Search for “crypto license Georgia” and you’ll mostly find law firms selling one. This page isn’t a sales pitch. It’s a founder’s map of what Georgian law actually requires to run a crypto business here: who has to register with the National Bank, what goes into an application, how much capital the amended rules demand, and which commonly quoted numbers come from the law and which only from law-firm websites.
One thing upfront: this is an explainer built from the NBG’s published texts and secondary sources, not legal advice. Registration is a regulated process with real money at stake, so you will want a Georgian lawyer for the filing itself. What this page can do is make sure you walk into that meeting knowing the right questions.
It’s a registration, not a license
Georgian law doesn’t create a “crypto license”. Article 52⁵ of the Organic Law on the National Bank of Georgia makes registration with the NBG mandatory for virtual asset service providers (VASPsVASPVirtual Asset Service Provider — a crypto exchange, ATM operator or custodian. In Georgia every VASP must be registered with the National Bank (NBG).), and only a registered VASP — or a bank or other financial institution authorised under its own law — may provide virtual asset services. The procedure sits in the NBG’s “Rule on Registration of Virtual Asset Service Providers at the NBG, Cancellation of Registration and Regulation”, approved by Order No. 94/04 of 13 June 2023 and in force since 1 July 2023.
The distinction matters less than marketing pages suggest — registration is still permission to operate, followed by supervision — but it helps you read offers critically. Anyone selling a “Georgian crypto license” is selling help with an NBG registration.
The regime is young. Before 1 January 2023 Georgia had no registration or licensing system for crypto businesses at all. Firms already operating then had 90 days from the rule’s entry into force to apply. Today’s register (version 23 October 2026) lists 43 providers, all limited liability companies, numbered 0001-9404 to 0044-9404. The broader legal picture — the payment ban, KYC rules, stablecoins — is in our guide to crypto regulation in Georgia.
Who has to register, and who doesn’t
You need registration if you provide any of these seven services for the benefit of another person:
| Service | Typical business |
|---|---|
| Exchange (incl. kiosks) | Exchange office, crypto ATM operator, online broker |
| Transfer | Sending crypto on customers’ instructions |
| Safekeeping or administration | CustodialCustodialSomeone else (an exchange, a bank app) holds the keys for you. Easy to use, but you depend on that company. wallet, key custody |
| Portfolio management | Managing individual crypto portfolios |
| Trading platform | Exchange with an order bookOrder bookThe live list of buy and sell orders on an exchange. The deeper it is, the less the price moves when you trade. |
| Lending | Crypto loans |
| ICO and related services | Token launches, including stablecoin issuance |
Exchange covers crypto to fiat, crypto to crypto and crypto to financial instruments. Look at how existing providers are registered: Cryptomat (0005-9404) and PayBit (0033-9404) hold exchange “including via kiosks” for the machines covered in our crypto ATM guide, while full-stack platforms such as Cryptal (0002-9404) and WhiteBIT Georgia (0007-9404) are registered for all six service groups the register records.
You don’t need separate registration if:
- you’re a commercial bank, microbank, microfinance organisation or brokerage company — these may provide exchange, transfer, safekeeping and auxiliary crypto services under their own licenses, subject to restrictions;
- you trade P2P solely with your own funds on a platform without providing services to third parties (NBG FAQ);
- your product deals only in NFTs, which fall outside the legal definition of a virtual asset because it requires assets to be non-unique.
Three structural rules catch founders out:
- One business only. A registered VASP may do nothing except virtual asset services, the auxiliary activities they need, and exchanging its own crypto. If you also build software or run an IT agency, that needs a separate company.
- No agents. Services may not be provided through an agent, according to Crystal Intelligence’s summary of the rule.
- Free zones don’t help. The NBG stated in October and November 2025 that crypto providers in free industrial zones also need NBG registration under the Law on Free Industrial Zones.
