Georgia VASP Registration:
Central-Bank Supervision, Accessible Capital Requirements

Banks and payment partners ask who regulates you. A light-touch registration may not be enough, and a full EU licence may be too much.

In Georgia, the answer is the National Bank of Georgia (NBG). Crypto has its own rulebook, one regulator oversees registration, supervision and AML compliance, and capital follows the services you actually provide. Directors need no Georgian nationality or residence — the NBG looks for real management in Georgia.

Protegra builds the registration end to end, so the file the NBG reviews matches the business you run.

Assess your Georgia route Calculate your setup cost ⟶
WHY TEAMS CHOOSE PROTEGRA

Built for Crypto — Not Adapted to It

A Georgian project runs through one regulator, but it still involves separate workstreams: registration, supervisory capital, risk management, AML/CFT and banking. Protegra approaches them together — so the work submitted to the NBG reflects what the product will actually do.

100% crypto-focused.

We build Georgian VASP registrations around the way crypto businesses actually operate.

Assess your Georgia route

Crypto is our focus

We work with crypto business models rather than adapting a generic financial-services checklist. Exchange, transfers, kiosks, custody, trading platforms, lending and stablecoins create different questions under Georgian rules; we examine how those functions connect before recommending a route.

One plan across separate workstreams

NBG registration, supervisory capital, risk management, AML/CFT and bank onboarding have different owners and lead times. We identify the dependencies early — such as the bank statement the application now needs — and build one coordinated plan. Stablecoin and securities questions are scoped separately, so you can see what each workstream covers and what it does not.

Controls designed for live operations

A registration and a set of policies are not enough if the platform cannot capture the data or produce the records needed to operate — and the system must be demonstrated to the NBG before registration is completed. We connect the compliance framework to onboarding, transaction flows, blockchain analytics, sanctions screening, record-keeping and management oversight.

Clear scope and direct communication

Before work begins, we define the deliverables, responsibilities, and separately scoped items. Clients can discuss questions with the people working on the project rather than navigating unnecessary layers of communication.

Support beyond the application

The work continues after registration: penetration tests, an independent auditor's opinion on your risk-management framework within the first 12 months, Travel Rule deadlines and NBG inspections. Protegra can support ongoing AML/CFT compliance, AML officer arrangements, independent reviews, remediation, and regulatory-change work.

Who is this for?

For businesses making a Georgian market-entry decision

You may already run a crypto business elsewhere, hold a Georgian registration, or plan a new launch.

Crypto companies looking beyond the EU

MiCA may not be your first market, or its capital and timeline may not fit this stage of the business. We assess whether your model can run from Georgia under NBG registration, and what an EU route would add later.

Already-registered Georgian VASPs

Your registration predates the August 2026 amendments. You have until 1 July 2027 to put a risk-management framework in place and until 1 September 2027 to meet minimum supervisory capital; Travel Rule compliance follows by 31 December 2027. We run the gap analysis and the remediation plan.

Exchanges, OTC desks and kiosk operators

Whether you exchange crypto for lari, foreign currency or other virtual assets — online, at a branch or through self-service kiosks — we map onboarding, execution, cash handling and custody against the NBG's rules for head offices, branches, kiosks and video surveillance.

Custody, trading-platform and lending teams

These services sit in the higher capital tiers: GEL 250,000 and GEL 350,000. We size capital to the services you actually register and flag restrictions early, such as the ban on lending virtual assets to individuals.

Stablecoin issuers

Georgia now has a dedicated rule for issuing stablecoins: full reserve backing, redemption at par, quarterly reserve verification and capital from GEL 500,000. We assess whether your token, reserves and governance can meet it.

What you need to know is whether the model can operate from Georgia as designed — and what must be in place before the first client transaction.

Assess your Georgia route

≈ €1,717 fee.
Capital from
≈ €51,500.
AML before
the first client.

The Georgian regulatory landscape

One regulator, more than one rulebook

The NBG supervises virtual-asset services, payment services and the securities market. That simplifies who you deal with — not what you need to assess. A product that starts as an exchange can add custody, a stablecoin or a tokenised instrument, and each change can move its regulatory position.

WorkstreamWhat to assessAuthority
VASP registrationWhich virtual-asset services you provide, which capital tier applies, and the head-office, systems and fit-and-proper requirementsNational Bank of Georgia
AML/CFT and Travel RuleClient due diligence, monitoring, sanctions screening, suspicious-transaction reports and transfer informationNBG (supervision); Financial Monitoring Service of Georgia (reports)
Stablecoin issuanceReserves, redemption, the offering document (whitepaper), governance and the NBG's prior consentNBG, under its stablecoin rule
Securities and payments perimeterWhether a token digitally represents money, a security or another financial instrument (outside the virtual-asset definition), and whether you provide fiat payment servicesNBG, under securities-market and payment-services law

A business may need one workstream or several. VASP registration does not stand in for a securities or payment-services decision.

