One warning up front: this is not a formality and not the equivalent of a quick company registration. The entry barrier is high, and this guide sets it out honestly.
Who needs VASP status
Registration applies to anyone providing intermediary services with virtual assets. Under National Bank rules the perimeter covers:
- Crypto exchanges.
- Providers exchanging crypto for fiat currency and back.
- Operators of payment and settlement transactions in virtual assets.
- Other intermediaries dealing in virtual assets.
Holding crypto personally, mining for yourself or occasional private transactions do not fall under the intermediary regime. What is regulated is providing services to third parties.
Requirements on legal form and presence
This is where the first hard constraints appear:
- Only an LLC or a JSC registered in Georgia is permitted.
- Operating as an individual entrepreneur in virtual assets is prohibited.
- The head office must be located in Georgia.
- The responsible officer must be present in Georgia at least 14 days per month.
- Registration with the National Bank is required before operations begin.
The rule on sole traders rules out private traders and small exchange projects. If you are weighing legal forms for a different business, the comparison is in LLC, sole trader or JSC in Georgia.
The 14 days a month rule is a real obligation
The responsible officer requirement is routinely underestimated. This is not a nominee director on paper but a person physically in the country for half the working month who answers for compliance. It is a direct cost line and a hiring problem.
Operational restrictions
NBG rules prohibit several practices that are common on unregulated markets:
- Providing services through agents, meaning third parties acting on the VASP's behalf, is prohibited.
- Lending in virtual assets is prohibited.
- Fees may be charged in Georgian lari or in the virtual assets that are the subject of the service.
The ban on the agency model closes off rapid scaling through a partner network. The business has to serve clients itself.
Capital requirements
For ordinary VASP activity no dedicated minimum capital is set for an LLC. For a JSC the general rule applies: minimum subscribed capital of GEL 100,000, with at least 25% paid in at incorporation.
A separate regime governs stablecoin issuance. There the capital requirement is at least GEL 500,000, and those funds must be legally and operationally separated from the reserves backing holders' claims.
No formal minimum does not mean a cheap entry
Capital is only one line. Real cost is driven by compliance infrastructure, legal support, a salaried responsible officer and banking.
The registration process
The process runs in sequence:
- Register an LLC or JSC in Georgia.
- Open a corporate bank account.
- Prepare the document package to National Bank requirements.
- File the application with the National Bank of Georgia.
- Review, during which the regulator may request further material.
The exact document list depends on the type of activity. An application for an exchange and one for currency conversion services are assembled differently.
Treat the bank account as its own project: banks scrutinise crypto businesses harder than ordinary companies. Practical points are collected in Opening a corporate account in Georgia.
Source note
> Registration with the National Bank of Georgia is mandatory. Operating as an individual entrepreneur in virtual assets is prohibited. The responsible officer must be present in Georgia at least 14 days per month.
Source: VASP licence in Georgia, Legalese
An honest look at the entry barrier
Georgia is often described as an easy jurisdiction for crypto business. As of 2026 that description is out of date: since the NBG regime came in, the threshold has risen noticeably. What to weigh before starting:
- The regulator reviews applications on the merits and may request additional material. Timelines depend on the quality of the package and NBG workload.
- Banking remains the bottleneck. A refusal to open an account blocks the whole project, and there are few alternatives on the market.
- Compliance is a running cost: AML and KYC procedures, reporting, internal controls.
- The ban on agency models and on lending in virtual assets rules out some business models.
- The in country presence requirement for the responsible officer creates permanent operating cost.
If the business model cannot carry those conditions economically, VASP registration will not fix it. Sometimes the right answer is a different activity perimeter or a different licence, such as a payment institution licence.
Frequently asked questions
Can VASP status be obtained by an individual entrepreneur?
No. National Bank rules permit only an LLC or a joint stock company registered in Georgia. Operating as an individual entrepreneur in virtual assets is prohibited, so incorporating a legal entity is always the first step.
Do I need registration if I only trade crypto with my own funds?
No. The regime covers providing services to third parties: exchange, custody, arranging settlements and other intermediation. Trading on your own account and simply holding assets do not trigger the VASP registration requirement.
What is the minimum capital for a VASP?
No dedicated minimum capital is set for an LLC carrying out VASP activity. For a joint stock company the general rule of GEL 100,000 applies, with at least 25% paid at incorporation. Stablecoin issuance carries a separate threshold of at least GEL 500,000.
How long does the process take?
There is no single fixed term. The National Bank reviews applications on the merits and may request further documents, which extends the timeline. It is realistic to plan for several months including incorporation and opening the bank account.
Can services be delivered through agents or partners?
No. The rules expressly prohibit providing services through agents, meaning third parties acting on behalf of the provider. Clients must be served directly, which rules out scaling through a partner network.
How Legalese handles this
We start with an assessment rather than a filing: whether your model meets the VASP definition, whether it can carry the presence and compliance requirements, and whether there is a realistic banking route. If the answer is no, it is more useful to say so before you spend.
If the project clears that check, we incorporate the entity, support the corporate account opening, prepare the package to National Bank requirements and handle communication with the regulator, including responses to follow up requests.
The scope of work is on the VASP licence in Georgia page. If the company does not exist yet, we begin with LLC incorporation.
Key points
- VASP registration with the National Bank of Georgia is mandatory for exchanges, exchange offices and other intermediaries in virtual assets.
- Only an LLC or a JSC qualifies. Operating as a sole trader in this field is prohibited.
- The head office must be in Georgia and the responsible officer must spend at least 14 days a month in the country.
- Agency distribution and lending in virtual assets are prohibited.
- No minimum capital is set for an LLC, a JSC needs GEL 100,000, and stablecoin issuance needs at least GEL 500,000.
- The hard part is rarely the application itself: it is banking and the running cost of compliance.
To check whether your project clears the requirements, book a free consultation.