COREDO > Crypto Licence in Georgia

Crypto Licence in Georgia

Georgia is one of the most attractive jurisdictions for cryptocurrency businesses thanks to its flexible regulation and favourable tax environment. The country offers official VASP registration, transparent rules for working with virtual assets, and accessible conditions for international crypto companies.

Since 2016, COREDO has been assisting clients with obtaining VASP registration in Georgia, providing full support — from company incorporation to communication with the National Bank of Georgia.

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Cost of the service
from EUR 9,600

Regulatory Framework for Virtual Assets in Georgia

The regulation of cryptocurrency activities in Georgia is based on amendments to the Law of Georgia on Facilitating the Suppression of Money Laundering and Terrorism Financing. Legislative changes concerning virtual assets entered into force on 1 January 2023, and the mandatory VASP registration regime with the NBG became effective on 1 July 2023.

VASP registration is administered by the National Bank of Georgia under the Order of the Minister of Finance of Georgia and operates as a notification-based procedure: the NBG is required to process an application within 60 calendar days of submission, and this period may be extended twice, each time by a further 60 calendar days. The registration does not require annual renewal — the registered entity must simply maintain ongoing compliance with NBG regulations on a continuous basis.

The key secondary legislation is NBG Order No. 94/04, which approved the “Rule on Registration of a Virtual Asset Service Provider (VASP) at the National Bank of Georgia, Cancellation of Registration and Regulation.” This document establishes registration requirements, Fit & Proper criteria for administrators and significant shareholders, requirements for the head office, branches, software and AML/CFT compliance.

The National Bank of Georgia is vested with the authority to issue and revoke VASP registrations, conduct inspections, impose sanctions and establish regulatory requirements. In June 2024 the NBG adopted a Regulation on Penalties, setting the amounts of sanctions for violations of AML/KYC requirements and the conditions of licensed activity. From 1 January 2026 all registered VASPs are required to publicly display or make available the NBG administrative-legal act confirming their registration.

The NBG also ensures compliance of Georgian VASPs with international standards, including FATF recommendations on virtual assets and Travel Rule requirements for crypto-asset transfers.

Types of VASP Activities in Georgia

Under Georgian legislation a virtual asset service provider (VASP) is a person providing services involving virtual assets for the benefit of another person. The law defines the following types of regulated activities:

Exchange of virtual assets for fiat currencies

conversion of convertible virtual assets into national or foreign currency and vice versa, including operations through exchange platforms and self-service kiosks.

Exchange between virtual assets

conversion of one form of convertible virtual assets into another, including the exchange of tokens, cryptocurrencies and stablecoins among themselves.

Storage and management of virtual assets

ensuring secure custody of clients’ convertible virtual assets, management of private keys and custodial services.

Virtual asset portfolio management

managing portfolios of convertible virtual assets on behalf of clients, including asset balancing and investment strategies.

Administration of trading platforms

creation and operation of platforms for trading convertible virtual assets, ensuring liquidity and order execution.

Initial virtual asset offering (ICO)

organisation and conduct of the initial offering of convertible virtual assets, including documentation preparation and investor attraction.

Lending secured by virtual assets

provision of credit products using convertible virtual assets as collateral.

A VASP may register for one or more types of activity within a single registration.

Advantages of Obtaining VASP Registration in Georgia

Georgia offers a number of competitive advantages for crypto companies, making it an attractive alternative to more expensive jurisdictions.

Favourable tax regime.

Georgia applies the Estonian corporate tax model: a 15% corporate tax is charged only on distributed profits, while reinvested profits remain tax-free. Cryptocurrency conversion transactions are exempt from VAT. Income from cryptocurrency operations for individuals is treated as foreign-sourced and is exempt from personal income tax.

Absence of minimum share capital for LLCs.

Unlike European jurisdictions, where MiCA requires minimum capital of EUR 50,000 to EUR 150,000, in Georgia the registration of a company in LLC form does not require mandatory minimum capital. For joint-stock companies (JSCs) the minimum capital is GEL 100,000 (approximately EUR 34,000), with at least 25% paid at registration.

Fast and affordable company incorporation.

