Georgia’s 2026 framework treats a stable virtual asset as more than token code. A registered VASP needs prior written NBG consent, and the issuer must operate a coherent system of reserve backing, segregation, redemption, holder information, capital, reporting, governance and resilience.
Begin with prior consent and perimeter
Separate issuance, initial offering, distribution, exchange, transfer, custody and other subsequent services. Identify the issuer, VASP, reserve holders, custodians, banks, technology providers and target users. Do not market or launch on the assumption that ordinary VASP registration automatically covers the stablecoin.
Maintain 100% reserve backing
Circulating units and reserve assets must remain connected. Define eligible reserve composition, valuation, liquidity, concentration and reconciliation; escalation for breaks; and management reporting. The reserve should be capable of meeting redemption rather than merely matching an accounting number.
Segregate reserve assets
Reserve assets and the issuer’s own capital have different purposes. Account structure, legal title, custody agreements, access rights and insolvency analysis should make segregation meaningful through normal operation and stress.
Design redemption before distribution
State who may redeem, at what value, through which channel, within what time, with what fees and checks, and how failed or disputed requests are handled. Test a high-volume or provider-outage scenario, not only the happy path.
Make the offering document match the system
Holder rights, reserves, redemption, governance, technology, fees, risks and conflicts should agree across public disclosure, contracts, smart contracts, operations and management information. Product changes require controlled assessment.
Capital and scale
The framework includes a minimum GEL 500,000 capital baseline and a scaling formula connected to the model. Capital planning should be read with reserve, operating-cost, incident and growth assumptions and confirmed for the exact structure.
Monthly reserve and circulation reporting
Order No. 201/04 introduced a formal monthly return for stablecoin issuers. The first report, covering the initial reporting period, is due by 15 October 2026; each subsequent report is due by the 10th day of the following month. The electronically signed Excel return is submitted to VASP@nbg.gov.ge and covers issued and circulating units, daily issuance and redemption, reserve composition and location, and the reserve-coverage ratio.
Operational and cyber resilience
Key compromise, ledger failure, reconciliation breaks, bank or custodian outage and unavailable redemption can become liquidity and confidence events. Connect security, continuity, incident response, communication, liquidity and regulatory escalation.
Our stablecoin workstream
CryptoLicense.ge can deliver feasibility and prior-consent preparation, reserve and redemption architecture, governance, offering-document coordination, technology and control evidence, testing and continuing-change support. Specialist accounting, audit, custody, tax and technical providers are scoped transparently.
Legislation and regulatory materials
Our regulatory assessments and implementation work are based on the Georgian legislation and National Bank of Georgia materials below. Legal texts available in our legislation library open on CryptoLicense.ge; the official Matsne source is linked at the bottom of each legal-text page.