Georgia's 2026 Stable Virtual Asset Regulatory Framework
In March 2026 the National Bank of Georgia announced a framework for initial offerings of stable virtual assets that includes full reserve backing, segregation of reserve assets and capital, redemption, disclosure, reporting, technology, operational-risk and capital requirements. Issuers and service providers must check the operative instruments for their exact model.
Why this issue changes business decisions
A stable-asset project requires more than a token description. Counsel and financial specialists need to map the issuer, reserve holder, custodian, distributor, redemption party, VASP functions, customer rights, technical controls and jurisdictions. A claim of stability should be tested against the legal right to redeem and the quality, control and segregation of the reserve.
The project should separate issuance risk from exchange, custody, transfer and payment questions. One entity may perform several regulated functions, but each function still needs classification, governance and documentation. Cross-border distribution may also trigger laws outside Georgia.
What the official Georgian sources show
NBG's 10 March 2026 announcement describes 100% reserve backing, segregation of own capital and reserve assets, redemption obligations and transparency and reporting requirements for issuers. Official source
The same announcement identifies offering-document, technology, operational-risk and capital requirements. It says the framework builds on 17 December 2025 amendments to the Organic Law on NBG granting full supervision in the virtual-asset field. Official source
An announcement is not a substitute for the operative legal instruments. Before offering, the company should verify effective dates, application documents, eligible reserves, custody, audit, redemption and ongoing reporting requirements with current NBG materials. Official source
Decisions to record before the company acts
Map issuer, reserve, custody, distribution, VASP and redemption responsibilities.
Do not market stability or redemption beyond documented legal and reserve arrangements.
Prepare offering, risk, governance, technology and reporting documents together.
Obtain separate advice for every foreign market in which the asset will be offered or used.
Issues counsel should connect
Regulatory perimeter
Map each product, customer, asset, payment and custody flow against Georgian definitions and restrictions.
Entity and governance
Design ownership, management, fit-and-proper evidence, authority and local control arrangements.
Registration pack
Coordinate policies, business description, systems evidence and application materials required for the proposed activity.
AML/CFT framework
Prepare risk assessment, onboarding, monitoring, escalation, reporting and record controls with qualified compliance input.
Customer documents
Draft terms, disclosures, complaints, risk information, privacy and product-specific consent records.
Operations and outsourcing
Allocate security, resilience, data, audit and regulator-access responsibilities across vendors and group companies.
A practical sequence for this matter
- 1
Document the product and transaction flow without relying on marketing labels.
- 2
Issue a regulatory-perimeter and gap analysis against current NBG and statutory materials.
- 3
Confirm structure, owners, managers, compliance resources and technical dependencies.
- 4
Prepare application, governance, AML, customer and outsourcing documents.
- 5
Support regulatory questions, launch controls and an update process for rule changes.
Documents and evidence
- product and funds-flow diagrams
- business plan and financial model
- owner, beneficiary and manager information
- system architecture and outsourcing contracts
- AML/CFT risk assessment and procedures
- customer journey, terms and disclosures
- data map and security incident process
- capital, reserve or safeguarding evidence where applicable
Risks to test
- activity begins before classification or registration
- a group licence is assumed to cover Georgia
- product description differs from actual flows
- AML procedures are generic and unresourced
- outsourcing obscures responsibility or regulator access
- 2026 framework changes are omitted from launch planning
Official public sources used
This publication cites only legislation, registries and regulators. It does not rely on other law firms or competitor commentary as authority.