Do You Need a Crypto License in Georgia? (2026 Rules)
Does Georgia issue a crypto license?
Georgia does not issue a document called a “crypto license.” What exists is registration as a Virtual Asset Service Provider (VASP) with the National Bank of Georgia. Anyone providing virtual asset services for another person must register, and only a company incorporated in Georgia can hold that registration. The regime has applied since 1 July 2023.
One clarification before anything else, because it derails a lot of research: this article is about Georgia the country in the South Caucasus — capital Tbilisi, currency the lari (GEL), financial regulator the National Bank of Georgia (NBG). It has nothing to do with the US state of the same name, whose money-transmission rules are a completely separate subject.
The obligation attaches to serving others. The NBG’s own guidance frames the duty as arising for a person who provides virtual asset services for another person. Institutions that are already licensed and supervised — commercial banks, microbanks, microfinance organizations and brokerage companies — are treated differently, but the carve-out is narrower than it is usually described: they may provide three of the seven services (exchange, transfer, and safekeeping or administration) plus the auxiliary activities needed to deliver them. Portfolio management, administering a trading platform, lending and initial coin offerings are not open to them. For microbanks the possibility runs from 1 July 2023.
Everyone else who wants to run an exchange, a custody wallet, a trading venue or a managed crypto portfolio out of Georgia needs the registration first.
If you provide services without being registered, the NBG’s position is that you must cease providing them. The regulator has publicly warned the market against dealing with unregistered providers, so operating “while the file is being prepared” is not a workable plan.
Which services count as virtual asset services?
Seven services are regulated, and most summaries shorten the list to four or five. The NBG’s English-language VASP page names all seven, and the exact wording matters because several of the categories are wider than their short titles suggest:
- Exchange (including via kiosks) between a convertible virtual asset and fiat currencies (national or foreign), between one or more forms of virtual assets, or between a convertible virtual asset and a financial instrument
- Transfer of a convertible virtual asset
- Safekeeping and/or administration of a convertible virtual asset or of the instrument enabling control over a virtual asset
- Portfolio management of convertible virtual assets (excluding collective portfolio management)
- Administration of a trading platform for convertible virtual assets
- Lending of a convertible virtual asset
- Initial Coin Offering of a convertible virtual asset and/or a service related to an initial coin offering
Four of those qualifiers do real work. Crypto-to-crypto exchange is named directly, so a product that never touches fiat is inside the regime on the face of the list — no argument about transfer or lending needed. Safekeeping extends to the instrument that enables control over an asset, which is where key and wallet-control models get tested rather than at the question of who nominally holds the coins. Portfolio management is caught except where it is collective, so fund-style pooled management falls outside this particular category. And the ICO category covers services related to an offering, so advising on or running someone else’s token launch can be regulated even if you never issue anything yourself.
What if my model sits on the edge?
Publishing non-custodial software and running a business that merely accepts crypto as payment for unrelated goods are the usual borderline cases, and they turn on whether you are performing a listed service for another person. Note that “non-custodial” is not a safe harbor by itself: because safekeeping and administration reach the instrument enabling control over an asset, the question is whether your design gives you that control, not how you label it. The instrument that governs this is the Registration Rule — formally the “Rule for the Registration, Cancellation of Registration, and Regulation of Virtual Asset Service Providers with the National Bank of Georgia,” approved by Order No. 94/04 of the Governor of the NBG on 13 June 2023. The NBG publishes an English description of it, but the full text is available only in Georgian, so it does not resolve every configuration in English. If your model is anywhere near the line, get the classification assessed in writing before you build, not after.
VASP registration is not Virtual Zone status
These two get conflated constantly, and they answer different questions. VASP registration is regulatory permission from the NBG to provide crypto services to other people; Virtual Zone Person status is a tax status for exported IT services, granted through a separate process. One does not imply, replace or accelerate the other, and a company can need both, either or neither. If your real question is the tax treatment of an IT company, start with our guide to Virtual Zone status in Georgia; for how a Georgian company is taxed generally, see the Georgia tax guide.