How we identify the route

We review the client journey from onboarding to withdrawal:

What the client buys, sells, sends, receives, or holds.

Where lari, foreign currency and virtual assets move — online, at branches or through kiosks.

Who controls wallets, private keys, and client assets.

Whether a token is a virtual asset, a stablecoin, or a digital representation of a security or financial instrument.

How trades are executed: bilaterally or on a platform you operate.

Whether the product includes lending, portfolio management, or an initial offering.

What banks, payment providers, custodians, and analytics vendors do on the company's behalf.

Where the company is managed from and which clients it serves.

The output is a route based on the operating model — not the label on the website.Assess your Georgia route
NBG VASP REGISTRATION

What Is VASP Registration with the National Bank of Georgia?

GEL 5,000 (≈ €1,717)
NBG registration fee

The fee is set by the Law of Georgia on Registration Fees, and proof of payment is filed with the application.

GEL 150,000 – 350,000 (≈ €51,500 – €120,200)
Minimum supervisory capital

GEL 150,000 for exchange or transfer, GEL 250,000 for other services, GEL 350,000 for a trading platform. If you offer several services, the highest applicable minimum applies.

GEL 3,000 (USD/EUR 1,000)
Occasional-transaction due diligence threshold

For one-off virtual-asset transactions, client due diligence applies above GEL 3,000, USD 1,000 or EUR 1,000 — far below the GEL 15,000 threshold for other one-off transactions.

Regulator and AML supervisor
National Bank of Georgia (NBG)
Registration route
VASP registration; the registration act names the services you may provide
Qualifying activity
Exchange (including through kiosks), transfer, safekeeping and administration, portfolio management, trading-platform administration, lending, and initial offerings, including stablecoins
Company vehicle
A Georgian limited liability company (LLC) or joint-stock company (JSC)
Local presence
A head office in Georgia from which administrators actually manage the business; one person authorised to represent the company present in Georgia at least 14 days a month
NBG decision period
60 calendar days from a complete filing; the NBG may extend it twice, by 60 days each time
Financial intelligence unit
Financial Monitoring Service of Georgia

Virtual-asset services in Georgia may be provided only by NBG-registered VASPs or, for certain services, by commercial banks, microbanks, microfinance organisations and brokerage companies. Registration has been mandatory since 1 January 2023, and the NBG's registration rule has applied since 1 July 2023.

The framework is no longer AML-only. In December 2025, amendments to the Organic Law on the National Bank of Georgia gave the NBG full supervisory powers over VASPs. The August 2026 amendments put them to work: capital tiers by service, a risk-management framework covering operational risk, cybersecurity and business continuity, and registration acts that name each provider's services.

Minimum supervisory capital is mandatory. Since 27 August 2026, an application must include a bank statement showing the capital is paid in, and a registered provider must maintain it at all times. Providers registered before that date have until 1 September 2027 to comply.

Registration does not guarantee market access

NBG registration authorises virtual-asset services from Georgia. It does not guarantee a bank account, a payment partner, or access to other markets — serving clients in the EU, for example, generally requires MiCA authorisation. Banks and other partners make their own risk decisions, and NBG registration is not a government endorsement.

WHY GEORGIA

The Capital Bar Is Moderate. The Supervisory Bar Is Real.

Georgia's value is not that it is lightly regulated. It offers one regulator, a regime written specifically for virtual assets, and capital floors below MiCA's for exchange, custody and trading platforms — so more of the first investment can go into operations, controls and market entry.

Capital

Capital sized to the service
  • Capital follows the services you register: an exchange-only model does not carry trading-platform capital.
  • The floors work out at roughly €51,500 – €120,200; MiCA requires €125,000 for exchange or custody and €150,000 for a trading platform.
  • The capital must be real: at least 75% core capital, with intangible assets and revaluation reserves deducted.
  • A shortfall must be reported to the NBG immediately, with a restoration plan within five working days.

Structure

One Georgian company, one real head office
  • An LLC can be registered with Georgia's Public Registry in one working day for GEL 200, or the same day for GEL 400.
  • If your administrators or owners have already passed NBG fit-and-proper review at an NBG-supervised entity, the NBG may take that into account and waive some documents.
  • Administrators qualify on knowledge and experience: a relevant degree, or at least two years in a management role in finance or virtual assets.
  • Georgia's 15% corporate profit tax generally applies when profits are distributed, not while they are reinvested.

