Georgia VASP September 2026 Updates
VASP Licensing in Georgia: Key Regulatory Updates — September 2026
The regulatory framework for Virtual Asset Service Providers (VASPs) in Georgia has been updated, introducing a number of additional obligations that VASPs should take into account.
Below is a practical overview of the key changes introduced by the National Bank of Georgia (NBG). 🇬🇪
💰 New Supervisory Capital Requirements
One of the most significant changes is the introduction of a mandatory supervisory capital requirement.
Previously, Georgia did not impose a specific supervisory capital requirement on VASPs. Under the updated framework, a VASP must maintain separate supervisory capital throughout its operation, in addition to its ordinary investment or working capital.
The minimum amount depends on the type of VASP services provided:
GEL 150,000 — exchange and/or transfer services; GEL 350,000 — trading platform services; GEL 250,000 — other VASP services.
Where a company provides multiple types of services, the highest applicable capital threshold must be maintained.
The existence of the required capital must be confirmed by a bank statement at the time of registration, and falling below the applicable threshold may result in sanctions, including a monetary fine.
👥 Significant Shareholders — 10% Threshold
The updated framework also changes the threshold for determining a significant shareholder.
A person holding 10% or more of the company's shares or stock is now considered a significant shareholder and is subject to enhanced regulatory scrutiny.
This is a notable change from the previous approach, under which the threshold applied to holdings above 10%.
🛡️ Risk Management Framework
VASPs are also subject to additional risk management requirements.
Within 12 months of registration, the company must fully establish its risk management framework and obtain an independent auditor's opinion.
In addition, every version or edition of the risk management framework must be retained for at least 8 years from the date the relevant service ends.
📩 Customer Complaints
The updated requirements introduce a specific timeframe for handling customer complaints.
A VASP must review a customer complaint within no more than one month and inform the customer of the final outcome.
This creates a clear regulatory timeframe for the internal handling of customer complaints.
⚠️ Expanded Fines and Sanctions
The regulatory changes also expand the categories of violations that may lead to fines.
Importantly, a breach of the supervisory capital requirement has been added as a specific ground for sanctions.
For VASPs, this means that maintaining the required supervisory capital is not only a registration requirement but also an ongoing compliance obligation.
📌 What VASPs Should Consider
The September 2026 updates introduce several areas that require attention from existing and prospective VASPs in Georgia, particularly:
maintaining the required level of supervisory capital; assessing shareholder structures in light of the new 10% significant shareholder threshold; establishing and documenting an appropriate risk management framework; obtaining an independent auditor's opinion within the applicable timeframe; maintaining risk management records for the required retention period; and ensuring that customer complaints are handled within the prescribed one-month period.
For businesses operating or planning to operate as VASPs in Georgia, these changes should be incorporated into the company's regulatory and compliance planning.
NUR Legal provides legal support to businesses navigating VASP authorisation and regulatory requirements in Georgia.
This article provides a general informational overview of the regulatory changes reflected in the September 2026 update and should not be considered legal advice.
If you are having any questions or seeking for an assistance - contact NUR Legal team by info@nur-legal.com.
Comments