Liechtenstein DSG

Data Protection Act 2018 (Datenschutzgesetz, DSG) + Communications Act (Kommunikationsgesetz, KomG)

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LiechtensteinOpt-inNational
ePrivacy Directive
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Key Facts

Effective Date
January 1, 2019
Enacted
October 4, 2018
Enforcing Authority
DSS (Datenschutzstelle — Data Protection Authority)
Consent Model
Opt-in
Applies To
Any entity processing personal data of individuals in Liechtenstein, including through cookies

Overview

Liechtenstein implements the GDPR through its Data Protection Act 2018 (DSG) and the ePrivacy Directive through the Communications Act (KomG). While the DSG is fully GDPR-aligned via EEA Decision 154/2018, the KomG has not been fully updated for the 2009 ePrivacy amendments that introduced strict opt-in cookie consent.

What This Means for Your Website

  • Informed consent is required for non-essential cookies under the combined DSG and KomG framework
  • GDPR consent standards apply through the DSG
  • Penalties match GDPR scale: up to CHF 22 million or 4% of global turnover
  • The Datenschutzstelle actively regulates data protection compliance

Key Requirements

The Datenschutzstelle (DSS) enforces data protection with GDPR-scale penalties in two tiers: CHF 11 million or 2% of turnover (Tier 1) and CHF 22 million or 4% of turnover (Tier 2). The potential gap in cookie-specific provisions due to the KomG not being fully updated means GDPR consent principles apply through the DSG as the primary framework.

How ConsentStack Handles This

ConsentStack applies GDPR-compliant opt-in consent for Liechtenstein visitors, ensuring compliance with both the DSG and KomG requirements regardless of the implementation gap.

Penalties

Up to CHF 11 million or 2% of global annual turnover (Tier 1). Up to CHF 22 million or 4% of global annual turnover (Tier 2).

Maximum Fine
CHF22,000,000 aggregate
Revenue-based
4% of annual revenue

Key Requirements

  • Informed consent for non-essential cookies through DSG and KomG
  • Consent must meet GDPR standards via DSG
  • Users must be informed about purposes of processing
  • Right to file complaints with the Datenschutzstelle
  • Data subject rights aligned with GDPR

Notable Provisions

  • KomG not fully updated for 2009 ePrivacy amendments
  • GDPR-aligned penalty structure (CHF 11M/22M)
  • EEA member applying GDPR through EEA Decision 154/2018

