How to to register a payment system provider in Georgia

There are some 60+ fintech startups providing digital financial services in Georgia today. These include neobanks, digital wallet operators, and providers of money transfer services, among others. Most fall within the PSP, or Payment Service Provider, designation. In this article, we will tell you how to become an official PSP and what benefits you can expect from being one.

Payment System Provider in Georgia

According to the Law on Payment Systems and Payment Services, only commercial banks, microfinance organizations, and non-banking institutions (LLC or JSC in form) registered with the National Bank as Payment Service Providers can provide financial services in Georgia.

To obtain official status as a provider, a PSP license, you will have to submit a voluminous package of documents to the Georgian regulator. 

Please note that the PSP license regulates the provision of financial services with fiat money only. To transfer, exchange, or store cryptocurrency in Georgia, you will need a Virtual Asset Service Provider (VASP) license. We wrote in detail about what goes into getting one and about GeCrypto, one of the first companies to get onto the VASP register, staking a claim to about 20% of the cryptocurrency exchange market in just six months.

As for the Electronic Money Institution (EMI), common in Europe and Asia: an EMI registry simply does not exist in Georgia. If you intend to issue payment instruments, you will need a basic PSP license only.

What services require a PSP license

The list can vary, but if you plan to provide the services below, you will definitely need a PSP license:

• Money transfers, domestic and international, even if they don’t require the payer’s personal account or bank card
• Withdrawal of funds, crediting to a recipient, and all related operations from customer analysis and verification to clearing and charging a fee for the service
• Payments via direct debit, bank card, or other electronic instrument using the customer’s own funds or credit line
• Issuing and servicing payment instruments, e.g., virtual cards
• Issuing electronic money and performing transactions with it via internet, cell phone, and other technologies
• Payment Initiation Services pulling directly from the customer’s bank account, bypassing other networks 
• Account Information Services securely aggregating bank account data (balances, transactions, history) from multiple banks to present in a single place

What services do not require a license

Financial operations that do not require a PSP license in Georgia can be found in Paragraph 2, Article 13 of the Law On Payment Services and include:

• Cash transfer services through a commercial intermediary without payment infrastructure
• Cash currency exchange services that do not require the customer to create a personal account (ordinary currency exchanges, like dollars or euros for lari)
• Operations conducted by regulated participants of the securities market: purchase and sale of shares, payment of dividends, bond coupons, etc.
• Cash collection, such as for non-economic (e.g., charitable) activities
• ATM cash dispensing services on behalf of a card issuer (but not itself a payment service). If the company provides cash withdrawal services via its own virtual cards at partner terminals, a license will certainly be required
• IT for other financial services, like payment data processing, cryptography, the maintenance of customer authentication systems

Requirements for PSP beneficiaries

Only joint stock (JSC) or limited liability companies (LLC) can apply for a spot on the National Bank’s register. But it’s not only the company that must meet strict requirements: Its beneficiaries, the individuals or legal entities that own 10% or more of the authorized capital, will also be scrutinized.

• The shareholders of a payment service provider cannot have been convicted of financing terrorism, money laundering, or other crimes, especially grave ones. A criminal record check issued no more than 60 days prior to the application will be required.
• The beneficiaries and founders must have good credit. To verify financial activity, the National Bank requests bank statements or information from the register of debtors (if available).
• The educational background of the beneficiaries and managers must correspond to the company’s sphere of activity, something that can be attested to by diplomas and certificates.
• Finally, the founders of the company must be in the country for at least 14 days within a calendar month before filing the application. This is not a mere formality: Your company will have almost no chance of being included in the PSP register without permanent executive representation in Georgia. And the requirements for the office, equipment, and personnel are also strict.

You’ll also want to give due consideration to the electronic platform the business will employ to provide services. It must have the latest encryption technologies, guard against cyberattack, undergo regular audits and risk assessments, and comply with international security standards such as the PCI DSS (Payment Card Industry Data Security Standard).

What documents to submit to the National Bank

Everything in the application for inclusion in the PSP register must be translated into Georgian and notarized. The are a dozen different documents:

• The PSP register application (standard form)
• Information on company beneficiaries and statutory documents to unambiguously identify the beneficiaries
• A list of the payment services the business will provide. The license is not universal: You will have the right to provide only those services included in the application
• An outline of the services (a separate document for each) describing how the payment cycle is organized and the technologies, intermediaries, or agents involved
• Information about the electronic system: name, website, registration details, infrastructure, etc.
• The compliance matrix, consisting of AML/CFT policies, internal guidelines for assessing partners, employees and customers (KYB, KYE, KYC), the general data protection regulation (GDPR), contracts with employees, and data on counterparties, especially foreign counterparties
• The company business plan, which will help the National Bank assess risks and the organization’s financial stability
• A receipt for the state duty (GEL 10,000, or USD 3,700)
• This is not an exhaustive list. It the platform involves internal accounts, for example, you’ll need a bank guarantee to deposit 100% of customer funds

How long it takes to register

The National Bank of Georgia is obliged to review the documents within 60 days of receiving your application (though the countdown gets paused if the regulator requests clarifications or finds errors, meaning it can take much longer).

Why you should turn to a specialist

It is possible to register a business in Georgia in one working day, but if you plan to work with financial services, you must be ready to undergo real scrutiny. It is almost impossible for a small or medium-sized business to pass without help: There is simply too great a risk of errors in the documentation, and the need to resubmit can continue endlessly. Errors can also manifest themselves after registration and threaten the business’ very existence.

What’s more, PSP license holders are required to submit monthly, quarterly, and annual reports to the regulator and face hefty fines for failing to do so. In 2025, for example, the National Bank fined CPay GEL 14,000 for violations in money laundering supervision and PayUnicard GEL 39,000 GEL for client verification that was deemed insufficient. And these are not isolated cases.

The specialists at PB Services can help you avoid legal and financial risks, collect and prepare the documents needed for fintech services in Georgia, help you get the most out of the existing tax regime, and find promising niches for startups. After you get your license, we can help you with comprehensive outsourcing services for accounting or HR.