Crypto License in Georgia
Georgia has become a practical jurisdiction for crypto businesses that want a regulated environment outside the European Union, without the complexity of MiCA licensing. Virtual Asset Service Providers (VASPs) operating in Georgia must complete mandatory registration and remain under ongoing oversight of the National Bank of Georgia (NBG).
Unlike EU regimes where MiCA authorisation is the central “passport” licence, Georgia applies a registration-based framework with substantive supervisory review. Applicants must clearly define their crypto services, demonstrate real operational presence in Georgia, and implement day-to-day controls that can withstand regulatory inspection.
The Georgian regime places strong emphasis on transparent ownership, responsible management, operational substance, and risk-based internal controls. A complete registration file typically includes corporate and ownership disclosures, a business plan, service and transaction-flow descriptions, and evidence that the company is operationally ready to provide the declared services.
At Legalaes, we provide end-to-end legal and regulatory support for VASP registration in Georgia—from incorporation and structuring to full application drafting, local substance planning, banking support, and regulator communication—ensuring a smooth, compliant, and predictable market entry.
Regulatory Overview
VASPs in Georgia are regulated and supervised by the National Bank of Georgia. Companies providing virtual-asset services for the benefit of other persons must register with the NBG before commencing operations.
Georgia’s model is not a “notification” regime. Registration is granted only after a substantive assessment of the applicant’s corporate structure, ownership transparency, operational readiness, and internal control environment. Registered VASPs remain subject to ongoing supervision and are expected to maintain compliant operations, documentation, and systems over time.
Core regulatory sources (official):
Types of Crypto Licensing in Georgia
Georgia does not use rigid licence “classes” with fixed minimum capital per activity. Instead, registration is service-based: the applicant declares which virtual-asset services it will provide, and the regulator evaluates the business model, transaction flows, systems, and controls for that specific scope.
Typical registrable services include:
- Exchange of virtual assets for fiat and vice versa
- Exchange of one virtual asset for another
- Transfer of virtual assets on behalf of clients
- Custody / safekeeping / administration of virtual assets and cryptographic keys
- Trading platform related services (where applicable and properly controlled)
The practical standard is proportionality: the internal framework (people, systems, controls, funding) must match the risk level and scale of the declared services.
Services Allowed Under a Georgian VASP Registration
Subject to the scope approved by the NBG, a registered VASP may:
- Operate crypto-to-fiat and fiat-to-crypto exchange services
- Facilitate crypto-to-crypto exchange services
- Transfer virtual assets on behalf of clients
- Provide custodial services and safeguard cryptographic keys
- Use third-party technology and providers (with proper documentation and oversight)
Overview of Requirements to Obtain VASP in Georgia
- A Georgian-incorporated company with real operational presence in the country.
- Transparent ownership structure with disclosed beneficial owners.
- Credible directors and responsible persons with an acceptable background.
- A clear business model and defined scope of crypto services.
- Internal systems to manage onboarding, transactions, and reporting obligations.
- Adequate funding to operate sustainably for at least the first year.
- A complete registration file suitable for NBG review (business plan + service/flow descriptions + governance and control documentation).
Legal services for Obtaining a VASP License in Georgia
Foundational VASP Registration Support
For companies entering Georgia for the first time
- Company incorporation in Georgia and statutory setup support
- Business model scoping and registration readiness mapping
- Preparation and submission of the VASP registration application
- Review of business plan and financial forecast (regulator-readiness alignment)
- Coordination with the National Bank of Georgia during early-stage review
Regulatory & Operational Build-Out
For full registration readiness and operational design
- End-to-end preparation of the registration file (corporate, ownership, personal and operational annexes)
- Business plan development and transaction-flow descriptions aligned with declared services
- Drafting of the internal controls framework (risk approach, onboarding rules, monitoring logic, record-keeping, reporting routines)
- Translation / notarisation / legalisation support (where required)
- Banking support and fund-flow mapping
- Local substance support (office/premises alignment and operational readiness)
- Full regulatory representation and handling of clarifications until final decision
Ready-Made VASP Company
For immediate or near-immediate market entry (subject to availability)
- Pre-registered Georgian company with completed VASP registration
- Clean corporate history (no debts, liabilities, or regulatory issues)
- Registered legal address / office setup
- Corporate bank account opened and active
- Corporate and regulatory documentation pack in place
- Ownership transfer support and post-transfer regulator communication support
Eriks Fijalovs
Head of Blockchain and Crypto
Detailed Requirements for VASP in Georgia
List of required documents
- VASP registration application and declarations
- Corporate documents (charter, incorporation certificate, resolutions)
- Ownership structure and beneficial owner disclosures
- Identification/KYC documentation for directors and UBOs
- Criminal-record certificates (typically covering recent years and relevant jurisdictions)
- Business plan with financial projections
- Detailed descriptions of services and transaction flows
- Internal controls documentation (risk approach, onboarding, monitoring, record-keeping, reporting)
- Technical/IT documentation (systems, custody/security measures, access control, audit trails)
- Proof of financial resources / funding plan
- Apostilled/legalised foreign documents with Georgian translations (where applicable)
Business Premises Requirements
- Registered headquarters in Georgia
- Lawful use of office premises
- Premises suitable for operational activity, record-keeping, and regulator interaction
- Practical ability for inspection and access to records (as required by the NBG rule)
Bank Account Requirements
- Georgian corporate operational bank account for day-to-day business use
- Clear mapping of funds flows and operational use (customer flows, settlement arrangements, custody logic if applicable)
- Evidence of sustainable funding to support the first year of operations (linked to financial forecasts)
Personnel Requirements
- Directors / management: fit-and-proper individuals with relevant experience
- Beneficial owners: transparent disclosure and reputational assessment
- Responsible persons: clear accountability for day-to-day controls and regulatory interaction
- Operational staffing: adequate coverage for the declared services and scale
Government Fees (Official)
- VASP registration fee: GEL 5,000 under Georgia’s Law on Registration Fees (National Bank registration fees schedule).
