Georgia's Next Digital-Money Opportunity: Tokenized Bank Deposits

Georgia does not need another digital-money concept in search of a problem. It needs a practical way to make regulated bank money work more efficiently across modern payment, securities and trade-finance infrastructure.

Tokenized commercial-bank deposits offer that opportunity.

They would not replace the lari, commercial banks or central-bank settlement. Properly designed, a tokenized deposit remains a liability of a licensed bank and a claim held by its customer. The difference is that the claim can be represented on programmable infrastructure, allowing money and assets to move together under predefined conditions.

This distinction matters. Georgia's most valuable next step is not necessarily a broad retail digital-currency project or the introduction of a private stablecoin. It is the controlled modernization of the bank money that Georgian households and businesses already use.

The institutional logic follows the central conclusion of the Intelligence Economy Institute's study, Tokenization Lessons from Georgia: successful tokenization begins with law, governance, auditability and trusted registries. The token is the final layer, not the foundation.

Georgia already has much of the foundation

The timing is unusually favorable.

In February 2025, the National Bank of Georgia invited supervised financial institutions to participate in a regulatory sandbox covering deposits and certificates of deposit recorded using distributed-ledger technology. The NBG explicitly noted that Georgia's existing framework did not yet regulate such instruments and identified possible benefits including new products, secondary-market functionality and lower operational costs. The purpose was therefore not simply to test technology. It was to co-create the regulatory framework with market participants. National Bank of Georgia ↗

Georgia is also expanding its open-finance architecture. New standardized services include recurring and future-dated payment initiation, variable recurring payments and consent-based access to deposit and loan information. These APIs could eventually become the customer and data-access layer surrounding tokenized bank money. National Bank of Georgia ↗

At the settlement layer, the NBG's instant-payments project is designed to support 24-hour, year-round GEL payments for banks and non-bank providers. Tokenized deposits should complement this infrastructure, not compete with it. The instant-payment system can provide reach and conventional account connectivity, while tokenized deposits add conditional execution and synchronization with tokenized assets. National Bank of Georgia ↗

The domestic deposit base is already substantial. Georgia's Deposit Insurance Agency reported approximately GEL 75.4 billion in deposits in July 2026. This means the policy question is not whether Georgia can invent a new form of money. It is whether a limited part of an existing, regulated deposit base can be represented and transferred more efficiently. Deposit Insurance Agency of Georgia ↗

Georgia's market is also concentrated enough to coordinate but diverse enough to test several operating models. The NBG currently lists 17 licensed commercial banks, including large universal banks, SME-focused institutions, regional banking groups and digital-native entrants. National Bank of Georgia ↗

What a tokenized deposit is

A tokenized deposit should be understood as a digital representation of an ordinary commercial-bank deposit.

The issuing bank remains responsible for the liability. Customer identification, transaction monitoring, sanctions screening, accounting and regulatory reporting remain bank responsibilities. The holder should be able to redeem the tokenized representation into a conventional account balance at par.

The instrument is therefore fundamentally different from an unregulated cryptoasset. It is also different from many stablecoins, whose holders may have a claim on a reserve structure or private issuer rather than a deposit claim against a supervised bank.

The international policy direction increasingly reflects this distinction. The Bank for International Settlements has described a future monetary architecture combining tokenized central-bank reserves, tokenized commercial-bank money and tokenized assets. The objective is to retain the two-tier monetary system while allowing money and assets to operate on programmable infrastructure. Bank for International Settlements ↗

Project Agorá, led by the BIS and participating central banks, similarly explores how tokenized commercial-bank money can be used for payments while tokenized central-bank money provides the settlement anchor. Its design preserves the roles of commercial and central banks and addresses legal, regulatory and AML/CFT requirements alongside technology. BIS Committee on Payments and Market Infrastructures ↗

For Georgia, that is the correct starting principle: innovation should upgrade regulated money, not create a parallel monetary system.

Four opportunities for Georgia

1. Delivery-versus-payment for tokenized financial instruments

Georgia's clearest wholesale use case is the settlement of tokenized certificates of deposit, bonds or other eligible financial instruments.

Today, the movement of an asset and the movement of money may involve separate systems, reconciliations and timing risks. A programmable transaction can make the asset transfer conditional on the corresponding payment. Either both legs complete, or neither does.

This delivery-versus-payment model could reduce settlement risk and manual reconciliation. It would also give the NBG's tokenized-deposit and tokenized-securities work a common operating objective.

The first pilot should use a straightforward GEL-denominated instrument with clearly identified issuers, investors and custodial responsibilities. It should demonstrate real settlement finality rather than merely moving test tokens between wallets.

2. SME working capital and trade finance

Georgia's SMEs frequently face a gap between completing economic activity and receiving usable liquidity. Tokenization cannot solve the underlying credit-risk problem, but it can improve the information and execution surrounding a financing transaction.

A verified invoice, purchase order or receivable could be linked to conditional financing. A bank could release funds when agreed data or documentary conditions are satisfied. Repayment could be synchronized with receipt of the underlying commercial payment.

The value would come from less reconciliation, faster confirmation and clearer control over the use of funds. It would not come from removing the bank's underwriting responsibilities.

This model is especially relevant to Georgia's agricultural, logistics, tourism and import-export businesses, where multiple counterparties and documents must often be coordinated.

