The EGG regulates the professional issuance of electronically or magnetically stored monetary value representing a claim on the issuer, issued after receipt of funds for payments and accepted by persons other than the issuer.
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EGG · LR 950.3 · LGBl. 2011 Nr. 151 · Editorial explanation · not an official translation
Liechtenstein EGG: Electronic Money and Issuer Licensing
An independently authored explanation of the official EGG consolidation effective on 1 July 2025 and FMA materials. It is not an official translation, the full legislation or a ready-made classification of a token, wallet or payment product.
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.
Before issuing electronic money in Liechtenstein, an institution needs FMA authorisation; the licence may also cover listed payment and related services but does not turn received funds into bank deposits.
Electronic money is issued at par against received funds and is generally redeemed at par on the customer's request; redemption terms and any permitted fees must be disclosed clearly in advance.
Customer funds are safeguarded, while an e-money token may also engage MiCAR; EGG, ZDG, MiCAR, AML and operational-resilience analysis should be assembled into one product map.
02
Capital, safeguarding and control
An institution must maintain the statutory capital and own funds in light of issuance volume and ancillary services, together with sound governance, internal control, accounting, audit and risk procedures. Amounts received for e-money issuance or for an unrelated payment transaction are safeguarded through the cross-reference to Article 20 ZDG; the FMA may prescribe a particular safeguarding method in light of the actual model. Material changes to safeguarding arrangements are notified to the FMA in advance. Outsourcing remains permissible only with governability, oversight, confidentiality and data access preserved, while records and evidence are retained for the statutory period. These controls belong not only in the licence file but in daily reconciliation, treasury and exit planning.
03
Issuance, redemption and adjacent regimes
The issuer issues e-money at par against the funds received and, on request, returns the monetary value to the customer at par. Before the customer is bound, the contract must state redemption terms clearly; a fee is allowed only in statutory circumstances, where agreed and proportionate to actual cost. When the instrument is also used for payments, ZDG contractual and security rules engage. If the product is an e-money token, official FMA material identifies parallel MiCAR application, including issuer, white-paper and notification requirements; registration under a technology or token regime does not replace EGG authorisation. AML, sanctions, data protection, marketing and jurisdiction-by-jurisdiction distribution require separate review.
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.
FMA authorisation page for e-money institutions
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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.