The Legal Framework of Digital Wallet Regulation in Georgia
Digital wallet regulation in Georgia begins with the monetary and payment norms of the Organic Law on the National Bank. The starting point is unambiguous: Article 39¹ of the law provides that a virtual asset is not a legal tender, and payments made in virtual assets are prohibited, save for the cases defined by a legal act of the National Bank which are necessary for providing virtual asset services. This means that electronic wallets operating in lari and other lawful payment instruments, on the one hand, and cryptocurrency wallets, on the other, fall under different legal regimes: the former under the payment-services rules, the latter under the prohibition-and-exceptions system for virtual assets. Classifying the product correctly at the design stage is therefore the first compliance decision any wallet issuer makes.
Payment Service Provider Status — Article 48²
A digital wallet issuer performing a payment function falls within the National Bank's supervisory perimeter. Under Article 48², the National Bank supervises payment system operators and payment service providers in accordance with Georgian legislation — through registration, deregistration, inspection, the setting of additional requirements, the determination of initial and ongoing capital, the imposition of restrictions and the application of sanctions. The rules on registration and its cancellation, and the sanctions — including the amount of monetary fines and the procedure for their imposition — are determined by normative acts of the National Bank, and the fines are directed into the state budget. The National Bank may also grant a payment system the status of a systemically or exceptionally important payment system and set the corresponding capital and asset criteria, and it determines the fitness criteria for administrators. For a wallet business model, these requirements must be built into the operational budget and the governance structure from the outset, not retrofitted after launch. In practice this means deciding, before release, who the registering entity will be, with what initial capital, how ongoing capital requirements will be met as the product grows, and which persons satisfy the administrator fitness criteria.