VASP License in Georgia

Suitable for companies exchanging convertible virtual assets for fiat currencies, foreign currencies, other virtual assets or financial instruments.

Suitable for businesses that administer a convertible virtual asset trading platform under the supervision of the National Bank of Georgia.

Suitable for companies facilitating the transfer of convertible virtual assets from client wallets to designated third-party wallets.

Suitable for businesses that store, safeguard, or administer virtual assets, or provide instruments that enable clients to control virtual assets.

Suitable for companies planning to conduct an ICO of convertible virtual assets or provide services related to ICO preparation and execution.

Suitable for companies managing portfolios of convertible virtual assets, excluding collective portfolio management.

Suitable for businesses providing lending of convertible virtual assets, provided that such lending is not offered to physical persons.

Suitable for foreign-owned crypto businesses that want to establish a regulated Georgian entity for operations, partnerships, banking readiness or international expansion.

Suitable for projects that need a practical entry point into regulated crypto activity with company formation, AML/KYC policies, VASP application support and operational setup.

The applicant must be established as a Georgian legal entity before applying for VASP registration.

A Limited Liability Company can apply for a VASP License in Georgia, and there is no minimum share capital requirement for an LLC.

A Joint Stock Company may also apply, but it must have a minimum share capital of GEL 100,000, with at least 25% paid upon incorporation.

The company must maintain its head office in Georgia, where the actual management of the VASP’s activities is carried out.

If the company has a single shareholder who also acts as a director, it must appoint at least two directors.

A director may not simultaneously act as a director of another VASP, unless both entities belong to the same corporate group.

Directors, administrators and holders of a significant shareholding of 10% or more must satisfy the applicable Fit & Proper requirements.

At least one authorized representative of the VASP must be physically present in Georgia for at least 14 calendar days per month.

Foreign founders can structure a VASP project in Georgia through a local legal entity, provided that corporate, governance, Fit & Proper, compliance and local presence requirements are met.

Directors must meet the applicable governance and Fit & Proper requirements. If the company has one shareholder who also acts as director, at least two directors must be appointed.

A director cannot simultaneously serve as a director of another VASP, unless both VASPs belong to the same corporate group.

Administrators of the VASP must satisfy the applicable Fit & Proper requirements and be suitable for their role in the company’s management and operations.

Holders of a significant shareholding of 10% or more must pass Fit & Proper checks.

At least one authorized representative of the VASP must be physically present in Georgia for at least 14 calendar days per month.

The company must appoint a dedicated Compliance Officer responsible for overseeing and ensuring the effectiveness of the compliance framework.

Before starting operations, the VASP must establish a compliance control system proportionate to its business model, risks and regulated activities.

The company must implement AML/CFT measures in accordance with the Law of Georgia on Facilitating the Prevention of Money Laundering and Financing of Terrorism.

Customer due diligence and preventive measures must be applied to one-time transactions involving convertible virtual assets exceeding USD 1,000, EUR 1,000 or GEL 3,000.

Before commencing operations, the VASP must implement an electronic monitoring system proportionate to the nature, scale and ML/TF risks of the business.

The monitoring system must enable automated detection of suspicious and unusual transactions, including activity involving distributed ledger technology.

Documents confirming registration of the Georgian legal entity, including company formation documents and corporate details.

A clear description of the proposed virtual asset services, including exchange, transfer, custody, trading platform administration, ICO-related, management or lending activities.

Information on the company’s organizational structure, directors, administrators, authorized representatives and internal management model.

Documents identifying shareholders and holders of significant shareholdings of 10% or more, including information required for Fit & Proper assessment.

Supporting documents for directors, administrators and significant shareholders to confirm their suitability, reputation and compliance with regulatory expectations.

AML/CFT documentation prepared in accordance with Georgian anti-money laundering and counter-terrorist financing requirements.

Documents confirming that the company has established a compliance control system before starting virtual asset operations.

Information on the dedicated Compliance Officer responsible for overseeing and ensuring the effectiveness of the compliance framework.

Procedures for applying customer due diligence and preventive measures, including for one-time transactions above the relevant thresholds.

Documents describing the electronic monitoring system used to detect suspicious and unusual transactions, including activities involving distributed ledger technology.

Information on KYC/KYT solutions, internal compliance processes, governance implementation, and corporate banking or payment arrangements where applicable.

A business plan and other supporting materials explaining how the company will operate, manage risks and comply with Georgian VASP requirements.

The official registration fee for obtaining a VASP License in Georgia is GEL 5,000, approximately €1,700.

There is no minimum share capital requirement for a Georgian Limited Liability Company applying for VASP registration.

If the applicant is structured as a Joint Stock Company, the minimum share capital is GEL 100,000.

For a Joint Stock Company, at least 25% of the GEL 100,000 share capital must be paid upon incorporation.

According to the provided framework, there is no annual license renewal fee in Georgia.

The standard corporate income tax rate in Georgia is 15%, generally applied under the distributed profit taxation model.

The standard dividend withholding tax rate is 5%.

The provided framework indicates no VAT for virtual asset-related activities.

In addition to the registration fee, applicants should budget for company formation, legal documentation, AML/KYC policies, compliance setup, KYC/KYT integration, local director or representative support, and banking or payment arrangements where applicable.

