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Stablecoin regulation in Georgia

Irakli

RegHub Georgia Specialist

Initial offerings of stablecoins in Georgia now fall within a distinct legal framework. Stablecoin regulation in Georgia determines the legal treatment of these digital instruments, the conditions for market entry and the duties of each participant. Businesses, investors and professional operators need to understand the product's economics as well as the updated rules governing transactions in it.

A business preparing to launch a stablecoin in Georgia begins by classifying the proposed asset. Unlike conventional cryptoassets, whose prices can move sharply with market conditions, a stablecoin is designed to preserve value against a designated unit of account. The company must then examine the conditions applicable to the issuer, the regulatory supervision of the project and every approval or registration step required before operations begin. Issuance does not stand apart from the company's wider regulatory position: its services, organisational model and legal status must all form part of the analysis. Only then is the company in a position to ascertain which stablecoin requirements in Georgia apply, whether its current permissions cover the planned activity and whether a further procedure is needed. Before the initial offering can proceed, Georgia's central bank, the National Bank of Georgia (NBG), must consent in writing.

Stablecoin regulation in Georgia: legal sources

The NBG is the principal authority for this regime. Georgia requires every virtual asset service provider (VASP) to register. The Organic Law on the National Bank of Georgia provides the institutional basis for the NBG's powers over finance and virtual assets. The NBG supervises relevant market participants in prudential matters and consumer protection. Cybersecurity and operational risks also fall within its remit, together with other relevant areas.

A company planning an issue must account for the NBG's general mandate as well as the dedicated instrument. VASP registration is mandatory under the general regime. The dedicated instrument is The Rule for the Initial Coin Offering of a Stablecoin by a Virtual Asset Service Provider (the Rule), which the NBG adopted to create a safe, transparent system for initial offerings of stable virtual assets. An issuer nevertheless remains governed by the general VASP regime. Together, the general regime and the Rule establish the stablecoin requirements in Georgia for both the provider and the offering.

The Rule separately regulates:

• the issue of the asset and the conditions for its initial offering;

• information that the whitepaper must contain;

• the permitted composition and organisation of reserve assets;

• custody arrangements for those reserve assets;

• the stablecoin redemption process;

• disclosure of information;

• reports to the regulator;

• management of technology and operating risks;

• the required regulatory capital; and

• the participating parties' respective rights and duties.

The underlying VASP regime also applies. Among other matters, it addresses the provider's administrators, persons with significant ownership interests, beneficial owners and operating infrastructure.

Legal classification

Stablecoin regulation in Georgia recognises the term “stable virtual asset” as a distinct legal category. A marketing label cannot settle the classification. Legal treatment turns instead on the instrument's economic function, the method used to maintain its value and the terms offered to users.

To fall within the definition currently in force, the token must reference either the Georgian lari or one foreign fiat currency. Its design must include a mechanism for maintaining value, supported by reserve assets. The stablecoin label alone is therefore insufficient: the law follows the token's actual features and the terms on which it is initially offered.

To classify the token and design its operating model, the company must examine reserve backing. The issuer has to preserve the prescribed coverage as the circulating supply changes. An important feature for classification is the presence of a person in charge of organising the initial offering. Before proceeding, the company must therefore consider the token's features alongside its own legal status.

Reserve requirements and categories under Georgia stablecoin rules

Every circulating token must be fully covered by reserve assets. At no time may the reserve assets be worth less in aggregate than the combined nominal amount of all stable virtual assets then outstanding. This 100% coverage requirement is intended to increase the digital instrument's resilience and protect holders' interests. The issuer must create, safeguard and administer the reserve assets as prescribed, keeping them legally and operationally apart from its own property so that they independently back its obligations to holders.

The first permitted model uses the Georgian lari as the token's value reference. It is particularly relevant to projects intended for domestic settlement, digital payments and transactions with users in the local market. For an initial offering on Georgian territory, the company must first determine what procedure governs its dealings with the regulator. A company that is not yet registered as a VASP must complete that process and obtain the NBG's written consent before opening the offering.

Alternatively, the token may reference a single foreign fiat currency. Dollar- and euro-linked products are the most familiar examples in practice. They are commonly used for international settlement, cross-border transfers and digital financial services. Use of a foreign reference does not take activity conducted in Georgia outside Georgian law. Any company proposing to issue a stablecoin in Georgia must classify that activity in law and determine the applicable NBG requirements.

The regulatory scope changed on September 10, 2026. Effective from that date, an amendment removed the category based on a non-fiat reference asset and restricted qualifying reserves to liquid assets. A project should therefore apply the amended definition, rather than the broader wording in the Rule as first adopted.

Participants and their respective positions

Regulatory duties depend on the function performed. Georgia stablecoin rules distinguish the VASP responsible for issuance and the initial offering from holders, investors and other users. Before entering the market, each company should define its role and identify the corresponding obligations. Its activities must comply with those rules both when the asset is launched and while it remains in circulation.