- Official legal gazette (Matsne): https://matsne.gov.ge/ka/document/view/16054 (see the section listing NBG registration fees, including “virtual asset service provider registration – 5,000 lari”).
Roadmap to Obtaining a VASP License in Georgia
Our approach follows a structured, regulator-centric methodology designed to reduce uncertainty, avoid rework, and keep the application file internally consistent.
Eriks Fijalovs
Head of Blockchain and Crypto
Initial Scoping & Registration Strategy
We review your product, target markets, and planned services to determine what must be declared for registration and how the risk profile will be perceived. This stage defines the scope (exchange/custody/transfers), identifies higher-risk elements early, and sets the operating assumptions for the application.
Company Incorporation & Ownership Setup
We incorporate the Georgian entity, set up corporate governance, and structure the ownership disclosure in a way that is transparent and defensible. Where the group structure is multi-layered, we ensure the chain of control is documented cleanly.
Business Plan & Service/Flow Design
We draft the business plan and describe the services in operational terms: onboarding, customer types, products, transaction flows, custody/control points, third-party providers, and risk controls. This becomes the core narrative the regulator will assess.
Internal Controls Framework
We prepare a practical internal control environment that can be operated day-to-day: onboarding rules, risk classification, monitoring approach, escalation, record-keeping, reporting responsibilities, and governance oversight—structured for real operations, not just paper compliance.
Banking & Financial Readiness
We support corporate banking readiness and map money/asset flows clearly, including how operational funds are used, where liquidity sits, and how the business remains funded through its first operating year.
Application Pack Compilation & Quality Review
We compile the full file (corporate, ownership, personal and operational annexes) and run consistency checks to prevent contradictions between the business plan, service descriptions, and supporting evidence.
Submission & Regulatory Engagement
After submission, we manage communication with the NBG, coordinate responses to clarification requests, and update the file in a controlled manner. Response speed and consistency here are key to timeline control.
Registration Grant & Go-Live Support
Following registration, we support go-live readiness by helping translate the approved framework into operational routines and ensuring governance and documentation remain aligned for the first supervisory cycle.
Estimated Timeframes to Obtain VASP Registration in Georgia
Timeframes depend on model complexity and documentation readiness. For a well-prepared application, an indicative structure is:
1. Company setup and ownership structuring
Time Frame: ~ 1-2 weeks
Incorporation, governance baseline, and ownership disclosure preparation.
2. Documentation and application pack preparation
Time Frame: ~ 4-6 weeks
Business plan, services/transaction flows, internal controls framework, technical documentation, and supporting evidence.
3. Filing and regulatory review
Time Frame: ~2–3 months (typical)
Substantive assessment and clarification rounds. Complex models (custody-heavy or multi-service structures) may extend timelines.
Total indicative timeline:
~3–5 months, depending on complexity and responsiveness during review.
Advantages of VASP in Georgia
01
Faster route to a regulated operating setup
Georgia’s registration model can allow well-prepared businesses to achieve regulated market entry faster than heavy authorisation regimes, while still providing a defined supervisory perimeter.
02
Single competent authority and clear accountability
A single regulator (NBG) supervises registration and ongoing requirements, which reduces fragmentation and makes supervisory communication more direct and consistent.
03
Service-based flexibility for real business models
Rather than forcing companies into rigid licence classes, Georgia allows registration based on the services you actually provide—exchange, custody, transfers—so the framework fits the operating model.