Market

A supervised market with a clear rulebook
  • 43 VASPs on the NBG register as of September 2026, headquartered in Tbilisi and Batumi.
  • Registrations continue: 12 new providers joined the register between January and August 2026.
  • In December 2024, MONEYVAL re-rated Georgia "largely compliant" on the FATF standard covering new technologies and virtual-asset service providers.
  • A dedicated stablecoin rule since March 2026, for tokens pegged to the lari, another currency or another asset.
Start your registration

Georgia.
Your regulated
base between
Europe and Asia.

CHOOSE YOUR REGISTRATION TRACK

Which Georgia Crypto License Route Fits: Exchange, Custody, Trading Platform, or Stablecoin?

Georgia does not use MiCA-style crypto licence classes. There is one VASP registration, and the NBG's registration act names the services you may provide. The service mix sets the capital tier: offer several services and the highest applicable minimum applies.

For exchange, OTC and kiosk operatorsMinimum supervisory capitalGEL 150,000

Exchange & Transfer VASP

Covers exchanging virtual assets for lari or foreign currency, for other virtual assets, or for financial instruments, online or through self-service kiosks, and transferring virtual assets on clients' behalf.

It fits fiat on- and off-ramps, OTC desks, crypto ATM networks and transfer services that do not hold client assets.

Included

  • NBG VASP registration for exchange and/or transfer
  • AML/CFT, sanctions and Travel Rule obligations
  • Head-office, branch and kiosk requirements, including video surveillance where cash changes hands
  • A Georgian operating structure

Does not automatically cover

  • Holding client balances: expect custody to be assessed as a separate service, which moves the capital floor to GEL 250,000
  • Operating a trading platform or order book
  • Accepting crypto as payment for goods and services, which is prohibited except where the NBG defines otherwise
  • Serving clients in the EU, which generally requires MiCA authorisation
Calculate cost ⟶Apply ⟶
For custody, portfolio-management and lending modelsMinimum supervisory capitalGEL 250,000

Custody, Portfolio Management & Lending

Covers safekeeping and administration of virtual assets or of the instruments that control them, such as keys; portfolio management (excluding collective portfolio management); lending of virtual assets; and initial offerings and related services, other than stablecoin issuance.

Included

  • NBG VASP registration for the selected services
  • A risk-management framework: operational risk, cybersecurity, fraud, business continuity and IT disaster recovery
  • Key-management and client-asset controls
  • AML/CFT programme and transaction monitoring

Does not automatically cover

  • Lending virtual assets to individuals, which is prohibited
  • Commissions or other benefits on portfolio management from anyone other than the client, which are prohibited
  • Collective portfolio management, which is outside the VASP regime
Calculate cost ⟶Apply ⟶
For order-book exchangesMinimum supervisory capitalGEL 350,000

Trading Platform Administration

Covers operating a platform on which convertible virtual assets are traded.

Where a platform also provides exchange, custody or other services, GEL 350,000 is still the applicable minimum — the highest tier for standard VASP services.

Included

  • NBG VASP registration for trading-platform administration
  • Readiness for an NBG demonstration of the electronic system
  • Automated transaction monitoring using blockchain data, live before launch
  • Risk management, penetration testing and vulnerability scanning

Does not automatically cover

  • Listing tokens that digitally represent securities or other financial instruments
  • Issuing your own stablecoin
  • Access to EU clients
Calculate cost ⟶Discuss your trading-platform model ⟶
For stablecoin issuersMinimum supervisory capital fromGEL 500,000

Stablecoin Issuance

Do you plan to issue a token pegged to the lari, another currency or another asset?

Since March 2026, a dedicated NBG rule governs initial offerings of stablecoins by registered VASPs. The offering needs the NBG's prior written consent, and an unregistered issuer must first register as a VASP.

What the rule requires

  • Reserves of at least 100% of the stablecoins in circulation, held in the currency of the peg
  • Redemption at nominal value within three business days, or five for requests above GEL 300,000
  • Quarterly verification of reserves by an independent auditor, published
  • Audited annual financial statements by 15 July
  • An offering document (whitepaper) and corporate-governance requirements
  • Capital of GEL 500,000; once reserves reach GEL 1 million, GEL 500,000 plus at least 2% of average daily reserves over the previous six months, capped at GEL 50 million

This is more than an application form. The issuer has to show how reserves, redemption and disclosure work in practice.

