FMA Liechtenstein: MiCAR transition period has ended and TVTG registrations have expired
The Financial Market Authority Liechtenstein (FMA) has announced that the transition period under Article 143(3) of MiCAR ended on 1 July 2026. In a notice published on 7 July 2026 under its "Supervision and Regulation" category, the authority stated that registrations under the TVTG have accordingly expired as of 2 July 2026, with respect to activities subject to authorisation under MiCAR.
The FMA gave the legal basis for that expiry as Section II, Paragraph 2 (Transitional Provisions) of the Act of 5 December 2024 amending the TVTG, published as LGBl. 2025 No. 113. It added that the corresponding entries in the FMA register are being updated on an ongoing basis, and directed readers to the ESMA register for an overview of providers of crypto-asset services authorised under MiCAR. That is the whole of the announcement.
What the end of the MiCAR transition period means for Liechtenstein
MiCAR is Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and Article 143 contains its transitional measures. ESMA describes the relevant paragraph as a "grand-fathering" clause, Art. 143 (3), "allowing entities providing crypto-asset services in accordance with national applicable laws before 30 December 2024 to continue to do so until 1 July 2026 or until they are granted or refused a MiCA authorisation." The end date is therefore fixed in the Regulation itself rather than set nationally, and the clause always ran to whichever of the two events came first.
Liechtenstein is not an EU member state but is part of the European Economic Area, so MiCAR reaches it through EEA incorporation. The FMA explains that the Regulation is implemented through the Law implementing Regulation (EU) 2023/1114 on Markets in Crypto-Assets (EWR-MiCA-DG), which entered into force on 1 February 2025. Its standing guidance on MiCAR in Liechtenstein had already stated that TT service providers whose business model falls under MiCAR could continue operating under the TVTG during the transitional period running until 1 July 2026, and that registered TT service providers "must therefore obtain authorisation in accordance with Article 63 MiCAR by 1 July 2026" to continue beyond that date. The July notice confirms that this window has closed.
Why did TVTG registrations expire on 2 July 2026?
The one-day offset between the two dates is the detail most easily misread. The transition period ended on 1 July 2026, meaning 1 July was the last day it covered. The expiry of the TVTG registrations is dated the following day, the first day on which the affected activities were no longer covered by a national registration.
The FMA does not present that expiry as a discretionary supervisory act. It points to the transitional provisions of the December 2024 amending act, so the registrations lapsed by operation of that provision rather than by individual decision. Note also how tightly the expiry is scoped: it applies "with respect to activities subject to authorization under MiCAR", and on the face of that wording says nothing about TVTG registrations covering activities outside MiCAR's authorisation scope.
What is the difference between a TVTG registration and a MiCAR authorisation?
The announcement turns on that difference. Under the TVTG, providers appeared on the FMA register as registered TT service providers. Under MiCAR, the operative status is an authorisation as a crypto-asset service provider granted in accordance with Article 63. A firm does not move from one to the other automatically, which is why a transition period was needed at all.
The practical consequence the FMA singles out is market access: cross-border activities within the EEA, that is passporting, "will be possible only once an authorisation as a crypto-asset service provider has been obtained." On the FMA's own account a TVTG registration never conferred that. For anyone assessing a counterparty, the useful discipline is to stop treating "regulated in Liechtenstein" as a single status, and to ask instead which status, under which instrument, for which activities, and as at which date.
How can you check whether a crypto-asset service provider is still authorised?
The FMA points to two places and is candid that one of them is in motion. Its own register entries, it says, are being updated on an ongoing basis, which is a plain statement that the register was not fully reconciled when the notice was published on 7 July 2026. An entry read shortly after the deadline could still reflect a status that had already lapsed in law. For the new regime, the FMA directs readers to the ESMA register, where an overview of providers authorised under MiCAR can be found.
One caution about the source itself: the English version of the FMA notice carries an explicit disclaimer that the content "has been translated using a fully automated machine translation tool" and that "some content may not be accurately translated." Where a legal consequence turns on exact wording, and the scoping phrase quoted above is exactly such a phrase, the German original and the underlying act are the texts to rely on.
What does the FMA announcement not say?
Worth stating plainly, because a short regulatory notice invites readers to fill the gaps from memory. The announcement gives no figures at all. It does not say how many TVTG registrations expired, how many Liechtenstein firms obtained MiCAR authorisation before the deadline, or how many applications were pending, granted or refused, and it names no firms.
It also sets no further dates: no completion date for the register update, no wind-down period for affected activities, and no description of the supervisory consequences for a provider that continues a MiCAR-scope activity without authorisation. Any such detail, if it exists, lives in the amending act or in later communications rather than in this notice. What the notice does do is fix two dates, identify the provision behind them, confirm the register is being brought into line, and name where the successor status can be verified.
Source: FMA Liechtenstein