedures pursuant to Articles 60 and 63 MiCAR
This page is addressed to persons who plan to submit a (preliminary) application pursuant to Article 63 MiCAR (see "(Preliminary) applications pursuant to Article 63 MiCAR" below), as well as to financial entities already licensed in Liechtenstein by the FMA and listed in Article 60 MiCAR (credit institutions, central securities depositories, investment firms, electronic money institutions, UCITS management companies, alternative investment fund managers, and market operators within the meaning of Directive 2014/65/EU) wishing to provide the crypto-asset services listed in Article 60 MiCAR (see "Notifications pursuant to Article 60 MiCAR" below).
The FMA has been available for informal preliminary discussions since June 2024. Since October 2024, it has been accepting initial documents and information in the form of preliminary applications. With the entry into force of the EWR-MiCA-DG on 1 February 2025, MiCAR has been pre-implemented in Liechtenstein. Since then, interested parties have been able to submit regular applications pursuant to Article 63 MiCAR.
(Preliminary) applications pursuant to Article 63 MiCAR
As part of the ordinary authorisation procedure, applicants must actively demonstrate to the FMA that they meet the authorisation requirements. The procedures set out in MiCAR are extremely strict in terms of timing. Since the step-by-step development of an application within these deadlines is possible only to a very limited extent, complete and high-quality applications are an essential prerequisite for obtaining authorisation.
Against this background, we recommend the following:
- Familiarise yourself thoroughly with the European authorisation requirements and assess at an early stage whether and how you can provide the required evidence.
- Take advantage of the opportunity to submit preliminary applications. Please note that preliminary applications are also expected to be as complete and high-quality as possible.
- As needed, seek economic and legal advice and, where appropriate, representation from experts experienced in financial market authorisation procedures.
If you are interested in submitting a (preliminary) application, you can contact the Fintech Unit at casp[at]fma-li.li. After an informal preliminary discussion, you will be provided with the necessary documents for submitting the required information.
Notifications pursuant to Article 60 MiCAR
In contrast to an application pursuant to Article 63 MiCAR, a notification pursuant to Article 60 MiCAR requires only the complete submission of the information specified in paragraph 7. For as long as the notification remains incomplete, the financial institution concerned may not provide crypto-asset services. The FMA reviews the submitted information for both formal and material completeness. The information is considered materially complete only if it is at least conclusive, consistent, and not manifestly inappropriate. It should be noted that this entails a significant effort in terms of description and justification.
If you are interested in submitting a notification, you can contact the Fintech Unit at casp[at]fma-li.li. After an informal preliminary discussion, you will be provided with the necessary documents for submitting the required information.