Assess your stablecoin model ⟶
Assess your registration scope
Which Georgia route fits?

Find the starting point for your model

Your business
VASPNBG VASP registration
StablecoinNBG stablecoin rule
Securities / paymentsSecurities / payments perimeter
Crypto exchange or OTC desk
Likely starting assessment

VASP registration: exchange (GEL 150,000)

Do not overlook

Custody if clients keep balances; the bank statement for capital before filing

Crypto ATM or kiosk network
Likely starting assessment

VASP registration: exchange through kiosks (GEL 150,000)

Do not overlook

Kiosk video recording, NBG-agreed remote identification, premises rules

Wallet or custody provider
Likely starting assessment

VASP registration: safekeeping and administration (GEL 250,000)

Do not overlook

Key control, cybersecurity, penetration testing, business continuity

Order-book exchange
Likely starting assessment

VASP registration: trading-platform administration (GEL 350,000)

Do not overlook

The highest tier across all services; which tokens you list

Lending or yield product
Likely starting assessment

VASP registration: lending (GEL 250,000)

Do not overlook

Lending virtual assets to individuals is prohibited

Stablecoin issuer
Likely starting assessment

Stablecoin rule, with VASP registration (from GEL 500,000)

Do not overlook

Reserves, redemption at par, quarterly verification, NBG consent

Tokenised securities or real-world-asset platform
Likely starting assessment

Securities-market analysis; separate VASP classification

Do not overlook

Digital representations of securities and financial instruments are not virtual assets

Merchant crypto-payment service
Likely starting assessment

Activity assessment

Do not overlook

Paying for goods and services with virtual assets is prohibited except where the NBG defines otherwise

Non-custodial software or wallet provider
Likely starting assessment

Activity and control assessment

Do not overlook

Whether you exchange, transfer, or control assets for others

Likely starting assessmentCheck separately / depends on the model

This is a starting-point guide. The final route depends on how the business operates — not on which description seems closest.

Assess your Georgia route
AML/CFT compliance & AML officer support

Build a programme the business can actually run

Registration is the beginning of the AML/CFT obligation, not the finished product. Georgian law treats a VASP as an accountable person: it needs internal instructions approved by management, a person responsible for the compliance system, staff training, and an independent audit function. The NBG also expects automated transaction monitoring based on blockchain data to be running before the first client.

Know the client

KYC/KYB, beneficial ownership, client-risk rating and a remote-identification process agreed with the NBG. One-off virtual-asset transactions above GEL 3,000 trigger due diligence.

Understand the risk

An organisational ML/TF risk assessment, enhanced due diligence, PEP checks — and no business relationships with unregulated VASPs or financial institutions.

Monitor activity

Blockchain analytics, automated detection of unusual transactions, sanctions screening of people and wallet addresses, and suspicious-transaction reports to the Financial Monitoring Service.

Capture the data

Every operation recorded and logged so it can be retrieved quickly from the head office, records kept for five years, and Travel Rule data in place by 31 December 2027.

Maintain oversight

Training, management reporting, policy updates, testing and remediation — with no privacy coins or tools that defeat traceability.

Enforcement can scale with volume. In October 2026, the NBG published a fine of more than GEL 572 million on one registered provider, almost all of it for 572,033 services provided without the identification the law requires, each counted separately under the penalty rule then in force. Controls have to work for every client and every transaction, not just on paper.

Who owns compliance?

Georgian law requires a member of the management body, or a person with managerial authority, to be responsible for the effectiveness of the compliance system — and a designated person to run it, with timely access to information and the independence to decide on suspicious-transaction reports. Titles vary: AML officer, compliance officer, MLRO. The responsibility does not.

Where appropriate, external support can provide programme oversight, high-risk escalation, staff guidance, remediation, and inspection preparation. The company remains responsible for its programme even when it uses an external specialist.

Independent effectiveness review

Internal instructions must set out an independent audit function that checks whether the compliance system works. Separately, within 12 months of registration, a VASP needs an independent auditor's opinion confirming that its risk-management framework meets the NBG's requirements.

A review that tests client files, alerts, screening results, and reporting decisions also answers the questions banks and partners ask.

Build your AML/CFT programmeDiscuss AML officer support ⟶
How Protegra supports the project

From regulatory assessment to operational readiness

A registration project works best when the application, the compliance programme, and the product tell the same story. Protegra's support can be scoped across the workstreams the business actually needs.

