Hardly any other European financial centre has managed, within such a compact geographic perimeter, to translate the ever-accelerating OECD agenda on tax transparency into binding domestic law as swiftly and thoroughly as the Principality of Liechtenstein; and yet, with the draft Crypto-Asset Reporting Framework Act (“CARF-G”) and the amending statute to the Automatic Exchange of Information Act (“AIA-G-rev”), the country is about to raise the bar once again, preparing both the market and its supervisory ecosystem for a first bilateral and multilateral exchange of crypto-asset data for reporting periods beginning 1 January 2026.

What started in 2023 as a political Joint Statement signed by more than forty jurisdictions, thereby announcing the intent to honour the new OECD standards, has now materialised in Vaduz through a comprehensive Government bill covering CARF, the revised Common Reporting Standard (“CRS 2023+”) as well as consequential amendments to FATCA-, AStA- and CbC-legislation. The legislator’s motivation is of strategic nature: only an unrestricted, timely alignment with the global rulebook preserves the legal certainty demanded by private clients and regulated entities alike.

While the classic CRS focusses on traditional financial accounts, CARF extends the reporting perimeter to any digital representation of value that can be transferred using distributed-ledger technology, thereby closing the “token gap” that allowed investors to migrate from depositary receipts to unregulated wallets. Under the draft, crypto-service providers with a Liechtenstein nexus must conduct due diligence, collect Tax Identification Numbers, and transmit transaction-level information to the Tax Administration, which in turn forwards the data via the multilateral CARF-MCAA channels to participating partner states.

The CRS 2023+ mirrors digital change as well, explicitly integrating e-money products and central bank digital currencies into the notion of a deposit-taking institution and tightening documentation requirements. To spare financial intermediaries the burden of running parallel legacy and upgraded reporting engines, the bill opts for an “all-in” approach: from 1 January 2026 every Liechtenstein financial institution must apply the revised standard, irrespective of whether the counter-party state has itself moved to CRS 2023+.

Existing virtual-asset service providers obtain a grace period until 31 December 2026 to complete their CARF registration, yet only if the foreign state to which they have a stronger nexus has not enacted corresponding duties meanwhile; the Government may temporarily loosen nexus rules by ordinance to avoid double compliance frictions. Enforcement will combine routine AML-KYC reviews with targeted, risk-based audits, anticipating future OECD peer-review scrutiny and aligning with the principality’s Financial-Centre Strategy..

Because CARF-G is designed as a reciprocal regime, Liechtenstein-resident crypto-asset users will receive unprecedented transparency towards foreign tax authorities, while service providers face novel data-management, IT-security and contractual-law questions. Early adoption projects should therefore encompass:

Bergt Law’s interdisciplinary team – combining regulatory and fintech expertise – is already supporting institutions on sandbox simulations, governance frameworks and negotiations with technology vendors. For tailored assistance please contact us via bergt.law/en.

Sources: Report And Motion Concerning CARF, AIA, FATCA, ASTA, CBC, No. 47/2025.

Key take-aways at a glance

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