georgia (Georgia) Digital Banking and Commercial Banking License Application Guide

georgia (Georgia) Digital Banking and Commercial Banking License Application Guide

Subject to the Law on Commercial Banking Activities and the National Bank of Georgia (KJV) Regulated statutory financial license

The banking industry in Georgia is regulated by the National Bank (NBG). in accordance with 2022 Amendments to the Commercial Banking Activities Act, NBG establishes "Conditional License" system. The system provides digital banks with 4 annual regulatory sandbox period, The initial minimum capital requirement is 5000 Ten thousand lari (GEL) downgraded to 500 Ten thousand lari. Licensed institutions support access to the Single Euro Payments Area (SEPA) and Open Finance (Open Finance) networks. Businesses involving crypto assets need to complete virtual asset service provider (VASP) registration at the same time. Hong Kong Huitong provides corporate establishment, Compilation of materials for executive fitness (Fit and Proper) review and legal agency services for license application.

Release time: Application preparation reference
Hong Kong Huitong service teamApply for support
Document preparation and project coordination
work focus: business needs, Document consistency and matters to be confirmed
Service direction: Business description, Sorting out application materials and ongoing compliance matters
Service Description: Organize disclosure regulatory requirements based on proposed business operations, Material list and project nodes. Involving legal opinions, During audit or professional assurance, The corresponding professionals and service scope should be confirmed separately.; Competent agencies and banks make independent review decisions.
Familiar with the regulatory application process
Professional compliance team
Standardized compliance process
Multi-jurisdictional services

1. national bank of georgia (KJV) [Statutory Classification and Supervisory Definition of Licenses]

Statutory license type Supervisory Qualification and Business Permissions
Digital banking license
(Digital Bank License)
Legally characterized as holding"Conditional license"of commercial banks. Limited to provision of banking services through digital channels (no branch operating model), And apply open banking and Banking as a Service (BaaS) architecture.
Regular commercial bank license
(Commercial Bank)
Provide comprehensive personal and business banking services, Covers taking deposits, grant loans, Payment settlement, Forex trading, Asset Management and Investment Banking.
Foreign bank branch license
(Foreign Bank Branch)
foreign banks ingeorgiabranches established, Under dual jurisdiction of parent company regulator and NBG.
Peace Bridge in Tbilisi, Georgia
Peace Bridge in Tbilisi, Georgia.

2. [Statutory capital requirements and sandbox mechanism] for digital banks and commercial banks

Regular commercial bank capital: The minimum statutory regulatory capital for a regular commercial bank license is 5000 Ten thousand lari (GEL).

Digital bank initial capital: conditional licensing system, Initial minimum capital requirements for digital banks lowered to 500 Ten thousand lari (GEL).

4Capital increase during the annual transition period: Digital bank with conditional license, Must be in 4 During the sandbox transition period, capital will be gradually replenished to 5000 Ten thousand lari.

Funding source review: The applicant must provide proof of legal sources of authorized capital and regulatory capital, Capital verification funds must be deposited into the NBG designated custody account.

3. [Legal Red Lines and Quota Requirements for Corporate Structure and Senior Executives]

Board structure: The board of directors shall consist of at least 3 composed of people, and must contain 1 local residents of Georgia. Allow foreign investment 100% holding.

Executive qualifications: Chief Executive Officer (CEO) must have 5 More than 10 years of banking management experience; Mandating a Chief Compliance Officer (CCO) to enforce AML/CFT policies, and Chief Financial Officer (CFO).

gender diversity quota: The proportion of female representatives on the supervisory boards of commercial banks must be within 2025 Year 6 moon 1 Reached the day before 40%; The proportion of women on the board of directors is recommended to reach 33%.

suitability review (Fit & Proper): All proposed directors, Executives and major shareholders must submit criminal records and details of sources of wealth, Under NBG review.

4. Submitted to the National Bank of Georgia (KJV) [Core review document list]

Review feature categories NBG statutory requirements submission details
Executive Due Diligence Documents Provide proof of identity of directors and shareholders, No criminal record and source of funds documents, for Fit and proper review.
Business and Financial Planning Submit business plan, Includes board structure, business model, Business strategy and multi-year financial forecast statements.
Compliance and Security Architecture Submit network security architecture documents, Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Policy Paper.
Tbilisi city and commercial buildings in Georgia
Tbilisi city and commercial buildings in Georgia.

5. Georgia Digital Bank License [Statutory Application and Approval Process]

Stage one: Name pre-review and data preparation

The bank name must contain "Bank" or "Financial". Submit name to NBG for pre-qualification, Prepare business plan and compliance policy.

Stage 2: Capital injection and application submission

Will 500 The initial capital of RMB 10,000 is deposited into the NBG regulatory account. Submit Articles of Incorporation to NBG, Proof of funds and background information of senior executives.

Stage three: NBG due diligence

NBG’s background to shareholders, source of funds, AML/CFT Policy, Review of IT security measures and capital adequacy.

Stage four: Issue of conditional license

A "conditional license" is issued after passing the review, Enter 4 annual regulatory sandbox period. The approval cycle is usually 6-12 months.

Stage five: Become a full-time official after the expiry of the sandbox

4 Implement additional requirements according to NBG regulations within the year and make up for them 5000 Ten thousand lari capital, Conversion to regular commercial banking license.

6. Regulatory Sandbox Business Restrictions and [Red Line for Delisting]

Personal deposit intake limits: During the sandbox period, The amount of a single personal deposit may not exceed the legal maximum insured by the Georgia Deposit Insurance Corporation.

Forced revocation mechanism: Failure to comply with license restrictions, or failed to 4 Completed within the year 5000 Marriage capital replenishment, The conditional license will be immediately revoked.

Strong supervision of crypto assets: Involving cryptocurrency business, Virtual asset service provider (VASP) registration and AML/CFT reporting obligations must be strictly fulfilled.

Annual audit submission: Licensed banks are required to submit independent financial audit reports and AML/CFT compliance reports to the NBG annually, subject to prudential supervision.

Georgia Geography and Mountain Environment
Georgia Geography and Mountain Environment.

7. Georgia Bank License [Statutory Government Fees and Capital Details]

Project Category Legal amount standard (GEL)
Digital bank initial capital lowest 500 Ten thousand lari(Must be deposited into a supervision account).
Regular bank/regular capital lowest 5000 Ten thousand lari(Digital banks need to make up within 4 years).
Official application fee The initial license application fee payable to NBG is approx. 30 Ten thousand lari.
Statutory annual maintenance fee Need to pay every year 5 Ten thousand – 20 Ten thousand lari Varying annual supervision fees (approved based on scale).

8. Ganghuitong provides enterprises with full-process services for company registration and license application., Covers preliminary assessment, document preparation, Application submission and subsequent compliance support.

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Corporate establishment and personnel allocation

Register a Georgia entity, implement 1 Requirements for local resident directors, help achieve 40% Female supervisor quota.

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Business plan and legal drafting

Writing a network security architecture, Financial Forecasts and Business Plans, Develop NBG compliant AML/CFT operations manual.

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Official application and defense agent

Help complete 500 Verification of legal funds of Wanli, Submit information with NBG on behalf of the applicant and handle compliance defense.

9. Core Legal Questions and Answers on Georgia’s Digital Bank Regulatory License (FAQ)

10. Relevant regulations, Regulatory information and further reading

Data category Related information
Legislation and regulatory guidance