Regulatory overview
- Scope
- Georgia
- Authorities
- Regulatory index
- Latest regulatory change
GeorgiaGeorgia requires VASP registration with the National Bank and expanded its capital, governance and risk requirements in 2026. Stablecoin issuance requires specific consent, reserves and redemption arrangements. Existing-provider transition periods do not exempt new applicants. VASP status also does not permit general commercial payments or replace the regime for tokenized securities.
In Georgia, a virtual asset business must identify its services before applying for National Bank of Georgia, NBG, registration. The framework covers functions such as exchange, transfer and custody; representations of securities and financial instruments require separate assessment.
The 2026 changes add service-specific requirements and develop stablecoin issuance rules. This guide connects registration, capital, reserves and client rights to distinguish a service platform from an issuer promising a stable asset value.
Which assets and services Georgian rules cover
NBG defines VASP services involving convertible virtual assets, including exchange, transfers, custody, portfolio management, platforms, lending and initial offerings. The definition excludes representations of money, securities and financial instruments. Order 94/04 of 2023 established registration and must be read alongside subsequent amendments rather than as an unchanged text.
The 2025 supervisory expansion and 2026 implementation address capital, customer protection, cybersecurity and operational risks. Earlier descriptions of exclusively AML supervision are incomplete. For stablecoins, Order 214/04, effective from 10 September 2026, changes definitions, reserves and transition arrangements under the original March rules.
What the NBG registers and supervises
The National Bank registers and supervises VASPs alongside its responsibilities for other financial activities. Its September announcement requires registration decisions to identify authorised services and provides for adding this information to the public register. A company's registration should not be treated as unrestricted issuance, trading and custody permission.
The Georgian registry page links a provider list dated 16 September 2026. This supports identity and registration checks but does not replace examination of the individual decision and its conditions. Projects combining securities, payments and virtual assets must distinguish permissions for each function.
Which capital and permissions match the service
The regime requires a Georgian corporate establishment and assessment of the model, owners and management. The September supervisory amendment introduces service-specific capital: GEL 150,000 for exchange or transfer and GEL 350,000 for platforms, with separate categories for other services and stablecoins. Combined services use the highest relevant minimum, distinct from the project's total budget.
NBG announces risk-framework compliance by 1 July 2027 and capital compliance by 1 September 2027 for already registered providers. These periods do not automatically exempt a new applicant. The stablecoin rule requires prior written consent for an initial offering, in addition to the corresponding VASP registration.
Which rights and reserves must support issuance
A tokenized security falls outside NBG's ordinary virtual-asset definition and requires assessment under the instrument's own rules. Technical representation does not itself establish equity, enforceable debt or land transfer. The structure must identify the right, issuer, relevant register, transfer restrictions, custody and exercise arrangements.
For stablecoins, the March rule establishes reserve and capital separation, redemption rights and audit controls. The September amendment retains at least 100% backing, specifies the fiat-currency link and adds bank-concentration limits. Reserves do not constitute a state guarantee or remove AML conditions for redemption.
Which restrictions affect payments and operations
The original regulation restricts services through agents and virtual-asset lending to individuals. Official payment FAQs distinguish VASP services from ordinary commercial receipts: voluntary acceptance does not authorise the latter. Exceptions for service fees or regulated conversion should not be described as unrestricted use of virtual currencies.
Order 215/04 updates reserve reporting from 10 September. Separately, the stablecoin amendment extends the documentation period for existing issuers to one year from the regime's commencement, with conditional continuation pending a decision. The old six-month period is not reproduced or offered as an entry route for new issuers.
How to prepare registration, issuance and controls
Start with a service and flow inventory: the asset, contracting company, key control and intended clients. Compare it with the services in the registration decision and the capital applicable to the planned combination. Extensions announced for existing operators do not automatically apply to a new company.
A stablecoin project additionally needs prior consent, reserve policy, redemption and reporting arrangements, reading the March rule with September 2026 amendments. Tokenized securities require assessment under the instrument’s rules. Check the consolidated law and individual decision; the public register alone does not settle every condition.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Supervision is no longer limited to registration and AML.
- Capital and controls vary by service and transitional status.
- September amendments change reserves and issuer transition requirements.
- VASP registration does not authorise a securities token.
Regulatory milestones
Initial VASP registration regime
General application of Order 94/04, with specific deferred requirements.
Reserve and reporting amendments
Orders 214/04 and 215/04 apply, changing transition arrangements for existing issuers.
Frequently asked questions
No. An initial offering requires prior written NBG consent and compliance with specific reserve, capital, redemption and documentation requirements.
The announced periods concern already registered providers. They are not a general exemption for new applications; the applicable regime must be checked.
The NBG’s September announcement requires the highest applicable minimum among the services supplied. That amount does not represent every business cost or reserve requirement. NBG · September supervisory reform.
The amendment requires registration decisions to identify authorised services. Check those services and conditions against the functions the provider will actually perform. NBG · September supervisory reform.
The rule establishes reserves and redemption against the issuer. Those obligations do not turn a token into a guaranteed deposit or remove applicable redemption conditions. Order 52/04 · Stablecoins.
