Armenia now runs a real, live licensing regime — not a draft. The Law on Crypto-assets (HO-159-N) was adopted on 29 May 2025 and has been in force since 4 July 2025; the Central Bank of Armenia (CBA) regulates both the public offering of crypto-assets and services involving them; and the first regulatory package was published on 21 January 2026, in force from 31 January. This is a new-entrant page: the regime works, the regulator is actively communicating, and the question is not whether it exists but how to enter it correctly.
The date that concerns every operator already in this market: 31 January 2027. In the CBA's reminder of 14 September 2026, entities that were already providing crypto services as of 4 July 2025 must be registered and licensed by that date — or cease their activity. That is the banner of this page: the window is open, but it is not open-ended.
The Law and the Regulator: HO-159-N and the CBA Package
Law HO-159-N governs the crypto-asset — cryptographically-based property existing only electronically via distributed ledger or similar technology — and its market; it was amended by HO-515-N of 17 December 2025. The first regulation package — CBA Board decisions and regulations on licensing, managers, offer documents and capital (including Decision No 228-N / Regulation 7/02) — was published on 21 January 2026 and entered into force on 31 January of the same year. On its own pages the CBA states it plainly: it regulates and supervises the public offering of crypto-assets and the provision of services involving them.
The 31 January 2027 Barrier — and Who May Apply
An applicant is a legal entity only — a joint-stock company or a limited liability company, registered and licensed with the CBA (Article 20 of the law). A foreign company enters the market through an Armenian subsidiary or a branch (Article 21) — a branch also needs CBA authorisation, while a representative office may not provide services (Article 22). Authorised financial institutions (investment companies, fund managers, banks, payment and e-money organisations for e-money tokens, and others) may also provide the services under their own status.
The ten licensed services sit in Article 16: operating a trading platform; custody; purchase and sale on own account; purchase and sale on a client's behalf; reception and transmission of orders; placing; portfolio management; advice; transfer of crypto-assets; issuance of asset-referenced tokens. The transitional rules: operators active as of 4 July 2025 — until 31 January 2027; legacy public offerings survive only where a compliant offer document was published and submitted to the CBA within three months of 31 January 2026 while the assets remain in circulation.
Process and the Capital Ladder in AMD
The application file is defined by Article 20: the statute, a business plan for certain services, internal rules, executive details, capital held in an account with an unaffiliated Armenian bank, statements on premises and information security, and proof of the state-duty payment. The CBA must decide within 2 months (1 month for an additional-service licence) and deliver the decision within 5 working days; twelve rejection grounds are listed; and acquiring a qualifying holding requires prior CBA consent (Article 28 — decision within 1 month). The state-duty amount is deferred to the Law on State Duty — confirm it with the regulator (cba.am); no unofficial figure is printed on this page.
The minimum total capital, under CBA Decision No 228-N (Regulation 7/02), splits by service in AMD:
- advice — AMD 10 000 000;
- client-side dealing, reception/transmission of orders, placing, portfolio management, transfer services — AMD 20 000 000;
- own-account dealing and custody — AMD 50 000 000;
- operating a trading platform — AMD 70 000 000;
- issuance of asset-referenced tokens — AMD 200 000 000.
The required minimum is the greatest of three candidates: the fixed figure, 25% of fixed costs, or — for ART issuers — 2% of average reserve assets (3% with 50 000 or more acquirers). If a licensee falls more than 10% below its threshold, the licence is repealed — here capital is a safety parameter, not a budget line. No published list of licensees exists yet — check cba.am.
The Georgian Layer: What Applies at Home Despite an Armenian Licence
An Armenian authorisation is an instrument for the Armenian market — it carries no European passport and rewrites no Georgian law. The organic law on the National Bank of Georgia (No 101044): Article 52-5(2) — a VASP registers with the National Bank; Article 52-5(3) — unregistered provision is impermissible; Article 52-5(4) — only the virtual asset service and auxiliary activity; Article 39-1 — a virtual asset is not legal tender; Article 48 — supervision belongs to the National Bank.
The AML law (No 4690334): Article 3(1) makes VASPs accountable persons; Article 4 assigns AML supervision to the National Bank; Article 11(1) sets the crypto KYC trigger at USD 1 000 / EUR 1 000 / GEL 3 000; Article 17¹ is the Travel Rule, its accompanying-information content defined by a National Bank act (Article 52-5(1) of the organic law). An Armenian licence cancels none of this: Georgia-facing activity requires its own registration.
Frequently Asked Questions
How much capital does an Armenian licence need?
By service: advice — AMD 10 000 000; client-side and other intermediary services — AMD 20 000 000; own-account dealing and custody — AMD 50 000 000; a trading platform — AMD 70 000 000; ART issuance — AMD 200 000 000. The minimum is the greatest of the fixed figure, 25% of fixed costs and, for ART, 2–3% of reserve assets.
What happens on 31 January 2027?
For operators active as of 4 July 2025 it is the barrier: registered and licensed by that date, or cease. The CBA confirmed this again in its 14 September 2026 reminder, urging providers not to postpone.
Can a Georgian company be licensed directly?
No — the applicant is an Armenian legal entity (JSC or LLC) only. A foreign group enters through a subsidiary or a branch (Article 21); a representative office may not provide services (Article 22).
What is the state duty?
The amount is deferred to the Law on State Duty and has not been printed in our official sources — confirm it with the regulator (cba.am). Unofficial figures have no place on this page.
How We Help on Legal.ge
Legal.ge builds the Armenian route from the capital ladder: we fix your services' minimum under Decision No 228-N, set up the Armenian JSC/LLC or branch, assemble the Article 20 documentation — the account with an unaffiliated Armenian bank, the premises and information-security statements — and track the 2-month decision clock and the 1-month qualifying-holding consent. For active operators we build the plan backwards from 31 January 2027; for everyone, the Georgian ring: National Bank registration and AML compliance. Contact us to start the Armenian route from your service list.