The NBG’s 60-calendar-day decision period is one regulatory stage inside a larger implementation. A credible timeline separates model classification, evidence collection, people, premises, systems, policies, testing and translation from review of the prescribed filing.
The statutory clock in one view
| Event | Rule / practical effect |
|---|---|
| Prescribed filing submitted | The NBG decides on registration or refusal within 60 calendar days from submission of the information/documents required by the rule and Annex 5. |
| Documentation is deficient | The NBG can set a 30-calendar-day period to cure deficiencies or clarify submitted data. |
| Additional information, system demonstration or office access requested | The decision clock stops from the NBG request and resumes when the applicant has responded or provided the required access. |
| Additional time is necessary | With reasons, the NBG may extend the decision deadline by a further 60 calendar days and notify the applicant before the original period expires. |
Phase 1 — classify the service before building the file
Confirm customers, countries, assets, control, custody, fiat legs, providers, execution model, revenue and regulatory overlaps. Resolve prohibited or out-of-perimeter features before they become embedded in contracts, software and public launch plans.
Phase 2 — fix the applicant, ownership and management facts
Prepare or form the Georgian LLC/JSC, reconstruct direct and indirect ownership to UBO level, identify significant owners, select administrators and begin time-consuming foreign public documents early. Criminal-record certificates should be scheduled close enough to filing to remain within the applicable validity windows.
Phase 3 — establish the operating environment
Secure the head office, finalise governance and presence arrangements, define staffing, select and diligence providers, document website/application rights and build the service schemes. Product scope, cash channels and branches should be fixed early because they can materially change the evidence set.
Phase 4 — configure and test the system
The system should be capable of performing the service presented in the schemes and supporting customer records, transaction processing, monitoring, cases, logs, reconciliation, reporting, access control and supervisory demonstration. The NBG may ask for a system demonstration at any stage of application review.
Phase 5 — complete policies, business plan and Georgian filing versions
Finish the three-year plan, organisational structure, AML/CFT instruction and risk assessment only after the product/provider/system facts are sufficiently stable. Reconcile names, jurisdictions, services, roles, providers, volumes and controls across the file before notarisation, apostille/legalisation and Georgian translation are treated as final.
Phase 6 — pay the official fee and file
The GEL 5,000 registration fee is paid before registration and the payment receipt is filed with the prescribed documents. At submission, version control shifts from “working draft” to a controlled regulatory record.
Phase 7 — respond to NBG review without fragmenting the dossier
Regulatory questions should be answered against the complete application, not in isolation. A response about a provider, system feature, owner, administrator or transaction flow may require coordinated changes across an annex, scheme, business plan, policy and contract. Where a material model change emerges, assess whether the filing architecture itself needs to be reconsidered.
Phase 8 — decision, controlled launch and first supervisory cycle
Registration should trigger the approved operating model, not a different commercial version created while the application was pending. Confirm registration-act display, staff access, live controls, reporting calendar, change control, provider monitoring and the first 90-day assurance plan before scaling customer acquisition.
What most often changes the overall project duration?
- Complex or changing ownership and beneficial-ownership evidence.
- Foreign criminal records, corporate documents, apostille/legalisation and translation.
- Administrator recruitment, fit-and-proper evidence or governance redesign.
- Uncontracted banks, PSPs, custodians, liquidity venues or technology providers.
- System functionality that cannot reproduce the filed service scheme.
- Generic AML/CFT materials that require rewriting after product and risk facts change.
- Late addition of services, cash locations, countries, custody or stablecoin features.
- NBG deficiency notices, information requests, demonstrations or permitted extension of the decision deadline.
Applicable legislation and regulatory materials
Our registration work is mapped to the current Georgian legal framework and the applicant’s actual operating model. Legal texts reproduced in the CryptoLicense.ge legislation library link to the official Matsne source from the relevant legal-text page.