Crypto Licensing

Georgia Crypto Licence

One registration with the National Bank, no capital lock, and a statutory 60-day decision window. We prepare the file and see it through.

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Why Georgia for Your Crypto Licence

Georgia gives you a regulated VASP authorisation at one of the lowest entry costs in the European neighbourhood: a single registration with the National Bank of Georgia, no statutory minimum capital, a flat GEL 5,000 state fee paid once, and a statutory 60-day decision window. The regime is anchored in the Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism, whose VASP amendments took effect on 1 January 2023, replacing a period in which crypto activity ran largely through Free Industrial Zones with no dedicated conduct supervisor. We deliver authorisation here as a serviced jurisdiction.

Expert Comment

Georgia sets no statutory VASP capital floor, but the National Bank assesses financial soundness case-by-case where you hold client assets or pre-fund liquidity; for any realistic custody or exchange model, expect the NBG to demand credible proof of adequate capitalisation, making the “no floor” theoretical rather than operational — we structure your capitalisation upfront to clear this with a single filing.

Daniel Tomberg CEO & Senior Partner, Tomberg & Partners
The short version: Georgia is the right call for cost-sensitive crypto and fintech operators whose target markets are CIS, the Caucasus, Turkey and MENA, and who want a fast, low-fee authorisation without a capital lock. It is not the route for founders whose primary market is EU retail, where MiCA CASP authorisation in an EU member state remains the only path to a passport. We deliver both, so we will tell you straight which one fits.

Low entry, no capital floor. Georgia sets no VASP-specific minimum capital, the registration fee is a single GEL 5,000 charge rather than an annual levy, and a Georgian LLC can be formed with nominal share capital. For early-stage operators and over-the-counter desks that cannot justify the six-figure deposits demanded by Dubai’s VARA or the activity-specific floors of Kazakhstan’s AIFC, it is one of the cheapest credible entry points in the region. The trade-off is no EU recognition and a thinner supervisory track record than Tier-1 regulators, which we weigh with you before we file.

A genuinely favourable tax position. Georgia operates an Estonian-style corporate tax model: profits are taxed at 15% only when distributed, with a 5% withholding tax on dividends. Financial operations by VASPs, including crypto-to-fiat exchange, are exempt from value-added tax (VAT) without the right to deduct input VAT, and individuals pay 0% on crypto gains under a 2019 Public Decision of the Ministry of Finance. Retained corporate profit and personal trading gains are lightly taxed; we structure the entity so the VAT exemption-without-deduction, a real cost for capital-intensive operations, is priced in from the outset.

Speed and remote formation. A Georgian LLC incorporates in roughly five to seven business days, and the process is largely document-driven, so most founders never relocate to Tbilisi. Georgia’s position at the crossroads of the South Caucasus, with strong links to Turkey, Azerbaijan, Armenia and the wider CIS, gives operators concentrated in those markets a recognised regional footing at low cost. A Georgia VASP cannot passport into the EU single market, so we treat it as a regional base, not a European one, and say so plainly when an EU route would serve you better.

Which Business Models Suit Georgia

Georgia fits operators who want a low-cost, fast-to-obtain authorisation for markets outside the EU passport. Before we file, we confirm your model maps cleanly onto the seven regulated activities and that Georgia genuinely serves your plan rather than an EU jurisdiction.

