Georgia uses a mandatory National Bank of Georgia registration regime for businesses that provide covered virtual-asset services for the benefit of another person. The filing is not an incorporation exercise: the applicant must present a coherent operating company, service scheme, governance, technology and AML/CFT control environment.
The commonly used phrase “crypto licence” refers in Georgia to VASP registration with the National Bank.
The general VASP applicant must be a Georgian legal entity in one of these forms.
The registration fee is paid before registration and proof of payment forms part of the filing.
The applicable minimum depends on the registered services and is distinct from the filing fee.
The decision period applies after the prescribed filing; it can pause and may be extended by a further 60 days with reasons.
Which activities fall within VASP registration?
The regulated categories include exchange of convertible virtual assets, transfer, safekeeping or administration of assets or instruments enabling control, individual portfolio management, administration of a virtual-asset trading platform, lending of convertible virtual assets, and an initial coin offering of a convertible virtual asset or a service related to that offering.
The legal classification follows the actual service delivered for another person. Commercial labels such as broker, OTC desk, wallet, gateway, remittance product or technology platform are not decisive on their own. A multi-service product can map to more than one VASP activity.
What VASP registration does not solve
- Unrelated business activities. A standard VASP is generally not authorised to conduct activities outside virtual-asset services, auxiliary activities necessary to provide them and exchange of its own virtual assets.
- Payment and securities perimeter. Fiat payment flows, acquiring, securities-like instruments and other financial services must be assessed separately where they form part of the model.
- Virtual-asset payments. A virtual asset is not legal tender in Georgia and the general rule prohibits payment with virtual assets except for the limited cases necessary to provide virtual-asset services.
- Stablecoin issuance. A stablecoin project can require an additional NBG workstream beyond ordinary VASP registration. See our stablecoin framework analysis.
The applicant should already resemble the company it intends to operate
Order No. 94/04 requires more than a newly incorporated shell. The filing connects the Georgian head office, administrators, significant owners and UBOs, supervisory capital, service flows, providers, website/application, electronic system, three-year plan, organisational structure and AML/CFT framework. The NBG may request a live system demonstration and access to the head office or branches during review.
What the filing must prove
How the NBG review period actually works
| Regulatory point | What it means for the project |
|---|---|
| Complete prescribed filing | The NBG decision period is 60 calendar days from submission of the information/documents required by the rule and Annex 5. |
| Deficiency notice | Where the submitted documentation does not meet the rule, the NBG can give 30 calendar days to correct deficiencies or clarify data. |
| Additional information / access | The NBG can request additional information, a system demonstration or access to the head office/branches. The 60-day decision clock stops while the relevant request is outstanding and resumes after the required response or access. |
| Extension | Where necessary and reasoned, the NBG may extend the decision deadline by a further 60 calendar days and notify the applicant before the original period expires. |
The statutory period is therefore not a promise that a project can be designed, documented, built and approved in 60 days. Preparation time depends on the ownership chain, foreign records, administrators, premises, providers, technology, testing, translations and the quality of the evidence file.
Registration begins supervision
The registered company must maintain the applicable capital threshold and operate through the service scheme, people, premises, systems and controls that support its registration. Product, ownership, administrator, location, website/app and other material changes can trigger prior notice or consent requirements. Inactivity, material non-compliance, critical or high-risk resilience deficiencies, inability to support supervision or divergence from the registered scheme can place the registration at risk.
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.