What the National Bank requires
The registration file is a substantive one. The NBG reviews the corporate structure, beneficial ownership, the fitness and propriety of management, operational readiness and the AML/CFT control environment — it is not a form-filling exercise with a fee attached.
| Requirement | What it means in practice | Source status |
|---|---|---|
| Georgian legal entity | Only a company registered in Georgia can be a VASP. In practice an LLC, incorporated before the application. | Confirmed — NBG |
| Scope of services | Every service you intend to provide must be enumerated against the seven statutory categories. | Confirmed — NBG |
| Head office in Georgia | Documented right to use or own the premises for the head office and any branch or service center. | Reported |
| Fit-and-proper management | Dossiers on directors, significant shareholders and beneficial owners, including source of capital. Foreign directors are permitted, but the expectation is real local management and attendance in person for interviews. | Reported |
| AML/CFT framework | Written compliance policies and procedures plus an institutional ML/TF risk assessment. KYC, transaction monitoring and suspicious-activity reporting apply from day one. | Reported |
| Business plan | Three-year plan with budget and financial projections, plus a schematic description of how each service will actually run. | Reported |
| Minimum capital (base registration) | No published statutory minimum for plain VASP registration. Financial capability and the source of funds are still assessed. | Reported — treat as the most likely item to change; verify |
| State fee | 5,000 GEL is the figure cited consistently by Georgian advisers. The NBG does not publish a fee in its English-language materials. | Reported — NBG publishes no fee; confirm before budgeting |
| NBG decision period | 60 calendar days from a complete submission, reportedly extendable by a further 60. | Reported |
How to register as a VASP in Georgia
The sequence below is the order the work actually has to happen in. Steps 3 to 5 are where the calendar time goes.
- Classify your services. Map every planned activity against the seven categories and decide what you are not applying for. Scope creep after filing is expensive.
- Incorporate the Georgian company. The entity has to exist before it can apply. Our walkthrough of how to register a company in Georgia covers the registry mechanics and what can be done remotely.
- Build the substance. Premises with documented rights of use, appointed officers, and internal systems that would hold up under inspection rather than existing only on paper.
- Draft the compliance pack. AML/CFT policies and procedures, ML/TF risk assessment, the three-year business plan, the schematic service descriptions and the technical infrastructure documentation. Practitioners put one to two months on this stage alone.
- Assemble the fit-and-proper dossiers. Directors, significant shareholders and beneficial owners, with documented source of capital. Expect the people named to be available for interview in Tbilisi.
- File with the NBG and pay the state fee. The complete registration form with all appendices and supporting documents.
- Answer the NBG’s follow-up questions. The regulator can request further documentation; applicants are reportedly given 30 calendar days to cure deficiencies. Missing that window is a common self-inflicted delay.
- Receive the decision and start operating under supervision. Registration is the beginning of an ongoing reporting and compliance relationship, not the end of the project.
VASP registration timeline: NBG review vs. total project time
Two different clocks get quoted as one number. The NBG’s review period is reportedly 60 calendar days from a complete submission, extendable by a further 60. The project — incorporation, premises, drafting the compliance pack, assembling dossiers, then review and follow-up questions — is realistically four to six months.
Both figures come from practitioner sources rather than a published NBG timetable, so treat them as planning assumptions. The gap between them matters commercially: if a partner or investor is told “two months,” they are being quoted the regulator’s review window, not the date you can take a customer.
What makes files stall
Thin AML documentation, a business plan that does not match the services applied for, beneficial ownership that cannot be traced to a documented source of funds, and “presence” in Georgia that is really just a registered address. There is also a reported detail worth knowing: the state fee is said to be payable per submission, including resubmissions — meaning a rejected file can cost the fee twice.
How much is the NBG state fee for a VASP in Georgia?
The state fee reported consistently by Georgian advisers is 5,000 GEL — indicatively around €1,600–1,750 or US$1,800–2,000 at mid-2026 rates (conversion indicative; GEL is the figure that counts). The NBG does not publish a fee in its English materials, so confirm the current amount with the regulator before you budget.
The fee is also the smallest line in the budget. The real cost drivers are company formation and its recurring obligations (see what it costs to start a company in Georgia), physical premises, the compliance officer or officers, professional drafting of the AML and operational documentation, and ongoing accounting and reporting once you are supervised. Anyone quoting a single all-in number without seeing your service mix is guessing.