NBG registration and AML/CFT setup

  • Service mapping against the NBG's list of virtual-asset services.
  • Georgian company, head-office and governance set-up.
  • Fit-and-proper files for administrators and owners of 10% or more.
  • Business plan, service schemes and organisational structure.
  • AML/CFT internal instructions, risk assessment and remote-identification process.
  • Filing, NBG clarification rounds and system-demonstration readiness.

Capital, risk and systems readiness

  • Capital tier and structure: core capital, deductions, subordinated debt.
  • Bank onboarding pack and capital-funding sequence.
  • Risk-management framework: operational risk, cybersecurity and fraud.
  • Business continuity and IT disaster recovery.
  • Penetration-testing and vulnerability-scanning plan.
  • Preparation for the 12-month independent auditor's opinion.

Ongoing compliance

  • AML officer support, where appropriate.
  • Change notifications, ownership thresholds and NBG consents.
  • Travel Rule implementation ahead of 31 December 2027.
  • Inspection preparation and remediation.
  • Policy updates and regulatory-change monitoring.
  • Banking and payment-partner compliance support.

Stablecoin issuance and securities-perimeter work are scoped separately, according to the model and the specialists required.

Discuss your project scope
COST CALCULATOR

What Does VASP Registration in Georgia Cost?

Select the workstreams relevant to your model to estimate the Year 1 cost of company formation, NBG registration, AML/CFT setup, risk management, compliance ownership, and ongoing support. Minimum supervisory capital is shown separately: it stays on your balance sheet — it is not a fee.

Depending on the model, costs may include:

Georgian company formation and head office.

Regulatory assessment and registration support.

AML/CFT instructions, risk assessment, and implementation.

A risk-management framework, business continuity, and cybersecurity.

An AML officer or external compliance support.

KYC/KYB, sanctions screening, and blockchain analytics.

Travel Rule capabilities.

Penetration testing and the independent auditor's opinion.

Certified Georgian translations and apostilles.

Bank onboarding.

Separately scoped stablecoin or securities work.

Three levels of support

How much of the work do you want us to do?

01 · TEMPLATES

You get the documents. You file them yourself.

€9,000
  • The full policy, procedure and governance pack for this regulator
  • Application forms filled in as far as your own data allows
  • One handover session so you know what goes where
  • You deal with the NBG yourself
02 · TAILORED

We write the file around your business.

€30,000
  • Everything above, rewritten around your actual model
  • Business plan, service schemes, governance and AML/CFT built from your data
  • We assemble and check the whole file before it goes in
  • You submit and answer; we stay on call throughout
Every figure on this page assumes this level
03 · DECISION

We carry the file to the NBG's answer.

€60,000
  • Everything above, and we file it
  • Every NBG question and clarification round comes to us
  • Meetings and system-demonstration preparation handled for you
  • We stay on the file until the decision is issued

One registration, three levels — the NBG asks for exactly the same file in all three, and what changes is how much of it sits with you. The middle level is the default here: every price on this page is quoted at it, and the selector above the total switches between them.

Moving up or down changes our fee and nothing else — not the capital, not the state fees, not the statutory clock. Carrying a file to the decision is not a promise of approval: no adviser can give one, and an adviser who does is selling you something other than advice.

Protegra registration supportService mapping, NBG filing preparation, fit-and-proper files, business plan, service schemes and clarification management — together with the full AML/CFT programme and the risk-management framework€30,000
Georgian company formationLLC set-up, charter and Public Registry filing. Plus the GEL 200 registry fee (one working day)€2,000
Head office in GeorgiaPremises that meet the NBG's head-office requirementsMarket rate, contracted directly
AML officer supportCompliance ownership support, management reporting, escalation, and programme maintenance. €18,000 annualised€1,500 / mo
Risk-management testingPenetration tests, vulnerability scans, and the independent auditor's opinion on the risk-management frameworkThird-party quote
Ongoing AML complianceProgramme maintenance, risk-assessment updates, training, testing, management reporting, and regulatory-change monitoring. The range is wide because it depends on volume and product mix, so this line is switched off by default — turn it on to see it in the total€15,000–80,000 / yr
Certified translations and apostillesGeorgian translations of every filed document; apostilles for foreign documentsAt cost
Stablecoin issuance workReserve, redemption, whitepaper, and governance work under the NBG stablecoin ruleSeparately scoped
ChargeAmount
NBG registration feeGEL 5,000 (≈ €1,717)
LLC registration (Public Registry, one working day)GEL 200 (≈ €69)
Minimum supervisory capital — held on your balance sheet, not spent, and excluded from the totalGEL 150,000–350,000 by service (≈ €51,500–€120,200); stablecoin issuers from GEL 500,000 (≈ €171,700)

Our fees are set in euros. Government charges are in lari, converted at the NBG official rate published 15 October 2026 (EUR 1 = GEL 2.9129).

