Where Banking Income Is Concentrated

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BTU researchers calculate that Bank of Georgia and TBC Bank accounted for 86.04% of net fee and commission income across 17 Georgian commercial banks in January–September 2026, compared with 75.61% of their assets on September 30. The gap shows that net earnings from services are more concentrated in the two largest banks than assets are, while the price customers pay requires a separate comparison.

Key Takeaways

• BTU researchers calculate that Bank of Georgia and TBC Bank’s share of January–September 2026 net fee and commission income across 17 Georgian commercial banks exceeded their September 30 asset share by 10.44 percentage points.
• Across the same 17 Georgian banks, the two largest banks’ net fee and commission income share fell from 87.42% in January–September 2025 to 86.04% in January–September 2026; their end-September asset share also fell.
• For users of banking services in Georgia, a bank’s share of net fee and commission income is not a price indicator: the relevant comparison is the total cost and terms of the services they actually need.

Georgia’s banking assets are heavily concentrated in its two largest banks, but the distribution of assets does not tell the whole story. Using National Bank of Georgia reporting, BTU researchers calculate that Bank of Georgia and TBC Bank account for 86.04% of commercial banks’ net fee and commission income-10.44 percentage points more than their share of assets. The difference raises an important question: how should competition in banking services be assessed without confusing the size of a bank with the terms offered to its customers? [1]

On October 23, BM.ge reported on banks’ nine-month financial results. Alongside the discussion of profits, there is a question with everyday relevance: where do net earnings from services accrue? Accounts and transfers are needed to manage household budgets, pay employees and settle suppliers’ invoices. Assessing the banking market therefore matters beyond prospective borrowers and shareholders. Service terms also affect people and companies whose relationship with a bank is built around everyday payments. [5]

Two Different Measures

Assets describe the resources recorded on a bank’s balance sheet at a particular date. They include loans, cash and other assets. Here, the reference date is September 30, 2026. Net fee and commission income is a flow over a period: fee and commission income less the corresponding fee and commission expenses. The period examined is the nine months from January through September. We are therefore comparing two distributions: who holds what share of assets, and who earns what share of net fee and commission income.

Why might bank size and service earnings be distributed differently? A loan portfolio forms part of a bank’s assets, while service usage also involves other kinds of activity. Processing more transfers does not itself require a bank to make proportionately more loans. Active use of accounts and other services can generate income without a matching increase in assets. A large asset share and a large fee-income share therefore need not be equal. Comparing the two distributions shows the size of that difference.

Both years cover the same 17 commercial banks reporting in Georgia. Crystal and MBC, two microbanks, are excluded from both measures’ aggregates. Bank of Georgia and TBC figures refer to their local operations. This common scope shows how assets and net fee and commission income are distributed within Georgia’s commercial banks. Assets describe the position on a particular day, while income is the result accumulated over nine months.

Distribution of Assets and Net Fee and Commission Income in 2026

Source: National Bank of Georgia; BTU researchers’ calculations. Assets are a point-in-time stock; income is a nine-month flow. Microbanks are excluded from both measures. [1]

The other 15 commercial banks account for approximately GEL 98.36 million of net fee and commission income. That amount combines different banks’ businesses, so the aggregate share should not be treated as an identical picture of every service. An important provider for a particular type of customer may be relatively small across the whole market. Moving from the aggregate to individual services is therefore useful: a large market-wide gap identifies where more detailed information would help, while customers need comparisons that match their particular requirements.

One boundary is especially important when reading net fee and commission income: it is not the total amount paid by customers. Corresponding fee expenses have already been deducted; when they exceed fee income, a bank’s result can be negative. Those entries remain in the calculation. The 86.04% share therefore describes the distribution of net earnings rather than the price a particular customer pays. Comparing prices and usage requires examination of the actual service terms.

A High Share Is Not a Rising Share

A snapshot can easily be turned into a story that the two largest banks must be gaining share. To test that interpretation, BTU processed the September 2025 reporting on the same basis. The historical comparison does not overturn the main finding, but it changes how it should be read. In both years, net fee and commission income was more concentrated in the two banks than assets were. Yet the two banks held a smaller share of both measures in 2026 than a year earlier. [1][2]

The Two Largest Banks’ Shares Across the Same 17 Commercial Banks

Source: National Bank of Georgia September reporting for each year; BTU researchers’ calculations. Shares were calculated from unrounded inputs before rounding for display. [1][2]

Their net fee and commission income share fell by 1.38 percentage points, while their asset share fell by 1.86 points. The gap between the two shares consequently widened slightly even though both shares declined. There is no contradiction: the asset share fell faster. Announcing an increase in fee-income concentration solely because the gap widened would be incorrect. The more accurate conclusion is that the two largest banks’ combined share remained high but declined in this particular two-year comparison.

