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.
1. From voluntary pilot to hard-law obligation
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.
2. Core mechanics of the CARF-G
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.
3. Interaction with the revised CRS
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+.
4. Transitional relief & governance
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..
5. Business implications – why stakeholders should act now
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:
- mapping of token flows against CARF reportable events;
- upgrading onboarding questionnaires to capture digital-asset indicators;
- revisiting cross-border client agreements, especially with U.S. persons under the adjusted FATCA scheme; and
- implementing secure APIs that segregate CARF data from classic CRS files yet allow consolidated oversight.
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
- Go-live date: first reportable period starts 1 January 2026; data exchange begins 2027.
- Scope expansion: CARF captures crypto-asset transactions; CRS 2023+ now covers e-money and CBDCs.
- Single-standard principle: Liechtenstein applies the revised CRS to all counterparties from day one.
- Reciprocity & peer review: data will flow bidirectionally; compliance quality will be externally assessed.
- Operational urgency: providers need new diligence procedures, IT pipelines and contract language in 2025.
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