VASP Registration (Crypto License) in Georgia: A Complete Guide 2026

If you plan to provide virtual asset services in Georgia, registration with the National Bank of Georgia is mandatory. This is what the market calls a "crypto license". This guide sets out what documentation you will need, what a crypto license costs, how long the process takes and where applications most often stall.

The rapid growth of the virtual asset market, together with the tightening of global AML/CFT standards on the prevention of money laundering and terrorist financing, put regulation of this sector on the agenda. As a result, Order No. 94/04 of the President of the National Bank of Georgia of 13 June 2023 made the provision of virtual asset services subject to registration.

"In practice this process is often called a "crypto license". In the terminology of the law it is not licensing, it is registration as a virtual asset service provider (VASP). What that changes in practice is discussed in section 1 below".

1. "Crypto License" or VASP Registration, What Is the Difference

In the market this procedure is almost always called a "crypto license" or a "cryptocurrency license". Georgian legislation does not recognise any such license. What exists is registration as a virtual asset service provider (VASP) with the National Bank of Georgia.

The difference is procedurally substantive. In licensing, the administrative body assesses the applicant on the merits and takes its decision largely within its own discretion. Registration turns on whether the applicant meets the requirements set in advance by the regulation: if the documentation is complete and the requirements are met, the National Bank enters the provider in the register.

There are three practical consequences:

• you do not receive a "license certificate", you are entered in the register of virtual asset service providers maintained by the National Bank of Georgia;
• in a contract, in banking documentation or in correspondence with a foreign counterparty, the correct wording is "a virtual asset service provider registered with the National Bank of Georgia", not "holder of a crypto license";
• registration is not a one off act, the National Bank supervises the provider after registration as well and is entitled to cancel the registration where certain conditions arise.

Using the term "crypto license" in conversation or in a search engine is not a mistake, that is how the market speaks. The mistake occurs when "license" appears in an official document, in an application, or in material submitted to a bank.

2. What a VASP Is and Who the Regulation Applies To

Before turning to the procedure, the statutory terms need to be understood precisely, because whether the registration obligation arises depends on exactly these definitions.

Virtual asset

A virtual asset is a digital representation of value used for the purposes of investment or payment. It is fungible, it is not unique, and it may be the object of trade or of transfer in digital form. The law does not treat the digital representation of funds, securities or other financial instruments as a virtual asset.

Convertible virtual asset

A convertible virtual asset has an equivalent value on the market in fiat currency, in another virtual asset or in a financial instrument into which it can be exchanged.

Which services fall under the regulation

Virtual asset services include:

• exchange of convertible virtual assets, including through self service kiosks;
• transfer of virtual assets;
• custody and administration of virtual assets, including control of wallets;
• portfolio management;
• administration of a virtual asset exchange;
• initial offering (Initial Coin Offering, ICO);
• lending of virtual assets.

The regulation does not extend to the management of a collective portfolio composed of convertible virtual assets.

Who counts as a provider

A provider is any person who, for a commercial purpose and for the benefit of another, carries out the services listed above. It is these two elements, a commercial purpose and acting for the benefit of another, that determine whether the registration obligation arises.

A separate restriction applies to fees: when managing a portfolio composed of convertible virtual assets, the provider is prohibited from receiving a commission, interest or any other monetary or non monetary benefit from any person other than the customer.

3. What Documentation You Will Need

Documentation is submitted to the National Bank in the original or as a notarised copy. A document issued in a foreign country must additionally be apostilled or legalised, unless legislation provides otherwise. Every document must be accompanied by a duly certified translation into Georgian.

If you are not established in Georgia, part of the documentation has to be obtained from the country of origin and each item has its own validity period. The sequence and the timing of collecting documents is therefore no less important than their content.

3.1. Registration forms and the state fee

• a fully completed registration form for a virtual asset service provider (Annex No. 1);
• a list of the virtual asset services to be provided (Annex No. 2);
• a table showing the correspondence between the documentation submitted and the required registration documentation (Annex No. 5);
• a receipt for payment of the registration fee of GEL 5,000, set by Article 7, paragraph 11, subparagraph "h" of the Law of Georgia on Registration Fees.

3.2. Corporate status and beneficial owners

The documentation must confirm the legal status of the company and must establish who its real owners are.

