Georgia Crypto Licence Requirements in 2026

A Georgia crypto (VASP) licence requires a Georgian company (an LLC or JSC) with a local director and registered office, VASP registration with the National Bank of Georgia, and fit-and-proper owners. Georgia is the value play in regulated crypto, and its requirements list is short — but “short” is not the same as “loose”. Since 1 July 2023 the National Bank of Georgia (NBG) has run a genuine Virtual Asset Service Provider regime, and the applications that stall do so on the same thing every time: a file that treats the licence like an offshore registration when the NBG expects real substance and a real AML programme.

This is the checklist we work from on our own desk. It covers exactly what qualifies you and what you have to submit, grouped into three buckets — Corporate, Compliance and Technical — plus the point most cost-focused guides bury: Georgia is fast and cheap, but it is a supervised central-bank registration, so a local company, a local director and a registered office are requirements, not options.

The three buckets, at a glance

The National Bank of Georgia registers a VASP once your file satisfies three distinct sets of requirements. Miss any one and the registration does not clear — the NBG reviews the company, the people behind it and the technology together, exactly as a credible regulator should.

The rest of this guide walks each bucket in the order you should assemble it. Costs sit outside scope here — for the full fee breakdown see the Georgia crypto licence cost guide, and for how the tax picture shapes the structure, our Georgia crypto tax explainer.

Corporate requirements: a real Georgian company

The applicant is a company incorporated in Georgia — either an LLC or a JSC — registered before the VASP application goes in. This is where Georgia parts company with a pure offshore permit. The NBG expects genuine substance:

• A local director. The company must have a director resident in Georgia. This is a substance requirement, not a formality, and it is the single detail cheaper guides get wrong when they market Georgia as a “no-presence” jurisdiction.
• A registered office. A physical registered office in Georgia, not just a mailbox.
• A transparent ownership and control structure. The NBG wants to see who owns and controls the entity, with no opaque layering.
• A business plan. A description of the virtual-asset services you intend to offer — exchange, custody, transfer, brokerage — your target markets and the operating model behind them. This is where the regulator forms its view of what you actually intend to run.

The substance is modest by EU standards and we arrange it as part of the engagement, but it is the reason a Georgian VASP carries more weight with banks and counterparties than an unsupervised registration. There is no MiCA-style capital tier to meet — Georgia is not an EU regime and does not impose the €50,000-to-€150,000 own-funds floors that CASP applicants face — so the corporate cost is company setup, the resident director and the office, not locked-up capital. For the full picture of how the regime works — legitimacy, market reach and where it fits against an EU CASP — read our flagship Georgia crypto licence guide.

Compliance requirements: fit-and-proper and source of funds

This is the bucket that decides most timelines. The NBG runs fit-and-proper checks on the owners and the management team — not just the named applicant — and each of them has to clear the same bar.

Suitability of each person. Every beneficial owner and key manager must:

• carry no criminal convictions, financial crime and fraud in particular;
• appear on no sanctions or watch list;
• demonstrate a good reputation and a clean business history;
• provide source-of-funds evidence showing the capital behind the venture is legitimate.

File per person. For each owner, director and officer you submit a certified passport copy, a recent proof of address, a professional CV and a police-clearance (criminal-record) certificate, alongside the source-of-funds documentation. An open source-of-funds question is the most common reason a Georgian file drifts past the statutory window, because the National Bank will not register on partial ownership or funds documentation.

The AML/CFT programme. Alongside the people, you file the programme that governs them in operation:

• AML/CFT policies and procedures — built to NBG expectations and mapped to the FATF Recommendations, covering customer due diligence, ongoing monitoring for suspicious activity, and record-keeping.
• An appointed AML officer (MLRO) — a named compliance officer with clear governance and reporting lines.
• Travel Rule coverage — because these are virtual-asset services, your onboarding and monitoring must capture originator and beneficiary data on transfers.

The obligation does not end at registration: you carry an ongoing duty to actually operate the AML programme you filed, report to the NBG, and keep policies current. A written policy that no one runs is a supervision risk, not a safeguard. Our primer on AML and KYC covers what an operable programme looks like in practice.

Technical requirements: platform, security and custody

The third bucket is about running a secure, well-governed platform. The NBG expects documented technical standards at application, and the depth scales with the services you offer — a custody provider faces more than a pure brokerage.

If you provide custody, the NBG’s attention concentrates on how client assets are held: key management, wallet architecture, recovery procedures and segregation of client crypto from the firm’s own. Hot- and cold-wallet policy, multi-signature or MPC key custody, and a tested recovery process are the details the National Bank wants documented rather than promised. A brokerage or exchange that does not take custody still has to document cybersecurity, access control and monitoring, but the custody load is lighter. Either way the principle is the same — the platform integrity has to be demonstrable, not asserted, and the technical file has to line up with the services you described in the business plan.

Assembling the file in the right order

Requirements are one thing; sequence is another. The order that avoids rework is: incorporate the Georgian LLC or JSC and arrange the local director and registered office first; assemble every owner and key-person file — passports, CVs, police clearances, source of funds — in parallel; draft the AML/CFT policies against the actual operating model and appoint the AML officer; then finalise the technical documentation before you file with the National Bank. Filing with gaps — a missing source-of-funds letter, an AML policy written for a different product, an undocumented custody arrangement — is what turns a two-month registration into a four-month one.

The economics are why operators put up with the substance: a state fee near $500, an NBG decision window around 60 days, and a jurisdiction where crypto is very lightly taxed. What Georgia does not give you is EU passporting — a Georgian VASP serves global markets, and to reach EU users you need an EU CASP licence, which many groups run alongside a Georgian base. Everything else about the file is designed to prove one thing to the National Bank: that a real, supervised business sits behind the registration.

Ready to assemble your file, or want a second opinion on documents you have already prepared? Our team handles the full requirements pack — company, substance, AML build and the NBG submission — end to end, and will review any file against the regulator’s expectations before you submit. Book a free consultation and we will tell you exactly what is missing.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.