TaxAdvisory.ge · Assio Lex and Associates LLC

Build your virtual asset business in Georgia with an application prepared around your actual services. We help founders organise VASP registration, corporate setup and the compliance documents required by the National Bank of Georgia.

Prepare your VASP application

  • Define the virtual asset services, customers and transaction flows.
  • Organise company, ownership and management documents.
  • Prepare the business plan, AML/CFT policies and operational procedures.
  • Review technology, security, risk and business-continuity documentation.
  • Prepare the submission and respond to the National Bank’s questions.

Plan capital and operating requirements

The September 2026 supervisory framework sets minimum capital according to the services offered:

Plan capital and operating requirements
ServiceMinimum supervisory capital
Convertible virtual asset exchange and/or transfer150,000 GEL
Trading platform administration350,000 GEL
Other services, excluding stablecoin initial coin offerings250,000 GEL
Stablecoin initial coin offeringAt least 500,000 GEL; scales with reserves

Where several services are offered, the highest applicable threshold applies. Existing registered providers have transition dates of 1 July 2027 for the risk framework and 1 September 2027 for capital. New applicants should plan around the requirements applying to their application.

Choose the support you need

Company incorporation: EUR 1,280. Application assistance using client-prepared documentation starts from EUR 5,500. A managed documentation and application engagement starts from EUR 25,000. We confirm the work, ongoing support and separate regulatory, capital, office and staffing costs in your proposal.

Map each virtual-asset service the business will provide

Describe how a customer enters the system, funds a transaction, receives the service and withdraws assets or money. Identify the legal entity dealing with the customer and every custody, exchange, technology and banking partner. This flow of assets and responsibilities determines the regulatory analysis and the operational documents.

Preparing a VASP registration file
WorkstreamPractical questionsRecords to prepare
Business modelWhich services are provided and to which customers?Service description and transaction diagrams
Ownership and managementWho owns, controls and runs the provider?Ownership chain, management details and supporting records
AML controlsHow are customers, wallets and transactions assessed?Risk assessment, onboarding and monitoring procedures
Client assetsWho holds assets and authorises movements?Custody arrangements, access controls and reconciliation procedures
TechnologyHow are security, incidents and continuity handled?System description, vendor agreements and response procedures
Capital and financeWhich current requirement applies to each service?Capital plan, funding evidence and financial forecasts

Treat the September 2026 framework as a financial planning item

The National Bank expanded the supervisory framework in September 2026. The applicable capital and risk-management requirements should be matched to the precise services and the provider’s registration position. An exchange business, a trading platform and a stablecoin-related activity should each be assessed under the relevant current provision.

A capital plan should identify the proposed funding, ownership of the funds, timing and the company’s expected costs. For an existing provider, put the applicable transition dates and implementation work into the management calendar. Retain the calculation and approval supporting the company’s position.

Make the policies workable for the actual team

An onboarding policy should say who reviews a customer, which information is obtained and how an exception is escalated. A monitoring procedure should describe the data the company actually receives. Test those steps against sample transactions and make sure the responsible employees can operate them before launch.

Discuss the next step

Send your planned services, ownership structure and the countries you intend to serve. We will discuss the application work and local arrangements you need.

Request a consultation

Frequently asked questions

Which virtual asset activities need NBG registration?

Assess the precise services against the NBG framework and prepare the registration for those service types. The provider’s registration identifies the activities it is authorised to provide.

What should a VASP applicant prepare first?

Start with the business model, service categories, customer and asset flows, ownership, management and funding. Use these to prepare the application, AML controls, technology records and the applicable capital plan.