3. Programmable escrow and corporate treasury

Tokenized deposits could support escrow arrangements in which funds move only after predefined commercial conditions are met.

Examples include payment following confirmed delivery, staged disbursement for construction or procurement, and automated treasury movements subject to limits and approvals.

The contract should automate execution, not legal interpretation. Dispute-resolution rights, correction procedures and human override mechanisms remain necessary. A bank must be able to freeze, reverse or recover funds when required by law or a validated operational event.

4. Regional and cross-border payments

Georgia's economic model is closely connected to trade, tourism, remittances and regional financial flows. The IMF's 2025 consultation projected deposit dollarization at approximately 51 percent and credit dollarization at around 40.5 percent, illustrating the importance of currency and cross-border considerations. International Monetary Fund ↗

Tokenized deposits could eventually help synchronize payment, foreign-exchange and trade-document processes. Georgian banks with strong links to Türkiye, Azerbaijan, Kazakhstan and European payment networks may be particularly relevant.

However, cross-border functionality should not be the first stage. It introduces additional questions around foreign-exchange regulation, correspondent banking, sanctions, data transfer and recognition of settlement finality.

Georgia should first establish a credible domestic GEL instrument. Regional interoperability can follow once the domestic legal and operational model has been proven.

Why interoperability matters more than the token

A single bank can issue a token representing its own deposit. That is technically straightforward. The harder question is whether another bank, customer or market infrastructure can accept and settle it with confidence.

If every bank creates a proprietary token, wallet and rulebook, Georgia will reproduce existing silos on newer technology.

A common framework should define:

1. The legal nature of the holder's claim.
2. The issuing bank's balance-sheet and accounting treatment.
3. Issuance and redemption at par.
4. Settlement finality and the connection to central-bank money.
5. Technical and operational interoperability between banks.
6. Customer identification, AML/CFT and sanctions controls.
7. Privacy and authorized access to transaction data.
8. Cybersecurity, key recovery and business continuity.
9. Error correction, freezing, revocation and dispute resolution.
10. Regulatory reporting and audit access.

The principle of par convertibility is particularly important. One tokenized GEL deposit issued by one bank must not become economically different from a GEL deposit issued by another bank because of incompatible technology or uncertain redemption.

Central-bank money remains the neutral settlement asset that supports the singleness of money. Tokenized deposits can introduce programmability, but final interbank obligations must still connect credibly to the NBG's settlement infrastructure.

Deposit insurance must be explicit

Georgia increased deposit-insurance coverage to GEL 50,000 per eligible depositor per bank from April 2026. Deposit Insurance Agency of Georgia ↗

A tokenized representation of a deposit should not accidentally interrupt customer protection. The regulatory framework should state clearly whether and under what conditions a tokenized deposit remains an insured deposit.

This cannot be left to interpretation after issuance. Customers, banks, auditors and insolvency authorities must understand the treatment before real value enters the system.

A practical Georgian pilot

Georgia should establish a common pilot involving the NBG, a deliberately varied group of three or four banks, and the relevant payment and securities-market infrastructure operators.

The bank group should include:

• A large universal bank capable of testing scale and liquidity
• An SME or microfinance-oriented bank
• A digital-native bank
• A bank with regional or trade-finance capabilities

The pilot should begin in GEL and test two complementary flows.

The first should be wholesale delivery-versus-payment for a tokenized certificate of deposit or bond. The second should be an SME or trade-finance transaction involving conditional disbursement or a verified receivable.

Each participating bank should remain the issuer of its own deposit liability, but all participants should use a common legal rulebook, data standard and interface specification. The architecture should be technology-neutral and avoid dependence on one ledger or vendor.

The pilot should connect issuance and redemption to conventional bank accounts and demonstrate how interbank positions are ultimately settled or reconciled through existing NBG infrastructure.

Success should be measured using operational outcomes:

• Time required to issue and redeem at par
• Settlement completion and failure rates
• Reduction in manual reconciliation
• Processing cost per transaction
• Liquidity and collateral requirements
• Compliance-alert quality
• Recovery from operational errors
• Customer and operator usability
• Interoperability across participating banks

The NBG should also establish stop conditions. The pilot should not proceed to production if legal ownership is uncertain, par convertibility cannot be maintained, banks cannot interoperate, or operational recovery cannot be demonstrated.

This discipline is consistent with international experience. Hong Kong's Project Ensemble has moved toward real-value transactions involving tokenized deposits and digital assets, while UK Finance has tested tokenized sterling deposits as regulated commercial-bank money rather than a substitute private currency. Hong Kong Monetary Authority ↗ UK Finance ↗

The opportunity

Georgia should not measure success by the number of tokens issued. It should measure whether regulated money can settle real economic activity more safely, quickly and transparently.

Tokenized deposits fit Georgia's institutional trajectory because they build on regulated banks, central-bank settlement, digital public infrastructure and an increasingly mature financial-innovation framework.

They also provide banks with a constructive role. Deposits remain within the banking system. Banks continue to manage customers, liquidity, credit, compliance and redemption. Programmability becomes a new capability of commercial-bank money rather than a reason to disintermediate commercial banks.

The opportunity is therefore not to create a Georgian crypto market by regulatory design. It is to establish a carefully governed form of programmable bank money that can support tokenized securities, SME finance and, eventually, regional settlement.

Georgia has the institutions, market size and policy momentum to test this model credibly. The next step is a common rulebook and a real multi-bank transaction.