  • Exchange desks and bureau-style operators. The exchange activity covers crypto-to-fiat conversion including self-service kiosks, the natural home for over-the-counter desks and Georgia’s sizeable physical crypto-exchange-office sector.
  • Custody and wallet providers. The safekeeping and administration activity authorises holding clients’ assets and private keys, with no capital floor to lock up before launch.
  • CIS, Caucasus, Turkey and MENA-facing operators. Georgia gives a recognised regional footing at low cost for operators whose client base sits outside the EU.
  • Cost-conscious and early-stage founders. No statutory capital floor and a single GEL 5,000 state fee keep both the entry and ongoing run-rate low, which suits operators testing a model before scaling into a higher-tier regime.
  • × EU-retail operations. A Georgia authorisation confers no passport. If your primary market is EU retail, we deliver MiCA CASP authorisation in Lithuania, Cyprus or Malta instead. We will tell you straight.
  • × Tokenised securities or RWA. Georgia’s VASP regime excludes tokens that represent securities; those follow the Securities Market Law. Where your model needs it, we scope the securities route or EU fund licensing alongside crypto permissions.
  • × Institutional counterparties weighting regulator pedigree. The NBG VASP regime dates only from 2023. Where counterparties demand a long enforcement history, a Tier-1 regulator may suit better, and we deliver several.

What We Do for You

We deliver the authorisation, we do not hand you a shortlist and step back. From the first scoping call to the day your entity is entered on the NBG public VASP register, you deal with one accountable firm and our in-country specialists. We file the work and we stand behind it.

  • Form your Georgian company. We incorporate your Georgian LLC or JSC through the National Agency of Public Registry, typically in five to seven business days and remotely by power of attorney, establish the head office in Georgia, and appoint the administrators the regime requires.
  • Build the AML/CFT pack. We draft every policy bespoke to your model and to the Georgian statutes: customer due diligence, ongoing monitoring, sanctions screening, transaction monitoring, record-keeping and the reporting interface to the Financial Monitoring Service. Generic templates pulled from offshore libraries are recognised on sight and trigger deficiency notices, so we do not use them.
  • Prepare the people and the proof. We assemble fit-and-proper files for every administrator and significant or beneficial owner, including the criminal-record clearance, source-of-funds and financial-standing evidence that decides most NBG information requests.
  • Write the business plan. We produce the three-year business plan with budgeting projections the registration rule demands, mapped to the specific activities you intend to provide.
  • File and manage the application. We submit the registration form, the list of activities, owner information, the compliance declaration and the policy set to the National Bank of Georgia, pay the GEL 5,000 fee, and deal with the regulator’s questions directly through to a decision within the 60-day statutory window.
  • Scope banking and ongoing compliance. We structure the entity so it can bank cleanly and prepare the source-of-funds dossier banks expect, then set up the AML/CFT reporting cycle and the notification obligations so the authorisation stays in good standing.

We scope and quote each engagement to your specific model and activity mix. Tell us what you are building and we will map your route to authorisation and price it.

Regulatory Framework

Georgia regulates virtual asset services through a single statutory registration regime supervised by the National Bank of Georgia. The legal basis sits in the Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism, whose VASP amendments took effect on 1 January 2023 and brought virtual asset service providers within the list of accountable persons. The operative instrument is the NBG Rule on Virtual Asset Service Provider Registration, effective from 1 July 2023.

Definition: Georgia VASP

A Virtual Asset Service Provider (VASP) in Georgia is a person registered with the National Bank of Georgia to provide, for the benefit of another person, one or more of seven regulated activities (set out below). The designation tracks the FATF Virtual Asset Service Provider definition, and a separate NBG rule governs the initial coin offering of a stablecoin.

What the regime covers, and what it does not

Two regimes bind a Georgia VASP. The NBG VASP Registration Rule is the conduct and registration instrument for all seven activities, with the NBG as supervisor and registrar; the AML/CFT Law applies to every VASP, with customer due diligence triggered at one-time transactions of USD 1,000, EUR 1,000 or GEL 3,000 and reporting to the Financial Monitoring Service. Several adjacent regimes do not authorise virtual asset services: the Free Industrial Zone and Virtual Zone Person regimes are tax statuses only, so a zone company providing a regulated activity must still register with the NBG, and mining and validation sit outside the perimeter entirely. Before 2023 the sector grew up around these zones with no dedicated conduct supervisor; the VASP regime arrived through AML amendments in force from 1 January 2023 in line with FATF Recommendation 15 and Georgia’s MONEYVAL commitments, with existing providers given a 90-day window to file. As of June 2026, Georgia has no MiCA-style market-conduct or stablecoin-reserve prudential regime beyond the NBG rules. We classify your activities against these lines before filing.

