Walk into almost any shop in Georgia and you’ll see the same picture – two POS terminals sitting side by side.
“Cash or card? TBC or BOG?” – questions every customer hears daily. What seems like harmless choice is, in fact, a symptom of deeper fragmentation in our payment infrastructure.
Now imagine a world where every merchant has one intelligent terminal, capable of recognizing your card automatically and routing the transaction through the most efficient and affordable channel. No confusion. No double hardware. No hidden costs.
The draft amendment recently circulated by the NBG to the Law on Payment Systems and Payment Services could redefine the structure of Georgia’s payment ecosystem. It expands the central bank’s authority to oversee institutions and infrastructures critical to national financial stability, introducing new designations such as Systemically Important Commercial Banks and Systemically or Exceptionally Important Payment Systems (SIPS) – entities whose disruption could shake the economy.
Importantly, such systems will also be required to grant non-discriminatory access to technical capabilities that enable smart routing – allowing PSPs, processors, and merchants to direct transactions via the most cost-effective network.
What Is Smart Routing?
Smart routing allows payment systems to dynamically select the optimal network – Visa, Mastercard, or a local scheme – for each transaction based on cost, speed, or reliability.
Globally, regulators such as the UK Payment Systems Regulator (PSR) and the European Central Bank (ECB) promote open access, but few impose direct routing obligations on infrastructures.
To function securely, routing engines must handle sensitive data such as the PAN (Primary Account Number), BIN, and merchant category codes – all governed by PCI DSS v4.0. This means smart routing can only operate within PCI-certified environments, using tokenization, encryption, and HSM-based processing to ensure compliance and protect cardholder data.
MultiPOS – A Practical Alternative
At the physical level, MultiPOS (Multi-Acquirer POS) provides a simpler way to achieve similar results.
A single terminal can connect to multiple acquirers – Bank of Georgia, TBC, or other acquirers – allowing merchants to manually or automatically select the best route. Unlike system-level smart routing, MultiPOS operates at the terminal level, avoiding full PAN exchange and complex compliance exposure while still giving merchants flexibility, redundancy, and better pricing.
Both Smart Routing and MultiPOS pursue the same goals: fair competition, lower merchant costs, and stronger resilience.
While Smart Routing represents a long-term systemic reform, MultiPOS offers immediate, practical impact for merchants and PSPs in Georgia’s evolving market.
Fair Access or Regulatory Overreach?
Requiring systemic systems to enable non-discriminatory smart routing access could be transformative – fostering competition and aligning with EU-style open-access frameworks like PSD2 and the Interchange Fee Regulation (IFR).
Yet it raises serious questions:
1. Who bears the compliance cost of building PCI DSS-certified routing infrastructure?
2. Should regulators mandate technology, or instead create market conditions that let innovation emerge naturally?
These are not technical details – they define whether regulation becomes a catalyst for innovation or an obstacle to progress.
The “two terminals on the counter” model once symbolized growth. Today, it signals inefficiency.
Payments are no longer about hardware on the counter, but intelligence in the network where every transaction finds its smartest path.
Author: Mariam Gogia