Georgia Stablecoin Regulation 2026: NBG Order No. 52/04 Explained

On March 6, 2026, Governor of the National Bank of Georgia Natela Turnava signed Order No. 52/04 — the Rules for the Initial Coin Offering of a Stablecoin by a Virtual Asset Service Provider. The order entered into force upon publication and applies to all VASPs registered with the NBG.

This is the legal foundation that makes GEL₮ possible. It is also the rule any other entity wishing to issue a stablecoin in Georgia must follow.

This article is research, not legal advice. TK Counsel can advise on your specific situation.

Who Does This Rule Apply To?

The rule applies to Virtual Asset Service Providers (VASPs) registered with the National Bank of Georgia. A VASP in Georgia covers:

Exchange of virtual assets for fiat currency (and vice versa)
Exchange between virtual assets
Transfer of convertible virtual assets
Custody or administration of virtual assets
Portfolio or wallet management
Operation of a trading platform
Lending of virtual assets
Initial coin offering (ICO) services

If your business does any of the above in Georgia, you likely need VASP registration. If you want to issue a stablecoin, you need VASP registration plus NBG's prior written consent.

What Is a Stablecoin Under Georgian Law?

The rule defines a stablecoin as a virtual asset pegged to:

The Georgian lari (GEL)
A foreign fiat currency, or
Another asset

Where the value is maintained by liquid and/or other assets agreed with the NBG.

Critically, the rule applies to any stablecoin issued by a Georgian VASP — not just GEL-pegged tokens. Foreign stablecoins like USDT or EURT would also fall under the framework if issued by a Georgian VASP.

The Reserve Requirement

The cornerstone of the rule is 100% reserve backing at all times.

For a lari-pegged stablecoin specifically, permitted reserve assets include:

| Reserve Asset Type | Requirements | |--------------------|--------------| | GEL fiat cash | Held at NBG-licensed commercial banks or microbanks | | GEL current demand deposits | At NBG-licensed banks/microbanks | | GEL short-term deposits | Maximum residual maturity as agreed with NBG | | Georgian government debt securities | Residual maturity not exceeding 1 year | | Minimum liquid asset share | At least 10% in cash and/or demand deposits |

For stablecoins pegged to foreign currency or other assets, different reserve compositions may apply subject to NBG approval.

The rule requires daily reserve composition monitoring by the issuer.

Reserve Segregation

This is the rule's most protective element for stablecoin holders:

Reserves must be segregated from the issuer's own assets at all times
Reserves must be unencumbered — no liens or claims against them
Reserves exist for the benefit of stablecoin holders, not the issuer's creditors
In insolvency, reserves are isolated from the issuer's estate

This is structurally similar to a bankruptcy-remote structure. In theory, even if the issuing company goes under, the reserves should not be available to general creditors.

Custody Requirements

Reserve assets must be held with authorized or licensed custodians:

For Georgian custodians: must be licensed as a bank or microbank by the NBG
Foreign custodians: must meet NBG-approved equivalent standards

Issuers must maintain custodian agreements that comply with the rule's segregation requirements.

Redemption Rights

The rule creates enforceable redemption rights for stablecoin holders:

General client redemptions: no later than 3 business days
Large redemptions (above GEL 300,000): no later than 5 business days
Redemption at nominal value
Fees must be reasonable, proportionate, and publicly disclosed

For non-client redemptions (e.g., institutional holders), the issuer may apply enhanced due diligence, AML checks, and sanctions screening — but the redemption obligation still applies.

Audit and Reporting

Issuers must publish the following quarterly:

Reserve composition
Total issued stablecoin volume
Average maturity of reserve assets
Related reserve information

These must be verified by an independent qualified external auditor:

| Reserve Size | Audit Firm Requirement | |--------------|------------------------| | Below GEL 15 million | Qualified external auditor (not specified) | | Above GEL 15 million | Must use a listed firm: Deloitte, PwC, EY, KPMG, Grant Thornton, RSM, BDO, or equivalent |

Annual financial statements must also be audited.

Material discrepancies must be reported to the NBG immediately.

Issuer Capital Requirements

Any VASP issuing a stablecoin must maintain minimum regulatory capital of GEL 500,000 (approximately $183,000 at current rates). The rule does not cap maximum capital — it scales upward based on reserve size and risk profile.

Prior Approval Process

No stablecoin ICO can proceed without prior written NBG consent. The issuer must submit:

Business plan and corporate governance structure
Reserve management and custody arrangements
AML/CFT policies
Technical infrastructure description
Auditing arrangements
Redemption mechanism details

The NBG reviews and approves or rejects. There is no guaranteed approval.

NBG Enforcement Powers

If an issuer violates the rule, the NBG can:

Impose monetary fines
Suspend or revoke the stablecoin approval
Require suspension or restriction of issuance or redemption
Act in cases of reserve breaches, capital violations, false information, illegal ICO activity, or other breaches

The NBG has broad supervisory authority over VASP compliance more generally, including the power to conduct on-site and off-site inspections.

What This Means for GEL₮

GEL₮ was announced on May 25, 2026 — two months after Order No. 52/04 came into force. For GEL₮ to operate legally in Georgia, Tether's issuing entity must:

Be registered as a VASP with the NBG
Obtain prior written consent for the stablecoin ICO
Maintain 100% GEL-denominated reserves, segregated from its own assets
Use NBG-licensed custodians for reserve assets
Publish quarterly reserve attestations verified by an independent auditor
Meet minimum capital requirements (GEL 500,000)
Provide redeemability within the specified timeframes

Whether Tether has completed or begun this approval process is not publicly confirmed. Tether's own announcement stated that structure, rollout, and regulatory implementation details will be announced later.

Implications for Businesses

If you are considering:

Accepting GEL₮ as payment: verify the issuer has NBG approval before extending credit or accepting the token
Integrating GEL₮ into a platform: ensure your own AML/KYC framework covers stablecoin receipt
Applying for a VASP license with stablecoin ambitions: Order No. 52/04 sets a high bar — expect rigorous NBG scrutiny on reserve management, custodians, audit arrangements, and redemption infrastructure
Advising foreign crypto clients on Georgia: the rule creates a clear compliance pathway but requires significant legal and operational infrastructure — this is not a light regulatory commitment

How TK Counsel Can Help

TK Counsel advises businesses on:

VASP registration with the NBG
Compliance with Order No. 52/04 for stablecoin issuers
AML/KYC frameworks for crypto businesses
Banking compliance for crypto-related transactions
Source-of-funds documentation for account unfreezing

Applying for a VASP license in Georgia, or looking to issue a lari-pegged stablecoin? We map NBG Order No. 52/04 to your specific structure — see our banking compliance service page.