ROADMAP WITH PROTEGRA

How Long Does VASP Registration in Georgia Take?

A Georgian VASP project combines company and head-office set-up, bank onboarding and capital funding, the application file, systems readiness, and the NBG's review. Preparation usually takes around three months. The NBG then decides within 60 calendar days of a complete filing, can extend that period twice by 60 days each time, and pauses the clock while it waits for your answers or for access to your head office.

Because the application must now include proof that the capital is paid in, bank onboarding sits on the critical path. We start it in the first weeks, in parallel with the documents.

Map the complete business modelAssess clients, products, fiat and virtual-asset flows, custody, kiosks, trading functions, outsourced providers, and target markets. Identify the NBG services involved and the capital tier that follows.

We assess the business against Georgian rules:

  • Exchange and transfer activity, online and through kiosks
  • Custody and the wallet-control model
  • Trading-platform functions
  • Lending, portfolio management, and initial offerings
  • Stablecoin or tokenised-instrument features
  • Client onboarding and target markets
  • Capital tier and group structure
  • Fit-and-proper position of administrators and owners of 10% or more

The outcome is a practical registration route — not an assumption based on the company's preferred label.

Set up the Georgian operating baseRegister the Georgian LLC (one working day at the Public Registry), adopt the charter, appoint directors, secure head-office premises, and decide who will represent the company in Georgia at least 14 days a month. If a sole shareholder is also the director, a second director is required.

The NBG expects the head office to be where administrators actually manage the business, with premises evidenced by an extract from the real-estate register. We also start the fit-and-proper evidence: criminal-record certificates for every administrator and significant owner from each country of residence in the past 10 years — Georgian certificates no older than 15 days and foreign ones no older than 60 days at filing — apostilled and translated into Georgian.

Put the capital where the NBG can see itOpen the corporate account, fund the minimum supervisory capital, and obtain the bank statement the application needs. Structure it so at least 75% is core capital; intangible assets do not count.

Banks run their own due diligence on ownership, source of funds, and the business model. We prepare the onboarding pack from the same business plan and service schemes as the NBG file, so both tell the same story.

Build the file around the real businessA three-year business plan and budget, the organisational structure for the first six months, service schemes showing how information, virtual assets and funds move from start to finish, AML/CFT internal instructions and risk assessment, and the risk-management framework.

We build the compliance foundation:

  • Management-body member responsible for AML effectiveness
  • Person responsible for the compliance system
  • Internal instructions approved by management
  • Organisational ML/TF risk assessment
  • Client identification and a remote-identification process for NBG agreement
  • Sanctions screening of people and wallet addresses
  • Transaction monitoring and escalation
  • Record-keeping and logging
  • Staff training programme
  • Independent audit function
  • Business continuity and IT disaster-recovery plan

Show it workingBlockchain analytics and automated monitoring live before the first client; the electronic system ready for an NBG demonstration; Travel Rule data flows designed; websites, apps, and kiosks documented for the file.

Submit a complete filePay the GEL 5,000 registration fee and file the application with its annexes. If the NBG finds gaps, it sets 30 calendar days to fix them, and its clock pauses until you respond.

Documents are filed as originals or notarised copies, with foreign documents apostilled or legalised and an authenticated Georgian translation of everything.

The statutory clockThe NBG decides within 60 calendar days of a complete filing and may extend twice by 60 days each time; the clock pauses while the NBG waits for your answers or for access to your head office. The electronic system must be demonstrated to the NBG before registration is completed. Once registered, the provider appears on the NBG's public register within two working days.

08

Post-Registration Support

INCLUDED, NOT OPTIONAL

Registration starts the supervisory relationship.

Start on time

Begin providing services within six months of registration; otherwise the NBG can cancel it.

Changes and consents

Report some changes within 10 days, notify planned changes at least 30 days ahead, and obtain NBG consent before new administrators or significant owners take over.

Risk management and testing

Penetration tests of critical systems every year, vulnerability scans at least twice a year, and the independent auditor's opinion within 12 months of registration.

Travel Rule and transparency

Travel Rule compliance by 31 December 2027, and the NBG registration act displayed on every website, app, branch, and kiosk.