The Seven Regulated Activities

Georgia’s VASP framework defines seven regulated activities under the NBG Registration Rule. A single authorisation can cover one or several, declared in the application; there are no tiered licence classes and no token-type sub-categories. The activities track the FATF VASP perimeter and broadly correspond to MiCA’s crypto-asset services, though Georgia operates a registration rather than a passportable authorisation. We confirm which activities your model needs and file for exactly those.

  • Exchange between virtual assets and fiat or financial instruments. Crypto-to-fiat conversion, including via self-service kiosks; the most common activity for over-the-counter desks and bureau-style operators.
  • Transfer of virtual assets. Moving virtual assets between addresses or accounts for a client.
  • Safekeeping and administration (custody). Holding and safeguarding clients’ assets, including private-key management.
  • Portfolio management. Discretionary or advisory management of a client’s virtual-asset portfolio.
  • Administration of a trading platform. Operating a venue matching buyers and sellers, the equivalent of an exchange.
  • Lending of virtual assets. Extending or arranging credit denominated in or collateralised by virtual assets.
  • Initial coin offering. Issuing or arranging issuance to the public; a stablecoin ICO is governed by a separate NBG rule.

What falls outside the perimeter

Mining and validation are not VASP activities; pure software and IT development that provides no regulated service may instead qualify for Virtual Zone Person tax status; and personal use of digital assets, including trading on one’s own account or holding crypto as treasury, stays outside the perimeter where no regulated service is offered to others. The authorisation applies regardless of where clients sit but confers no rights outside Georgia: it does not authorise services to EU residents and carries no passport. The NBG can refuse, suspend or cancel an authorisation for failed fit-and-proper criteria, inaccurate information, or breach of the head-office, software-system or AML/CFT requirements, which is why we build the application to clear all four on the first pass.

What the National Bank of Georgia Requires

A Georgian VASP needs an LLC or JSC with a head office in Georgia, fit-and-proper administrators and owners, a three-year business plan and a bespoke AML/CFT framework. The National Bank of Georgia assesses applications against fit-and-proper, head-office, software-system and AML/CFT criteria rather than a capital floor: there is no VASP-specific minimum capital, though the NBG evaluates financial soundness where the model involves holding client assets or pre-funding liquidity. The binding constraint is documentation quality, not the rules themselves; applications stall on weak source-of-funds evidence and recycled templates, not on the decision clock. We prepare each of these to the standard that clears.

Registration Requirements at a Glance

RequirementStandardNotes
Eligible entityGeorgian LLC or JSCForeign legal entities cannot hold the registration directly
Minimum capitalNone (statutory)NBG assesses financial soundness where client assets are held
State feeGEL 5,000 ≈ $1,850Single registration fee; no annual licence fee
Head officeIn GeorgiaBranches, kiosks and software systems declared to NBG
Fit and properAdministrators + significant / beneficial ownersAssessed by NBG on integrity, competence and financial standing
Business planThree-year forecastWith budgeting projections, per the registration rule
AML/CFT frameworkMandatoryCDD trigger: one-time transactions ≥ USD 1,000 / EUR 1,000 / GEL 3,000
NBG decision window60 calendar daysExtendable by a further 60 calendar days

As of June 2026. A limited liability company carries no minimum share capital, whereas a joint-stock company requires GEL 100,000 of authorised capital (25% paid in at incorporation) as a matter of general company law, separate from the VASP perimeter.

