---
title: "E-Money Licensing"
url: "https://legal.ge/en/service/technology-and-digital-law-en/e-money-licensing-en"
field: "Technology & Digital Law"
description: "E-money provider: National Bank registration, permitted activities and consumer fund protection under Georgian law. Legal.ge."
reviewed: "2026-02-15"
updated: "2026-11-07"
publisher: "legal.ge"
---

# E-Money Licensing

> Source: legal.ge, https://legal.ge/en/service/technology-and-digital-law-en/e-money-licensing-en

## 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.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/technology-and-digital-law-en/e-money-licensing-en

### Is there a separate e-money license?

No. Issuing electronic money is a payment service, and providing it requires registration with the National Bank of Georgia as a payment service provider — apart from the status of a commercial bank, microbank or microfinance organization, this is the only lawful route.

### May a provider grant loans?

Yes, under strict conditions: lending must not be the main activity and the loan is granted only for executing a payment operation; the term does not exceed 12 months; the loan is not granted from the consumer's funds; and the aggregate stays within the National Bank's norms.

### How quickly does the National Bank review a significant share acquisition?

Within 1 month of the submission of information; silence within that period means consent. A request for additional information suspends the period until it is submitted.

### How does the law protect funds held as e-money?

Consumer funds are placed separately from the provider's own, on a nominal possession account; no interest accrues on them, their use for credit is prohibited, and e-money must be exchanged for funds upon request. These funds are not a deposit.