Begin Step 1Plan your Georgia launch ⟶
WHY PROTEGRA

When Does a GEL 5,000 Fee Stop Being Simple for a Georgia VASP?

A GEL 5,000 fee can create the wrong expectation. Georgia keeps the entry cost moderate, but the NBG still expects paid-in capital, a real head office, working systems and an AML programme that fits the model before it registers a provider.

See how we work

“We have the company. Why can't we file next week?”

The application must include a bank statement confirming that the minimum supervisory capital is paid in. That puts bank onboarding—and the bank's own due diligence—on the critical path.

⟶ We sequence banking, capital, and documents so the filing date is real.

“Which capital tier applies to us?”

The registration act names each service you provide, and when you provide several, the highest applicable minimum applies. An exchange that also holds client balances can end up in a higher tier than planned.

⟶ We map every service against the NBG's list, so your registration scope and your capital plan match.

“Can we run the Georgian company from abroad?”

Not entirely. Administrators must actually manage the business from the head office in Georgia, and one person authorised to represent the company must be in Georgia at least 14 days a month.

⟶ We design governance that works on the ground, before incorporation decisions become expensive to reverse.

“Can we reuse our group AML manual?”

A group manual is a useful starting point, but it is usually written around another regulator's thresholds, reporting channels and identification methods.

⟶ We adapt it to Georgian law: the GEL 3,000 threshold, reporting to the Financial Monitoring Service, the NBG's sanctions rule, an NBG-agreed remote-identification process, and an authenticated Georgian translation.

“Will our platform stand up to the NBG's review?”

Compliance depends on data. The electronic system must be demonstrated to the NBG before registration is completed, and the NBG expects monitoring, logging and record retrieval to work from the first client.

⟶ We test onboarding, monitoring and record retrieval against the rule before the NBG does.

“We are registered. What do we need by 2027?”

The August 2026 amendments apply to existing providers too, with transition periods running into 2027 and existing registration acts updated by 1 January 2028.

⟶ We run the gap analysis — risk management, capital, Travel Rule — and turn it into a remediation plan with owners and dates.
CLIENT EXPERIENCE

How These Problems Get Resolved

Select a challenge to see how a Georgia VASP project moves from a registration question to an operating compliance model.

Before Protegra
The documents were nearly ready, but the corporate account was not open — so there was no capital statement to file and no realistic submission date.
With Protegra
Bank onboarding started in the first weeks, with a pack built from the same business plan and service schemes as the NBG file. The capital was funded and evidenced before submission.
Talk to a Georgia VASP expertSchedule a free call
FAQ

