Routing the online revenue of a gambling business through payment infrastructure — payment service providers (PSPs), card schemes and merchant-of-record (MoR) models — is technically far simpler than it is legally. The market builds this segment on the providers' own rules, and the task of this page is to draw exactly the boundary where that practice rests on a layer of Georgian law: what precondition makes revenue lawfully processable, what obligations run along the payment chain, and what remains purely the policy of the specific PSP — scheme registration requirements, MoR pricing and territorial acceptance lists, to be re-verified from the provider's own materials in every case.
The Structural Problem: Gambling Payments Are a Filtered Category
In the payments industry, gambling is recognised as a separate, persistently scrutinised category: a provider serving this segment takes on additional risk itself, and its internal filters are therefore much stricter than in ordinary e-commerce. For a Georgian organiser this means the question is not merely "will the provider take a gambling business" but "what documentary basis will that acceptance have". This is where the Georgian layer enters — and its proper fixation is the argument that passes the provider's risk filter.
The Permit as the Precondition of Lawful Processing Revenue
Under article 5, part 1 of the Law of Georgia on gambling, organising games and supplying them into Georgia requires a permit, and under article 11, part 2 the permit is issued only to an entrepreneur registered in Georgia. In the payments context the law reads as follows: the permit is the precondition that makes the processing of the revenue lawful — and for a provider it is the first document demanded. Where system-electronic supply is in play, the picture is completed by the selected-person regime of article 36-1 and integration with the state control system — the infrastructural trail that must be consistent with the payment chain.
AML Along the Payment Chain
Every ring of the payment chain subject to Georgian law opens obligations under the AML law: article 3 defines the circle of obliged persons, article 11 the rules for customer identification and verification, and article 12 the flow of data. Practically, engaging a PSP is a second KYC/AML cycle for the organiser — similar to the bank-account cycle, but oriented on the dynamics of transactions: what is examined is not only who the organiser is but what the transaction profile looks like. To this are added article 29(b) of the gambling law — registration of winnings with reporting to the Financial Monitoring Service — and the margin logic of Tax Code article 80, part 7, which defines the tax character of the amounts flowing through payments (together with the article 81 rates); on the player's side, article 8 operates.
Advertising Limits and Their Effect on PSP Onboarding
One norm is often missed in technical discussions yet bears directly on payment integration: article 8-3, part 1, subparagraph "a" of the Georgian law on advertising restricts the placement of gambling advertising to websites holding a permit for the system-electronic form. Its practical significance for the provider relationship is that the onboarding process is tied to permit status: a platform that cannot satisfy the advertising rules creates a problematic profile for processing as well. The legality chain here is single: permit — website status — the right to place advertising — and only then full payment integration.
VAT and Merchant-of-Record Invoicing
Article 171(b) of the Tax Code keeps gambling services VAT-exempt, in line with the carve-out of article 172, part 4, subparagraph "ს" — and that exemption bears directly on the invoicing of merchant-of-record flows. In the MoR model, where the provider itself acts as the merchant of record and accounts to the client for the result, the correct tax character of the invoices is decisive: the exempt status of gambling services is the basis on which that accounting must be built. At the same time, MoR pricing, scheme registration requirements and territorial acceptance lists are the provider's own policy — verified from the PSP's materials and confirmed with it directly in every case.
Frequently Asked Questions
Four questions dominate the payments topic.
Why does the PSP demand the permit?
Because the permit is the precondition of lawfully processable revenue: article 5, part 1 requires it for organising and supplying, and article 11, part 2 issues it only to a registered entrepreneur. The provider anchors its own risk filter on that document.
Is the payment chain covered by AML?
For the Georgian rings of the chain — yes, the law's articles 3, 11 and 12 impose obligations, with article 29(b) additionally operating on the organiser's side for winnings registration. In practice this means a second KYC/AML cycle focused on the transaction profile.
Can gambling advertising run on any site?
No — article 8-3, part 1, subparagraph "a" of the law on advertising restricts placement to system-electronic websites holding a permit. This directly affects PSP onboarding as well.
How is a merchant-of-record flow invoiced?
Under the VAT-exempt character of gambling services — Tax Code article 171(b) with article 172, part 4, subparagraph "ს". Pricing and acceptance lists are confirmed with the PSP.
How We Help on Legal.ge
Legal.ge approaches the payments topic with the same file-based method that works for banking: we build the organiser's Georgian legal profile — permit status within articles 5 and 11, the website's compliance with article 8-3, part 1, subparagraph "a" of the advertising law, the tax character under articles 80, 81 and 171(b) — and turn that profile into the package a PSP demands at onboarding. Where the decision belongs to the provider's policy — scheme registration, MoR pricing, territorial lists — we prepare the list of questions and fix the answers received, so that a directed integration never rests on unverified assumption. Contact us before the provider conversation — the legality chain starts with the permit and ends with the invoice, and every ring of that chain must be held in advance.