MiCAR governs public offers and admission to trading of ARTs, EMTs and other cryptoassets and ten categories of CASP services.
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EWR-MiCA-DG · Regulation (EU) 2023/1114 · TVTG · LGBl. 2026 Nr. 277 · Editorial explanation · not an official translation
MiCAR and TVTG in Liechtenstein After the Transition Period
An editorial explanation of the current EWR-MiCA-DG, MiCAR and TVTG interaction after the transition ended on 1 July 2026. It does not confirm a token classification, product permissibility or any provider's authorisation.
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.
ART activity is reserved to credit institutions or Article 21 authorisation holders, EMT activity to credit and e-money institutions, and CASP services to specified financial entities or Article 63 authorisation holders.
The Article 143(3) MiCAR transition ended on 1 July 2026; TVTG registrations expired from 2 July for activities requiring MiCAR authorisation.
Cross-border EEA passporting is available only after the relevant MiCAR status has been obtained.
TVTG has not disappeared: it and MiCAR operate in mutually exclusive fields, while a model with different elements may require permissions under both frameworks.
Before applying MiCAR, the asset must be tested under MiFID II; a cryptoasset that is a financial instrument is excluded from MiCAR and follows another financial-law regime.
01
Classification and regulated activities
The regulatory route begins by classifying the asset and every service. MiCAR covers ARTs, EMTs, other cryptoassets and custody, trading-platform operation, exchange for funds or cryptoassets, execution and placing, reception and transmission of orders, advice, portfolio management and transfer services. A public offer of another cryptoasset may not require authorisation but remains subject to Articles 4 et seq. If the asset is a MiFID II financial instrument, it falls outside MiCAR, so a marketing label such as 'token' does not determine the regime.
02
The transition has ended
The EWR-MiCA-DG took effect on 1 February 2025 and the Article 143(3) MiCAR transition ended on 1 July 2026. FMA expressly announced that TVTG registrations expired from 2 July 2026 for activities requiring MiCAR authorisation. An earlier registration therefore no longer permits continuation of CASP activity brought within MiCAR. Article 59(1)(b) financial entities use the Article 60 route, while other providers require Article 63 authorisation; EEA passporting arises only after the proper authorisation is in place.
03
TVTG and MiCAR coexistence
TVTG continues as the national token-law framework in fields outside MiCAR; when MiCAR was implemented, its scope was adjusted so that the two regimes apply to mutually exclusive subject matter. FMA identifies NFTs as a possible example where an asset genuinely outside MiCAR may remain under TVTG, but an exclusion cannot be decided from the name or asserted uniqueness alone. Where a business model combines different assets and services, separate elements may require MiCAR authorisation and TVTG registration or permission. The analysis must cover the product, functions, clients, territory and every service.
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.