The National Bank of Georgia has significantly expanded the regulatory framework for Virtual Asset Service Providers (VASPs).
On August 26, 2026, amendments were introduced to the Rules on VASP Registration, Cancellation of Registration, and Regulation. The primary focus of these amendments is risk management, financial stability, cybersecurity, and operational resilience.
💡 What changes?
▪ Supervisory Capital: A minimum supervisory capital requirement is introduced — ranging from 150,000 to 350,000 GEL (depending on the type of service).
▪ Risk Management Framework: A risk management system corresponding to the scale and complexity of operations becomes mandatory (covering identification, assessment, monitoring, reporting, and mitigation).
▪ Operational Resilience and Cybersecurity: Special emphasis is placed on the stability of technological infrastructure, managing the risks of fraud and abuse, and business continuity.
▪ Periodic Testing: Requirements are established for conducting systematic penetration testing and vulnerability scanning.
▪ Adding New Services: Offering a new type of virtual asset service by a provider is subject to prior consent from the National Bank.
▪ Stablecoins: For primary offerings, additional requirements have been defined regarding corporate governance, supervisory capital, audit reports, and the offering document (Whitepaper).
⏳ Important Deadlines:
📌 By July 1, 2027 — Already registered providers must ensure compliance with the new risk management requirements;
📌 By September 1, 2027 — Already registered providers must ensure compliance with the minimum supervisory capital requirements;
📌 By January 1, 2028 — The National Bank must align the relevant individual acts and lists of existing providers with the new requirements.
🎯 How to prepare for the changes?
The new regulation establishes a completely new, higher standard of financial and technological resilience in the VASP sector. Ensuring compliance with the new requirements is a complex process, making early preparation critically important.
🤝 LC HUB (Legal & Compliance Hub) offers full legal and AML/Compliance support. Among other services, we provide penetration testing (pentests) and align your software/technological systems with the new standards.
Our team is ready to provide all necessary services to ensure your company meets the new requirements of the National Bank smoothly, seamlessly, and on time.