Non-passporting licence routeVASP licence / registrationNo passporting

VASP Licence in Georgia

Georgia is a fast non-EU VASP licence and registration-style route for teams that want a lighter setup under the National Bank of Georgia, while accepting no EU passporting and a separate activity, banking and scope review.

Processing time
From 2 months
Service price
22 700 EUR
Required share capital
Not required
State fee
No state fee
Annual supervision fee
No annual fee
Banking difficulty
Medium
RegulatorNational Bank of Georgia (NBG)
Market access
No passporting

CSV-only page: National Bank of Georgia scope, process and activity permissions require legal review before client use.

Regulatory status should be confirmed by local counsel before relying on this route.

What is the Georgia VASP route?

Georgia is positioned as a non-EU VASP licence and registration-style route supervised by the National Bank of Georgia. It can be attractive where speed, low substance and simple maintenance matter, but it is not an EU passporting authorisation or a premium regulatory brand.

VASP
Jurisdiction
Georgia
Regulator
National Bank of Georgia (NBG)
Regime
VASP
Legal basis
Best fit: fast non-EU VASP registration-style setup.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

VASP activity scope in Georgia

Treat the Georgia route as activity-specific. Exchange, brokerage, wallet, custody, payment, staking and advisory models can create different permission, compliance and banking questions, so the file should not describe one generic VASP approval as covering every virtual asset service.

  • Exchange

    Licensed

    Exchange operations fit within the permitted activities of this route.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Licensed

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Not covered

    EU passporting not available from this route.

  • Startups

    Licensed

    Lower complexity makes this accessible for smaller teams.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Operating model and application file

The CSV snapshot shows low substance: no required share capital, local staff, physical office or audit. That lowers setup friction, but the application still needs a coherent operating model, compliance controls and a narrow description of actual services.

  • Define the exact activity set instead of using a broad all-services VASP narrative.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Prepare AML, sanctions, onboarding, transaction monitoring and outsourcing materials.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Connect banking and PSP requirements to the proposed fiat flows, customer geography and token policy.

    Operational control area that should be covered in the applicant's governance and compliance model.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Fast non-EU route vs reputation-led alternatives

Georgia's commercial tradeoff is speed and low maintenance against medium regulatory reputation and no passporting. It can suit early non-EU operations, but reputation-sensitive exchange, custody or institutional projects may need a stronger jurisdiction.

  • Regulatory reputation

    Onshore (this jurisdiction)

    Medium

    Offshore comparison

    Lower recognition

  • Banking access

    Onshore (this jurisdiction)

    Challenging

    Offshore comparison

    Often restricted

  • Compliance burden

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Variable

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

When Georgia VASP is not suitable

Georgia is weak where the project needs EU passporting, a premium regulatory image, broad institutional acceptance or a claim that one permission covers every virtual asset activity.

  • The business needs EU/EEA passporting or MiCA positioning.

  • The main sales point is premium regulatory reputation.

  • The activity includes custody, staking, DeFi, yield or payment rails that have not been separately reviewed.

  • The launch plan depends on guaranteed bank or PSP onboarding.

Consider instead

  • Malta (MiCA) MICA — EU/EEA passporting and stronger regulatory perception
  • Dubai (VARA) VASP — Higher-reputation VASP route for UAE/MENA positioning
  • Canada (MSB) MSB — Fast registration-style route with strong market recognition

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Suitable

Exchange operations fit within the permitted activities of this route.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Suitable

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Not suitable

EU passporting not available from this route.

Startups
Suitable

Lower complexity makes this accessible for smaller teams.

Not sure if your model fits? Request a licensing assessment

Business model fit — Georgia

Assess how well this route covers your planned activities.

Fit score

Good fit
2/6
Partial fit
4/6
Poor fit
0/6

Georgia covers some but not all planned activities

Some activities need additional licensing or separate review before committing.

Is Georgia VASP authorisation right for your project?

Best for

  • Fast non-EU VASP registration

Not suitable for

  • EU passporting and premium regulatory reputation

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalNot required
Not required
Local staffNot required
Not required
Physical officeNot required
Not required
AuditNot required
Not required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local substance and maintenance

Georgia is light on formal substance in the CSV snapshot: local staff, physical office, audit and share capital are listed as not required. Even so, banks, PSPs and counterparties may still ask for evidence of management, compliance ownership and real operating controls.

