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.
The Boundary of Electronic Money and Deposits — Article 48³
The second key boundary lies between banking activity and payment services. Under the first part of Article 48³, no one may take deposits and, using them, extend credits without a banking-activity licence or a microbank-activity licence issued by the National Bank. The second part paints a broader picture: an entrepreneur or a group of affiliated persons may not, without registration as a microfinance organization, a licence for non-bank deposit-taking credit activity or a banking licence, raise repayable monetary funds from more than 20 natural persons — including individual entrepreneurs — or advertise the raising of such funds from a broad circle of persons. This threshold is precisely the point where managing sums accumulated on customers' accounts crosses into the banking perimeter. At the same time, the restriction does not extend to services connected with electronic money as defined by the Law on the Payment System and Payment Services — and that exception is the legal footing of the payment model of digital wallets. The law also regulates the microbank's authority to raise repayable funds from natural persons within the frame of the relevant law.
Payment Infrastructure — Article 63
Digital wallets cannot function without payment infrastructure, and the management of that infrastructure belongs under the Organic Law to the National Bank: it may develop and issue regulatory legal acts on clearing, settlement, payment services and payment systems, organize the creation and implementation of systems, manage and administer them, assist banks and supervise the systems operating in Georgia. For a provider this means that the wallet's technical integrations — settlement rules, clearing deadlines, systemic requirements — are defined by acts of the National Bank, and every amendment of those acts must be reflected in the product plan without delay.
Frequently Asked Questions
Can you pay with cryptocurrency in Georgia?
As a general rule, no: a virtual asset is not a legal tender; only the cases defined by an act of the National Bank are excepted.
What does an issuer of a payment-functioning wallet need?
Registration as a payment service provider with the National Bank, in compliance with the capital and administrator requirements.
When does a wallet become banking activity?
When deposits are taken and used to extend credits — permissible only under a licence; raising repayable funds from more than 20 natural persons is also restricted.
What is the electronic-money exception?
Services connected with electronic money under the Payment System Law are not subject to the fund-raising restriction — the foundation of the wallet payment model.
How We Help on Legal.ge
Digital wallet regulation requires a simultaneous mapping of monetary, payment and banking norms onto your product's functions. On Legal.ge you can engage a financial-law specialist who will assess the legal qualification of your wallet, plan the registration and protect your interests in dealings with the National Bank. Submit a request on the site and get qualified assistance.