Stablecoin issuance in Georgia is a separate regulatory workstream. Ordinary VASP registration is not enough: the current framework requires prior written NBG consent and dedicated requirements around reserves, capital, redemption, disclosure and ongoing controls.
We structure the project around the stablecoin liability itself: legal rights, Whitepaper, reserve assets and custody, 100% backing, regulatory capital, issuance and redemption, reconciliation, reporting, technology resilience and the relationship between issuer and VASP functions.
Regulatory classification
The first question is whether the proposed token falls within the Georgian stable virtual asset framework and what entity will issue and service it. The consent process and operating controls should be designed before promotion or technical launch, not added after the token is circulating.
- Prior NBG consent
- Whitepaper and token rights
- Reserve backing and segregation
- Capital, redemption and resilience
Build the reserve and redemption model before issuance
The operating design should connect every token in circulation to eligible reserve assets, reserve custody, segregation, reconciliation and a legally and operationally executable redemption process. Capital planning and provider dependencies should be included from the outset.
Required stablecoin evidence
The file should include the Whitepaper, issuance and redemption rules, reserve policy, custody and account ownership, reconciliation methodology, valuation and monthly reporting, regulatory-capital evidence, technology controls, incident response and governance for changes to the token or reserve model.
Principal control risks
Stablecoin projects fail credibility tests when reserves are treated as treasury cash, segregation is ambiguous, redemption is only a marketing promise, the Whitepaper does not match actual mechanics, or capital, reconciliation and technology resilience are considered only after launch.
Prior NBG consent changes the launch sequence
The project should be planned around regulatory consent, Whitepaper and reserve readiness before issuance or promotion. Ordinary VASP registration should not be represented as sufficient authority to issue a stablecoin.
Scope of our engagement
Our stablecoin work can cover classification, prior-consent workstream, Whitepaper review and preparation support, reserve and segregation architecture, capital planning, issuance/redemption controls, reconciliation and reporting, custody/provider arrangements, application evidence and operational readiness. The legal text uses “Whitepaper,” which we retain in the project documentation.
Monthly issuer return
The first stablecoin report is due by 15 October 2026. Thereafter, an electronically signed Excel return is due by the 10th of each month for the preceding calendar month and is submitted to VASP@nbg.gov.ge. It covers issuance, circulation, daily redemptions, reserve composition and location, and the coverage ratio. Reserve coverage must remain at least 100%.
Consent strategy
Sequence entity, VASP status, NBG consent and launch dependencies before token issuance or promotion.
Reserve evidence
Demonstrate 100% backing, segregation, custody, reconciliation and the relationship between reserves and tokens in circulation.
Redemption readiness
Make redemption rights, operational timing, liquidity, incident handling and customer disclosure consistent with the Whitepaper and systems.
Stablecoin issuance and reserve chain
A practical sequence used to test whether contracts, systems, providers and control ownership describe the same service.
Issues to resolve before filing
No. The current Georgian stable virtual asset framework requires prior written consent from the National Bank of Georgia in addition to the relevant VASP framework. The consent, reserve and disclosure workstream should therefore be planned before launch.
The issuer should be able to demonstrate that tokens in circulation are fully backed by qualifying reserve assets, with clear account and custody ownership, segregation, valuation, reconciliation, reporting and controls preventing reserve use inconsistent with the regulatory framework.
The current framework includes a GEL 500,000 minimum regulatory-capital baseline for the relevant stablecoin activity, subject to the exact legal and operational structure. Capital planning should be reviewed against the current regulation before filing.
Use accounts, custody arrangements, internal ledgers, governance and reconciliation that distinguish reserve assets from operating funds and make the ownership and permitted use of reserves clear. The legal documentation, Whitepaper and actual account structure should be consistent.
Test normal and stressed redemption, reserve liquidity, pricing/valuation inputs, bank or custodian outage, reconciliation breaks, system failure, privileged access, communication, incident escalation and the ability to evidence each decision and transaction.
