Liechtenstein as a Regulatory Venue: 5 Practical Facts on Gambling Law

Liechtenstein has developed a modern, EEA-compatible gambling framework that combines market access with strict requirements on governance, integrity, player protection, and AML/CFT.

For operators, investors, payment providers, and platform businesses, success in this jurisdiction depends less on commercial positioning and more on a robust compliance architecture and regulatory resilience.

1. Key Takeaways

• System shift (2016): A police-permit model replaced concession-style selection. If statutory requirements are met, a permit is generally granted as a matter of entitlement.

• Capital metrics: Minimum share capital of CHF 5,000,000 plus an ongoing equity ratio of 30% of total assets or 20% of gross gaming revenue (whichever is higher).

• Compliance core: UBO transparency (from 5% voting rights), security concept (surveillance/IT/data retention), and strict SPG/AML duties involving EAKS and FIU reporting.

• Player protection: Mandatory social concept and a central player-ban register; exclusion processes are a key supervisory focus.

• Online & Moratorium: No lawful online gambling offering exists while the moratorium applies (Casino permits suspended until 31.12.2025; Online concessions until 31.12.2028).

2. 2016: Permits Instead of Concessions — Transparency Instead of Discretion

The current architecture was shaped by a prolonged dispute over concession allocation that reached the highest level of judicial review. In response, the Gambling Act was fundamentally revised in 2016.

Since then, casino operations are permitted via a police-permit model: where the statutory criteria are satisfied, the applicant generally benefits from a legal entitlement to the permit.

Key point: Permit replaces concession — transparency replaces selection discretion.

3. Legal Framework: GSG as the Core, Purpose as the Compass

The Gambling Act (GSG) is the central statute. Implementation is further specified by secondary legislation, in particular the Casino Ordinance (SPBV), the Online Gambling Ordinance (OGV), and the Lottery and Betting Ordinance (LWV).

Interpretation is strongly guided by the statutory purpose clause: Article 2 GSG provides the teleological compass for open-textured legal standards. Core objectives include:

1. An orderly, secure, and transparent gambling environment.

2. The prevention of money laundering, organized crime, and terrorist financing.

3. Protection against socially harmful effects.

Legal Reception: Parts of the framework are designed with reference to proven models (e.g., Swiss law), increasing coherence and international compatibility. However, reception binds — but not blindly. Departures require objective reasons and must be clearly articulated.

4. Market Access: Capital, UBO Transparency, and Security

Openness is paired with concrete minimum standards. For casinos, the operational hurdles are significant and must be proven prior to licensing.

• Legal form / Seat: Typically AG or SE; in justified cases, a GmbH may be permissible. A seat in another EEA state is possible only in exceptional scenarios (requires comparable licensing, equivalent supervision, and effective legal assistance).

• Minimum Share Capital: CHF 5,000,000.

• Ongoing Equity Ratio: At least 30% of total assets or 20% of gross gaming revenue — whichever is higher — throughout the entire permit period.

• Fit-and-Proper / UBO Disclosure: Disclosure of beneficial owners starting from 5% voting rights, complete documentation, and continuous updates.

• Security Concept (Art. 10 GSG): Strict access controls, continuous video surveillance of relevant areas, IT security (incl. logging), and data retention for at least 45 days.

The practical result: Operation is feasible, but only with demonstrably robust corporate and financial structures.

5. AML and Player Protection as Operating Duties

Casinos fall directly under the Due Diligence Act (SPG) and must implement AML/CFT systems accordingly.

• AML/CFT: Documented compliance concept, use of an electronic accounting and control system (EAKS), proper record-keeping, and active reporting to the FIU.

• Player Protection: A mandatory social concept covers early detection of problematic play, self-exclusion, staff training, limits, and cooperation with specialist services.

• Ban Register: Exclusions are recorded in a central player-ban register valid across all casinos, recording grounds and duration.

6. Moratorium, Online Regime, and Cross-Border Aspects

Moratorium Status (Casinos & Online)

A time-limited admission stop currently applies.

• New Casino Permits: Suspended until 31.12.2025.

• Online Gambling Concessions: Suspended until 31.12.2028.

Pending applications remain unaffected. As long as the online moratorium remains in force, Liechtenstein does not have a lawful online gambling offering.

Key point: A moratorium is time-bound regulation — not a permanent prohibition.

Online Gambling System Logic

Unlike land-based casinos, online gambling requires a government concession (no legal entitlement). Applications are reviewed by the Office of Economic Affairs (AVW) and decided by the Government. Network blocking of unlicensed online providers is currently not part of the Liechtenstein model.

Cross-Border Exclusion

Cross-border cooperation on player bans is a notable policy signal. The underlying logic is social-preventive: where exclusion is imposed to prevent harmful play, protection should not end at the national border.

7. FAQ: Common Regulatory Questions

Who grants permits and who supervises compliance?

The key licensing and operational authority is the Office of Economic Affairs (AVW). The FMA supervises compliance with SPG/AML obligations in this context.

What is the minimum capital requirement for a casino?

The minimum share capital is CHF 5,000,000. Additionally, an ongoing equity ratio of 30% of total assets or 20% of gross gaming revenue (whichever is higher) must be maintained.

Is there lawful online gambling in Liechtenstein right now?

No. Online concessions are suspended until 31.12.2028 due to the moratorium.

How is player protection implemented?

Through a mandatory social concept (early detection, self-exclusion, limits) and a central player-ban register capturing exclusions across all licensed venues.

8. Glossary

• GSG: Gambling Act (Geldspielgesetz); the core statute.

• AVW: Office of Economic Affairs (Amt für Volkswirtschaft); licensing and enforcement authority.

• FMA: Financial Market Authority; AML/SPG supervisor for casinos.

• SPG: Due Diligence Act (Sorgfaltspflichtgesetz); governs AML/CFT duties.

• EAKS: Electronic accounting and control system.

• Police-permit model: A licensing regime where a permit is granted as a matter of right if criteria are met (unlike a discretionary concession).

Call to Action

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