Fit-and-proper, local substance and AML/CFT

The rule sets fit-and-proper criteria for the VASP’s administrators and for its direct and indirect significant shareholders, including ultimate beneficial owners: the NBG assesses integrity, competence and financial standing and reviews criminal-record and source-of-funds evidence, which is where most information requests originate and where we put the most preparation. There is no explicit residency test on administrators, but the head-office-in-Georgia requirement and bank-onboarding expectations mean at least one resident director or manager is usually advisable to anchor local substance; foreign-only boards are accepted less readily by Georgian banks. A registered VASP must keep its head office in Georgia and declare its branches, self-service kiosks and software systems, with kiosks falling within the exchange activity. Every VASP is an obliged person under the AML/CFT Law, with the customer-due-diligence trigger at one-time transactions of USD 1,000, EUR 1,000 or GEL 3,000. We assemble the fit-and-proper files, structure the local substance and build the AML/CFT framework to meet each of these.

Application Process and Timeline

The pathway runs from Georgian entity formation through document preparation to a single NBG decision; there is no authorisation-in-principle stage and no capital-deposit condition. Most stages run remotely, and the binding constraint is preparation quality, not the decision clock. A well-prepared single-activity authorisation runs roughly two to four months end-to-end, with the bespoke AML/CFT documentation and the fit-and-proper evidence the time-intensive components, not the NBG decision itself. We run the whole sequence and keep the regulator’s clock moving.

Stage 1 1–2 weeks

We form your Georgian entity

We incorporate your Georgian LLC or JSC through the National Agency of Public Registry, typically in 5–7 business days and remotely by power of attorney, and establish the head office in Georgia. We open the banking conversation in parallel, since it is often the longer-lead item.

Stage 2 4–8 weeks

We build the business plan and AML/CFT pack

We draft the three-year business plan and the bespoke AML/CFT framework: customer due diligence, ongoing monitoring, sanctions screening, record-keeping and the reporting interface to the Financial Monitoring Service. This pack is where the application is won or lost, and it cannot be templated.

Stage 3 1 week

We compile fit-and-proper evidence

We assemble identity, criminal-record clearance, source-of-funds and financial-standing evidence and CVs for every administrator and beneficial owner. Gaps here are a leading cause of NBG information requests, so we close them before filing.

Stage 4 1 week

We file with the NBG

We submit the registration form, the list of activities, owner information, the compliance declaration, the business plan and the AML/CFT policies, and pay the GEL 5,000 fee.

Stage 5 Up to 60 days (+60)

We manage review to a decision

The NBG assesses fit-and-proper, financial soundness, head-office and software-system requirements and AML/CFT robustness. We handle every information request through the 60-day statutory window, extendable by a further 60.

Stage 6 1 week

Authorisation and commencement

On a positive decision your entity is entered on the NBG public VASP register and may commence activity. We set up the notification routine so material changes reach the NBG on time thereafter.

The honest point: the AML/CFT framework must be bespoke to your model and reference the Georgian statutes; generic templates trigger deficiency notices on sight. This is the work we do best, and it is why we file rather than refer. Building the documentation pack and fit-and-proper evidence in parallel with formation, and scoping banking at the same time, is the single biggest timeline saving available, and it is how we run every engagement.

Taxation

Georgia operates an Estonian-style corporate tax model that founders coming from EU jurisdictions find familiar: company profits are taxed at 15% only when distributed, not as they are earned, with a 5% withholding tax on dividends. Financial operations by VASPs, including the exchange of crypto into fiat, are exempt from VAT, but without the right to deduct input VAT. Individuals pay 0% on gains from the supply or exchange of crypto assets, under a 2019 Ministry of Finance Public Decision. We structure your entity to use the reliefs it qualifies for and to price the VAT exemption-without-deduction in correctly.

