1. PSP/EMI license legal access conditions and substantive operation requirements
Legal entity and physical office location
must be ingeorgiaRegister a local legal entity。Strict legal requirementspayment service provider（PSP) must establish a real physical office location，It is prohibited to adopt a pure letterbox operation model with no substantial economic basis.。
Statutory Capital Compliance
The applicant must meet the requirements of the National Bank of Georgia for different categories (PSP orEMI) the minimum initial capital threshold set。The sources of all paid-in capital must be fully legal and traceable。
Anti-money laundering (AML) and compliance review
Must establish and submit internal Anti-Money Laundering (AML) compliance with NBG standards andCounter-terrorism financing(CFT) Control Manual，Establish statutory monitoring and reporting mechanisms for high-risk customer groups and transactions。
Translation and notarization of foreign language materials
Mandatory provisions of legal procedures，All overseas application documents submitted to NBG、Compliance manual and business plan, etc.，All must be translated into Georgian (საქართველო) according to law and completed territorial notarization。
2. 2023-2026 Regulatory dynamics and industry compliance trends
- 2023-2024Year
Capital adequacy ratio regulatory upgrade：NBG promulgated the "Regulations on Capital Adequacy Ratio Requirements for Payment Service Providers" (effective January 1, 2024)，Introducing a risk-based capital assessment framework，Importance to the systempayment service providerand payment originators setting mandatory minimum regulatory capital thresholds。
- 2023Year
VASP and Microbanking Legislation：Implement "Virtual asset service providerLaw"，Bringing Cryptocurrencies Officially Under NBG Regulation；In the same year, the minimum capital was established as 1000 Microbank Category in Wanli，And fully launch the GIMS electronic compliance declaration portal system。
- 2025Year
AML strengthens anti-money laundering administrative enforcement：NBG significantly strengthens anti-money laundering and customer due diligence supervision。Due to violation of AML and KYC statutory regulations during the year，Penalty imposed on CPay in accordance with the law 14,000 Larry administrative fine；Penalties imposed on PayUnicard 39,000 Larry administrative fine。
- 2026Year
Tightening of localization compliance for foreigners：From March 1, 2026，For foreign executives、"Right to work" legal access restrictions for self-employed and remote employees，In principle, companies are required to prove that there are no qualified local candidates before they can issue a work permit.，Significantly raising the local compliance threshold for foreign-invested entities。
3. List of statutory application submission files and review elements
Articles of Association of the Applicant、Legal person registration certificate and structure penetration document of ultimate beneficiary (UBO)。
Official Georgian translation of the complete set of documents，and a notarized or apostille certificate with legal validity。
Elaborate on your target market、Financial forecast and business plan for customer fund security mechanism。
Internal Compliance Controls and Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT) Management Procedures Manual。
Proof of fitness and proper of the proposed directors and senior management team，Include identity documents and no criminal record。
4. Foreign-funded institution license application and compliance procedures
Stage one：Corporate establishment and capital contribution (2-4week)
Complete limited liability company (LLC) registration with the Georgia Department of Justice Public Service Hall。Leasing physical office space that meets regulatory requirements，and complete the actual payment and capital verification of the statutory initial capital.。
Stage 2：Case file preparation and document localization (3-5week)
Hong Kong Express prepares AML manual and business plan based on NBG review standards。Translate all supporting documents and complete set of case files generated overseas into Georgian in accordance with the law and complete the notarization procedures。
Stage three：Formal submission of inquiry to NBG (3-6months)
Submit a license application to the National Bank of Georgia (NBG)。Cooperate with regulatory authorities on sources of funds、Multiple rounds of inquiries on technical system architecture and anti-money laundering risk control models。
Stage four：Licensing and special tax filings (2-4week)
Obtain PSP or EMI license after meeting all statutory conditions。Follow-up will be based on business needs，Submission of application for tax-exempt status to the Ministry of Finance of Georgia for “Virtual Regional Entity” status。
5. Analysis of Georgia Statutory Requirements and Compliance Elements
| Check category | statutory regulationStandards and Compliance Analysis |
|---|---|
| Paid-in capital and adequacy ratio | Need to meet the minimum own capital threshold set by NBG for specific licenses in accordance with the law，and must comply with 2024 The Capital Adequacy Ratio Requirements Regulations came into effect in，Ensure system risk coverage。 |
