Kazakhstan’s Freedom Bank, a key part of Nasdaq-listed Freedom Holding Corp., is preparing to enter Georgia’s banking market – a small, highly digital and highly concentrated market with strong local players, well-developed payment infrastructure, and a regulatory framework for digital banks. For Freedom Holding, this is not a one-off project but part of a broader strategy: exporting the ecosystem model it built in Kazakhstan into new markets.
The Georgian market
Georgia is a market with a population of around 3.9 million people, according to final 2024 census data published by Geostat. At the same time, banking penetration is already close to saturation. The fintech development strategy of the National Bank of Georgia states that in 2023, 2.9 million people aged 15 and over had at least one payment account with a commercial bank – 98.7% of the population in that age group.
The banking sector remains the core of the financial system. KPMG’s review for the first half of 2025 says that as of June 30, 2025, there were 17 commercial banks operating in the country; sector assets reached 99.48 billion lari, or about $37.08 billion, the loan portfolio stood at 66.49 billion lari, or about $24.78 billion, deposits at 62.64 billion lari, or about $23.35 billion, and net profit for the half-year at 1.55 billion lari, or about $0.58 billion.
One distinctive feature of the market is its high level of concentration: the two largest banks, Bank of Georgia and TBC Bank, accounted for 77.3% of banking-system total assets. This means that a new player will not be competing in a fragmented market, but against an entrenched duopoly where the largest banks have long been investing in mobile apps, payments, and ecosystem services.
The National Bank of Georgia directly notes that banks play a leading role in digital financial services, and that customer experience has become a key competitive differentiator. As a result, banks are developing “all-inclusive banking apps” and digital ecosystems.
Structurally, Georgia’s financial sector can be divided into several groups. The first group consists of traditional universal banks: Bank of Georgia, TBC Bank, Liberty Bank, Basisbank, Credo Bank, ProCredit Bank, and others. The NBG publishes a list of licensed commercial banks, which also includes Pave Bank Georgia, Hash Bank, and Paysera Bank Georgia among active market participants.
The second group consists of fully digital banks: the NBG’s fintech strategy says that three of the 17 commercial banks are fully digital.
The third group consists of non-bank financial institutions. As of March-April 2025, the country had 29 microfinance organizations, 156 lending organizations, 702 currency exchange bureaus, 19 insurance companies, four pension schemes, two stock exchanges, and 35 licensed payment service providers.
Georgia’s digital infrastructure is developing faster than the size of the market might suggest. The NBG reports that from February 2025 to February 2026, more than 915,000 transactions were initiated through Open Banking, while Open Banking services were used more than 9.3 million times in total.
For Freedom, this is an advantage: the market is ready for API-based models, digital onboarding, and account-to-account payments. But it is also a challenge: customer expectations are shaped not by newcomers, but by strong incumbent banks.
How Freedom Holding Corp. is entering Georgia
Freedom Bank is entering Georgia by establishing a local entity. On November 28, 2025, the bank announced that Kazakhstan’s Agency for Regulation and Development of the Financial Market had allowed JSC Freedom Bank Kazakhstan to establish a subsidiary in Georgia.
The planned bank’s charter capital has already been set at 5 million lari – around $1.8-2 million. It will consist of 5 million ordinary shares with a nominal value of 1 lari each.
For Georgia, this means the emergence of another contender in the digital banking segment, but one with an existing technology base and experience scaling its business in Kazakhstan.
Freedom Holding Corp. has already tested this model internationally in Tajikistan. In 2025, Freedom Bank Tajikistan began pilot operations and started integrating with local services. For its Georgian project, this experience matters because of the procedural expertise it provides: obtaining approvals, securing a local license, integrating with national payment infrastructure, and adapting the product line.
Broader expansion plans
For fiscal 2025, the Freedom Holding reported revenue of $2.05 billion, compared with $1.67 billion a year earlier, while total assets as of March 31, 2025, stood at $9.9 billion. Revenue for the first nine months of the 2026 fiscal year totaled $1.69 billion, while net income stood at $145.4 million.
Freedom Holding Corp. is currently focused on building an integrated ecosystem. Its flagship product, Freedom SuperApp, combines brokerage, banking, and insurance solutions with shopping, price comparison, savings tools, and cashback services. This combination of financial products and everyday consumer services is the model the group aims to replicate outside Kazakhstan.
For Freedom Bank, Georgia is not the largest market, but it is an important test case. Bank account penetration is almost universal; the country has a strong digital culture and a developed Open Banking infrastructure, and assets are highly concentrated in the hands of the two market leaders. The company will have to prove that its Kazakh ecosystem model can compete with well-established Georgian banks.
Freedom Holding’s logic is to build a cross-border financial and digital platform. For Georgia, this means the arrival of an ambitious player with capital, technology, and a super-app model. For Freedom Holding Corp., it is a test of how exportable Kazakhstan’s growth formula really is.
