How a provider enters the regulator's register
A frequent question is how to obtain a licence for virtual asset services. The operative framework in Georgia is built differently: there is no separate licensing statute, and the mandatory route into the market is registration with the National Bank of Georgia and satisfaction of the requirements it establishes. This regime determines who may provide such services, what the National Bank examines, and what powers it holds after registration. On this page we explain this framework in detail.
Registration and the monopoly of the registered
A virtual asset service provider is obliged to register with the National Bank and to satisfy the requirements established by it. The rules of registration, deregistration and regulation are established by a normative act of the National Bank. The law draws a strict boundary here: it is impermissible to provide virtual asset services through a person that is not a provider registered with the National Bank or a representative of the financial sector empowered to do so by the legislation regulating its own activity. Moreover, a provider is prohibited from carrying out any activity other than the provision of the services, the ancillary activity necessary for them and the exchange of its own virtual asset — registration is thus granted in exchange for specialisation.
What the National Bank examines at entry and afterwards
The National Bank's supervision includes registration and its cancellation, inspection and regulation, the issuance of written instructions, and the imposition of additional requirements, restrictions and sanctions. It matters what information the Bank may demand: the sources of the origin of capital, and the direct and beneficial owners of a significant share, including the origin of property or monetary funds. The Bank may, by a legal act, establish requirements for the holder of a significant share and define the fitness criteria for administrators — so preparing for entry means not only filling in forms but making the ownership structure and the management team transparent.
After registration the regulation continues: the Bank may verify compliance with legislation or with its own requirements on site or remotely, audit accounting documents and reporting components, and receive any information, including confidential information. It may set a minimum supervisory capital and standards for the storage of assets and the management of risks, including operational and cyber-security risks, and require a general risk-management framework and effective internal control. Where a provider, or a relationship with one, creates heightened money-laundering or terrorism-financing risk, a risk of circumventing international financial sanctions, or impedes traceability or supervision, the Bank may suspend or restrict the activity. For violations it may impose a sanction, including a monetary fine, which is transferred to the state budget. The Bank also determines the accompanying information for transfers, the rules of regulation, the liquidation procedure, may exempt a provider from certain norms, and issues acts for the protection of consumers.
The institutional basis: why the National Bank
This regime is not accidental. Under the organic law on the National Bank, the Bank's main task is to ensure price stability, and it must ensure the stability and transparency of the financial system. Among its functions is directly the supervision of the financial sector, and it is from this function that the supervision of virtual asset providers flows. Institutionally, the rules are set by the Bank's council: among its powers are defining the main directions of the supervision and regulation of the financial sector's activity and issuing legal acts. The practical requirements you prepare against are therefore changed and renewed by the council's acts — tracking the current state of the regulation is a provider's permanent task.
How we can help
We help plan the preparatory route: we determine whether your business model falls within the definition of a provider, explain the requirements towards the ownership structure and administrators, assist in preparing the registration package, and support subsequent interaction with the supervisor. Contact us — we will assess your project under the current norms.
The full supervisory toolkit
Beyond inspection, the law gives the National Bank a full toolkit within its supervision: the issuance of written instructions in day-to-day regulation; the power to suspend or restrict particular types of operations, including by types of virtual asset; the restriction of business relations with other providers where they create undesirable risk; and the determination of the content of accompanying information connected with transfers. The same block includes the power to issue legal acts for the protection of consumers and an exemption mechanism — for a definite term or conditionally — allowing the Bank to define flexibly which norms extend to which provider. The power to determine the liquidation procedure means that exit from the market is also under the control of the regulator. Taken together, these instruments make supervision continuous rather than a one-off entry review.
The preparatory stages in practice
Building on the registration requirements, preparation spans several directions. First, establishing and documenting the ownership structure and the origin of capital, since the Bank demands information on the owners and beneficiaries of a significant share directly. Second, preparing the management team against the criteria the Bank sets for administrators. Third, building the internal system of asset storage and risk management, including operational and cyber-security risks, and planning sufficient capital. Fourth, preparing the transfer processes for the recording of accompanying information. Each of these directions generates concrete documentary and technical tasks, which is precisely why preparation calls for qualified cooperation.