VASP licence in Georgia
VASP licence in Georgia: the National Bank registration a virtual asset service provider actually needs
Georgia does not issue a document called a crypto licence. A business that exchanges, transfers, holds or administers virtual assets for other people registers as a virtual asset service provider with the National Bank of Georgia and is supervised by it from that day on. The first question is whether your product is caught at all, and that is answered in writing before anyone is asked to pay for a file.
This route fits you if
- You provide a virtual asset service to other people as a business: exchange between virtual assets and fiat, exchange between one asset and another, transfers, custody, or administration of the instruments that control assets.
- You are ready to register before you operate, rather than after a bank closes the account.
- You can describe your custody model in operational detail: cold and hot storage, who authorises a movement of assets, how keys are backed up, how an incident is detected and handled.
- You accept that the AML programme, including the travel rule, is the application rather than an annex to it.
- You want the banking question tested early, because for crypto files it is usually the binding constraint.
Take another route if
- You mine or trade for your own account and provide no service to anyone else. That is usually outside the perimeter, and we will say so rather than sell you a file. Read the perimeter analysis
- Your product is a non-custodial wallet or an analytics tool with no client order flow. The answer may be that you need nothing, which is a cheaper answer to buy. Ask about the perimeter
- You move client money in fiat rather than virtual assets. That is payment services, a different National Bank regime. Payment services
- You want a registration in two weeks with no substance behind it. It does not exist here, and the people selling it are selling a problem.
How it is priced
What a VASP file costs, and why no number appears above
Georgia sets the regulator's charges and the financial-standing condition by activity, and both change. A figure published here and wrong on the day you file would cost you far more than reading this table.
| Perimeter opinionA written answer on whether your product needs registration at all, and under which limb of the definition. Quoted before it starts and credited against the registration engagement. | Fixed fee |
| Registration file and filingGovernance, ownership and fit-and-proper evidence, the custody and key-management description, the AML programme, the application and the correspondence with the National Bank to decision. | In the proposal |
| National Bank chargesThe regulator's own fees are set by the National Bank, passed through without a mark-up and stated in the proposal as they stand on the day it is issued. | At cost |
| Georgian company, address and tax registrationFormation from €400, registered address from €120 a year. Priced from the published list, not folded into the licensing file. | From the price list |
| AML programme and independent reviewThe business risk assessment, the policies, wallet screening and travel-rule procedures, and the periodic independent review a supervisor expects to see. | In the proposal |
| Regulatory retainer after registrationReporting, policy updates, officer and ownership changes and correspondence with the regulator, sized to the registration. | Monthly |
No registration fee, capital figure or decision date is quoted on this page on purpose. The scoping review ends with a written proposal that states the regime, the file, a realistic timeline and every fee in force when it is issued; the professional fee is fixed once the engagement letter is signed, and government and third-party charges are passed through at cost. Formation and address prices come from the Trustlex price list of 2026-10-14.1.
The route to the registration
- 1
Perimeter analysis, in writing
What the product does, for whom, and with whose assets. You get a written answer on whether registration is required and under which limb of the definition, with the architectural choices that would change it named. Some clients stop here, correctly.
- 2
Scoping proposal
The regime, the file the National Bank will expect, a realistic timeline measured in months, and the split between professional, government and third-party costs. Nothing is paid for the file before you have read it.
- 3
The entity, the ownership file and the officers
A Georgian company with ownership transparent up to identifiable beneficial owners, and directors and key function holders whose fit-and-proper evidence is assembled before it is asked for.
- 4
Custody, security and the AML programme
The key-management policy, the split between cold and hot storage, segregation of client assets, wallet screening, sanctions, the travel rule including the counterparty that cannot return the data, and the reporting line to the Financial Monitoring Service. Written so that it works on the day it is inspected.
- 5
Filing, follow-up questions and the decision
The application is filed and defended. The National Bank asks follow-up questions, and how fast they are answered is what sets the pace. You are told where the file stands rather than left to infer it.
- 6
Banking, tested early rather than last
Registration does not entitle anyone to a bank account, and Georgian appetite for crypto-facing businesses is narrow. We test the banking question with the institutions while the file is being built, so that a supervised business is not left without a payment route.
What the file needs from you
- A written description of the product and the money flow: what is exchanged, transferred, held or administered, and for whom
- Ownership up to identifiable beneficial owners, with evidence behind each layer
- Passports, CVs, clean-record and reference material for owners, directors and key function holders
- Evidence of financial standing appropriate to the activity, maintained continuously rather than at filing only
- The custody and key-management model in operational detail, including incident response
- Your AML/CFT programme, or the instruction to write one: risk assessment, due diligence, monitoring, screening, travel rule, reporting, training and independent testing
- Named third parties: analytics provider, custody technology, outsourced functions, and the contracts behind them
A custody model that cannot be explained in operational detail is not ready to file. Filing it anyway spends the regulator's patience rather than buying time.
Questions about the VASP regime
Is it a licence or a registration?
Georgia registers virtual asset service providers with the National Bank of Georgia and supervises them from that point. People search for a crypto licence, and the honest answer is that the instrument is a registration. Commercially it comes to the same thing: without it, providing the service as a business is not lawful in Georgia.
Which activities are caught?
In outline: exchange between virtual assets and fiat currency, exchange between one virtual asset and another, transfer of virtual assets, custody or administration of assets or of the instruments that control them, participation in and provision of financial services related to the offer or sale of a virtual asset, and lending or borrowing in virtual assets offered as a business. Mining and holding for your own account are treated differently from providing a service to others, and the perimeter question is always the same: are you doing this for other people, as a business?
What is the fee, and what capital is required?
We publish neither figure. The National Bank's charges and the financial-standing condition are set by activity and change, and a number that is wrong on the day you file is worse than no number at all. The scoping proposal states both as they stand when it is issued, and the professional fee is fixed once the engagement letter is signed.
How long does it take?
Months rather than weeks, and the pace is set by how quickly you can produce evidence rather than intentions. The banking relationship often takes longer than the registration itself. We will not put a date on a decision that belongs to the regulator.
Does registration get us a bank account?
No. Registration confirms that the business is supervised; it does not oblige any bank to serve it, and Georgian appetite for crypto-facing businesses is narrow and differs by institution. Test the banking question before you commit to customers.
Does a Georgian registration let us serve clients anywhere?
No. It authorises the activity under Georgian law and gives you a supervised home. It does not make you lawful in a client's country: market access is decided where the client is, for every licence in the world. We say this before anything is built on it.
Can you guarantee the registration?
No, and nobody can. The decision is the National Bank's. What we can do is tell you honestly, before the engagement starts, whether the file is realistic, and say so plainly if it is not.
General information, not legal or tax advice. Fees reflect the Trustlex price list of 2026-10-14.1; rates, thresholds and registry practice reflect September 2026 and change. The route for your case is confirmed by a lawyer at review.
Read before you start
Start with the perimeter question
Describe the product in a few lines and book a scoping call. You will get a written answer on whether registration is required, and the route if it is.