04
Proportional approach to financial expectations
The regime focuses on “financial adequacy” in practice—matching funding and controls to the real scale and risk—without imposing a single mandatory capital figure for every model.
05
Full foreign ownership permitted
International founders can retain full ownership while meeting local governance and substance expectations through clean structuring and real operational presence.
06
Tax model that supports reinvestment
Georgia’s profit tax rate is 15%, and the system is widely used as a “distributed profit” model (tax triggered on defined taxable events/distributions), which can be attractive for companies reinvesting into product, compliance and growth. (See official tax references below.)
07
Clear AML reporting architecture
VASPs are treated as reporting entities under Georgia’s AML framework, with a defined FIU (Financial Monitoring Service) and structured reporting expectations.
08
Practical regional positioning
Georgia is often used as an operational bridge between Europe, the Middle East and emerging markets, with a cost structure that can be attractive for scaling operations.
Legislative and Regulatory Resources
- Profit tax (15%) : https://www.rs.ge/LegalEntityTaxes-en?cat=1&tab=1
- Withholding at source (incl. dividends 5%): https://www.rs.ge/LegalEntityTaxes-en?cat=4&tab=1
Taxation of VASP Companies in Georgia
Georgia’s taxation is governed by the Tax Code of Georgia and Revenue Service guidance. The outline below is a practical summary for operating companies.
1. Corporate Profit Tax (Profit tax rate)
Corporate Profit Tax (Profit tax rate)
The profit tax rate is 15% (general rule).
Official references:
- Tax Code (Matsne): https://matsne.gov.ge/en/document/view/1043717
- Revenue Service overview: https://www.rs.ge/LegalEntityTaxes-en?cat=1&tab=1
2. Dividends and withholding tax
Dividends and withholding tax
Dividends are subject to 5% taxation at source (withholding).
Official references:
- Revenue Service (withholding): https://www.rs.ge/LegalEntityTaxes-en?cat=4&tab=1
- Revenue Service FAQ: https://www.rs.ge/LegalEntityTaxFAQ-en?cat=10&tab=1
3. VAT (Value Added Tax)
VAT (Value Added Tax)
- VAT is a separate tax regime and depends on whether a particular service is VAT-able and where it is supplied.
- For crypto businesses, VAT treatment should be assessed per revenue stream (exchange fees, service fees, technology fees, etc.) and client geography. Official baseline reference: Tax Code (Matsne): https://matsne.gov.ge/en/document/view/1043717
4.Payroll and employment
Payroll and employment
- Payroll taxes and mandatory contributions apply for local employees in Georgia.
- Cross-border teams require analysis based on tax residency and place of work, particularly where “substance” expectations are relevant.
5. Practical takeaway for founders
Practical takeaway for founders
For businesses reinvesting earnings into growth and compliance, Georgia’s tax framework can be operationally attractive. However, optimal structuring depends on shareholder residence, distribution strategy, and cross-border operations—so tax planning should be aligned with the business model from the start.
FAQ – VASP License in Georgia
1) Is VASP registration mandatory in Georgia?
Yes. Businesses providing virtual-asset services for the benefit of other persons must register with the National Bank of Georgia before starting operations.
2) Who is the regulator?
The National Bank of Georgia (NBG) is the competent authority for registration and ongoing supervision.
3) What services usually trigger registration?
Exchange services (fiat/crypto, crypto/crypto), transfers, custody/safekeeping, and other service-based activities described in the NBG framework.
4) Do we need a Georgian company?
In practice, registration is tied to a Georgian-incorporated structure and a real operational presence in the country.
5) Is a physical office required?
Yes. Georgia expects operational substance: a registered headquarters and premises suitable for business activity, record-keeping, and regulator interaction.
6) Is there a fixed minimum capital requirement?
No fixed statutory capital number applies as a universal rule; expectations are proportional to the scale and risk profile of the business. You must demonstrate financial adequacy for operations.
7) What is the government fee for registration?
The official registration fee is GEL 5,000, listed in Georgia’s Law on Registration Fees (NBG registration fees schedule).
Official source: https://matsne.gov.ge/ka/document/view/16054
8) Can foreign founders own 100% of the company?
Yes. Full foreign ownership is permitted, provided ownership is transparent and governance/substance requirements are met.
9) How long does registration take?
A well-prepared file commonly takes ~3–5 months, depending on complexity and the number of clarification rounds.
10) What happens after registration?
Registered VASPs remain under ongoing supervision and must maintain operational controls, records, and reporting routines. Material business changes should be managed carefully and documented consistently.
Each of our projects receives unique and tailored solutions in accordance with the initial objectives and vision of the shareholders.
May also interest you
