System Operator Registration: Who Needs It and What the National Bank Requires
Payment platform compliance takes shape around three pillars: the operator's status, the right to provide payment services, and the rules for accepting instruments. The law is clear: a legal entity may carry out the management of a payment system in Georgia only if registered with the National Bank of Georgia as a system operator. Registration and its cancellation follow the procedure and requirements established by the Bank, and this is not a one-off formality — the operator ends up in a permanent supervisory relationship.
The National Bank's powers over operators are broad: to promote the availability and unhindered execution of payment services and the reliable, safe and effective functioning of payment systems and their interoperability, the Bank sets relevant requirements; it defines the suitability criteria of the operator's administrator by legal act; it demands and receives financial, statistical and other information within its competence; and it requires information about planned changes significantly affecting service provision to be submitted 30 calendar days in advance. The intention to acquire a significant share also requires an application — all of these elements are routine parts of a compliance programme.
The Exception from Operator Registration and System Deployment
Not every payment system needs operator registration: the requirements do not extend to the National Bank and its systems, a central depository licensed by the Bank, a licensed commercial bank or microbank, and a payment service provider that uses the system only to provide services to its own customers. The classification of the platform — for whom and how the system works — therefore decides whether the exception applies.
The deployment procedure is precise: a payment service provider, including a commercial bank, may deploy a payment system in agreement with the National Bank and must submit the description of the system in advance of deployment. The Bank decides on the authority to deploy the system no later than 2 months from the submission of the description, and where additional information is requested, that period is suspended until it is submitted. Timely coordination of the deployment plan is therefore the critical path of the project.
The Right to Provide Services and the Rules of Accepting Instruments
At the level of services the rule is: it is impermissible for payment services to be provided by a person that is not a payment service provider registered with the National Bank, a commercial bank, a microbank or a microfinance organization, or another person provided by law. On registration the provider is granted the right to carry out specific services; the Bank publishes the list of providers with the services allowed for each; and the provider's capital must at no stage of its activity be less than the calculated supervisory capital. An application to acquire a significant share is decided by the Bank within 1 month — and no answer within that period counts as consent.
The rules of dealing with payees are part of compliance too: a payment service provider may not impose on a payee a restriction that forbids the payee, on a specific payment instrument, the right to charge a payer a commission or to offer a discount; the commission set must not exceed the direct cost incurred by the payee through the use of that instrument. The provider and the payee may not refuse acceptance of a payment instrument on the basis of the issuer or the consumer, except in cases defined by the National Bank. A payee that charges a commission must notify consumers clearly and post the information visibly at the entrance and at the cash register, and in distance sales — on the website, within a reasonable time before the transaction.
The practical compliance calendar looks like this: once the platform concept is fixed, the classification question is decided — whether the operator-registration exception applies; next the system description is prepared and submitted to the National Bank; in parallel the payment service provider status and the capital norm are verified; and during operation the 30-calendar-day change-notification regime and the rules on commissions and payee information are maintained continuously. Building this calendar early spares late rework.
The decision on the exception must be substantiated in documents: the system description shows exactly who the customers are, how the platform processes payments, and which role belongs to each participant. That description is precisely the basis on which the Bank assesses the system and decides, under its established procedure, on the authority to deploy it.
Frequently Asked Questions
Who needs operator registration?
Every legal entity managing a payment system — except the Bank, a central depository, a licensed bank or microbank, and a provider serving only its own customers.
How long does deployment take?
Up to 2 months from the description; requesting more material suspends the period.
Who may lawfully provide services?
A registered provider, a commercial bank, a microbank, a microfinance organization or another person provided by law; registration covers specific services.
How may commissions work?
The commission must not exceed the payee's direct cost; the information must be clear and visible — entrance, cash register and website.
How We Help on Legal.ge
Financial-technology lawyers on Legal.ge accompany payment platforms from choosing the status to daily compliance: we assess whether operator registration is needed, prepare the system description and applications, and structure the commission and notification rules. Contact us to build the compliance map of your platform together.