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White paperService 02 · 24 min read

Digital assets & crypto regulation 2026

A comparative reading of the Georgian virtual asset regime against MiCA and the regional jurisdictions competing for the same operators, written for founders choosing where to licence, and for institutions already licensed here.


1. The question this paper answers

Where should a virtual asset business licence, and what does that choice cost it in market access, banking and supervisory burden over the following three years? The paper treats the decision as an operating question rather than a legal one.

2. The Georgian regime in outline

Registration with the National Bank, a defined perimeter of regulated activity, fit-and-proper requirements for management, and an AML/CFT framework assessed on substance. The regime is comparatively fast and comparatively clear, and it is supervised more closely after grant than during it.

3. Measured against MiCA

MiCA buys passporting across the single market at the price of capital, governance and disclosure obligations that a young operator will feel. For a business whose customers are inside the EU, that price is usually worth paying. For one whose customers are not, it frequently is not.

Practice note

Licensing where the customers are is a better default than licensing where the process is easiest. Banking follows the customer base, and banking is what actually constrains a payments business.

4. The regional comparison

The UAE, Kazakhstan and the EU member states competing for this business each offer a different trade between speed, cost and access. The paper sets them side by side on the six criteria that decide the outcome in practice, including the one operators consistently underweight: whether a local bank will open the account.

5. Conclusions

Georgia is a strong choice for operators serving non-EU markets, for groups building an operating entity rather than a letterbox, and for businesses that need a licence and a platform at the same time. It is a weak choice for a business whose commercial plan depends on EU passporting.

Choosing a jurisdiction, or already licensed here? Book a call with the research centre and the licensing team.

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