The issuer performs the following functions:

• forming and issuing the digital asset;

• organising its initial offering;

• managing the reserve assets; and

• discharging the commitments owed to holders.

Under the Rule, the issuer must be a registered VASP. It must satisfy standards concerning corporate structure, governance and organisational arrangements. Further standards apply to reserve assets, internal controls, disclosures, risk management and compliance. The NBG separately assesses the mechanism intended to preserve the asset's stated value.

The general VASP regime continues to govern registration and supervision, whereas the special Rule governs initial offerings. Every provider must maintain internal controls. These may include, without limitation, procedures for customer identification and verification, determination of beneficial ownership, risk assessment, transaction monitoring and other appropriate measures. Before entering the stablecoin market, a registered provider should review its authorised services together with its policies and operating processes. Any element unsuited to the proposed activity may require amendment.

Investors and other users are treated differently. Merely acquiring or holding a stablecoin does not make the holder a VASP or an issuer. Nonetheless, rules on transparency, disclosure and user protection take their rights and interests into account. Before acquiring the asset, a user must receive reliable information about the product's principal features and its stabilisation method. The material risks and redemption conditions must also be stated clearly. Reserve coverage is directly relevant to holders: throughout circulation, the reserve assets must have an aggregate value no lower than the combined nominal amount of the outstanding stable virtual assets.

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Work required before a stablecoin launch

Preparation for a Georgian stablecoin launch starts with legal classification. Five questions guide the initial review:

• Does the proposed token meet the statutory criteria for a stable virtual asset?

• What value is it designed to preserve?

• Is its reference the lari or one foreign fiat currency?

• By what means will its stability be maintained?

• Which rights will attach to ownership of the token?

The review must also consider whether the instrument belongs to a different class of financial product or virtual asset. A name or brand cannot override its substantive legal and economic features.

Before filing with the NBG, the company should conduct a full legal and corporate audit of the proposed model against the stablecoin requirements in Georgia. The audit must determine whether the model complies with the law and whether the applicant can satisfy every condition for an initial offering.

The corporate part should cover:

• the company's registration records;

• its articles of association;

• the ownership chain;

• particulars identifying every beneficial owner;

• the identities of directors and other administrators;

• the necessary corporate resolutions;

• the distribution of decision-making powers; and

• contracts with the principal counterparties.

The company's VASP status requires separate analysis. That analysis must identify the services authorised by the current registration, compare them with the proposed activity and establish whether any further procedure is required before the initial offering.

Financial preparation starts with a sustainable economic model. The model should specify the anticipated issue volume and the structure of income and expenditure. It should also describe liquidity needs. The redemption process must be explained, as must the method for building reserve assets. Regulatory capital is calculated separately and may not be mixed with the reserve assets; its function is to sustain operations and absorb the relevant risks. The model must account for growth in issuance: whenever the circulating supply increases, reserve coverage must rise correspondingly.

The filing package must include that financial model, cash-flow projections and the capital calculation. It must also contain forecasts for operating expenditure and reserve value, a liquidity model and stress-test scenarios. A separately documented daily control must reconcile the circulating token count against the value of the corresponding reserve assets.

Technical preparation proceeds in parallel with the financial work. The company must develop or adapt its blockchain environment, smart contract, and token-issuance and redemption functions. It also needs wallets, cryptographic-key controls, systems for recording transactions and monitoring operations, and backup facilities. The internal IT environment must protect user assets and data, restrict access and log staff actions. It must also detect incidents and enable recovery from technical failure.

The whitepaper is the principal information document for the project. It must present prospective users and the NBG with a coherent description of the issuer, operating model, reserve assets, risks and holder rights. A dedicated section should identify the stablecoin by name, symbol and identifier. It should also give the reference currency, planned issue volume and timetable, together with the other particulars required by the Rule.

After filing, the NBG reviews the material and may request further documents or explanations. The applicant may launch a stablecoin in Georgia through an initial offering only after satisfying the applicable conditions and receiving the regulator's prior written consent. The offering must remain within the model accepted by the NBG.

Conclusion

Participants in the market for stable virtual assets now operate within a more structured and transparent legal setting. The NBG expects issuers and service providers to maintain adequate reserve backing and sound risk management, keep their technology secure and their finances resilient, and protect holders' rights. An issuer must meet corporate, financial, regulatory and technical requirements simultaneously when it launches a stablecoin.

Specialists from our consulting agency can help align a project with stablecoin regulation in Georgia by assessing the proposed structure and determining the applicable rules and risks. They can also prepare the filing materials and check them for consistency. It will be important for the company to obtain a legal review of its documents before they are filed. Areas the specialists will analyse include the issue model, holder rights, how reserve assets will be organised and contractual relationships with custodians. The same team can spot weaknesses early; corrections are then simpler and less costly.