VASP: Registration Documentation Checklist

A complete checklist under Order No. 94/04 of the President of the National Bank of Georgia of 13 June 2023, with annex references. The checklist helps verify that the package is complete before submission.

General formal requirement. Documentation must be submitted in the original or as a notarised copy. A document issued in a foreign country additionally requires an apostille or legalisation, unless legislation provides otherwise. Every foreign language document must be accompanied by a duly certified translation into Georgian.

Expected changes. As at August 2026, the National Bank has under consideration a draft amendment to Order No. 94/04 which would require additional documentation from an applicant for the initial offering of a stablecoin and would introduce capital and risk management requirements. The drafts have not yet been adopted; details are in section 8.

1. Registration Forms and the State Fee

• a fully completed registration form, Annex No. 1;
• a list of the virtual asset services to be provided, Annex No. 2;
• a table showing the correspondence between the documentation submitted and the required registration documentation, Annex No. 5;
• a receipt for payment of the registration fee of GEL 5,000.

2. Corporate Status and Beneficial Owners

• information on direct and indirect holders of a significant share and on beneficial owners, Annex No. 4;
• for a natural person, a copy of the identity document;
• for a legal person, an extract from the Register of Entrepreneurs and Non Entrepreneurial (Non Commercial) Legal Entities; for a non resident, an extract from the relevant registration authority. The extract must reflect all changes as at the date the application is submitted;
• for a joint stock company, additionally, an extract from the share register;
• documentation that makes it possible to establish the beneficial owner;
• an extract for the applicant company from the register, reflecting all changes.

3. Qualification, Reputation and Financial Standing of Administrators

• information on each administrator, Annex No. 3;
• a copy of the administrator's identity document;
• documentation on the education and work experience of the administrator and of the persons responsible for managing the activity, confirming the relevant knowledge or experience;
• criminal record certificates for the administrator and for the holders of a significant share, from every country in which the person was resident over the past 10 years. A Georgian certificate must be no more than 15 calendar days old, a foreign one no more than 60 calendar days old;
• information on shareholdings in entities subject to supervision by the National Bank: company name, identification code and the size of the holding;
• information on past and current business activity and financial standing, from a credit information bureau, from the register of debtors, or as provided by the person;
• information on the solvency of the organisations that the person managed or in which the person held or holds a significant share (bankruptcy or enforcement proceedings). If no such case occurred, written confirmation.

4. Infrastructure, IT Security and Technical Equipment

• information on the website to be used and a document confirming ownership of it or a right to use it, specifying the addresses;
• the name of the application, where it is hosted, the name of the developer and the developer's website address;
• an extract from the Public Register of rights over immovable property confirming ownership of or a right to use the head office and branch premises. The head office address must be given as the contact address in the registration form;
• detailed information on branches, Annex No. 7;
• video surveillance documentation, only where exchange is carried out in cash (other than through a self service kiosk): a copy of the installation act for the system on the external perimeter and, for the internal perimeter (the operating area and the cash desk), documentation confirming the presence of cameras, a purchase document, an installation document or photographic material;
• an extract for the developer of the electronic system from the relevant registration authority; the name of the system; the developer's website address; the place where information on obligations towards customers and on operations involving virtual assets will be stored.

The functionality of the electronic system must correspond to the planned services. The demonstration must take place at the National Bank before the registration process is completed.

5. Business Plan, Operational Scheme and Partners

• a schematic description of the service with a list of the virtual assets. The scheme must describe the movement of information, of virtual assets and of funds from the start of the service to its completion, identifying every participant: the transferor of the asset and their provider, the recipient and their provider (including the acquirer and the sub acquirer), and any intermediary provider, where one exists;
• information on contractual relationships with virtual asset and payment service providers licensed or registered by the National Bank or by a foreign regulator;
• a business plan with a budget forecast for at least the next 3 years. It must confirm that the company has appropriate systems, resources and procedures, and that it will carry out its activity on the territory of Georgia;
• organisational structure: the units of the head office, specifying their functions and headcount; a plan for structural development over the first 6 months of operations; if the company will operate through branches, a description of the branches' functions.