• information on direct and indirect holders of a significant share and on beneficial owners (Annex No. 4);
• supporting documents for the owners: for a natural person, a copy of the identity document; for a legal person, an extract from the Register of Entrepreneurs and Non Entrepreneurial (Non Commercial) Legal Entities, and for a non resident, from the relevant registration authority;
• the extract must reflect all changes existing as at the date the application is submitted. For a joint stock company, an extract from the share register is submitted in addition;
• documentation that makes it possible to establish the beneficial owner;
• an extract for the applicant company from the Register of Entrepreneurs and Non Entrepreneurial (Non Commercial) Legal Entities, reflecting all changes existing as at the date the application is submitted.

3.3. Qualification and reputation of administrators (Fit & Proper)

This block confirms that the administrators and the holders of a significant share meet the suitability criteria, known as Fit & Proper.

• information on each administrator (Annex No. 3);
• copies of the administrators' identity documents;
• information and documentation on the education and work experience of the administrators and of the persons responsible for managing the service, confirming that they have the relevant knowledge or experience;
• criminal record certificates from every country in which the person was resident over the past 10 years. A certificate issued in Georgia must be no more than 15 calendar days old, and one issued by the competent authority of a foreign country no more than 60 calendar days old;
• information on shareholdings in entities subject to supervision by the National Bank: company name, identification code and the size of the holding;
• information on past and current business activity and financial standing, obtained from a credit information bureau, from the register of debtors, or provided by the person themselves;
• information on the solvency of the organisations that the person managed or in which the person held or holds a significant share, including bankruptcy and enforcement proceedings, or written confirmation that no such facts occurred.

3.4. Infrastructure, IT security and technical equipment

• information and a document concerning the website to be used for the service, confirming ownership of it or a right to use it, and specifying the website address;
• the name of the application, where it is hosted, the name of the developer and the developer's website address, if customers will receive the service through an application;
• an extract from the Public Register of rights over immovable property confirming ownership of or a right to use the head office and branch premises. The head office address must be given as the contact address in the registration form;
• detailed information on branches (Annex No. 7);
• video surveillance documentation if you carry out exchange by receiving or handing over cash, other than through a self service kiosk: an installation act for the system on the external perimeter and, for the internal perimeter, a document confirming the presence of cameras in the operating area and at the cash desk, that is, a purchase or installation document or photographic material;
• an extract for the developer of the electronic system from the relevant registration authority, the name of the system, the developer's website address, and the place where information on obligations towards customers and on operations involving virtual assets will be stored. The functionality of the system must correspond to the planned services and must be demonstrated to the National Bank before registration is completed.

3.5. Business plan, operational scheme and partners

• A critical part of the business plan is that the company has a schematic description of how the service is carried out, specifying the list of virtual assets. The scheme must show the movement of information, of virtual assets and of funds from the start of the service to its completion, identifying every participant: the payer and the transferor of the asset, their provider, the recipient, the recipient's provider, including the acquirer and the sub acquirer, and any intermediary provider, where one exists;

If you plan several services, a separate scheme is submitted for each. If the schemes differ across virtual assets, a separate scheme must be prepared for each asset; where identical schemes are grouped together, the list of the corresponding assets must also be given. If a foreign virtual asset service provider or payment service provider participates in the scheme, a list of such providers must be submitted, identifying their supervisory authorities.

• Information on contractual relationships with virtual asset or payment service providers licensed or registered by the National Bank, as well as those licensed or registered in a foreign country;

• A business plan with a budget forecast for at least the next 3 years. The business plan must demonstrate that you have appropriate systems, resources and procedures to carry out the activity and that you plan to conduct that activity on the territory of Georgia;

• Organisational structure: a list of the structural units of the head office with their functions and headcount, a plan for the structural development of the head office over the first 6 months of operations and, if you will operate through branches, a description of the branches' functions.

3.6. AML/CFT compliance

• internal instructions, that is, a policy and procedure, developed in order to implement the compliance control system, including the money laundering and terrorist financing organisational risk assessment document. The National Bank is entitled to require, instead of or in addition to the internal instructions, that the same information be provided in the form of a questionnaire published on its official website;
• the National Bank reviews this documentation for the completeness of its constituent components, but is entitled to assess it on the merits as well, applying a risk based approach;
• a declaration confirming that the compliance control system is in place or will be in place before operations begin (Annex No. 8).

The declaration does not release you from the obligation to apply the requirements of Chapters III and IV of the Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism to clients with whom you established a business relationship before registration as well.

4. How Long the National Bank Takes to Review an Application

The National Bank takes its decision on registration or on refusal of registration within 60 calendar days of the submission of the registration information and documentation.

Where there is a justified need, this period may be extended twice, by 60 calendar days each time. The applicant is notified of an extension before the period expires. The review can therefore lawfully run to 180 calendar days.

