Crypto licence in GeorgiaOverview
Georgia brought virtual asset service providers under regulation through its AML legislation, with the National Bank of Georgia acting as registering and supervisory authority. Providing virtual asset services as a business requires registration with the NBG, and the regime initially concentrated on AML/CFT controls such as customer due diligence, monitoring, record keeping and reporting.
In September 2026 the NBG amended its Rule on Registration, Cancellation of Registration and Regulation of Virtual Asset Service Providers to extend supervision to prudential and operational matters. Minimum supervisory capital is now set by service type: GEL 150,000 for exchange (including via kiosks) or transfer of convertible virtual assets, GEL 350,000 for administering a trading platform and GEL 250,000 for other services. Providers offering several services must meet the highest applicable figure. Core capital must make up at least 75% of regulatory capital, and secondary capital, mainly subordinated debt from owners, is capped at one-third of core capital.
The amendments also introduce a dedicated framework for stablecoins. A provider planning an initial coin offering of a stablecoin must hold at least GEL 500,000, rising with the value of reserve assets, and meet governance, capital and whitepaper requirements under a separate NBG rule. Reserves must be held in liquid assets, with concentration limits on deposits at any one bank.
New risk management obligations cover operational, cyber, technology and fraud risk, business continuity, data protection, secure authentication and annual penetration testing of critical systems. Already-registered providers must meet the risk management requirements by 1 July 2027 and the capital requirements by 1 September 2027. Each provider's registration act will now state the exact services it may offer, and the public registry will show them.
Key benefits
- Clear registration framework administered by the central bank
- Proportionate, service-based capital thresholds rather than a single high minimum
- Dedicated legal pathway for stablecoin issuance, including lari-pegged tokens
- Transition period to July and September 2027 for existing providers
- Public registry specifying each provider's permitted services
- Competitive corporate environment and straightforward company formation
Requirements
- Georgian legal entity applying to the NBG for registration
- Minimum supervisory capital for the services sought, held largely as core capital
- Fit and proper owners, beneficial owners and administrators
- AML/CFT framework, including customer identification, transaction monitoring and suspicious activity reporting
- Use of the required electronic system for client and transaction records
- Risk management policies for operational, cyber, technology and fraud risk
- Business continuity, data protection, backup and secure customer authentication arrangements
- Annual penetration testing of critical systems and testing of other systems at least every three years
- Independent audit report submitted within 12 months of registration
Licence options & capital
Exchange or transfer of virtual assets
GEL 150,000
Exchange between virtual and fiat assets, including through self-service kiosks, and transfer of convertible virtual assets.
Other virtual asset services
GEL 250,000
Services such as custody and other activities not covered by the exchange or platform tiers, excluding stablecoin ICOs.
Trading platform administration
GEL 350,000
Operating a platform on which users trade virtual assets.
Stablecoin ICO
From GEL 500,000
Initial coin offering of a fiat-pegged stablecoin, with capital rising as reserves grow and dedicated reserve and disclosure rules.
Step-by-step process
- 1
Service definition
Identify each virtual asset service and the corresponding capital tier, since the registration act will specify permitted services.
- 2
Company formation and capitalisation
Incorporate the Georgian entity and pay in qualifying core capital.
- 3
Compliance and risk framework
Draft AML/CFT, risk management, cyber security and business continuity policies to NBG standards.
- 4
NBG application
Submit the registration application with ownership, management and policy documentation.
- 5
NBG review and registration
Respond to NBG questions; on approval, the provider is entered in the public registry.
- 6
Post-registration
Commission the independent audit within 12 months, run penetration tests and meet ongoing reporting.
Typical documents
- Company registration extract and charter
- Ownership structure and beneficial owner details
- Passports, CVs and criminal record certificates for owners and administrators
- Evidence of paid-in capital and source of funds
- Business plan describing each virtual asset service
- AML/CFT policy and risk assessment
- Risk management, cyber security and business continuity policies
- Whitepaper, reserve policy and governance documents for stablecoin issuers
How Legal Wealth helps
Legal Wealth helps virtual asset businesses register with the National Bank of Georgia and adapt to its new prudential regime. We define the services and capital tier precisely, structure capital to meet the core capital rules, and prepare the AML, risk and cyber documentation the NBG now expects. For existing providers, we build a plan to meet the 2027 deadlines without disrupting operations. Our work is discreet and compliance-first, and we can align the Georgian entity with principals' wider holding and succession arrangements.
Enquire with Legal WealthFrequently asked questions
Is it a licence or a registration?
The NBG uses registration. The registration act specifies the exact virtual asset services the provider may offer, and the NBG can cancel it for serious deficiencies.
How much capital is required?
GEL 150,000 for exchange or transfer services, GEL 250,000 for other services, GEL 350,000 for a trading platform and at least GEL 500,000 for a stablecoin ICO. Multi-service providers apply the highest figure.
When must existing providers comply?
Risk management requirements apply from 1 July 2027 and minimum capital requirements from 1 September 2027 for providers registered before the amendments.
Can a Georgian VASP issue a stablecoin?
Yes, under a separate NBG rule on stablecoin ICOs, with capital, governance, whitepaper and reserve requirements, including bank concentration limits.
What happens if capital falls short?
The provider must notify the NBG immediately, submit a restoration plan within five business days and suspend dividends and bonuses; fines may also apply.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