| Physical Operations Center | Must maintain a long-term and bona fide lease of physical office space within Georgia，and have compliance personnel present to perform their duties。 |
| Official and legal fees | Includes NBG statutory registration fees and annual license fees。Hong Kong Huitong's comprehensive legal agency fee covers case file drafting、Expensive Georgian translation, notarization and tax status application services for foreign texts。 |
6. Industry benchmark：PSP approval and compliance cases
Professional digital payment platform establishes market dominant position
Disclosure based on industry regulations，Except for large commercial banks that automatically obtain qualifications in accordance with the law，CPAY、Professional digital clearing platforms such as OPPA and eMoney Georgia have successfully passed NBG substantive review，Obtained PSP license according to law to carry out full business。
GeCrypto gets approval for the first batch of VASP registrations
in accordance with 2023 "Virtual Asset Service Provider Law"，GeCrypto successfully entered NBG supervision，Be one of the first businesses in the country to receive an official crypto license，Carry out compliant circulation and matching services of cryptocurrency in accordance with the law。
Statutory national treatment for enterprises with Chinese background
Georgia’s current bill imposes unified substantive access standards for domestic and foreign-funded institutions。haveChinese backgroundThe entity operates a physical outlet in accordance with the legal requirements、Capital verification，and comply with 2026 Under the premise of legal restrictions on the employment of foreign personnel in，Also enjoy equal national treatment when applying for licenses。
7. Review red lines and NBG disapproval reminders
Compliance system deficiencies： Submitted AML and KYC manuals do not comply with NBG regulatory requirements。Regulators have 2025 Penalties for such violations can be up to 39,000 Larry's punishment。
Translation and notarization defects： Legal documents submitted、Legally mandated translation procedures for business manuals into Georgian were not strictly followed，Or the overseas notarization/Apostille certification chain is broken.，Resulting in direct return。
Foreign personnel comply with illegal construction： since 2026 Since，If a foreign company forcibly appoints foreign executives without legal certification (without right to work) to perform their duties，Directly trigger administrative veto requirements。
8. Practical Legal Questions and Answers (FAQ)：Analysis of legal conditions and compliance pain points
Based on business essence，Mainly divided into payment service providers (PSP)、Electronic Money Institutions (EMIs) and Virtual Asset Service Providers (VASPs)，All are subject to legal supervision by the National Bank (NBG)。
If a licensed technology entity is granted “virtual regional entity” status，Revenue from its exports of technology and digital services outside Georgia，can be enjoyed according to law 0% Corporate income tax preferential treatment。
Absolutely prohibited by law。At the heart of the NBG review is the substance of the agency’s operations。Applicants must establish a real physical office location，Pure virtual address operations are prohibited。
In addition to the paid-in initial statutory capital，Institutions must comply with the Capital Adequacy Ratio Requirements Ordinance starting from 2024，Ensure that self-owned funds are sufficient to cover the systemic risk assessment limit。
Mandatory requirements。All overseas materials and business brochures submitted to the National Bank of Georgia，All must be translated into Georgian by law，And accompanied by legal notarization or apostille.。
Different regulatory frameworks apply。Virtual Asset Service Provider (VASP) specializes in crypto asset circulation；The PSP is aimed at legal currency and payment settlement business.，The two compliance standards cannot be mixed.。
Except for direct rejection，If you violate the regulations after obtaining the license, you will face heavy fines.。2025Year，NBG has imposed fines of tens of thousands of lari on a number of licensed payment platforms that have loopholes in KYC and anti-money laundering processes in accordance with the law.。
After preparing a complete set of Georgian translated and notarized documents in accordance with the law and submitting them to NBG，Combining substantive examination and compliance inquiries，The end-to-end statutory approval cycle typically requires 3 to 6 months。
From March 2026，Foreign executives must obtain the legal "right to work"。In principle, companies need to prove that there are no qualified local talents，Only then can foreign personnel be legally introduced to perform their duties。
Yes。Licensed entities must pay statutory annual fees in accordance with the law，and pass 2023 The GIMS company portal system launched in 2017 completes continuous electronic compliance reporting。
Commercial Bank of Georgia implements highly prudent KYC for opening accounts with financial institutions。Applicants must produce a complete Compliance Manual (AML Policy)、Physical office certificate and legal fund penetration report。
