Pursuant to Article 12(1) TVTG, legal and natural persons with headquarters (registered office) or place of residence in Liechtenstein who wish to professionally act as TT Service Providers must apply to be entered into the TT Service Provider Register (hereinafter "registration") in writing with the FMA before beginning their activity.

This also applies to Token Issuers who issue tokens in their own name or in the name of a client in a non-professional capacity if tokens in the amount of CHF 5 million or more will be issued within a period of 12 months (Article 12(2) TVTG).

The FMA fintech self-service offers initial rough guidance if you are unsure whether your business model contains a TT service. In addition, we recommend comprehensive legal advice in all cases. In the event of ambiguities or uncertainties, it is recommended to also submit a subordination enquiry with the FMA.
FMA Instruction 2020/2 – Enquiries under the TVTG

Direct form for subordination enquiries

Entry in the TT service register is on application (Article 12 in conjunction with Article 18 of the TVTG). Registration is performed only if all requirements set out in Article 13 TVTG have been met. Information needing to accompany the application can be found in FMA Instruction 2020/1.

FMA Instruction 2020/1 – Registration as a service provider under the TVTG

In accordance with Article 19(2) of the TVTG, the FMA will make a decision on full applications within three months. Registration is made at no charge and without formal decision per entry in the TT service provider register.

The TT Service applied for may be performed only after entry in the TT Service Provider Register.