The National Bank of Georgia (NBG) registers virtual asset service providers under Decree No. 94/04 of June 13, 2023. An LLC has no statutory capital requirement, the state fee is paid once, and the NBG reviews a complete application within 60 calendar days. Registration also requires a physical office in Georgia, fit and proper management, an administrator present in the country for at least 14 days each month and direct client servicing without agents. VASP registration in Georgia provides no access to the EU single market.
What a Georgian VASP Registration Covers
Registration is mandatory for any entity that provides virtual asset services in or from Georgia. The NBG's rules cover exchanges, providers of crypto-to-fiat and fiat-to-crypto conversion, operators handling virtual asset transfers, custodial wallet providers, and other intermediaries whose business involves virtual assets on behalf of third parties. Virtual assets that use privacy-enhancing technology preventing identification and tracing of parties are excluded; a VASP may not handle them. The regime does not apply to individuals buying or selling crypto for their own account.
Only a limited liability company (LLC) or a joint stock company (JSC) incorporated in Georgia may apply. Individual entrepreneurs are excluded from the framework entirely. The applicant's head office must be located in Georgia, and a registered mailing address alone does not satisfy the requirement. The NBG uses the registration process to verify corporate structure, beneficial ownership, fitness of key persons and the adequacy of anti-money laundering controls before a provider can begin operating.
Company Form and Capital Requirements
The NBG does not set a separate capital floor for VASP registration. For an LLC, Georgian corporate law imposes no minimum share capital, which is one reason the jurisdiction costs less to enter than an EU CASP authorization under MiCA. A joint stock company follows the general rule in the Law on Entrepreneurs: minimum subscribed capital of GEL 100,000, with at least 25 percent paid in at incorporation. That threshold belongs to Georgian corporate law, not to the NBG's VASP framework.
Stablecoin issuance falls under a separate regime. On March 6, 2026, the NBG signed Order No. 52/04 establishing rules for the initial coin offering of stablecoins by registered VASPs. Issuers must hold regulatory capital of at least GEL 500,000, and reserve assets backing holders' claims must be legally and operationally segregated from the company's own funds.
A standard VASP LLC therefore avoids a statutory capital floor. Georgian banks still assess the source of funds, projected transaction volumes and the company's ability to finance its operations when reviewing an account application.
Substance Requirements: Office, Director and the 14-Day Rule
The company must maintain a physical office in Georgia. The NBG expects a lease agreement and supporting payment documents at the application stage. A virtual address, a coworking desk or a mailbox service will not satisfy this requirement.
The management structure must provide sufficient local presence, and at least one administrator must meet the monthly presence requirement described below. The NBG evaluates directors, administrators and holders of qualifying shareholdings against fit and proper criteria. The application package includes CVs, apostilled criminal record certificates and declarations covering sanctions exposure, previous bankruptcies and regulatory disqualification.
The responsible administrator must be physically present in Georgia for at least 14 days each calendar month. The requirement continues while the company holds its VASP registration in Georgia. Salary, accommodation and travel should therefore be included in the recurring operating budget.
| Requirement | Key points |
|---|---|
| Company form and capital | Georgian LLC: no statutory minimum share capital; Georgian JSC: GEL 100,000 minimum subscribed capital, with at least 25% paid at incorporation; Stablecoin issuers: separate regulatory capital of at least GEL 500,000. |
| Local presence | Physical head office in Georgia. At least one responsible administrator must be present in Georgia for a minimum of 14 days each calendar month. |
| Restrictions | Services cannot be provided through agents or other third parties acting on the VASP’s behalf. Virtual assets cannot be lent to natural persons. Privacy-enhancing virtual assets that prevent identification or transaction tracing cannot be handled. |
| Review timeline | The NBG reviews a complete application within 60 calendar days. The review may be extended by another 60 days if additional information is required. |
What Georgia Prohibits
The NBG rules restrict two common operating models.
A registered VASP may not provide services through agents or other third parties acting on its behalf. Clients must be served directly, which makes the framework unsuitable for businesses that depend on an agent distribution network.
Lending of virtual assets is included in the NBG's list of virtual asset services, but a VASP may not lend virtual assets to natural persons. The restriction should therefore be assessed against the intended borrower category rather than treated as a complete ban on crypto lending. A VASP may charge a customer in Georgian lari or in the same virtual asset used for the relevant service.