Registration of a Georgian LLC takes one to two business days, and the state fee amounts to just GEL 200 (approximately EUR 70). Foreign investors may own 100% of the company without engaging a local partner or nominee director.

Strategic geographical location.

Georgia is situated at the crossroads of Europe and Asia, providing convenient access to the markets of both regions. The country has an Association Agreement with the EU and a network of double taxation avoidance agreements with 58 jurisdictions.

Moderate regulatory and business operation costs.

The NBG state fee for VASP registration is GEL 5,000 (approximately EUR 1,700), and the cost of living and office rental in Tbilisi is significantly lower than in European financial centres.

Compliance with international FATF standards.

The Georgian regulatory regime is built in accordance with FATF recommendations on virtual assets, ensuring recognition of Georgian VASP registration by partners and banking institutions worldwide.

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Cost of COREDO Services for Obtaining VASP Registration in Georgia

COREDO’s fees are structured transparently and divided into a core fee and a success-based component.

VASP registration core package — the Legal & Compliance Service Fee of EUR 9,600 + VAT, payable upfront. The package includes:

Georgian company (LLC) incorporation

preparation and filing of all documents for the registration of the legal entity that will act as the VASP applicant.

Legal structuring and regulatory guidance

analysis of the business model, structuring of the project and advice on NBG requirements at every stage of the process.

Preparation and review of all application documentation

drafting and legal review of every document in the registration package.

Apostille and translation support

assistance with the apostille and legalisation of foreign documents and arrangement of certified Georgian translations.

AML/CFT documentation and business plan

drafting of internal AML/CFT policies, the compliance matrix and a three-year business plan demonstrating genuine operational substance in Georgia.

Representation before the NBG

submission of the application, communication with the regulator and preparation of responses to its inquiries, with ongoing coordination until registration is fully complete.

Bank account opening

support for the initial engagement with a Georgian bank is included in the core package; in addition, COREDO assists with account opening at international EMI providers.

Success Fee

EUR 2,400 + VAT, payable only upon NBG approval of the VASP registration. This structure ties a substantial part of COREDO’s remuneration to a successful outcome.

Government registration fee

GEL 5,000 (approximately EUR 1,700), payable directly to the National Bank of Georgia and not included in COREDO’s fees.

Turnkey operational setup

EUR 1,200. COREDO recruits and arranges everything required to meet the NBG’s operational requirements: a local director (with physical presence in Georgia for a minimum of 14 days per month), an AML/Compliance Officer and a registered office address in Georgia.

Accounting and annual maintenance

costs depend on the company’s transaction volume and operational needs and are quoted individually.

Payment Terms

COREDO applies the following payment structure:

The Legal & Compliance Service Fee (EUR 9,600 + VAT) is payable upfront, before the commencement of work — it covers company incorporation, preparation of the full registration package and liaison with the NBG.

The Success Fee (EUR 2,400 + VAT) is payable only upon approval of the registration by the National Bank of Georgia.

The government registration fee of GEL 5,000 (approximately EUR 1,700) is transferred by the client directly to the National Bank of Georgia.

This structure ensures a balance of interests: the core fee covers COREDO’s operational costs at every stage of work, while a significant part of the payment is tied to the successful outcome of the registration.

Requirements for VASP Registration Applicants

To obtain VASP registration in Georgia the applicant must meet a number of requirements established by the NBG.

Legal form:

the application is submitted on behalf of a company registered in Georgia in the form of an LLC or JSC. Individuals and sole proprietors cannot obtain VASP registration.

Directors:

the company must appoint at least two directors, and at least one of them must be physically present in Georgia for a minimum of 14 days per month. There are no nationality or residency restrictions for directors and shareholders — where required, COREDO recruits a local director as part of the operational setup service.

Fit & Proper criteria:

administrators (directors) and direct or indirect significant shareholders (including beneficial owners) must meet NBG criteria. Business reputation, criminal record, education, professional experience and financial standing are assessed. Administrators must not have unexpunged convictions for economic, corruption or financial crimes.

Registered address and head office:

the VASP must maintain a registered legal address and an operational head office on the territory of Georgia. The head office must be equipped with a certified video surveillance system with recordings stored for at least 30 days; the requirements also apply to branches and self-service kiosks.

