Georgia's 2026 Stablecoin Framework for Issuers

NBG Governor Order No. 52/04 establishes the framework for a VASP’s initial coin offering of a stablecoin, including issuance and subsequent services. The regime requires full reserve backing, reserve segregation, redemption rights and deadlines, regulatory capital, accounting, external verification, a Whitepaper subject to NBG consent, risk management, cybersecurity and continuing reporting.

Reserve assets must track the liability continuously

The issuer must maintain reserve assets representing at least 100% of the nominal value of issued stablecoins at all times. Reserve assets are generally denominated only in the currency to which the stablecoin is pegged, subject to the rule’s specific reserve-asset framework and NBG consent mechanisms.

The reserve composition must be assessed daily. The financial institution where the issuer intends to place reserve assets is subject to NBG approval, and reserve-management arrangements should allow the issuer to access reserve assets when redemption is due.

Segregation must work in an insolvency scenario

Reserve assets must be segregated from the issuer’s own assets through effective internal controls so that they remain identifiable and protected from creditor claims in an insolvency scenario. They are to be maintained for stablecoin holders to the extent necessary to satisfy outstanding obligations, with mechanisms to isolate them from insolvency proceedings.

The rule also restricts encumbrance and third-party recourse over reserve assets. That makes account structure, custody agreements, control rights and legal documentation part of the prudential architecture, not back-office administration.

Redemption rights have defined deadlines

The issuer must support the right of a holder—client or non-client—to redeem at any time, subject to the AML/CFT and service-term conditions in the rule. For a client, redemption at nominal value is generally required no later than three business days after the request. Where a single client’s aggregate redemption request exceeds GEL 300,000 or the foreign-currency equivalent, the issuer may use a deadline of no later than five business days.

For non-clients, enhanced due diligence and the applicable AML/CFT and sanctions requirements must be completed before the deadline begins to run. Redemption fees and minimum purchase or redemption volumes may be set only on a reasonable and proportionate basis and must be disclosed clearly in advance.

Capital is separate from reserve backing

The issuer must maintain minimum regulatory capital of at least GEL 500,000. Where total reserve assets are at least GEL 1,000,000, the rule provides a scale-based calculation: the GEL 500,000 minimum plus no less than 2% of the average daily value of reserve assets over the preceding six months, subject to the rule’s GEL 50 million limit.

Reserve assets protect the stablecoin liability; regulatory capital protects the issuer’s resilience. The same funds should not be conceptually counted twice in the operating model.

Reserve verification and financial reporting are continuing obligations

An independent qualified external auditor must verify reserve assets quarterly. The report covers reserve composition and market value together with the nominal value and volume of issued stablecoins, and the issuer must publish the report quarterly on its website. Material discrepancies or deficiencies identified in the report must be notified to the NBG immediately and remediated.

The issuer must also engage an independent qualified external auditor annually and submit the prior year’s audited financial statements to the NBG no later than 15 July of the following year. Accounting records are subject to specific reliability, real-time entry, four-eyes, logging and retention requirements.

A separate monthly return starts in October 2026

Under Order No. 201/04, the first stablecoin issuer report is due by 15 October 2026. Subsequent reports are due by the 10th day of each month for the preceding calendar month and must be submitted as an electronically signed Excel file to VASP@nbg.gov.ge.

The return covers stablecoins issued and in circulation, daily issuance and redemption, reserve composition and location, and the reserve-coverage ratio. The reporting process should be generated from daily reconciled data because reserve coverage must remain at least 100%, not merely reach that level at month end.

The Whitepaper is a regulatory document, not marketing copy

Before the initial coin offering, the issuer must prepare a Whitepaper and submit it to the NBG for consent together with the prescribed operational-risk assessment. The Whitepaper covers the issuer, governance, other VASP services, participants and DLT platforms, stablecoin characteristics and target market, reserve backing and segregation, risks, compliance, technology, redemption and dispute resolution.

The Whitepaper must be published in Georgian; other languages may be added, but the Georgian version prevails in case of inconsistency or ambiguity. Updates should preserve prior versions, and Whitepaper version records must be retained for at least eight years after the stablecoin is withdrawn from circulation.

Advertising must follow the approved disclosure architecture

Advertising must correspond to the Whitepaper and cannot be made public before the Whitepaper is published. Product, reserve, redemption and risk claims should therefore be governed through the same change-control process as the Whitepaper rather than maintained as a separate marketing narrative.

Technology and operational resilience can determine consent

The framework requires a risk-management system proportionate to the scale and complexity of the issuer, including operational risk controls. The NBG materials also connect consent to the quality of audit and penetration-testing evidence: critical or high-risk vulnerabilities can prevent consent and can support suspension or revocation of consent already granted.

Key compromise, ledger failure, reconciliation breaks, unavailable redemption channels or a critical-provider outage should therefore be tested as liquidity, customer-protection and regulatory events—not only as IT incidents.