If the documentation submitted does not meet the requirements, the National Bank gives the applicant 30 calendar days to remedy the deficiency or to clarify the data. That period runs from the day the deficiencies are served in writing.

In our practice, deficiency letters from the National Bank most often concern AML/CFT policy documents and operational schemes. A single deficiency letter extends the process by at least 30 days, so the quality of the documentation directly determines the real timeline for registration.

5. AML/CFT Obligations After Registration

A VASP is an accountable person for the purposes of the Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism. This means that from the moment operations begin you must have an internal policy for assessing and managing risks in place, a compliance control system.

5.1. Customer due diligence (CDD/KYC) The provider identifies the customer and the customer's beneficial owner on the basis of reliable sources. This must be done before a business relationship is established, before a one off transaction is carried out, or where a reasonable suspicion of money laundering or terrorist financing arises.

5.2. Travel Rule, the information accompanying a transfer Order No. 253/04 of the President of the National Bank of Georgia, "On the Information Accompanying Transfers of Funds and Transfers of Virtual Assets", sets out which details must accompany a transfer of virtual assets at every stage of its execution.

A provider must achieve compliance with these requirements by 31 December 2027. The list below is therefore not yet a binding obligation, but it is worth taking into account now, while the electronic system is being designed, so that you do not have to rebuild the system later.

The order divides the accompanying information into two blocks, the data on the originator and the data on the beneficiary.

On the originator:

• first name and surname, or, for a legal person, the name;
• the virtual asset wallet identifier or, where there is none, the unique identification number of the transfer;
• address, identity document number, personal number, or date and place of birth.

On the beneficiary:

• first name and surname, or, for a legal person, the name;
• the virtual asset wallet identifier or, where there is none, the unique identification number of the transfer.

The information must accompany the transfer immediately and through a secure channel, and the provider must retain it for the period set by law. A separate procedure is needed for cases where the accompanying information is incomplete or has not been received at all. In those cases the provider must be able to decide whether to suspend the transfer, reject it or request additional information, and to document that decision. A separate approach also applies to dealings with self hosted wallets.

This list acquires its practical value in the technical specification for the electronic system: if the system provides for these fields from the outset, achieving compliance at the end of 2027 will be a matter of configuration rather than of rewriting the system.

6. Frequently Asked Questions

Who is subject to the obligation to register as a VASP?

The obligation arises if, for a commercial purpose and for the benefit of another, you provide virtual asset services: exchange, transfer, custody, administration, portfolio management, administration of an exchange, initial offering or lending.

What does registration as a VASP cost?

The registration fee is GEL 5,000 and is submitted to the National Bank together with the application in the form of a payment receipt. This is a state fee and does not cover the cost of preparing the documentation, translation, notarisation or the apostille.

How long does registration take?

The statutory period is 60 calendar days, but the National Bank is entitled to extend it twice, by 60 days each time. If a deficiency is identified, a 30 day period for remedying it is set.

Can a natural person be a VASP?

No. A provider may only be a legal entity established and registered under the legislation of Georgia, a limited liability company or a joint stock company. The right to provide services arises after registration with the National Bank.

Can services be provided through an agent?

No. Providing virtual asset services through an agent is not permitted.

Can virtual assets be lent to a natural person?

No. Lending virtual assets to a natural person is not permitted.

What happens if we provide services without registration?

Providing virtual asset services is not permitted for a person who is not a provider registered by the National Bank, or a representative of the financial sector to which the legislation governing its activity grants such authority. The amount of the monetary fine for a violation and the rules for imposing and enforcing it are set out in a separate order of the National Bank.

How Justice League Can Help

Registering as a VASP is a multi stage process. It requires corporate transparency, sound technological infrastructure, a management team with a clean reputation and the relevant qualifications, and the systematic organisation of AML/CFT documentation, all at the same time. A structured application reduces the risk of deficiencies and speeds up the process. Registration is part of our licences and permits practice.

Justice League has worked in business law for 9 years. Our compliance practice specialises in AML/CFT, blockchain technologies and VASP/PSP regulation, and handles the legal side of implementing institutional grade tools.

In the registration process we offer:

• legal analysis of the business model, whether your service falls under the regulation and which services specifically;
• preparation of the full package of registration documentation, including all annexes;
• development of AML/CFT policies and procedures and of the organisational risk assessment document;
• preparation of operational schemes by service and by virtual asset;
• representation before the National Bank and preparation of responses to deficiency letters.

The full list of Justice League services is available on the services page. The decision on registration is taken by the National Bank independently. Our task is to ensure that the application reaches it complete, consistent and well founded.

If you are considering registration as a VASP or have already received a deficiency letter, contact us

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