Plan your banking early and separately: Georgian banks apply close scrutiny to source-of-funds evidence, and opening a business bank account in Georgia runs on its own timeline independent of the NBG file.
If you want to issue a stablecoin: Order No. 52/04
A separate rule now governs stablecoin issuance: “The Rule for the Initial Coin Offering of a Stablecoin by a Virtual Asset Service Provider,” adopted 6 March 2026 by Order No. 52/04 of the Governor of the National Bank of Georgia. Article 2 of the order itself provides that it enters into force upon publication. The English text is published by the NBG, and the figures below are taken from it rather than from practitioner summaries. This section applies only if you intend to issue a stablecoin — it is an additional layer on top of VASP registration, not an alternative to it.
| Item | Requirement under the order |
|---|---|
| Who may issue | Registration as a VASP is the entry ticket, not the permission: a stablecoin offering in Georgia is prohibited without prior written consent from the NBG (Art. 1(4)), and an applicant not yet registered must first register as a VASP (Art. 1(5); Art. 12(1)). Consent rests on a whitepaper submitted to the NBG for approval together with an operational risk assessment form (Art. 13(1)), plus a recent independent audit report on risk-management and cybersecurity compliance — where critical or high-risk vulnerabilities are identified, the NBG will not grant consent (Art. 11(7)) |
| Regulatory capital — floor | At least 500,000 GEL, of which a minimum of 75% must be Tier 1; Tier 2 elements must not exceed one third of Tier 1 (Art. 5(1)–(2)) |
| Regulatory capital — scaling | Once reserve assets reach or exceed 1,000,000 GEL (one million), capital is the minimum plus at least 2% of the average daily value of reserve assets over the preceding six months, capped at 50,000,000 GEL (Art. 7(1)) |
| Reserve backing | At least 100% of the nominal value of the stablecoins in circulation at all times (Art. 8(2)), reserves segregated from the issuer’s own assets (Art. 8(8)(b)), composition assessed daily (Art. 8(8)(e)), and reserve information published on the issuer’s website (Art. 8(13)) |
| What counts as a reserve asset | A reserve asset is a liquid asset and/or another asset agreed with the National Bank (Art. 2(1)(h)). “Liquid asset” is defined separately as fiat currency and/or domestic and foreign government securities (Art. 2(1)(g)) — so the reserve pool is not limited to liquid assets |
| Composition of the reserve pool | Set by Appendix No. 1 to the Rule rather than by the main text (Art. 8(5)); other assets may be used only with NBG consent (Art. 8(6)). Only where reserves exceed 1,000,000,000 GEL (one billion) may an issuer, with NBG consent, use a different share ratio from that specified in Appendix No. 1 (Art. 8(7)). Appendix No. 1 is not part of the English version we could obtain |
| Where reserves are held | Reserve assets held in Georgia must sit with a commercial bank or microbank licensed by the NBG (Art. 8(8)(a)), and the NBG must approve the financial institution chosen (Art. 8(9)) |
| Redemption deadline | Exchange at nominal value no later than 3 business days from receipt of the request; 5 business days where a single client’s aggregate redemption request exceeds 300,000 GEL or its foreign-currency equivalent (Art. 9(5)) |
| Reserve audit — quarterly | Regular quarterly verification of reserve assets by an independent, qualified external auditor, covering the composition and market value of reserves, the nominal value of issued stablecoins and the total volume of reserves (Art. 11(1)). The report is published quarterly on the issuer’s website, and any material discrepancy must be notified to the NBG immediately and remedied (Art. 11(2)) |
| Financial audit — annual | An independent external auditor engaged annually, with audited annual financial statements filed with the NBG no later than 15 July of the following year (Art. 11(5)). Reports follow IFRS and audits follow ISA (Art. 11(6)) |
| Above 15,000,000 GEL in reserves | The corporate governance requirements of Art. 3(4)–(14) apply, including an audit committee whose reports the supervisory board reviews at least once per quarter (Art. 3(3); Art. 3(8)(f)). The quarterly and annual audits must then be carried out by one or more of the audit firms listed in Appendix No. 2 (Art. 11(9)) |
| Existing issuers (transition) | A VASP already conducting a stablecoin offering before the Rule entered into force must file the required information and documents, including the Art. 11(7) audit report, within six months of the Rule entering into force, and may continue issuing until the NBG decides (Art. 20(2)). An issuer intending to discontinue must notify the NBG within one month of the Rule entering into force (Art. 20(3)) |
One gap to understand before you design a reserve structure. The Rule does not set out the composition of the reserve pool in its main text — it delegates that to Appendix No. 1 (Art. 8(5)), and Appendix No. 1 is not part of the English version published alongside the order. That the appendix sets percentage quotas is clear from Art. 8(7), which allows an issuer to use “a different share ratio from that specified in Appendix No. 1” only above one billion GEL in reserves and only with NBG consent. The specific 10% cash quota that circulates in adviser summaries is therefore neither confirmed nor contradicted by the text available to us — treat any precise percentage as unverified until you have seen Appendix No. 1. Separately, the Rule never uses the word “algorithmic.” Reading the definition of a stablecoin — value maintained by liquid assets and/or other assets agreed with the National Bank — a purely algorithmic design would not meet it, but that is our interpretation, not a stated exclusion.
