From 1 February 2025, banking and investment regulation is divided among BankG, WPDG, WPFG and HPBG together with directly applicable or implemented EEA rules.
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BankG · WPDG · WPFG · HPBG · effective 2025-02-01 · Editorial explanation · not an official translation
Liechtenstein's New Banking and Investment-Firm Framework
An editorial explanation of FMA's official overview of the regime effective from 1 February 2025. The overview explains the allocation of sources and selected changes but does not replace the statutes, FMA instruments or an individual licensing analysis.
Editorial explanation · not an official translation
Key takeaways
This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.
BankG governs banks and financial holding companies together with the CRR; WPFG and the IFR cover the prudential regime for investment firms.
WPDG governs investment services and conduct of business, while HPBG governs trading venues including MTFs, OTFs and systematic internalisers.
The new BankG revises core definitions and the catalogue of banking activities and places risk-management and compliance-function requirements at statutory level.
Bank management and board functions require prior FMA approval; for significant banks that control extends to holders of key functions.
Licence expiry or withdrawal no longer automatically dissolves the company; open banking transactions must be settled and FMA appoints a liquidator when an operating bank's licence is withdrawn.
01
Four legislative pillars
FMA describes four connected pillars rather than one universal banking statute. BankG with the CRR covers banks and financial holding companies; WPFG with the IFR covers prudential rules for investment firms; WPDG covers investment services and market conduct; HPBG covers the operation and supervision of trading venues and exchanges. Simultaneous commencement of the statutes and implementing instruments does not make their licences interchangeable. The entity, service and infrastructure must first be classified before the applicable package and FMA process can be identified.
02
BankG, governance and control functions
The new BankG aligns the concepts of bank, deposit, credit and professional activity more closely with EEA law and revises the catalogue of banking activities. FMA highlights prior approval of management and board members and, for significant banks, key-function holders, separation of front and back office, and statutory risk-management and compliance functions. Changes to internal business rules may require approval. A bank project is therefore assessed on more than capital and a business plan: allocation of functions, fitness and propriety, control independence, operating model, CRR and secondary rules are central.
03
Licence, withdrawal and operational wind-down
The new regime separates licence expiry or withdrawal from corporate termination. FMA's overview states that, after 1 February 2025, withdrawal follows settlement of outstanding banking transactions; where an operating bank loses its licence, FMA appoints a liquidator to wind down those transactions. Expiry or withdrawal does not automatically liquidate the company. That distinction matters for exit planning, client protection, contracts, management of assets and liabilities and corporate decisions: ending regulated business and terminating the legal person are separate processes.
LILEX · LLV · FMA
Official sources
This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.
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Discuss the legal positionEditorial explanation · not an official translation. This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.