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

Georgia introduced a dedicated stablecoin framework in March 2026 through National Bank of Georgia (NBG) Order No. 52/04. The rule was then materially amended by Order No. 214/04, effective September 10, 2026.

For current compliance work, the March text should therefore not be read on its own. The consolidated rule and the September amendment are the relevant starting points.

Who can make a stablecoin initial offering in Georgia?

The current rule provides that a person may make an initial offering of a stable virtual asset only if it is registered by the NBG as a Virtual Asset Service Provider (VASP) under the applicable registration rules.

Georgia's Organic Law on the National Bank also prohibits the provision of virtual-asset services by a person that is not an NBG-registered VASP or another financial-sector representative specifically authorised by law to provide those services.

Stablecoin issuance is therefore not simply a corporate or technology launch. The issuer has to fit within the NBG's VASP and stablecoin supervisory framework.

What counts as a stable virtual asset under the amended rule?

The September amendment defines the regulated stable virtual asset as a convertible virtual asset expressed or denominated in units whose value is linked to the value of:

• the Georgian lari; or
• another fiat currency, such as the US dollar or euro.

The amended definition refers to maintaining value through liquid assets used for price stability and supply control. It also states that the definition does not include a digital representation of funds, securities, or other financial instruments.

This is narrower than the original May-era summary on this site, which referred broadly to a peg to another asset.

Reserve backing

An issuer must maintain reserve assets providing at least 100% backing of the nominal value of the stable virtual assets in circulation at all times.

Under the current rule:

• reserve assets must be denominated in the currency to which the stable virtual asset is pegged;
• the reserve must meet the requirements in the rule's annex, subject to permitted NBG-approved alternatives;
• where reserves are placed in Georgia, the relevant custodian must be an NBG-licensed commercial bank or microbank;
• reserves must be segregated from the issuer's own assets through effective internal controls; and
• the reserve must be maintained for the benefit of stablecoin holders to the extent needed to meet outstanding obligations.

The separate reporting rules give examples for a GEL-pegged reserve including GEL fiat, demand deposits, immediately withdrawable three-month deposits, and Georgian government debt securities with up to one year remaining maturity.

Capital requirements

The minimum supervisory capital is 500,000 GEL.

The current rule also scales capital with reserve size. Where reserve assets are at least 1,000,000 GEL, supervisory capital must include the 500,000 GEL minimum plus at least 2% of the average daily value of reserve assets over the previous six months, subject to the rule's 50,000,000 GEL cap.

Additional corporate-governance requirements apply where total reserve assets exceed 15,000,000 GEL.

Redemption

The current rule requires the issuer, on a client holder's request and subject to the applicable conditions, to redeem the stable virtual asset at nominal value no later than three business days after receiving the request.

If one client's aggregate redemption request exceeds 300,000 GEL or its foreign-currency equivalent, the issuer may complete redemption within five business days.

The issuer must make detailed redemption conditions public in advance, including the redemption period, fees, and any minimum purchase or redemption amounts.

Offering document and NBG process

Before an initial offering, the issuer must prepare an offering document and agree it with the NBG under the applicable process.

The current rule requires disclosures covering matters such as:

• the issuer and its VASP registration;
• ownership and governance;
• reserve structure and segregation;
• material market, liquidity, operational, cyber, technology, and regulatory risks;
• AML/CFT and sanctions controls;
• technology architecture; and
• complaints and dispute mechanisms.

NBG agreement of an offering document should not be described as a guarantee of the truth of every issuer statement. The rule itself requires appropriate caution around what NBG agreement signifies.

Audit and reporting

The framework includes independent external audit requirements and a separate NBG reporting regime for stable virtual assets.

Where reserve assets exceed 15,000,000 GEL, specified audit assessments must be carried out through firms listed in the rule's annex. Issuers should read the current audit and reporting provisions together rather than relying on a March 2026 summary.

Practical takeaway

A proposed Georgian stablecoin issuer should map the current structure against:

1. VASP registration requirements;
2. the consolidated Order No. 52/04;
3. the September 2026 amendment;
4. the stable-asset reporting rules;
5. reserve custody and segregation;
6. supervisory capital;
7. offering-document requirements; and
8. redemption, AML/CFT, sanctions, technology, and audit controls.

For a regulatory assessment, see Banking & Compliance or contact TK Counsel.