Georgia VASP Registration, Answered Honestly

Fees, structure, and process
01How much does VASP registration in Georgia cost?
The NBG registration fee is GEL 5,000. On top of that, you need minimum supervisory capital of GEL 150,000, 250,000, or 350,000 depending on your services — held on your balance sheet, not paid away. The real budget also covers company formation, a head office, people, systems, penetration testing, the independent auditor's opinion, translations, and professional support.
02Is there a minimum capital requirement?
Yes, and it is mandatory. Since 27 August 2026, a VASP must hold at least GEL 150,000 for exchange or transfer, GEL 250,000 for other services, or GEL 350,000 for trading-platform administration, and maintain it at all times; stablecoin issuers need at least GEL 500,000. New applicants file a bank statement proving the capital is paid in. Providers registered before the change have until 1 September 2027.
03Do we need a Georgian company?
Yes. A VASP must be a Georgian LLC or JSC with its head office in Georgia, so an existing group usually sets up a Georgian subsidiary. That company may carry out only virtual-asset services, the activities needed to provide them, and exchange of its own virtual assets — other group businesses stay in separate entities.
04Do the directors need to live in Georgia?
There is no nationality or residence requirement; the rule requires presence instead. Administrators must actually manage the business from the head office in Georgia, and one person authorised to represent the company must be in Georgia at least 14 calendar days a month. If a sole shareholder is also the director, the company needs at least two directors.
05How long does it take?
The NBG decides within 60 calendar days of a complete filing and may extend twice by 60 days each time; the clock pauses while it waits for your answers. With around three months of preparation — company, banking, capital, documents, and systems — a realistic planning range is about five to nine months from kickoff to registration. We work to keep preparation and responses moving, but we cannot guarantee when the NBG will decide.
Scope of the registration
06Which activities require registration?
Exchanging virtual assets for lari, foreign currency, other virtual assets, or financial instruments (including through kiosks); transferring virtual assets; safekeeping and administration; portfolio management; trading-platform administration; lending; and initial offerings and related services, when provided for others. Free Industrial Zones are no exception: the NBG has stated that providers there must be registered too.
07Does one registration cover every service?
No. The registration act names the services you may provide. To add one, you file its service scheme with the NBG at least 30 days in advance and need the NBG's consent, which it gives or refuses within one month of a complete file. A new service can also move you to a higher capital tier.
08Can we issue a stablecoin in Georgia?
Yes, under the NBG's stablecoin rule of March 2026. The issuer must be a registered VASP and needs the NBG's prior written consent; the rule then sets reserve, redemption, verification, disclosure and capital requirements, with capital from GEL 500,000.
09Are tokenised securities covered by VASP registration?
No. Under Georgian law, digital representations of fiat currency, securities, or other financial instruments are not virtual assets. They fall under securities-market or other financial legislation and need a separate assessment.
10Can customers pay for goods and services with crypto?
Paying with virtual assets is prohibited in Georgia except in cases the NBG defines. A VASP may, on a client's instruction, send the fiat proceeds of an exchange to the recipient's payment provider — so payment models need careful structuring.
11Does NBG registration give us access to other markets or a bank account?
No. NBG registration authorises services from Georgia only; serving clients elsewhere depends on each country's rules — in the EU, for example, that generally means MiCA authorisation.
Compliance obligations and ongoing support
12What AML obligations apply?
A VASP is an accountable person under Georgia's AML law. That means client due diligence (including one-off transactions above GEL 3,000), ongoing monitoring, sanctions screening, suspicious-transaction reports to the Financial Monitoring Service, and five-year record retention. Privacy coins and tools that defeat traceability are not permitted.
13Can an external specialist support the AML officer function?
Yes, as support. Georgian law still requires the company to give a member of its management body, or a person with managerial authority, responsibility for the effectiveness of the compliance system, and to name a person responsible for running it. External support does not move that responsibility away from the company.
14When does the Travel Rule apply?
The NBG's regulation on information accompanying transfers requires originator and beneficiary information to travel with virtual-asset transfers at every stage, including transfers through kiosks. VASPs must comply by 31 December 2027. How you implement it depends on how you send, receive, record, and monitor transfers, and on your wallet and counterparty model.
15What happens after registration?
You start services within six months, display your registration act on every channel, notify changes on time, run annual penetration tests of critical systems and vulnerability scans at least twice a year, and obtain an independent auditor's opinion on your risk-management framework within 12 months. The NBG inspects, and can fine or cancel a registration.
16What are the penalties for getting it wrong?
The NBG can fine both a VASP and its administrators under a dedicated penalty rule, and it can cancel a registration. Fines can scale with volume: one published in October 2026 exceeded GEL 572 million.
17We are already registered. What changes for us?
Three dates matter: a risk-management framework by 1 July 2027, minimum supervisory capital by 1 September 2027, and Travel Rule compliance by 31 December 2027. The NBG will also update existing registration acts to name each provider's services by 1 January 2028.
Get a personalised Georgia VASP planBook a call
Start now

Apply for VASP Registration in Georgia

Tell us what your business exchanges, transfers, holds, issues, or trades. We will assess which NBG services and capital tier apply and what needs to be built before operations begin.

Your assessment will cover:

The NBG virtual-asset services your model involves.

Your capital tier and how to structure it.

Company, head-office, and presence set-up.

AML/CFT, sanctions, and Travel Rule requirements.

Risk-management, cybersecurity, and testing obligations.

An initial implementation roadmap and cost scope.

The applicable route depends on the business model. NBG VASP registration does not replace securities-market, payment-services, or other applicable requirements in Georgia, or authorisation in other jurisdictions.

Blog

Latest news from Protegra

All articles ⟶
#Georgia#stablecoins
29 Oct 2026

Issuing a Stablecoin in Georgia Under the National Bank’s Stablecoin Rule

The capital requirements that Georgia introduced for virtual asset service providers in August 2026 got most of the attention this year, and they deserve it. But…

Read ⟶
#Georgia#VASP
19 Oct 2026

Georgia’s New VASP Capital Rules: A Barrier to Entry — or an Opening for Better-Funded Businesses?

GEL 150,000 (approximately EUR 51,200) is now a figure that anyone planning an exchange or virtual-asset transfer business in Georgia needs to understand. For…

Read ⟶
#Canada#Crypto License
15 Oct 2026

The Country That Won’t Sell You a Crypto License

Halifax, Nova Scotia, February 2019. Standing in front of a judge, a lawyer explains that a cryptocurrency exchange cannot find its customers’ money because the…

Read ⟶