LIECHTENSTEIN: the 2026 trust reform from a comparative perspective

Abstract The 2026 Liechtenstein Trust Reform aims to enhance the jurisdiction’s reputation by strengthening trust governance and eliminating control-free trusts. The reform was triggered by a 2018 Supreme Court ruling that denied discretionary beneficiaries the right to information, leading to situations where only the trustee was involved in trust governance. To resolve this enforcement deficit, the new legislation introduces the information holder, a mandatory role similar to a trust enforcer in other trust jurisdictions. The information holder is granted broad rights to receive information and annual reports, as well as the power to initiate judicial supervisory proceedings. While the settlor has the autonomy to designate this person (e.g. a beneficiary, the settlor, or a third party) the information holder carries a fiduciary duty and is liable for breaches of that duty. Significantly, the reform shifts the Liechtenstein trust model away from traditional English trust principles toward a regime resembling the Cayman Islands’ STAR Trust. Under these new rules, beneficiaries (both fixed and discretionary) generally lose their direct supervisory roles and rights to information, as these functions are transferred to the information holder. This legal transplant of the STAR Trust model raises questions regarding the applicability of traditional English trust precedents and international recognition.