The ZDG covers the professional provision of listed payment services, including transfers, payment-account operations, acquiring, payment-instrument issuance, payment initiation and account information; exclusions must be tested against the actual operating model.
Tax& Law+7 (495) 221 31 46Discuss a matter
ZDG · LR 950.1 · LGBl. 2019 Nr. 213 · Editorial explanation · not an official translation
Liechtenstein ZDG: Payment Services, Licensing and Customer Protection
An independently authored explanation of the official ZDG consolidation effective on 1 August 2025 and current FMA materials. It is not an official translation, the full legislation or confirmation that a particular business model falls within or outside a licence.
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.
A payment institution must obtain FMA authorisation before commencing business; corporate registration alone does not replace review of the licence, programme of operations, governance, capital, internal controls and ownership.
User funds received for payment execution are subject to statutory safeguarding, while the use of agents, outsourcing or technical providers does not remove the licensed institution's responsibility.
Customer documentation must address transparency of charges and timing, strong customer authentication, incident reporting, refunds for unauthorised payments, complaints handling and out-of-court dispute resolution.
02
Governance, safeguarding and operating model
The authorisation file should consistently describe the services, business plan, organisational structure, fitness of management, qualifying owners, risk governance, internal control, security and continuity. Funds received for payment execution must be safeguarded under Article 20 ZDG and may not be treated as ordinary operating finance in a way that transfers the institution's credit risk to users. Agent networks and outsourcing require documented authority, oversight and supervisory access to data. AML, data protection, cyber resilience and contracts with banks and payment systems must be assessed in parallel: a ZDG licence does not displace those separate regulatory layers.
03
User rights, security and disputes
The ZDG requires intelligible pre-contractual and ongoing information about the institution, service, charges, exchange rates, execution timing, communications and termination of a framework contract. Remote access and electronic payments engage strong customer authentication and protection of personalised security credentials. For an unauthorised operation, the baseline rule requires the provider to refund promptly, generally by the end of the following business day, although the result depends on notification, fraud and the user's degree of fault. Providers must maintain an effective complaints process; complaints to the FMA and statutory out-of-court resolution are available without excluding subsequent court proceedings.
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 payment institutions
Open official source ↗FMA ongoing supervision page for payment institutions
Open official source ↗Smart Global Capital
Need to apply Liechtenstein law to a foundation, trust, company or financial structure?
We review the corporate, tax and regulatory perimeter and transition rules and prepare a documented legal position.
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.