Tax Table

Tax TypeRateCrypto Application
Corporate Income Tax (standard company)15%On distributed profit only (Estonian-style); 0% on retained profit
Withholding Tax (dividends)5%On distribution to shareholders
Value Added Tax (VASP financial operations)ExemptCrypto-to-fiat exchange VAT-exempt, without input-VAT deduction
Personal Income Tax (individual crypto gains)0%Non-Georgian-source per the 2019 MoF Public Decision
Personal Income Tax (employment income)20%Standard flat rate on Georgian-source salary
Corporate Income Tax (Free Industrial Zone company)0%On qualifying in-zone activity; VASP registration still required
Corporate Income Tax (Virtual Zone Person)0%On exported IT services; not a VASP authorisation
VAT (mining: hash exported abroad)0%Zero-rated; domestic hash between residents is VAT-able
Mining income (individuals)0%Mined assets not treated as taxable income

As of June 2026. Verify against the Georgian Tax Code, the State Revenue Service and the relevant Ministry of Finance public decisions before structuring.

Free zones, mining and reporting

Georgia’s Free Industrial Zones offer 0% corporate income tax, VAT and dividend tax on qualifying in-zone activity, and Virtual Zone Person status grants 0% corporate income tax on exported IT services. Neither authorises virtual asset services: a zone company providing a regulated activity must still register with the NBG, so the tax status sits alongside the authorisation, not instead of it. We treat the two as separate workstreams, since conflating them is a common and costly mistake. On reporting, Georgia participates in the Common Reporting Standard (CRS) but is not in the first wave committed to the OECD Crypto-Asset Reporting Framework (CARF) and is not bound by EU DAC8; we plan for CARF-style reporting to reach Georgia as the timetable broadens.

Ongoing Compliance and AML/CFT

The authorisation is open-ended, but supervision is active and AML/CFT obligations are continuous. The National Bank of Georgia supervises VASPs primarily through the AML/CFT framework, alongside its power to suspend or cancel a registration, and we stay on as your standing compliance partner so the authorisation keeps the standard that won it.

The short version: the work does not stop at authorisation. The ongoing burden is lighter than in tiered-licensing jurisdictions, with no annual prudential capital return, but the AML/CFT and notification duties are live and the NBG is enforcing them. We set up the reporting cycle and run it with you.

Every VASP is an obliged person under the AML/CFT Law and must operate risk-based customer due diligence (triggered at one-time transactions of USD 1,000, EUR 1,000 or GEL 3,000), ongoing transaction monitoring and sanctions screening, suspicious-transaction reporting to the Financial Monitoring Service, and record-keeping, alongside corporate tax filing under the general Tax Code with statutory audit where thresholds apply. Any change to administrators, owners, head office, branches, kiosks or software systems must be notified to the NBG, and adding new activities requires the registration to be updated. The NBG can refuse, suspend or cancel a registration for breach, and in 2025 it publicly required virtual asset firms to demonstrate proof of registration, signalling active enforcement against unregistered operators. There is no DORA-style standalone ICT rulebook in Georgia; technology and cyber expectations sit within the software-system requirements and the AML framework, and we build them into the application and operationalise them afterwards.

Banking

Banking is one of our core services in our engagement, and we scope it alongside the registration rather than after it. Access for Georgia-registered VASPs is available but selective: source-of-funds and beneficial-ownership diligence are the main friction points, and international correspondent access for USD and EUR clearing is more selective again. The natural layer is a Georgian commercial bank holding GEL and major-currency operating accounts, supplemented by licensed EU electronic money institutions for international receivables and cross-border B2B flows.

The short version: an authorisation does not come with a guaranteed banking relationship. We structure your entity so it can bank cleanly and prepare the clear source-of-funds dossier and clean ownership chain that cut both onboarding time and rejection rate. We never name a specific bank or provider in advance, because acceptance turns on your own profile, but a credible operating story is the constant that moves an application forward, and we build it with you.

FATF Status and EU Market Access

Georgia’s AML/CFT framework is assessed by MONEYVAL, the Council of Europe’s FATF-style regional body, rather than the FATF itself. Georgia is not on the FATF grey list (Jurisdictions under Increased Monitoring) or black list (High-Risk Jurisdictions subject to a Call for Action) as of June 2026. MONEYVAL has recorded that Georgia strengthened its risk assessment and VASP regulation while noting further progress is needed; it remains under follow-up procedures, which reflect ongoing reform rather than a status warning.

