What being an e-money provider means in Georgia
Issuing electronic money — topping up wallets and using them for payments — is not regulated in Georgia as a separate "EMI license". The entry gate is the Georgian Law on Payment Systems and Payment Services: issuing electronic money is a payment service, and providing it requires registration with the National Bank of Georgia as a payment service provider. This page examines what falls within the concept of payment services, which activities a registered provider may pursue, how registration proceeds, and what requirements apply to consumer funds.
The concept of payment services and the exceptions
Under point 1 of Article 13 of the law, payment services include, among others: debiting funds from the payer's account and related operations; crediting funds to the payee's account; executing a payment operation through a payment instrument — direct debit, credit transfer, payment card or other electronic means; issuing and/or acquiring payment instruments, including e-money instruments; money remittance; issuing electronic money and executing payment operations with it via mobile phone, the internet or another electronic means; payment initiation services; and account information services. Point 2 of the same article exempts a fairly broad list from the law's scope: cash payments without an intermediary; payments through a commercial intermediary; cash-in-transit services connected with transporting banknotes and coins; cash-to-cash exchange not carried out through accounts; operations between participants of a payment system; technical support where the transferred funds do not come into the provider's possession; additional payments by an electronic communications operator — where they concern digital content, charitable or ticket purchases, a single operation does not exceed GEL 50 and the monthly per-subscriber total does not exceed GEL 300; as well as securities operations, payments between companies within a group, cash-back at merchants, ATM withdrawals on behalf of card issuers, and payment by cheque. Separately there is the regime of limited-use instruments operating by agreement with the National Bank — these exceptions define where an activity needs no provider status.