Virtual Asset Service Providers (VASPs) in Georgia

Georgia regulates crypto businesses through a dedicated Virtual Asset Service Provider (VASP) regime supervised by the National Bank of Georgia (NBG). If you plan to establish or relocate a crypto business to Georgia, this framework determines whether VASP registration is required, which virtual-asset services may be provided, and what regulatory and compliance obligations apply.

A VASP is, broadly, a person that provides a virtual-asset service for the benefit of another person. The regime therefore focuses on businesses providing crypto services to customers rather than individuals simply buying, holding or trading virtual assets for their own account.

When the rules took effect

Georgia’s principal legislative framework for virtual assets came into force on 1 January 2023. It introduced mandatory registration of VASPs with the National Bank of Georgia, suitability requirements for administrators, and an Anti-Money-Laundering and Counter-Terrorism-Financing (AML/CFT) supervisory framework.

The detailed VASP registration and regulation rules subsequently entered into force on 1 July 2023, introducing additional requirements including Fit-and-Proper criteria for administrators and significant shareholders and beneficial owners, as well as requirements concerning offices, branches, self-service kiosks, software systems and AML/CFT compliance.

The regulatory framework has continued to develop. Legislative amendments adopted in December 2025 expanded the NBG’s supervisory powers over VASPs, including in the areas of prudential supervision, consumer protection, cybersecurity and operational risk management. Additional rules have since been introduced for specific activities, including the initial offering of stable virtual assets.

Accordingly, Georgia’s VASP regime should no longer be viewed solely as a registration and AML/CFT framework; it is developing into a broader regulatory and supervisory regime for virtual-asset businesses.

What is a “virtual asset” and a VASP

A virtual asset is a digital representation of value that is interchangeable and non-unique, can be digitally traded or transferred, and can be used for investment and/or payment purposes. The definition expressly excludes digital representations of fiat currencies, securities and other financial instruments, which may instead be subject to other financial-sector legislation.

A convertible virtual asset is a virtual asset that has an equivalent market value in national or foreign currency, another virtual asset and/or a financial instrument into which it can be exchanged.

A Virtual Asset Service Provider (VASP) is a person that provides a virtual asset service for the benefit of another person. This distinction is important: dealing with virtual assets for one’s own account does not, by itself, constitute the provision of a virtual asset service to another person.

Which activities count as a virtual asset service

Under the Organic Law on the National Bank of Georgia, virtual asset services include:

• Exchange, including through kiosks, between convertible virtual assets and fiat currencies, between one or more forms of virtual assets, or between a convertible virtual asset and a financial instrument;
• Transfer of convertible virtual assets;
• Safekeeping and/or administration of convertible virtual assets or instruments enabling control over them;
• Portfolio management of convertible virtual assets, excluding collective portfolio management;
• Administration of a trading platform for convertible virtual assets;
• Lending of convertible virtual assets;
• Initial Coin Offerings (ICOs) of convertible virtual assets and/or services related to an ICO; and
• Any other virtual asset service designated by a relevant normative act of the National Bank of Georgia.

A registered VASP is prohibited from carrying out activities other than providing virtual asset services, carrying out auxiliary activities necessary for those services, and exchanging its own virtual assets.

Registering with the NBG

A person providing virtual asset services in Georgia must register with the National Bank of Georgia (NBG) as a VASP unless it is a financial-sector entity otherwise authorised by Georgian legislation to provide the relevant virtual asset services.

The registration framework covers, among other matters, Fit-and-Proper requirements for administrators and direct and indirect significant shareholders, including beneficial owners, as well as requirements relating to the VASP’s head office, branches, self-service kiosks, software systems and AML/CFT compliance.

Once a complete application has been submitted, the NBG generally makes its registration decision within 60 calendar days. The review period may be extended by a further 60 calendar days, with the applicant being notified accordingly.

Businesses that were already providing virtual asset services when the new regime was introduced were subject to transitional arrangements allowing them to apply for registration and continue operating while their applications were being considered. These transitional provisions are now primarily of historical relevance.

Other financial institutions

Separate VASP registration is not the only legal basis on which virtual asset services may be provided. Certain financial-sector entities, including commercial banks, microbanks, microfinance organisations and brokerage companies, may provide specified virtual asset services where this is permitted under the legislation governing their activities.

Their permitted activities are more limited than the full range of services available under the VASP framework and may include exchange, transfer and safekeeping/administration of convertible virtual assets, together with supporting activities permitted by the applicable financial-sector legislation.