Costs and Timeline
The state fee for VASP registration in Georgia is GEL 5,000, approximately USD 1,800. It is paid to the state treasury before submission. The registration does not carry an annual renewal fee.
The NBG reviews a complete application within 60 calendar days and may extend the review by another 60 days when further information is required. Company formation, document preparation and bank onboarding take place before submission. The full schedule therefore exceeds the regulatory review period and depends partly on the bank's assessment of the ownership structure, source of funds and business model.
Professional support starts from EUR 30,000 under Equilex's current estimate, covering company formation, document preparation, AML policies and submission management. Office rent, local personnel, travel, compliance systems and banking remain separate operating costs. The state fee represents only a small part of the first-year budget.
If you are assessing whether Georgia fits your model or how the local presence requirements apply to your team, schedule a call with the Equilex licensing team to assess the company structure, substance requirements and expected timeline.
The Registration Process
The company first incorporates as an LLC or JSC through the National Agency of Public Registry and opens a corporate bank account in Georgia. It then prepares the documentation package for submission to the NBG.
The package includes corporate formation documents, a full ownership and ultimate beneficial owner structure, a business plan describing the virtual asset services the company intends to provide, internal AML/KYC policies and procedures, transaction monitoring and reporting frameworks, and fit and proper documentation for all directors, administrators and qualifying shareholders.
During the review, the NBG may request explanations, updated documents or changes to the proposed controls. The company may begin regulated operations only after registration has been granted.
After registration, the company reports to the NBG and the Financial Monitoring Service of Georgia, complies with the Travel Rule and maintains the required office and local presence. The NBG may impose monetary fines for violations, categorized as less serious, serious or especially serious.
Tax Treatment
Georgia generally applies a distributed-profit model to resident companies. The profit tax rate is 15 percent and applies to distributed profit and other taxable disbursements defined by the Tax Code, including certain non-business expenses, free transfers and non-arm's-length transactions. Dividends paid by a resident enterprise to a natural person or a non-resident enterprise are generally subject to 5 percent withholding, subject to the recipient and any applicable exemption.
The Tax Code does not provide a general "0% crypto tax" rate for VASPs. Statements about individual crypto gains and VAT treatment depend on the taxpayer, transaction and applicable administrative guidance. A Georgian tax adviser should confirm the treatment before the company relies on an exemption or builds it into financial projections.
Georgia Is Not MiCA
Georgia is outside the EU and EEA. A Georgian VASP registration carries no MiCA passport, so serving EU-based clients requires a separate CASP authorization from a member-state regulator.
The company must also assess the licensing and solicitation rules of every country where it targets or accepts clients. Georgian registration does not replace local authorization in those markets.
Groups serving both markets may use a Georgian VASP for permitted non-EU operations and a European CASP for the single market. The Best Countries to Get a Crypto License in 2026 guide outlines the main cost, timeline and market-access differences between these routes.
For a broader view of crypto licensing routes, see the Equilex crypto licensing hub.
FAQ
Is there a minimum capital requirement for a Georgian VASP?
An LLC has no statutory capital threshold for standard VASP registration. A JSC follows the general corporate rule of GEL 100,000, with 25 percent paid at incorporation. Stablecoin issuers fall under NBG Order No. 52/04 and require regulatory capital of at least GEL 500,000.
Do I need to live in Georgia to hold a VASP registration?
The company needs a physical head office in Georgia. At least one responsible administrator must be present in the country for 14 days each calendar month. The associated salary, travel and accommodation form part of the company's recurring operating costs.
Can I serve clients through agents or partners in Georgia?
No. The NBG rules prohibit a VASP from providing services through agents or other third parties acting on its behalf. A business that depends on an agent distribution network will need a different operating structure or jurisdiction.
How long does VASP registration in Georgia take?
The NBG reviews a complete application within 60 calendar days and may extend the period by another 60 days. Incorporation, bank onboarding and document preparation take place before submission, so the full project lasts longer than the NBG review window.
Does a Georgian VASP registration allow me to serve EU clients?
No. Georgia is outside the EU and EEA, and its registration carries no MiCA passport. Serving EU-based clients requires CASP authorization from an EU member state. A group operating in both markets may require separate Georgian and EU entities.