Capital and risk requirements
Until autumn 2026 there was no minimum capital at all. On 8 September 2026 the NBG announced amendments to the registration rule that introduce minimum supervisory capital by activity:
| Activity | Minimum supervisory capital |
|---|---|
| Exchange (incl. kiosks) and/or transfer | GEL 150,000 |
| All other services, except stablecoin ICO | GEL 250,000 |
| Trading-platform administration | GEL 350,000 |
| Stablecoin ICO | GEL 500,000, rising with reserves |
If you offer several services, you must meet the highest applicable minimum. A business that exchanges, transfers and runs an order-book platform needs GEL 350,000, not the sum of the three.
The same amendments require a risk-management framework covering operational risk, cybersecurity, process management and business continuity. The NBG’s registration act will now list the exact service types you may provide, and the public register will show them — so plan your scope before you apply rather than adding services later. Providers registered before the change must have the risk framework in place by 1 July 2027 and meet the capital minimum by 1 September 2027. EY dates the underlying order 26 August 2026.
Registering a VASP step by step
The sequence below follows what the NBG rule covers: suitability, AML/CFT readiness at the application stage, infrastructure and post-registration duties. The order of the middle steps is flexible; in practice founders work on several in parallel.
Map your business to the seven services
Write down exactly which services you’ll provide and to whom. Check the exemptions above. If you’re a bank or brokerage, your own license may already cover exchange, transfer and custody. If you’ll run kiosks, say so: “exchange including via kiosks” is a distinct entry on the register.
Set up a dedicated Georgian company
All 43 registered providers are Georgian limited liability companies. Because a VASP may only provide crypto services, keep any software, marketing or IT work in a separate entity from day one. Restructuring later means touching a supervised company.
Prepare the fit-and-proper file
The NBG checks the suitability of administrators and of direct or indirect significant shareholders, including beneficial owners. Expect to document identity, ownership chains, experience and reputation for each. Complex foreign holding structures take the longest to evidence.
Build the AML/CFT framework
The rule requires an AML/CFTAMLAnti-money-laundering rules. They are why an exchange or bank may ask where your money came from. internal policy based on an organisational risk assessment at the application stage. Around it you’ll need customer due diligence procedures, sanctions and politically-exposed-person screening software, travel-rule data handling, five-year record retention, and reporting lines to the Financial Monitoring Service.
Prepare capital, risk management and infrastructure
Fund the supervisory capital for your highest-rated service, write the risk-management framework, and set up the head office, any branches and kiosks, and the software the rule covers. If you plan to issue a stablecoinStablecoinA token designed to track a currency, usually the US dollar. USDT and USDC aim to stay worth $1., you also need the NBG’s prior written consent under Order 52/04 and reserves of at least 100%.
Apply to the National Bank of Georgia
Submit the application and supporting documents and pay the fee. Law firms report GEL 5,000 and a decision within about 60 days (see below for how firm those figures are). Answer follow-up questions quickly; most delays come from incomplete ownership documents.
Go live and display your registration
Once the NBG issues its act, your company appears on the public register. You must display or make easily accessible the act confirming your registration at your head office, branches and kiosks and on your website and apps. From then on you’re a supervised, obliged entity.
Fees and timelines: what’s confirmed and what isn’t
Two numbers appear on almost every “crypto license Georgia” page. Neither is confirmed in the primary text we could access.
- Registration fee: GEL 5,000. Reported by Andersen and others. Sources disagree on whether it’s charged once (Georgia Today) or per submission (pbservices.ge), which matters if your first filing is returned.
- Decision time: about 60 days. Reported by Revera and pbservices.ge, described by some as calendar days. One firm says two to four months in practice.
The register gives a rough sense of pace. Twelve providers were added between 2 March 2026 (PayBit, 0033-9404) and 26 August 2026 (Laonor/YXXY, 0044-9404). The register shows registration dates, not application dates, so it can’t tell you how long any single file took.
Budget beyond the fee for legal drafting, AML software, the audit and, under the new rules, capital that sits in the company. Be wary of anyone quoting a fixed turnaround: the NBG decides, not the adviser.
After registration: ongoing obligations
Registration is the start of supervision, not the end of paperwork. The main duties:
- Customer due diligence. On establishing a business relationship and for any single crypto transaction above USD 1,000 / EUR 1,000 / GEL 3,000, or funds transfer above GEL 3,000, according to Andersen. We couldn’t verify the AML Law article.
