Georgia names self-service kiosks in its crypto rules, and added minimum capital for them in September 2026

The National Bank of Georgia lists exchange via kiosks among the services that require registration, so a machine is unambiguously in scope. In September 2026 it added minimum supervisory capital of GEL 150,000 for exchange and transfer services, with transition deadlines running into 2027.

● Green

Georgia is one of the few markets on this map where the regulator names machines explicitly. The National Bank of Georgia lists exchange between virtual assets and fiat currencies, including via kiosks, among the services that require registration as a virtual asset service provider,¹ and its registration rule, in force since 1 July 2023, sets requirements for the head office, branches, self-service kiosks and software systems.² That removes the ambiguity that complicates most other jurisdictions. What has changed, and changed recently, is the cost of entry. On 8 September 2026 the National Bank amended the rule to introduce minimum supervisory capital by activity: GEL 150,000 for exchange and transfer services including via self-service kiosks, GEL 350,000 for trading platform administration, GEL 250,000 for other services, and at least GEL 500,000 for stablecoin offerings, alongside new risk management, cybersecurity and business continuity requirements.³ As in most markets on our legislation map, GENERAL BYTES as a hardware and software vendor is not itself performing a licensable activity; it is the in-country operator of the machines who must hold the registration. For operators, Georgia remains unusually clear about what a machine is, and is no longer unusually cheap to enter.

Last updated: October 2026

Regulatory Framework and Its Evolution

Georgia built its regime around the FATF recommendations. The National Bank approved its rule on the registration, cancellation of registration and regulation of virtual asset service providers in June 2023, with effect from 1 July 2023, covering fit and proper criteria for administrators and for direct and indirect significant owners including beneficial owners, requirements for the head office, branches, self-service kiosks and software systems, anti-money laundering requirements to be met at the application stage, and further obligations after registration.² Providers already active before the rule had 90 calendar days to file.¹

The regime then moved from registration towards supervision. A bill amending the Organic Law on the National Bank of Georgia was submitted to Parliament on 17 September 2025, giving the National Bank explicit power to set minimum supervisory capital for providers and to make consumer protection rules, with the subordinate acts due by 1 September 2026.⁴ Those acts arrived on 8 September 2026. Besides the capital thresholds, they add risk management requirements covering operational risk, cybersecurity, process management and business continuity, and make registration decisions service-specific, so the public registry will state exactly which services each provider may offer. Existing providers have until 1 July 2027 for the risk management requirements and 1 September 2027 for the capital.³

Getting Registered: What a Machine Operator Needs

The registration itself is made with the National Bank, which supervises providers, and the Financial Monitoring Service handles suspicious transaction oversight. The applicant must be a Georgian company, its administrators and significant owners must satisfy fit and proper criteria, and the application has to show anti-money laundering arrangements before registration rather than after.²

Note that the company-law minimum capital for a Georgian limited liability company is a separate matter from the supervisory capital above, and the two are easy to confuse. Published guides written before September 2026, and guides written by firms that sell Georgian company formation, still describe the registration as having no capital requirement. That is no longer accurate for this activity. We were not able to verify the registration fee from a National Bank source, so any figure quoted elsewhere should be confirmed directly. As with the rest of our legislation map, registration sits with the in-country operator of the machines, not with GENERAL BYTES as hardware and software vendor.

AML and KYC

The framework was built on the FATF recommendations and anti-money laundering arrangements are assessed at the application stage, with further obligations continuing after registration and suspicious transaction reporting running to the Financial Monitoring Service.² The September 2026 amendments add operational risk, cybersecurity and business continuity requirements on top.³ For a machine network this means identity verification and monitoring have to be part of the build rather than something added once volumes justify it, and the service-specific registration means a provider cannot quietly extend into activities its decision does not cover.

Tax

Georgia is widely described as having a favourable tax position for crypto, including an exemption for individuals on income from the supply of crypto assets and a distributed profits model for companies under which retained earnings are not taxed until distributed. We were not able to verify either from a primary Georgian source, and every published description we found was written by a firm that sells Georgian company formation or licensing services, so these should be confirmed with a Georgian tax adviser rather than taken from this article. It is also worth noting that an exemption for individuals does not help a company operating machines, which is the structure the registration requires.

Importing the Hardware

One practical point does survive scrutiny. The European Union and Georgia have a Deep and Comprehensive Free Trade Area, which removed customs duties on trade in goods between them.⁵ Equipment shipped from an EU manufacturer therefore avoids the import-duty line that applies in many other markets, subject to the usual proof of origin documentation and local import VAT and clearance. Confirm the treatment of the specific goods with a Georgian customs broker before relying on it for a budget.

Banking

We did not find a source we could verify on how Georgian banks treat registered virtual asset service providers in practice, so this article makes no claim about it. The general point from other markets applies: a registration is the start of a banking conversation rather than the end of one, and banking appetite is worth testing in parallel with the application.

The Next 24 Months: From Registration to Supervision

The direction is clear and it is towards more supervision, not less. The capital thresholds, the risk management requirements and the move to service-specific registrations all arrived within the last two months, and the transition deadlines for existing providers run through 2027.³ Anyone assessing Georgia now should work from the amended rule rather than from material written earlier in 2026, because the entry economics are materially different.

What has not changed is the thing that makes Georgia unusual on this map: the National Bank names kiosks in its own list of services,¹ and its registration rule has set requirements for self-service kiosks since 2023.² An operator does not have to argue about whether a machine is in scope. The questions worth putting to the National Bank or to Georgian counsel are how the GEL 150,000 threshold is calculated for a provider whose only activity is machines, whether a new entrant must meet it at registration or by the 2027 transition date, and exactly which services a registration decision for a machine network would name.

Sources and references

1. National Bank of Georgia FAQ on virtual asset services: the listed services include exchange between virtual assets and fiat currencies including via kiosks, transfer, safekeeping and administration, portfolio management, administering a trading platform, lending and initial coin offerings: nbg.gov.ge
2. National Bank of Georgia, 20 June 2023: approval of the rule on Virtual Asset Service Provider Registration, Cancellation of the Registration and Regulation, in force from 1 July 2023, with fit and proper criteria for administrators and significant owners and requirements for the head office, branches, self-service kiosks and software systems: nbg.gov.ge
3. National Bank of Georgia, 8 September 2026: amendments adding minimum supervisory capital by activity (GEL 150,000 for exchange and transfer services including via self-service kiosks, GEL 350,000 for trading platform administration, GEL 250,000 for other services and at least GEL 500,000 for stablecoin offerings), risk management and business continuity requirements, service-specific registration decisions, and transition deadlines of 1 July 2027 for risk management and 1 September 2027 for capital: nbg.gov.ge
4. Andersen in Georgia on the bill amending the Organic Law on the National Bank of Georgia, submitted to Parliament on 17 September 2025, which gives the National Bank explicit power to set minimum supervisory capital for virtual asset service providers and to make consumer protection rules, with subordinate acts due by 1 September 2026: ge.andersen.com
5. European Commission on the EU and Georgia trade relationship and the Deep and Comprehensive Free Trade Area: ec.europa.eu

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. The National Bank of Georgia amended its rules for virtual asset service providers in September 2026 and transition deadlines run into 2027; always consult specialised local legal counsel and confirm current National Bank of Georgia requirements before considering market entry.