The regulatory sandbox can help an eligible innovator test a novel financial service in a controlled environment and engage with the National Bank. It should not be marketed as a provisional or temporary VASP licence, and participation does not remove the need for the authorisation or registration required for full commercial operation.
What a regulatory sandbox is for
A sandbox is a structured testing environment. A proposal should identify the innovation, consumer or market benefit, uncertainty to be tested, participants, limits, safeguards, data and success or exit criteria. The purpose is to learn under defined conditions, not to avoid building a compliant operating model.
It is not an automatic route for every crypto project
A conventional exchange, custody or transfer business that already fits the VASP framework may need to follow the ordinary registration route. Calling existing technology “innovative” does not by itself establish a sandbox case. The NBG decides whether and on what conditions a proposal is admitted.
It is not a temporary VASP licence
Sandbox participation should not be described to customers or investors as permission to conduct unrestricted VASP business. Test scope, users, duration, transaction limits, disclosures and safeguards may be restricted. A project that intends to continue at scale must plan the formal regulatory route and operating build in parallel.
Sandbox readiness questions
- What is genuinely new, and which rule or supervisory question requires testing?
- Who are the test users and how will they give informed consent?
- What asset, transaction and loss limits apply?
- How are customer assets, data, complaints, incidents and exit handled?
- What evidence will demonstrate success or reveal failure?
- Which licence, registration or product redesign follows the test?
Regulatory Laboratory and early dialogue
The NBG also presents innovation-support channels including its Regulatory Laboratory. The most appropriate route depends on whether the project seeks clarification, technical testing or a controlled live experiment. Early materials should be concise but concrete: architecture, customer journey, legal perimeter, risk register and proposed safeguards.
How we prepare an innovation engagement
- Separate the novel element from the ordinary regulated service.
- Write the legal and supervisory uncertainty as a testable question.
- Design limits, disclosures, monitoring, incident and exit controls.
- Map the post-test registration and operational work.
- Prepare meeting materials and coordinate regulatory responses.
CryptoLicense.ge can support the innovation dialogue and the later VASP build. We do not promise sandbox admission or present it as a way to trade before registration.
Official materials used for this guide
These links support the editorial baseline; the explanation above is written for founders and operators. Current consolidated legislation and later official instruments take priority.