20/10/25
Georgia’s regulatory transformation for Virtual Asset Service Providers (VASPs) marks a turning point in its financial innovation landscape. This article explores the key legislative updates, compliance expectations, and how these changes affect crypto companies operating in or through Georgia.
⚖️ Legal Framework and Official Standards
Since July 1, 2023, the National Bank of Georgia (NBG) has formally implemented a registration regime for entities providing crypto-related services, as outlined in Order No. 94/04 (“Rule for Registration, Cancellation, and Regulation of Virtual Asset Service Providers”).
The measure brings Georgia into line with the Financial Action Task Force (FATF) standards and integrates the sector under AML/CFT supervision, led by the Financial Monitoring Service (FMS).
Under this regime, registration is mandatory for companies offering:
– Exchange between crypto and fiat or crypto-to-crypto;
– Custodial wallet services;
– Transfer and safekeeping of virtual assets;
– Initial token or coin offerings (ICO); and
– Certain crypto-asset management services.
Applicants must establish a local legal entity, appoint a Georgian resident director or representative, maintain a physical office, and implement full AML/KYC controls, risk procedures, and record-keeping systems.
The registration fee is currently GEL 5,000, and the review period is typically 2 – 4 months, depending on the completeness of documentation and regulator workload.
Crypto assets remain non-legal tender in Georgia – they cannot be used directly for payments – but regulated entities may handle conversion and custody within their registered scope.
Taxation follows standard rules: corporate profits (15 %) are taxable, while most crypto-asset transfers are treated as VAT-exempt. However, the personal taxation of crypto gains is still under review and should be assessed case-by-case basis.
💼 Analysis and Comparative Context
Georgia’s system represents a registration-based model rather than a full licensing regime, comparable to early frameworks in Estonia and Lithuania before the EU’s MiCA regulation.
This approach ensures regulatory visibility and AML oversight while remaining accessible to smaller operators. It also positions Georgia as an appealing jurisdiction for crypto start-ups and fintech innovators seeking a compliant yet pragmatic base in the region.
However, the requirements for local substance and strong AML governance impose real obligations – purely remote or decentralised structures often find compliance challenging.
Unlike MiCA or Singapore’s PSA, Georgia’s regime imposes no minimum capital but focuses on compliance quality and management accountability.
The Free Industrial Zone (FIZ) model adds further incentives. Companies based in Tbilisi, Kutaisi, or Poti FIZs can enjoy 0 % corporate tax for income generated outside Georgia and a streamlined incorporation process. Nonetheless, entities must still complete NBG registration if they conduct any regulated VASP activity.
Areas of regulatory ambiguity remain – especially for DeFi, staking, and non-custodial wallet models – as these are yet to be tested under the new supervision practice. Industry observers expect further interpretive guidance in 2025 – 2026 as enforcement matures.
🧾 Practical Application and Industry Examples
A crypto-exchange serving fiat-to-crypto transactions must register with NBG, appoint a Georgian director, set up AML monitoring, and maintain a physical office. Only upon successful registration may it legally operate or advertise services in Georgia.
A wallet provider controlling clients’ private keys would also need registration, while non-custodial wallet developers may fall outside the regime – subject to NBG interpretation.
An ICO or token issuance platform must register before listing tokens convertible into other assets or fiat. The same applies to brokerage or asset-management firms working with digital tokens.
Crypto lending remains a sensitive area: although listed among potential VASP activities by some legal commentators, NBG oversight is stricter, and such services may be permitted only under enhanced supervision or additional authorisation.
By late 2024, the first approved VASP registrations were publicly disclosed under NBG’s oversight, confirming the regime’s operational phase. Firms such as GeCrypto and others reportedly completed the process successfully, signalling that the system is now active and enforceable.
Operating via a Free Industrial Zone continues to attract fintech companies aiming to serve global clients while maintaining compliance in Georgia’s stable legal environment.
🧠 Conclusion
Georgia’s crypto regulatory landscape has evolved into a structured, compliance-based environment that balances innovation with supervision. The VASP registration regime under NBG Order 94/04 provides legal certainty while inviting responsible crypto enterprises to operate transparently.
As enforcement expands in 2025, clarity around DeFi, staking, and novel crypto models will likely increase, shaping Georgia’s role as a regional compliance-friendly crypto hub.
Businesses planning to establish or relocate crypto operations to Georgia should ensure local presence, AML readiness, and regulatory dialogue from the outset.
For comprehensive assistance with VASP registration, compliance frameworks, or FIZ structuring, contact NUR Legal for tailored legal advice and regulatory representation.
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Kätrin Särap