EU market access

The honest point: a Georgia authorisation does not grant EU market access. MiCA contains no third-country equivalence regime, and Article 61 permits third-country firms to serve EU clients only on genuinely unsolicited contact, an exemption ESMA restricts narrowly: any EU-targeted marketing, EU-language content or geo-targeted advertising voids it. If you need systematic EU access, we deliver a CASP authorisation in an EU member state instead. For the detail, see Reverse Solicitation Under MiCA →.

How Georgia Compares

Georgia’s closest competitors are the EU MiCA jurisdictions an operator weighs against it: Lithuania, Cyprus and Malta inside the EU passport, with Gibraltar and Switzerland as established non-EU centres and Poland as the cautionary case. The key differentiators are EU market access, cost, capital, timeline and tax. Georgia undercuts every one of them on cost and capital, and trails them on EU access and supervisory pedigree. We deliver in each of the serviced jurisdictions below, so the comparison is not theoretical: we will tell you which route fits and file there.

FactorGeorgiaLithuaniaCyprusMaltaGibraltarPolandSwitzerland
Licence TypeNBG VASP authorisationMiCA CASPMiCA CASPMiCA CASPDLT provider licenceMiCA CASPFINMA authorisation / VQF
RegulatorNational Bank of Georgia (NBG)Bank of LithuaniaCySECMFSAGFSCKNFFINMA
Timeline2–4 months4–8 months4–8 months9–18 months6–12 monthsNot operational9–18 months
Min. CapitalNone (statutory)€50,000–€150,000€50,000–€150,000€50,000–€150,000tiered by activity€50,000–€150,000 (proposed)CHF tiered; bank-grade for some models
Corporate Tax15% on distribution only17% / 7% small12.5%~5% effective (refund system)12.5%19% / 9% small~12–21% (canton-dependent)
Local PresenceGeorgian entity + head officeOffice, resident MLRO, directorsOffice, directors, compliance functionOffice, directors, company secretaryOffice, substance, directorsOffice, directors (proposed)Office, substance, qualified management
EU PassportingNo (reverse-solicitation only)YesYesYesNoNo (legislation blocked)No
Best ForCost-sensitive CIS, Caucasus, Turkey, MENA operatorsEU-wide access; fintech ecosystemEU access; English-language; fund overlapEstablished exchanges; English-languageDLT-native operators; non-EU baseCurrently unsuitable (no MiCA route)High-end token and banking-adjacent models

Compare every crypto jurisdiction side by side →

The key difference: Georgia wins on cost, capital and speed; the MiCA jurisdictions win on EU market access. Lithuania, Cyprus and Malta all give a full EU passport at MiCA’s capital minimums, with Cyprus and Malta adding English-language proceedings and Cyprus a strong fund-structuring overlay. Gibraltar and Switzerland are credible non-EU centres with deeper pedigree but heavier cost, capital and timelines, and neither passports into the EU. Poland, after repeated legislative blocks, still has no operational MiCA route. If your market is EU retail, one of the passporting routes is the answer, and we deliver crypto licensing directly in Lithuania, Cyprus and Malta under MiCA. If it is the CIS, Caucasus, Turkey or MENA, Georgia is the sharper, cheaper tool, and we obtain it for you.

Frequently Asked Questions

Working with us
What does Tomberg & Partners actually do for a Georgian VASP authorisation?

We deliver the whole authorisation and stand behind it. We form your Georgian LLC or JSC, appoint the administrators, build the full bespoke AML/CFT pack and three-year business plan, assemble the fit-and-proper evidence, file with the National Bank of Georgia and handle every regulator query through to entry on the public VASP register. We scope banking alongside the registration and set up your ongoing reporting. You deal with one accountable firm and our in-country specialists, not a chain of intermediaries. Contact us and we will scope and quote your case.

How much does it cost?

