The EU’s transitional period under MiCA ended on July 1, 2026. Companies that spent the past year and a half on national registrations now need full CASP authorization to serve EU clients: minimum capital between €50,000 and €150,000 depending on the service class, local substance, and an application review that stretches past six months at many regulators.
For funded exchanges and custodians, that is the cost of the European passport. For a five-person OTC desk or a bootstrapped exchange serving clients in the Gulf or Central Asia, the math fails. Those teams still need a legal home, a register entry that banks accept, and a supervisor whose name carries weight in onboarding calls, which is why a VASP license in Georgia keeps appearing on their shortlists this year.
Inside the Georgian Register
Georgia has run a dedicated regime for virtual asset service providers since 2023. Registration sits with the National Bank of Georgia, and the perimeter covers the day-to-day work of most crypto businesses: exchange between crypto and fiat, crypto-to-crypto exchange, transfers, custody and administration of client assets, operation of a trading platform, portfolio management, and ICO-related services.
The applicant is a Georgian company, an LLC in most cases, incorporated through the National Agency of Public Registry. The company needs a physical office in Georgia, a resident director or a local compliance officer, and management and owners who pass the regulator’s fit and proper checks. The core of the application is the AML file: KYC procedures, transaction monitoring, and reporting lines that match what the National Bank expects from a financial institution.
Georgia sets no minimum capital tier of the kind MiCA imposes, so the money a founder would lock up as regulatory capital in the EU stays in the business. The calendar is the other draw: in practice, the full path from incorporation to a register entry takes around two to four months, and the pace turns on how fast the applicant produces a credible AML framework.
The Tax Layer
Georgian tax law adds the second half of the case. Individuals pay no personal income tax on gains from selling crypto, which the Revenue Service treats as exempt foreign-sourced income. Crypto-to-fiat exchange is exempt from VAT. Companies fall under the Estonian model: corporate income tax of 15% applies only when the company distributes profit, plus a 5% withholding on dividends, so a business can reinvest retained earnings without an immediate tax charge.
None of this replaces advice on a specific structure. The individual exemption depends on residency and on the activity remaining personal rather than commercial. As a baseline, it is one of the lightest tax loads attached to a regulated crypto regime.
The Three Limits
The register comes with three hard limits.
The registration stops at the EU border. A Georgian VASP serving European clients at scale sits in the same third-country position as any other non-EU provider, and MiCA’s reverse solicitation carve-out is narrow. A company built on EU retail revenue will still need CASP authorization somewhere in the Union.
Inside Georgia, crypto stays out of payments. Virtual assets are not legal tender, and the law prohibits paying for goods and services with them outside narrow cases.
Registration also brings real supervision. The National Bank collects reports and can fine a company, suspend its activities, or strike it off the register. Draft amendments under discussion in Tbilisi would go further, with capital requirements and wider supervisory powers on the table. The regime is light today, and a company choosing Georgia for the low entry bar should budget for that bar rising.
Built for Non-EU Markets
The Georgian register works best for businesses whose clients sit outside the EU: exchanges and OTC desks serving the Caucasus, Central Asia, the Gulf, or global non-EU retail; custody and wallet startups that need a supervised home base for banking; teams validating a product before committing EU-level capital. Several Georgian banks open accounts for registered providers.
Founders get this right by choosing markets before jurisdictions. A team that knows where its clients sit can tell whether Georgia is a home base or a distraction, and can put the register entry where the revenue is. MiCA’s deadline forced that order: pick the client map first, then the register that matches it.