AML/CFT compliance:

the appointment of a compliance officer (AML Officer), development and implementation of an AML/CFT policy, a risk management system, client identification procedures (KYC/KYB) and transaction monitoring, recording and reporting systems are required. The use of specialised blockchain analytics tools (Chainalysis, Elliptic) is recommended.

Software:

the VASP must demonstrate the availability of reliable technical systems for conducting virtual asset activities, including software and security system audits.

Notification of changes:

the VASP must notify the NBG at least 30 days before implementing any material or high-risk operational changes.

List of Documents for VASP Registration

The following set of documents is required for submitting a VASP registration application to the NBG:

Completed VASP registration form (in the format approved by the NBG) with a detailed description of all virtual asset services the applicant intends to provide.

Company incorporation documents — articles of association, memorandum of association, certificate of registration in the Georgian Register of Entrepreneurs.

Business plan with a three-year budget forecast — description of the business model, target markets, planned transaction volumes, revenue sources and financial projections, demonstrating genuine operational substance in Georgia.

Identity documents of directors and beneficial owners — passport or identity document of each director and beneficial owner (apostilled or legalised if issued abroad, with a certified Georgian translation), together with proof of residential address (not older than three months).

Criminal record certificates — for directors and significant shareholders from all jurisdictions of residence during the last 10 years, apostilled and accompanied by certified Georgian translations.

Education and professional background — CV of each director and responsible manager indicating education and professional experience.

Information on beneficial owners (UBOs) — data on all persons directly or indirectly holding a significant share in the company, including documents confirming the ownership structure.

Compliance matrix — a document demonstrating the applicant’s conformity with each NBG registration requirement.

AML/CFT policy — a comprehensive document describing procedures for combating money laundering and terrorist financing, client identification procedures, transaction monitoring and suspicious activity reporting.

Risk management rules — a document describing the system for identifying, assessing and managing operational, financial and regulatory risks.

Operational manual — description of internal procedures, technical systems and the VASP’s organisational structure.

Proof of source of funds — bank statement for three months or tax declaration confirming the legality of funds used to finance the activity.

KYC form — a completed company and key persons identification questionnaire in the NBG format.

CV of the AML Officer — resume of the appointed compliance specialist with confirmation of qualifications and experience in AML/CFT.

All foreign-issued documents must be apostilled or legalised and accompanied by certified Georgian translations. COREDO coordinates the apostille, legalisation and translations and assumes responsibility for the preparation, execution and review of all the above documents as part of the core package.

VASP Registration Procedure

The process of obtaining VASP registration in Georgia involves several sequential stages.

Preliminary assessment and incorporation (1–2 weeks).

COREDO analyses the client’s business model for compliance with NBG requirements, determines the types of activity for registration and carries out the incorporation of a Georgian LLC — this takes approximately one to two weeks from receipt of all required documents. At this stage the opening of a corporate bank account is also initiated and a registered office is secured.

01

Document preparation (3–4 weeks).

The COREDO team develops the complete registration package: business plan, AML/CFT policy, compliance matrix, risk management rules, operational manual and dossiers on directors and beneficial owners. Apostille, legalisation and certified Georgian translations are coordinated by COREDO. Preparation takes approximately three to four weeks from receipt of all client materials.

02

Application submission to the NBG.

Upon completion of preparation, COREDO submits the document package to the National Bank of Georgia. The regulator confirms receipt of the application and commences the review procedure.

03

Regulatory review (60–180 days).

The NBG is required to review the application within 60 calendar days of submission; this period may be extended twice, each time by a further 60 calendar days. During the review the regulator may request additional documents or clarifications — COREDO ensures prompt preparation of responses to all NBG inquiries and manages communication with the regulator until the decision is received.

04

Obtaining registration.

Upon a positive decision the NBG issues an administrative-legal act confirming the VASP registration. The company is entered into the register of registered VASPs and may commence regulated activities. The registration does not require annual renewal — the company only needs to maintain ongoing compliance with NBG requirements.

05

In the standard scenario the process from the start of work to obtaining registration takes around three to four months; if the NBG exercises its right to extend the review, the overall timeframe may increase.

Our Experts

The VASP registration process in Georgia is supported by COREDO’s leading specialists.