Other ePrivacy Directive Related Regulations

Loi Informatique et LibertésFrance
France has the most actively enforced cookie regime in Europe. CNIL issued 259 corrective decisions in 2025, with cookie-specific fines totaling EUR 486.8 million including EUR 325M against Google. A Refuse all button or Continue without accepting must appear on the first layer.
SI 336/2011Ireland
Ireland implements the ePrivacy Directive through SI 336/2011. The DPC is the lead supervisory authority for major tech companies headquartered in Ireland including Meta, Google, Apple, and Microsoft. Uniquely, cookie consent is limited to 6 months and must then be refreshed.
TDDDGGermany
Germany implements the ePrivacy Directive through Section 25 of TDDDG (renamed from TTDSG in May 2024). A Consent Management Ordinance (EinwV) became effective April 2025, establishing a voluntary framework for recognized consent management services. Cookie banners must not obscure website content.
Dutch Telecom ActNetherlands
The Netherlands implements the ePrivacy Directive through Article 11.7a of the Telecommunications Act. The AP launched a major enforcement sweep in April 2025, warning 50 organizations for misleading cookie banners or placing tracking cookies without consent. Cookie walls are not permitted.
Italian Privacy CodeItaly
Italy implements the ePrivacy Directive through Article 122 of the Privacy Code with detailed Garante cookie guidelines effective January 2022. Only technically necessary cookies may load by default. Scrolling is not valid consent, and closing a banner with "X" closes it without granting consent.
LSSISpain
Spain implements the ePrivacy Directive through Article 22 of the LSSI. Cookie violations are classified as slight offenses with EUR 30,000 fines per URL, but multiple URLs multiply penalties. AEPD allows consent-exempt analytics under privacy-friendly configurations, similar to CNIL.
Danish Cookie OrderDenmark
Denmark implements the ePrivacy Directive through the Cookie Order (Cookiebekendtgørelsen), administered by the Danish Business Authority. Cookie consent is a declared 2026 enforcement priority for Datatilsynet, which will examine whether Danish websites give users a genuine choice.
Portuguese ePrivacy LawPortugal
Portugal implements the ePrivacy Directive through Law 41/2004, with a distinctive tiered penalty structure distinguishing between large companies, SMEs, and natural persons. The CNPD issued 90 fines totaling EUR 559,950 in 2023, demonstrating active enforcement.
Polish Telecommunications LawPoland
Poland implements the ePrivacy Directive through Articles 173-174 of the Telecommunications Law. While Article 173(2) technically permits consent via browser settings, PUODO recommends active consent. Since 2019, Article 174 requires cookie consent to meet full GDPR standards.
Norwegian E-Com ActNorway
Norway's January 2025 amendment to Ekomloven marked a major shift from tolerating passive consent to strict opt-in. Pre-ticked boxes and browser settings are now explicitly invalid. Accept and reject options must have equal prominence. Datatilsynet sanctioned 6 websites for tracking pixel violations.
Belgian E-Communications ActBelgium
Belgium enforces strict cookie consent with one of the EU's most active DPAs. Cookie walls are prohibited, and a Reject all button must appear on the first layer with equal prominence to Accept all. Dark patterns in cookie banners are actively enforced against.
LEKSweden
Sweden implements the ePrivacy Directive through Chapter 9 Section 28 of LEK. In April 2025, IMY issued a landmark reprimand against Aller Media for dark patterns in cookie banners. Less than 25% of Swedish users accept cookies, reflecting strong privacy awareness.

Other Europe Regulations

GDPREuropean Union + EEA
The GDPR sets the global standard for data protection, requiring explicit opt-in consent before processing personal data of EU/EEA residents. For websites, non-essential cookies must be blocked until visitors actively consent. Pre-ticked boxes and implied consent are invalid.
PECRUnited Kingdom
PECR is the UK's cookie-specific law, requiring consent before storing or accessing cookies. The DUAA 2025 significantly increased penalties from GBP 500,000 to GBP 17.5 million and introduced analytics exceptions on an opt-out basis. Only strictly necessary cookies are exempt.
ePrivacy DirectiveEuropean Union + EEA
Article 5(3) of the ePrivacy Directive is the primary EU legal basis requiring cookie consent. It mandates prior informed consent before storing or accessing any information on a user's device, with narrow exceptions only for transmission necessity and explicitly requested services.
Loi Informatique et LibertésFrance
France has the most actively enforced cookie regime in Europe. CNIL issued 259 corrective decisions in 2025, with cookie-specific fines totaling EUR 486.8 million including EUR 325M against Google. A Refuse all button or Continue without accepting must appear on the first layer.
UK GDPRUnited Kingdom
The UK GDPR is the retained EU GDPR post-Brexit, with consent standards identical to the EU version. The UK adequacy decision was renewed December 2025, valid until December 2031. Combined with PECR, it forms the legal framework for cookie consent in the UK.
TDDDGGermany
Germany implements the ePrivacy Directive through Section 25 of TDDDG (renamed from TTDSG in May 2024). A Consent Management Ordinance (EinwV) became effective April 2025, establishing a voluntary framework for recognized consent management services. Cookie banners must not obscure website content.

Frequently Asked Questions

Does Liechtenstein follow GDPR cookie rules?

Yes. Liechtenstein applies the GDPR through EEA Decision 154/2018 via its Data Protection Act 2018. GDPR consent standards apply to cookies.

What are the penalties in Liechtenstein?

Up to CHF 22 million or 4% of global turnover — matching GDPR-scale penalties. The Datenschutzstelle enforces these in two tiers.

Is there a gap in Liechtenstein cookie law?

The Communications Act (KomG) has not been fully updated for the 2009 ePrivacy amendments. GDPR consent principles through the DSG fill this gap.

Stay compliant with Liechtenstein DSG

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