The amounts help explain the falling share. The two largest banks’ net fee and commission income increased from GEL 538.45 million in the first nine months of 2025 to GEL 606.48 million in the corresponding period of 2026. The other 15 banks’ combined result rose from GEL 77.48 million to GEL 98.36 million. Both groups earned more, but the second group grew faster relative to its starting amount. The two leaders therefore held a smaller share of a larger aggregate. This distinguishes growth in a bank’s own result from a change in its weight across the market. [1][2]

What Customers Actually Need to Compare

In BTU researchers’ assessment, examining individual services would help explain the different income distribution. More customers or more frequent transactions can generate more income even at the same tariff. The result can also change when customers choose different services carrying different charges. Corresponding fee expenses affect net income as well. These are possible explanations that aggregate bank figures cannot distinguish; each requires its own supporting data.

For businesses, the useful comparison begins in daily operations. A retailer may need to accept payments, receive the proceeds promptly and reconcile them with sales records. What matters is how those services work together and what using them costs. A manufacturer or service provider may care more about the terms for transfers to suppliers. In either case, information linked to the company’s actual operations is more useful for choosing a service than a bank’s overall share. It allows competing offers to be evaluated on the same basis.

Different businesses cannot judge the same offer in exactly the same way. An account-maintenance tariff alone cannot tell a company whether a service is suitable when it needs frequent transfers to suppliers. Payment-acceptance pricing also provides an incomplete picture if access to the proceeds or connections with accounting records create additional work. Those costs and requirements must be investigated in the actual service terms. A bank’s high net income cannot substitute for what a company can observe in its own operations.

For households, too, the starting point is usage rather than a bank’s position in a profit ranking. A recurring account or card charge and individual transaction fees affect frequent and occasional users differently. Customers also need to know what their chosen package includes and when extra charges begin. One free transaction does not make the entire service free. Equally, a higher recurring charge does not by itself establish that a particular customer’s final bill will be higher. The answer depends on what that customer needs and uses.

The National Bank of Georgia publishes standard tariffs for commonly used payment services as a starting point for comparison. The regulator notes that terms may change and current conditions should be confirmed with the bank. The page helps customers identify options, after which the details matter: whether an offer applies to their chosen package, channel and currency. Comparing equivalent terms also matters for small businesses that need to see the prices of several services as one overall cost. [4]

Choosing a Service and Choosing a Bank

Open banking provides a practical example in Georgia. The National Bank describes account-information access and payment initiation through standardized technical channels, with the customer’s explicit informed consent. An authorized service provider need not therefore be the bank holding the account. This does not mean that every banking service can be transferred to another provider, or that using the arrangement automatically lowers prices. [3]

For customers, the value of that choice would appear in concrete usability. If they can obtain needed account information or initiate a payment through a service that suits them, the location of their account need not be the sole determinant of choice. A business may value compatibility with its workflow; a household may want a clearer view of information. Understanding the terms and using the service easily also matter. BTU researchers’ assessment is that examining these practical opportunities would complement the picture provided by banks’ financial shares.

Further research should distinguish individual service groups and connect their income with usage volumes. Transaction data would show whether a service is used more frequently, while comparable tariffs would reveal whether its price has changed. Corresponding expense data would help explain the difference between fee income and the net result. The comparison should hold the product mix consistent, so increased use of a higher-priced service is not mistaken for a tariff increase. Such information would help companies evaluate offers, customers make choices and market researchers identify where competitive conditions are changing.

Where is banking income concentrated? Most of the net fee and commission income examined still accrues to Bank of Georgia and TBC, and their share exceeds their share of assets. At the same time, both shares are lower than a year earlier. The important question for Georgia is therefore broader than simply recording a high share: how understandable and comparable are service terms, and how useful are the available options for households and businesses? Financial reporting begins that inquiry; examination of customers’ actual costs and experience needs to carry it forward.

Questions and answers

Does the calculation include microbanks?

No. Both years cover the same 17 commercial banks. Crystal and MBC are excluded from all relevant aggregates.

Why use net fee and commission income rather than the amount paid by customers?

The reporting used provides the net result: fee and commission income less corresponding expenses. Measuring customers’ total payments would require different data.

Does the 86.04% figure show which bank is more expensive?

No. It is a share of net income. Comparing prices requires the current terms for the same service and the customer’s usage.

Does a falling share mean services have become cheaper?

No. A share can also fall because other banks’ results change. Changes in tariffs must be checked separately.