Number of schemes. If you plan several services, a separate scheme must be submitted for each. If the schemes differ by virtual asset, the schemes must be broken down by asset; where identical schemes are grouped together, specify the list of the corresponding assets. If a foreign virtual asset or payment service provider is involved in the scheme, submit a list of such providers, identifying their supervisory authorities.

6. AML/CFT Compliance

• internal instructions (a policy and procedure) for implementing the compliance control system, including the money laundering and terrorist financing organisational risk assessment document;
• a declaration by which the company confirms that the compliance control system is in place or will be in place before operations begin, Annex No. 8.

The National Bank is entitled to require the information in the form of a questionnaire instead of or in addition to the internal instructions; the questionnaire is published on its official website. The Bank reviews this documentation for the completeness of its components, but is also entitled to carry out a review on the merits, applying a risk based approach.

7. Travel Rule, Information Accompanying a Transfer

Compliance must be ensured by 31 December 2027 (Order No. 253/04). The information must accompany the transaction at every stage of its execution.

8. Expected Changes

This section describes the draft regulatory acts under consideration by the National Bank as at August 2026. The drafts have not yet been adopted and have not entered into force. Sections 1 to 7 describe the requirements in force.

8.1. Additional documentation for the initial offering of a stablecoin

If the applicant plans to provide the service of an initial offering of a stablecoin, the following would have to be submitted in addition to the items listed in sections 1 to 6, in accordance with Order No. 52/04 of the President of the National Bank of Georgia of 6 March 2026:

• corporate governance documentation;
• documentation relating to supervisory capital, including a bank statement confirming that the capital has been paid up;
• an audit opinion and, where the National Bank so requires, other related documents;
• the offering document;
• a compliance table for that documentation.

8.2. Minimum supervisory capital

Under the rule in force today there is no minimum capital requirement. Under the draft it would be set by type of service:

• Exchange (including through self service kiosks) or transfer - GEL 500,000
• Administration of a trading platform - GEL 2,000,000
• Other virtual asset services - GEL 1,000,000

Where more than one service is provided, the highest amount applies. At least 75% of the capital must consist of Tier 1 capital elements. Raising subordinated or convertible debt from a natural person is prohibited, other than from a partner, shareholder or beneficial owner.

8.3. Risk management framework and audit opinion

The provider would be required to maintain a documented framework for managing operational, cybersecurity, fraud and technological resilience risks, including:

• business continuity (BCP) and IT infrastructure disaster recovery (DRP) plans, tested at least once a year;
• penetration testing carried out annually on critical systems and, on the remaining systems, at least once every 3 years, as well as after every significant change;
• vulnerability scanning twice a year;
• retention of every version of the framework for 8 years from the date the service is terminated.

Within 6 months of registration, an independent audit opinion confirming compliance with the framework would be required. This is a post registration document, but its preparation should be planned at the application stage.

8.4. Change to the list of services (Annex No. 2)

• initial offering, and services related to an initial offering, would be separated out as distinct categories; • "administration of an exchange" would be replaced by the term "administration of a trading platform"; • exchange would be split into three subcategories: into national or foreign currency, into another virtual asset, and into a financial instrument.

8.5. Broader definition of a significant share

Under the draft, a significant share would also cover the ability to exercise significant influence over the provider, regardless of the size of the holding in the capital or in the voting rights. In practice this means that the documentation covered by sections 2 and 3 would extend to a wider circle of persons.

8.6. Dates

• Handling of customer complaints and reporting - 1 January 2027
• Risk management framework, for providers already registered - 1 July 2027
• Capital requirement, for providers already registered - 1 September 2027
• Travel Rule - 31 December 2027
• Liquidation rule - 1 September 2028

The transitional periods apply only to providers registered before the order enters into force. In addition, under the draft the order would not apply to administrative proceedings commenced before it enters into force. The timing of an application therefore carries independent weight.

Legal note. This checklist is current as at 24 August 2026 and is general in nature. Before submission, verify the version of Order No. 94/04 in force. Prepared by the law firm Justice League

The full list of Justice League services is available on the services page. The decision on registration is taken by the National Bank independently. Our task is to ensure that the application reaches it complete, consistent and well founded.

If you are considering registration as a VASP or have already received a deficiency letter, contact us

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