Pavel Kos

Head of Legal at COREDO. Has been with the company since 2017 and specialises in the licensing of financial and cryptocurrency companies across various jurisdictions. Responsible for strategic project planning, interaction with regulators and ensuring compliance with regulatory requirements.

Basang Ungunov

Lawyer at COREDO. Specialises in the preparation of legal documentation for licensing, legal analysis of business models and support for regulatory procedures. Provides legal expertise for all documents submitted to regulatory authorities.

Frequently Asked Questions

What is VASP registration in Georgia and why is it needed?

VASP registration is a mandatory procedure for registering a virtual asset service provider with the National Bank of Georgia. Since 1 July 2023 all companies conducting activities involving virtual assets on the territory of Georgia are required to register with the NBG. Operating without registration constitutes a violation of the law and entails the imposition of sanctions.

How much does VASP registration in Georgia cost?

COREDO’s core package (Legal & Compliance Service Fee) costs EUR 9,600 + VAT and is payable upfront. A Success Fee of EUR 2,400 + VAT is payable only upon NBG approval of the registration. In addition, the government registration fee of GEL 5,000 (approximately EUR 1,700) is paid directly to the National Bank of Georgia, and, where needed, a turnkey operational setup is available for EUR 1,200 (local director, AML Officer, registered office).

How long does it take to obtain VASP registration?

Incorporation of the Georgian LLC takes approximately one to two weeks, and preparation of the registration package takes three to four weeks from receipt of all client materials. The NBG reviews the application within 60 calendar days; this period may be extended twice, each time by 60 days. In the standard scenario the entire process takes around three to four months.

What is the minimum capital required for a VASP in Georgia?

For a company in LLC form no minimum share capital is required. For a JSC the minimum capital is GEL 100,000 (approximately EUR 34,000), of which at least 25% is payable at registration. Most VASPs register in LLC form.

What taxes does a VASP company in Georgia pay?

Georgia applies the Estonian model of corporate taxation: income tax (15%) is levied only upon dividend distribution. Retained earnings are not taxed. Crypto-asset transactions are exempt from VAT. IT companies may additionally obtain Virtual Zone Person status with a zero rate for corporate tax and VAT on the export of digital services.

Can a foreign company obtain VASP registration in Georgia?

Yes. Foreign investors may own 100% of a Georgian company, and directors and shareholders may be nationals of any country. It is necessary to register a company in Georgia (LLC or JSC), maintain a head office on the territory of the country, appoint at least two directors — at least one of whom is physically present in Georgia for a minimum of 14 days per month — and complete the VASP registration procedure with the NBG. COREDO supports the entire process, including remote incorporation and the recruitment of a local director.

What is the state fee for VASP registration?

The NBG state fee for VASP registration is GEL 5,000 (approximately EUR 1,700). This fee is payable directly to the National Bank of Georgia and is not included in the cost of COREDO’s services.

Does VASP registration in Georgia require annual renewal?

No. VASP registration in Georgia does not require annual renewal or periodic re-registration. The company must maintain ongoing compliance with NBG requirements and notify the regulator at least 30 days before implementing any material or high-risk operational changes.

Is Georgian VASP registration internationally recognised?

The Georgian regulatory regime is built in accordance with FATF recommendations on virtual assets and Travel Rule requirements. This ensures recognition of Georgian VASP registration by international counterparties, banking institutions and payment systems. However, registration in Georgia does not provide automatic access to EU markets (this requires a CASP licence under the MiCA regulation).

What is the difference between Georgian VASP registration and a CASP licence in the EU?

Georgian VASP registration is a national regime that is valid only on the territory of Georgia. A CASP licence under the MiCA regulation allows the provision of services throughout the entire EU (27 countries) through the passporting mechanism. At the same time the cost of a CASP licence in the EU is significantly higher (from EUR 29,000), and the minimum capital is from EUR 50,000 to EUR 150,000. Georgia is attractive for companies focused on the CIS, Middle East and Asian markets.

Get VASP Registration in Georgia with COREDO

COREDO provides comprehensive legal support for the VASP registration process in Georgia. Our team has been working in licensing since 2016 and possesses deep expertise in the regulatory requirements of various jurisdictions.

To receive an individual consultation and a cost estimate, contact our experts.