European Union/LI/Comparables
Liechtenstein
FMA Liechtenstein
The first comprehensive token statute in Europe, still in force, and the civil-law cousin of MiCA. TVTG registers VT service providers, writes token ownership into statute, and classifies tokens. It is an intermediary-plus-property-law file. It is not an offering exemption, and it does not passport into the Union.
TVTG
1 Jan 2020
EEA
Yes
MiCA overlap
Live
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
Token property law + VTSP registration
- In force
The Article 109 / NOR publicity function, for intermediaries
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 | TVTG token as a legal object; payment / utility / security | Partial | Property-law token, not a Howey wrapping. |
| Rule 103 | Basic information requirements on token issuers / VTSPs | Partial | Shorter, civil-law, not a 1-CRYPTO circular. |
| Rule 200 / 300 | No dollar-capped public-offer exemption | No analogue | Registration of the service provider is the gate. |
| Rule 500 | No Union passport from TVTG alone | No analogue | EEA membership plus MiCA now does the passporting work. |
Analysis
What the file is
TVTG entered into force on 1 January 2020. It does two things US federal law still does not: it says a token can be an object of civil-law rights, and it registers a catalogue of VT service providers (issuance, key custody, price vending, exchange, identity service). FMA Liechtenstein keeps a public register. Since MiCA applied, Liechtenstein as an EEA state lives in both books. TVTG’s property-law chapter remains the distinctive piece.
Research
The record
- TVTG is not a substitute for MiCA inside the Union. A Liechtenstein VTSP registration does not authorise a CASP in Frankfurt.
- The “container model” (the token as a container for rights) is the conceptual ancestor of a lot of later tokenisation statutes, including the Swiss DLT Act’s ledger-based security.
Ideation
What to file
- Rule 400 comments: ask what legal object remains after the CIC is deemed not to exist. TVTG has an answer. The proposing release mostly does not.
- Do not propose that the SEC register “VT service providers.” That is a Title V / CASP comment for a different paper.
Analysis
What the file is
TVTG entered into force on 1 January 2020. It does two things US federal law still does not: it says a token can be an object of civil-law rights, and it registers a catalogue of VT service providers (issuance, key custody, price vending, exchange, identity service). FMA Liechtenstein keeps a public register. Since MiCA applied, Liechtenstein as an EEA state lives in both books. TVTG’s property-law chapter remains the distinctive piece.
Primary sources on file
Token- und VT-Dienstleister-Gesetz (TVTG)
Liechtenstein Law Gazette/1 Jan 2020/RCA review 8 Sept 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.