Georgia continues to strengthen its position as a regional financial and investment hub with a modern regulatory environment and growing demand for flexible financial services. Obtaining a microbank license in Georgia offers businesses an opportunity to enter the regulated banking sector with a focused and innovative business model, particularly in SME, entrepreneurial, and agricultural financing.
Microbanks can play a significant role in expanding access to finance while operating under the supervision of the National Bank of Georgia. For investors and financial groups, this creates a valuable opportunity to establish a licensed financial institution in a fast-growing market with strategic access to the Caucasus region.
Phase 1: Pre-Application and Structural Alignment
Before applying, the future microbank must align its structure and operations with the regulatory requirements:
- The entity must be established as a Joint Stock Company (JSC), as microbank licenses are issued only to JSCs.
- Minimum paid-up capital must be at least 10 million GEL.
- At least 70% of the credit portfolio must consist of entrepreneurial (business) or agricultural loans.
- No single loan may exceed 1 million GEL.
- A preliminary consultation with the NBG Banking Supervision Department or Financial Innovation Office is highly recommended through BankingLicense@nbg.gov.ge to discuss the proposed business model and regulatory expectations.
Phase 2: Formal License Application
The application must be submitted to the National Bank of Georgia by an authorized representative or Supervisory Board member.
Required documentation includes:
- Updated founding documents and extract from the Registry of Entrepreneurs.
- Bank confirmation evidencing the 10 million GEL paid-up capital.
- “Fit and Proper” documentation for shareholders and Supervisory Board members, including criminal background checks from all countries of residence during the last 10 years and proof of legal origin of invested funds.
- Documentation confirming ownership or lease of the head office premises in Georgia.
Phase 3: Business Plan and Compliance Standards
Applicants must prepare a comprehensive 3-year business plan covering:
- Market strategy and target niche.
- Risk management policies, including Credit Risk, Market Risk, Operational Risk, and AML/CTF compliance.
- IT infrastructure and banking software implementation plans.
- Corporate governance structure, including at least 3 directors, internal audit procedures, organizational chart, and management responsibilities.
Georgian legislation also allows certain parallel management positions where affiliated entities are under common control, subject to regulatory conditions.
Phase 4: Communication and NBG Review
The substantive review process may take approximately 6 months and typically includes:
- Requests for additional information.
- Interviews with Supervisory Board members and directors.
- On-site inspections of systems, compliance standards, and office premises.
We can assist clients throughout the licensing process — from a corporate structuring and regulatory communication to preparation of compliance documentation and business planning.