- Travel rule. Collect and transmit originator and beneficiary information before sending or receiving crypto, as specified by the NBG.
- Record-keeping and reporting. Keep records for five years; NBG fine notices cite article 27 of the AML Law on recording and retention, and Financial Monitoring Service Orders No. 1 and No. 2 of 5 June 2020 on transaction reporting and identification of natural persons.
- Sanctions. Comply with the NBG’s sanctions rule (Order 208/04 of 4 August 2023).
- Display. Keep the registration visible in every channel (Order 266/04; the NBG gives 1 January 2026 as the start date, while some coverage dates it from the November 2025 announcement).
- Capital and risk. Meet the new capital minimum and risk framework, with the testing and audit cycle described above.
Enforcement is real. Under the penalty rule (Order 133/04 of 29 May 2024), the NBG fined Sher888 LLC GEL 465,000 for AML failures — including GEL 264,000 for 528 transactions without proper records and GEL 3,000 per client for failing to record the purpose of the relationship — and the company now sits on the register’s “Canceled” sheet. PayBit Georgia was fined GEL 3,000 for a record-keeping breach.
Foreign founders
Most interest in a “crypto license in Georgia for foreigners” comes from founders outside the country. The law treats them the same way: register a Georgian company, pass the fit-and-proper review, meet the AML and capital rules.
What the register shows is that foreign groups do this through local subsidiaries. Bybit Georgia Limited LLC (0019-9404, Kostava Street 14, Tbilisi) and Whitebit Georgia LLC (0007-9404) are the two global brands registered. We found no nationality restriction on owners or directors in the sources we read. Practical points for foreign founders:
- Ownership transparency. The NBG reviews direct and indirect significant shareholders and beneficial owners, so every layer of a holding structure needs documents.
- No agents, no free-zone workaround. Services can’t be provided through an agent, and a free industrial zone address doesn’t exempt you from registration.
- Not an IT company. Because a VASP may only do crypto services, it probably can’t use Georgia’s Virtual Zone Person status for IT companies, and a combined crypto-plus-software business needs two entities.
- Ready-made offers. Since the NBG reviews owners as well as the company, buying an already-registered company is unlikely to be a formality. Ask your lawyer how a change of significant shareholder is handled before you sign anything.
- Tax. A Georgian company pays 15% profit tax only on distributed profit and 5% on dividends; exchanging crypto for money is outside VAT. The individual 0% doesn’t apply to companies, and Small Business status excludes financial services. Our crypto tax guide has the details.
Banks, payments and the business model
A crypto exchange needs a bank. We found no Georgian bank that publishes its policy on onboarding crypto providers, and secondary sources report banks questioning crypto-related transfers. There are encouraging signs: TBC Bank’s in-app crypto trading is executed by Bybit Georgia, and Cryptal (0002-9404) accepts Bank of Georgia and TBC cards for deposits, which shows registered providers can get card acquiring. Our page on banks and crypto in Georgia tracks what’s known.
The payment ban also shapes what you can sell. Crypto isn’t legal tender, and Georgian businesses may not accept crypto as payment for goods or services. But a registered VASP may, on a customer’s instruction, convert crypto and send the fiat proceeds to a payment service provider or acquirer. That’s the legal foundation for merchant “crypto payments” in Georgia, and it’s a business only a registered provider can run. A VASP may also charge its own fee in the same crypto.
Two more things to plan for:
- Bank concentration for stablecoin issuers. EY reports that if fiat reserves exceed GEL 5 million, no more than 50% may sit with one bank; Andersen adds a cap of 10% of that bank’s share capital.
- Banks as competitors. Commercial banks, microbanks, microfinance organisations and brokerages can offer exchange, transfer and custody under their own licenses without VASP registration.
If you’re a customer rather than a founder, you don’t need any of this: just check that the provider you use is on the list of licensed crypto exchanges in Georgia, read our exchange comparison, or start from the crypto in Georgia overview.
