Obtaining a banking license in Georgia is one of the most complex, labor-intensive, and highly regulated processes. The National Bank of Georgia (NBG) sets the highest standards for entrants to the banking sector to ensure financial system stability. Obtaining a license involves more than just filling out an application; it is a multi-stage process involving detailed scrutiny of the business model, source of capital, management team qualifications, and IT infrastructure. Recently, a "Digital Bank" licensing model was introduced, opening opportunities for fintech companies. This service involves full legal and consulting support for license applicants, from preparatory work to obtaining the final license.
What Does the Bank License Application Service Cover?
Banking law experts on our platform offer a comprehensive service package:
- Preliminary Consultation and Structuring: Assessing the business model, selecting the license type (traditional vs. digital), and setting up the corporate structure.
- Documentation Preparation: Drafting founding documents, business plans, strategic development plans, and internal policies (credit, risk, AML).
- "Fit and Proper" Tests: Verifying and documenting compliance of administrators and significant shareholders with eligibility criteria.
- Capital Verification: Confirming the authorized capital (minimum 50 million GEL) and the legality of its origin.
- Communication with NBG: Representation at the NBG during all stages of application review, answering questions, and rectifying deficiencies.
Common Scenarios and Challenges
Clients often face the following challenges during the banking licensing process:
- Creating a Digital Bank: A tech startup wants a banking license. The difficulty lies not only in capital but also in meeting complex IT infrastructure and cybersecurity standards.
- Foreign Investor Entry: A foreign banking group wants to open a subsidiary in Georgia. It requires legalization of international documents and demonstrating a transparent ownership structure.
- Approval of Administrators: The NBG may refuse to appoint a director due to insufficient experience or past reputational issues.
- Source of Funds: The investor fails to convincingly demonstrate the legal origin of funds, which becomes grounds for license refusal.
Georgian Legal Framework
Banking licensing is regulated by the Law of Georgia on Activities of Commercial Banks and the Decree of the President of the National Bank "On Approval of the Rule for Licensing Commercial Banks". For digital banks, "Principles of Licensing a Digital Bank" apply, which allows for phased licensing. Legislation sets the minimum authorized capital amount (50 million GEL) and requirements for the governing body and operational infrastructure. The National Bank is authorized to extend the review period or request additional information at any stage.
Service Process: What to Expect
The process is divided into several stages: 1. Preparatory stage (audit, structuring) - 2-3 months; 2. Application submission and review - legally 3 months, but practically 6-12 months; 3. Preliminary approval or conditional license; 4. Obtaining the final license and starting operations. The lawyer coordinates auditors, business consultants, and founders to create a unified, convincing licensing package.
Why Choose Legal.ge?
Obtaining a banking license is the pinnacle of corporate law. Legal.ge connects you with lawyers who have direct experience dealing with the regulator and know what the National Bank looks for. Our experts will help you navigate this complex path without errors and successfully enter the Georgian financial market.
Updated: ...