Virtual Asset Service Providers (VASPs) in Georgia

Georgia regulates crypto businesses through a dedicated Virtual Asset Service Provider (VASP) regime run by the National Bank of Georgia (NBG). If you plan to build or relocate a crypto company here, this is the framework that decides whether you must register, what you can offer, and what compliance obligations follow. The rules are about services provided for others — not about individuals simply holding or trading their own coins.

When the rules took effect

Legislative changes on virtual assets came into force on 1 January 2023. They established three things: a mandatory registration regime for VASPs at the NBG, Fit-and-Proper criteria for administrators and significant owners, and an Anti-Money-Laundering and Counter-Terrorism-Financing (AML/CFT) supervision framework. At this stage the framework does not include prudential regulation aimed at consumer protection — its focus is registration, eligibility and AML/CFT.

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 or payment purposes. It does not include digital representations of fiat currencies, securities or other financial instruments — those may fall under securities or other laws instead. A convertible virtual asset is one with an equivalent market value in currency, another virtual asset or a financial instrument.

A VASP is a person who provides a virtual asset service for the benefit of another person. That “for another person” element is the trigger for registration.

Which activities count as a virtual asset service

The following are virtual asset services under the framework:

• Exchange (including via kiosks) between convertible virtual assets and fiat currency, between forms of virtual assets, or between a virtual asset and a financial instrument;
• Transfer of convertible virtual assets;
• Safekeeping and/or administration of convertible virtual assets, or of the instrument enabling control over them;
• Portfolio management of convertible virtual assets (excluding collective portfolio management);
• Administration of a convertible virtual asset trading platform;
• Lending of convertible virtual assets;
• Initial Coin Offering (ICO) of a convertible virtual asset, and related services.

A registered VASP is generally not allowed to undertake other activities beyond virtual asset services, the auxiliary activities needed to provide them, and exchanging its own virtual assets.

Registering with the NBG

A VASP must register with the National Bank and comply with its requirements. The procedure lives in “The rule for the Virtual Asset Service Provider’s (VASP’s) registration at the National Bank of Georgia, registration cancellation, and regulation” and its annexes, approved by decree N94/04 of the Governor of the NBG on 13 June 2023. Registration covers, among other things, Fit-and-Proper criteria for administrators and for direct and indirect significant owners (including beneficial owners), and requirements for the head office, branches, self-service kiosks, software systems and AML/CFT.

Once an application is complete, the NBG decides within 60 calendar days, with the option to extend by a further 60 calendar days on notice. Businesses that were already providing virtual asset services before 1 January 2023 were given a transition window to submit their documentation and could continue operating until the NBG decided on their application.

Other financial institutions

VASP registration is not the only route. Commercial banks, micro-banks (from 1 July 2023), microfinance organisations and brokerage companies may also provide a limited set of virtual asset services — exchange, transfer, safekeeping/administration and essential auxiliary activities — alongside their normal regulated business.

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 that law. In practice this means customer due diligence (KYC/KYB), an AML officer and internal AML policies, and rules on the information that must accompany virtual asset transfers (the “travel rule” approach).

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 for narrow cases defined by the NBG that are necessary to provide a virtual asset service. A Georgian company or individual entrepreneur therefore generally cannot accept crypto as payment for goods or services; a VASP may, however, take its commission or fee in the same virtual asset used for the service.

Trading your own crypto

The regime targets services provided for others. If you exchange virtual assets solely with your own funds as a client of a VASP or trading platform — including peer-to-peer trades with another client of the same provider, with no arrangement to act for a third party — you are not required to register as a VASP. How personal crypto gains are taxed is a separate question from this licensing framework; see the digital nomads guide for the broader tax context and confirm your position with a tax adviser.

A note on changing rules

The NBG maintains a public register of VASPs and issues the detailed rules, annexes and any additional requirements (including separate rules for stablecoin ICOs). Because secondary legislation and supervisory practice evolve, treat the figures and procedures here as a snapshot and confirm the current rule and annexes with the National Bank 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.