Local staff

Not required

Not required

Review local person requirements before setup.

Physical office

Not required

Not required

Physical office is not a stated requirement for this route.

Audit

Not required

Not required

Audit is not a stated requirement; internal controls still apply.

Planning notes

  • Do not present low substance as no governance or no compliance work.
  • Keep named responsibility for AML, risk, outsourcing and customer onboarding.
  • Budget for document maintenance even where no annual supervision fee is listed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
22 700 EUR EURFixed
State fee
No state feeFrom
Annual supervision feeRecurring annual cost after authorisation.
No annual feeNot applicable
Required share capitalMust be held, not an expenditure.
Not requiredNot applicable
Medium ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Georgia

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€22,700

Summary

One-off costs
€22,700
Annual (year 1)
€0
Total year 1
€22,700

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Georgia — From 2 months.

Total timelineFrom 2 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Georgia

    2–6 weeks

    Establish legal entity with required governance structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to National Bank of Georgia

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 2 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP feasibility

Georgia is marked medium for both banking difficulty and PSP availability. A VASP registration-style route can help structure the file, but account opening still depends on activity scope, fiat flows, client geography, AML controls and the bank's crypto appetite.

Banking difficulty
Medium

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare a banking pack before treating the route as commercially ready.
  • Explain fiat flow, source of funds, sanctions exposure, token policy and transaction monitoring.
  • Consider higher-reputation alternatives if the model depends on institutional banking or custody counterparties.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 9 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Regulator profile

Regulatory authority · Georgia

National Bank of Georgia (NBG)

Regulatory reputation
Medium

Moderate reputation; assess banking and partner acceptance case by case.

Setup complexity
Medium

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Risk assessment

Main risk dimensions for the Georgia route.

Regulatory risk
Medium

Route risk rating — regulatory risk: Medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
Medium

Route risk rating — banking difficulty: Medium. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
Low

Route risk rating — setup complexity: Low.

Maintenance cost
Low

Route risk rating — maintenance cost: Low. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
Medium

Route risk rating — regulatory reputation: Medium.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Georgia vs other VASP routes

Use Georgia as a fast non-EU benchmark. Compare Malta for EU passporting, Dubai for stronger VASP perception and Canada MSB for another fast registration-style route with different scope limits.

Current

Georgia

VASP

Price
22 700 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
Medium

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ EU/EEA passporting and stronger regulatory perception

− Higher substance and authorisation workload

View route

Dubai (VARA)

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Higher-reputation VASP route for UAE/MENA positioning

− Higher supervision cost and local operating burden

View route

Canada (MSB)

MSB

Price
20 600 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Fast registration-style route with strong market recognition

− MSB registration is not a broad crypto licence

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Georgia vs other VASP jurisdictions

Compare key parameters across VASP-regulated jurisdictions.

Sort by:
GeorgiaCurrent
Price22 700 EUR
TimelineFrom 2 months
BankingMedium
ReputationMedium
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Dubai
Price22 300 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Canada
Price20 600 EUR
TimelineFrom 2 months
BankingMedium
ReputationHigh

Check your readiness for Georgia VASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. The activity scope must be reviewed separately. Exchange, brokerage, wallet, custody, payment, staking, DeFi and advisory models can create different permission and compliance issues.

Yes, it can be suitable where the project wants a fast non-EU VASP registration-style route with low formal substance. It still needs activity, compliance and banking review.

No. Georgia is a no-passporting route. EU/EEA market access should be assessed through MiCA/CASP or another appropriate EU route.

Prepare the exact activity scope, AML and sanctions controls, customer onboarding flow, transaction monitoring, outsourcing model, token policy and banking or PSP feasibility package.

The CSV snapshot lists local staff and physical office as not required. That does not remove the need to show who controls compliance, operations and risk in practice.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

Your dedicated specialists

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    Enrico

  • Rein Tammik

    Rein

  • Jurata Žukaitė

    Jurata

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    Andrej

  • Marta Värna

    Marta

  • Katrin Lepik

    Katrin

  • Inga Stankavičiūtė

    Inga

Request a Georgia VASP assessment

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