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.