These institutions remain subject to their existing licensing and supervisory regimes and to the additional requirements applicable to their virtual asset activities.

AML/CFT obligations

Under the Law of Georgia On Facilitating the Prevention of Money Laundering and the Financing of Terrorism, a VASP is an obliged person and must comply with Georgia’s AML/CFT framework.

In practice, this includes customer due diligence (KYC/KYB), identification and verification of customers and beneficial owners, internal AML/CFT policies and controls, appointment of responsible compliance personnel, transaction monitoring and reporting obligations.

VASPs are also subject to requirements concerning the information that must accompany transfers of virtual assets — broadly corresponding to the international “travel rule” approach. The National Bank is authorised to determine these transfer-information requirements and supervises VASPs’ compliance with the AML/CFT framework.

Crypto is not legal tender

A virtual asset is not legal tender in Georgia. Under the Organic Law on the National Bank of Georgia, payments with virtual assets are prohibited, except in specific cases determined by the NBG that are necessary for providing virtual asset services.

Accordingly, a Georgian company or individual entrepreneur generally cannot accept cryptocurrency as payment for goods or services, including where those goods or services are supplied outside Georgia.

There are limited exceptions connected with the provision of virtual asset services. In particular, a registered VASP may receive its commission, interest or fee in the same virtual asset used for the virtual asset service provided.

Trading your own crypto

The VASP regime targets virtual asset services provided for the benefit of another person. Trading or exchanging virtual assets for your own account does not, by itself, make you a VASP.

The NBG specifically confirms that a person who exchanges virtual assets solely using their own funds or virtual assets, as a client of a VASP or virtual asset trading platform — including through P2P trading with another client of the same provider — is not required to register as a VASP, provided there is no arrangement with a third party and no virtual asset service is being provided for that third party’s benefit.

The tax treatment of gains from trading or disposing of your own virtual assets is a separate question from whether VASP registration is required. See the digital nomads guide for the broader Georgian tax context and consider confirming the tax treatment of your particular activities separately.

A note on changing rules

The NBG maintains a public register of registered VASPs and issues the detailed regulations, annexes and additional requirements governing their activities.

The framework continues to develop. For example, in 2026 the NBG introduced separate rules governing the initial offering of stable virtual assets by VASPs, including requirements concerning issuance, reserve assets, offering documentation, redemption and subsequent services.

Because the VASP framework includes secondary legislation that may be amended and supplemented by the NBG, registration requirements, procedures and ongoing compliance obligations should be checked against the current consolidated legislation and the latest NBG regulations before relying on them.

Frequently asked questions

Do I need to register as a VASP in Georgia?

If you provide a virtual asset service for the benefit of another person — for example running an exchange, transferring or safekeeping crypto for clients, managing portfolios, operating a trading platform, lending crypto, or doing an ICO — you must register with the National Bank of Georgia and meet its requirements. Trading purely with your own funds as a client (including P2P) is not, by itself, a VASP activity.

Which authority regulates crypto in Georgia?

The National Bank of Georgia (NBG). Legislative changes that came into force on 1 January 2023 established a mandatory VASP registration regime, Fit-and-Proper criteria for administrators, and AML/CFT supervision. The framework does not currently include prudential regulation for consumer protection.

What counts as a virtual asset service?

Exchange between convertible virtual assets and fiat, between virtual assets, or with a financial instrument (including via kiosks); transfer of convertible virtual assets; safekeeping or administration of them; portfolio management; administration of a trading platform; lending of convertible virtual assets; and initial coin offerings or related services.

Can other companies offer crypto services without being a VASP?

Certain regulated financial institutions can offer a limited set of virtual asset services: commercial banks, micro-banks (from 1 July 2023), microfinance organisations and brokerage companies. They may handle exchange, transfer, safekeeping/administration and essential auxiliary activities, alongside their normal business.

Can I pay for things in Georgia with crypto?

No. A virtual asset is not legal tender, and under the Organic Law on the National Bank of Georgia payments with virtual assets are prohibited, except for narrow cases defined by the NBG that are necessary to provide a virtual asset service. A Georgian business or individual entrepreneur generally cannot accept crypto as payment for goods or services.

How long does VASP registration take?

The NBG reviews a complete application and decides within 60 calendar days, and may extend the period by a further 60 calendar days, notifying the applicant before the original deadline. Requirements are set out in the NBG's registration rule and its annexes.