Before commencing operations, the VASP must have a compliance control system, AML/CFT procedures, and an electronic monitoring system proportionate to the nature and scale of its business.

Manimama reviews the proposed virtual asset business model, including the type of services, transaction flows, client structure, and applicable scope of VASP activity.

We determine the applicable regulatory requirements and define the optimal licensing strategy under the Georgian VASP framework.

The proposed company name is verified, incorporation documents are prepared, and the Georgian legal entity required for VASP registration is established.

Corporate, regulatory and supporting documents are prepared for submission to the National Bank of Georgia.

AML/CFT policies, business description, governance documents, compliance procedures and other required materials are prepared or reviewed.

The VASP registration application is submitted to the National Bank of Georgia together with the required documentation.

Manimama coordinates with the regulator during the review process and assists with responses to additional information requests.

We support implementation of the operational infrastructure required to commence virtual asset activities, including KYC/KYT solutions, internal compliance processes, governance setup, and corporate banking or payment arrangements where applicable.

Once the regulator completes the review and the registration is approved, the company can proceed with the regulated virtual asset activities within the approved scope.

After registration, Manimama assists with ongoing regulatory obligations, compliance monitoring, internal policy updates, regulatory reporting, and legal support.

At this stage, the proposed virtual asset activities, transaction flows, client structure, platform functionality and applicable regulatory requirements are reviewed.

The proposed company name is verified, incorporation documents are prepared, and the Georgian legal entity required for VASP registration is established.

Corporate, regulatory and compliance documentation is prepared, including AML/CFT policies, business description, governance materials and supporting documents required for VASP registration.

The VASP registration application is submitted to the National Bank of Georgia together with the required documents.

The National Bank of Georgia reviews the application and may request additional information or clarifications before completing registration.

In parallel with, or after, submission, the company prepares the infrastructure required to start operations, including KYC/KYT solutions, compliance processes, governance implementation, and corporate banking or payment arrangements where applicable.

After registration, the company should be ready to maintain ongoing regulatory obligations, compliance monitoring, internal policy updates and regulatory reporting.

The standard corporate income tax rate in Georgia is 15%.

Georgia applies a distributed profit taxation model, often referred to as the Estonian model. Corporate income tax is generally triggered when profits are distributed or when certain transactions are treated as equivalent to profit distribution.

If a Georgian legal entity reinvests profits and does not distribute them as dividends, corporate income tax may generally be deferred.

The standard dividend withholding tax rate in Georgia is 5%.

The provided framework indicates no VAT for virtual asset-related activities.

A company may consider a Free Industrial Zone structure if tax benefits are important, subject to confirming that the planned virtual asset activity is compatible with FIZ rules and NBG VASP registration requirements.

After registration, the VASP remains supervised by the National Bank of Georgia and must continue meeting regulatory expectations.

The company must maintain AML/CFT measures in accordance with Georgian anti-money laundering and counter-terrorist financing requirements.

The VASP must maintain a dedicated Compliance Officer responsible for overseeing the effectiveness of the compliance framework.

Customer due diligence and preventive measures must be applied to one-time transactions involving convertible virtual assets exceeding USD 1,000, EUR 1,000 or GEL 3,000.

The company must operate an electronic monitoring system proportionate to the nature, scale and ML/TF risks of its business.

The monitoring system must support automated detection of suspicious and unusual transactions, including activity involving distributed ledger technology.

The company should maintain proper directors, administrators, authorized representatives, and Fit & Proper-compliant key persons.

At least one authorized representative of the VASP must remain physically present in Georgia for at least 14 calendar days per month.

The VASP should maintain internal policy updates, compliance monitoring, regulatory reporting and legal support to ensure continued compliance with the Georgian VASP framework.

The applicant must clearly define which virtual asset services it will provide: exchange, transfer, custody, platform administration, ICO-related services, management or lending.

A Georgian VASP may provide lending of convertible virtual assets, but lending to physical persons is not allowed.

The applicant must operate through a Georgian legal entity, either an LLC or JSC, before applying for VASP registration.

The company must have its head office in Georgia, where the actual management of VASP activities is carried out.

If a company has a single shareholder who also serves as director, it must appoint at least two directors. This should be planned before incorporation or application submission.

A director may not simultaneously serve as director of another VASP unless both entities belong to the same corporate group.

Directors, administrators and holders of significant shareholding of 10% or more must satisfy Fit & Proper requirements.

At least one authorized representative of the VASP must be physically present in Georgia for at least 14 calendar days per month.

The company must establish a compliance control system before commencing operations and appoint a dedicated Compliance Officer.

The VASP must implement AML/CFT measures and apply customer due diligence to one-time transactions above USD 1,000, EUR 1,000 or GEL 3,000.

Before starting operations, the VASP must implement an electronic monitoring system capable of detecting suspicious and unusual transactions, including DLT-related activity.

The project should prepare KYC/KYT solutions, corporate banking or payment arrangements where applicable, internal compliance processes, and governance implementation.

If the company considers a Free Industrial Zone structure for tax benefits, it must first confirm that the intended virtual asset activity is compatible with FIZ rules and NBG VASP registration requirements.