The practical reading: the capital gap between plain VASP registration and stablecoin issuance is the single biggest fork in the road for a token project. Note that 500,000 GEL is the floor, not the requirement. Capital scales with the size of your reserve pool once reserve assets reach 1,000,000 GEL (one million), so the number to model is not a fixed 500,000 but a function of how much backing you expect to hold — and at least three quarters of it has to be Tier 1. A project that plans to grow should run that calculation before incorporation, not after. The consent step, though, not the capital, is the real gate: without the NBG’s prior written consent on a whitepaper, no offering is permitted at all.
Frequently asked questions
Do I need a VASP registration to trade my own crypto in Georgia?
No. The NBG states that a person is not subject to registration where they exchange virtual assets solely using their own funds or virtual asset resources, act as a client of a virtual asset service provider (including a virtual asset trading platform), transact with another client of that same provider, have no arrangement of any form with a third party, and do not provide a virtual asset service for that third party’s benefit. All five conditions have to hold. Break any one of them — pooled funds, managed accounts, matching counterparties — and the arrangement can fall inside the regime, so have unusual setups classified in writing.
Is a Georgian VASP registration valid in the EU?
No. Georgia is not an EU or EEA member state, so a Georgian registration carries no passporting rights into the European Union and is not a MiCA authorization. It authorizes activity under Georgian supervision. Serving EU customers is a separate regulatory question you need to answer in each target market.
Can a foreigner own and manage a Georgian VASP?
Foreign ownership of the Georgian company is standard, and foreign directors are reportedly permitted. What is not optional is substance: the NBG assesses fit-and-proper management and operational readiness, and the expectation reported by practitioners is that named officers manage the business locally and attend interviews in person. A director who never appears is a weakness in the file.
What happens if I operate without registering?
The NBG’s stated position is that a person who has not submitted the required registration documentation within the applicable period must stop providing virtual asset services. The regulator has also warned the public against dealing with unregistered providers. Beyond the regulatory exposure, an unregistered history damages your banking prospects and any future application.
Disclaimer: This article is general information, not legal, tax or financial advice, and reflects our understanding as of July 2026. Georgia’s virtual asset rules are actively developing, and while the NBG describes the Registration Rule (Order No. 94/04 of 13 June 2023) in English, its full text is published in Georgian only. The stablecoin requirements above are taken from the primary text of the order, but Appendices No. 1–3 to the stablecoin Rule (Order No. 52/04) — which set the composition of the reserve pool, the list of eligible audit firms and the operational risk assessment form — are not part of the English version we could obtain. The items marked “reported” in the tables above — including the 5,000 GEL state fee, the 60-day decision period, the 30-day period to cure deficiencies and the four-to-six-month project estimate — come from Georgian practitioners rather than a published NBG text, and must be verified before you rely on them. Primary sources: the National Bank of Georgia’s Virtual Asset Service Providers page, its VASP FAQ, the NBG announcement approving the VASP registration rule, and Order No. 52/04 on stablecoin initial coin offerings (PDF, English).
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