It depends on your activity mix, structure and complexity, so we scope each engagement and quote it rather than publish a number. The only mandatory state charge is the NBG VASP registration fee of GEL 5,000, paid once rather than annually, and there is no capital deposit to lock up. Because there is no annual licence fee and no statutory capital floor, the ongoing run-rate is materially lower than in tiered-licensing jurisdictions. Tell us what you are building for a quote.

Eligibility and structure
Is there a minimum capital for a Georgia VASP?

Georgia does not impose a statutory minimum capital floor specific to VASPs, and a Georgian LLC can in principle be formed with nominal share capital. In practice the National Bank of Georgia assesses financial soundness as part of the registration review and, where the model involves holding client assets or pre-funding liquidity, will expect evidence that the entity holds adequate funds to protect clients. We confirm what your model needs before you commit any funds. The absence of a hard capital floor distinguishes Georgia from regimes such as Kazakhstan’s AIFC, which sets activity-specific floors from USD 10,000.

Can a Georgian VASP authorisation cover tokenised securities or RWA?

No. Georgia’s virtual-asset regime expressly excludes tokens that represent securities, so a tokenised security falls under the Securities Market Law, not the VASP authorisation, and there is no dedicated tokenisation framework. Where the vehicle is a fund, we route via fund licensing; where your model needs securities permissions, we scope that route alongside the crypto authorisation.

Process and timeline
How long does it take to obtain authorisation?

The National Bank of Georgia decides within 60 calendar days of a complete filing, extendable by a further 60 where additional review is needed. End-to-end, including Georgian entity formation, the AML/CFT policies, the three-year business plan and fit-and-proper documentation, plan for roughly two to four months. The practical bottleneck is the compliance documentation pack and the fit-and-proper evidence, not the NBG decision window. We run the schedule and keep the regulator’s clock moving.

How is crypto taxed in Georgia?

Georgia applies an Estonian-style corporate tax model: company profits are taxed at 15% only when distributed, with a 5% withholding tax on dividends. Financial operations by VASPs, including the exchange of crypto assets into fiat, are VAT-exempt without the right to deduct input VAT. Individuals pay 0% on gains from the supply or exchange of crypto assets, because a 2019 Public Decision of the Ministry of Finance treats such income as non-Georgian-source. Free Industrial Zone or Virtual Zone Person status can access further exemptions, but those regimes interact with the VASP perimeter in ways that need case-by-case structuring, which we handle.

Market access and banking
Can a Georgia VASP serve EU clients?

A Georgia VASP authorisation does not grant EU market access or passporting rights, and MiCA contains no third-country equivalence regime for crypto-asset service providers. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative, and ESMA interprets this exemption narrowly: any EU-targeted marketing, EU-language content or geo-targeted advertising voids it. If you need systematic EU access, we deliver a MiCA CASP authorisation in an EU member state instead. See the guide to reverse solicitation under MiCA for full detail.

Will you arrange banking for the licensed VASP?

Banking is one of our core services and we scope it alongside the registration, not after it. Banking access for Georgia-registered VASPs is available but selective, with source-of-funds and beneficial-ownership diligence the main friction points and international correspondent access for USD and EUR clearing more selective again. We structure the entity so it can bank cleanly and prepare the source-of-funds dossier and clean ownership chain that move an application forward. We never name a specific provider in advance, because acceptance turns on your own profile.

Get a Georgia crypto licence quote

We form your Georgian company, build the AML/CFT pack, file with the National Bank of Georgia and obtain your VASP authorisation. Tell us what you are building and your target market, and we will map your route to authorisation and quote it.

Banking & Payments

A company and a licence still need a bank account

Banking is one of our three core services. We help high-risk and regulated businesses open the bank and payment accounts that others refuse: we work directly with EU EMIs, payment institutions and crypto-aware banks, confirm appetite before you apply, and make the introduction. Take it with your company and licence, or on its own.

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Tomberg & Partners

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