Neobank Licensing in Georgia — Payment-Service Registration
A neobank — a digital financial service operating without physical branches — functions in Georgian law under the status of a payment-service provider, and the legal path to its launch is defined by the Law on Payment Systems and Payment Services. This page explains the three layers: registration with the National Bank and capital requirements, the "significant provider" status and its additional duties, and the consumer-funds regime — the rules that safeguard a neobank clients' money. Every figure and requirement comes directly from the text of the law.
Registration and Capital — the Entrance Gate
It is inadmissible for payment services to be carried out by a person that is not a payment-service provider registered by the National Bank, a commercial bank, a microbank or a microfinance organization. Registration and its cancellation are carried out by the National Bank in the manner it establishes, and upon registration the provider is granted the right to carry out a specific payment service or services — the registration is thus specified by a list of permitted products. The National Bank publishes the list of providers with an indication of permitted services, where significant providers are shown separately.
The capital requirement is continuous: the provider's capital must at no stage of its activity be less than the supervisory capital determined and calculated under the National Bank's rules. An acquirer of a significant share must submit an application and documentation to the National Bank; the decision is taken within 1 month of the submission of the information, and the Bank's failure to answer within that period means consent to the transaction. Where the information is insufficient, the Bank may request additional documents, and the period is suspended until their submission.
The Significant Provider — an Additional Regime
Where the volume of electronic money issued by the provider or an associated person, or the turnover of other payment services, exceeds the National Bank's thresholds, the Bank may set additional requirements; where the provider is deemed significant for the financial sector, this regime may be extended by an individual administrative act even if the thresholds are not exceeded. A significant provider must maintain the established minimum capital at all stages — a microfinance organization must observe the greatest of the amounts required under this law and the microfinance law. The requirements continue to apply after the volumes fall below the thresholds; exemption is possible where the volume has not exceeded the thresholds for 3 consecutive months or the status was assigned on systemic-significance grounds.
Reporting duties also grow: a significant provider keeps accounts under International Financial Reporting Standards (IFRS) and publishes its annual audited financial statements on its website by 15 May of the following year — audited under the International Standards on Auditing (ISA). The Bank may request and receive any financial, statistical and other information within its competence.
Consumer Funds — the Core of Protection
Consumer funds received by the provider must be placed separately from the provider's own funds, in a nominal-possession account, and their use to secure the provider's obligations is prohibited. For individual significant providers the Bank may demand a guarantee and/or insurance policy, and may require the change of its conditions or of the guarantor. Consumer funds are not a deposit; interest accrual is prohibited, their use for granting credit or overdraft is inadmissible, and electronic money is the provider's obligation toward the consumer — upon request the provider must exchange electronic money for funds.
For business clients the rule is: a legal person and an individual entrepreneur may participate in the electronic-money scheme only as a payee; the equivalent of electronic money received by them must be transferred to their bank accounts by the provider no later than 15 banking days. Where a payer is involved, the provider ensures the fulfilment of obligations established by legislation and notifies the National Bank within 2 working days; the list of such providers is published on the Bank's website.
Frequently Asked Questions
Does a neobank need a banking licence?
For payment services — registration with the National Bank is required; carrying out payment services by an unregistered person is inadmissible. Taking deposits requires a separate status.
How quickly does the National Bank decide on a share acquisition?
Within 1 month of the submission of the information; silence within that period means consent. The period is suspended when additional information is requested.
What is the significant-provider status?
A regime of additional requirements for turnover exceeding thresholds or for systemic significance; exemption is possible where the turnover stays below the thresholds for 3 consecutive months.
How is clients' money protected?
Consumer funds are placed in a nominal-possession account separately from the provider's own funds; their use for security, interest or credit is prohibited.
When is the audited report published?
A significant provider publishes IFRS-prepared, ISA-audited annual statements by 15 May of the following year.
How We Help on Legal.ge
The Legal.ge team advises payment-service providers and neobanks: preparing registration applications under the National Bank's rules, planning capital, assessing the significant-provider status, documenting the consumer-funds regime and handling supervision. Contact us for a full legal plan for your project.