The registration question is not answered by calling a product a wallet, broker, OTC desk, software layer or Web3 platform. Georgian law looks at the service actually supplied for another person: who accepts the instruction, who controls the asset or control instrument, who executes or arranges the exchange, and who administers the customer relationship.
The short answer
A person providing a covered virtual-asset service for the benefit of another person must normally be registered with the National Bank of Georgia before starting that activity in Georgia. The formal status is VASP registration; “crypto licence” is useful market language but should not obscure the legal test.
The covered categories include exchange between convertible virtual assets and fiat, other virtual assets or financial instruments; transfer; safekeeping or administration of assets or instruments enabling control; individual portfolio management; administration of a virtual-asset trading platform; permitted virtual-asset lending; and an initial offering or a service related to it. Exchange through a kiosk is expressly within the perimeter.
Start with the customer journey, not the label
We normally begin with a whiteboard-level journey. Who attracts the customer? Which entity signs the terms? Where does identity verification occur? Who receives the order or transfer instruction? Which company controls the wallet, private key, API credential, omnibus account or withdrawal rule? Where do fiat and virtual assets settle? Who earns the spread, commission or fee? Those answers usually reveal the regulated service more clearly than a product name.
A “non-custodial wallet” may still require analysis if the operator can influence signing, recovery or transaction execution. A “technology provider” can move into the perimeter if it contracts with end users and performs the service, rather than supplying software to a separately accountable VASP. An OTC desk may be exchange, brokerage or principal trading depending on whose benefit the activity serves and how third parties are involved.
Founder scenarios
Exchange or brokerage
If the company accepts a customer instruction and exchanges or arranges exchange of convertible virtual assets, the starting assumption should be that registration analysis is required. Principal-versus-agency execution, liquidity venues, custody and fiat settlement change the evidence, not the need to analyse.
Custody and wallet operation
Safekeeping an asset or administering an instrument that enables control can be regulated. Key creation, co-signing, recovery, withdrawal approval, omnibus ledger control and the contractual allocation of responsibility must be mapped.
Transfers and remittance
Moving convertible virtual assets for customers is a covered category. The build should address originator and beneficiary information, counterparty VASPs, self-hosted wallets, sanctions and transaction monitoring from the beginning.
Platforms, managed portfolios, business lending and token offerings
Each is specifically capable of falling within the VASP perimeter. Other regimes may also apply. A token can resemble a security or another financial instrument; fiat movement can raise payment-services questions; lending, consumer, data and sanctions rules must be assessed separately.
Activities reserved or restricted in the wider framework
Registration does not permit every financial activity and does not turn virtual assets into legal tender. A VASP is generally limited to virtual-asset services, necessary auxiliary activity and exchange of its own virtual assets, subject to the detailed rules and exceptions for other authorised financial institutions. Product design must therefore ask both “is this a VASP service?” and “does another rule prohibit or separately regulate part of it?”
How CryptoLicense.ge performs the perimeter review
- Interview founders and product owners using the intended live journey.
- Map contracting entities, users, assets, instructions, custody/control, providers, fiat and virtual-asset legs.
- Classify each activity and identify payment, securities, lending, consumer, tax, data and sanctions overlaps.
- Record assumptions, prohibited features, open questions and redesign options.
- Deliver a written go, redesign or stop view with the evidence and implementation consequences.
The result is designed to support an investment and product decision, not merely a legal label. If registration is required, the map becomes the first controlled version of the application story.
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.