Clarifications to the Law on Labour Migration in Georgia

Here is the approach of the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia (based on the received official letters), regarding the requirement to obtain a work permit for carrying out labor activities, effective from 1 March 2026.

Key Takeaways

1. Self-Employed Foreign Nationals

A foreign national who does not hold a permanent residence permit in Georgia and derives economic benefit from activities carried out in Georgia is classified as a self-employed foreign national and is required to obtain a “right to carry out labor activity” (work permit).

Self-employed foreigners include:

Individuals:

• Shareholders/partners in a Georgian company and receive financial benefits/dividends for the company;
• Who trade and provide services in Georgia;

2. Company Directors

Under Georgian law, a company director is treated as a self-employed foreign national for work permit purposes.
If the director is a foreign national, obtaining a work permit is mandatory.

3. Absence from Georgia for More Than 6 Months

A foreign national’s absence from the territory of Georgia for more than six months may constitute grounds for revocation of the work permit.
However, such decisions are made on a case-by-case basis and depend on the circumstances declared at the time of application.

4. Liability

Carrying out labor or entrepreneurial activities without a valid work permit may result in the application of statutory sanctions, including administrative fines:

• GEL 2,000 for the first violation;
• GEL 4,000 for a second violation;
• GEL 12,000 for repeated violations.

Our legal team continues its communication with the competent administrative authority to obtain further clarifications, as several questions remain unanswered:

1. Will it be necessary to obtain work permit if a shareholder does not receive dividends;
2. In which term shareholder has obligation to obtain work permit, and if transitional period applies to them;
3. What other sanctions may apply to shareholders if they will not receive work permit (except monetary fine).

Please follow our updates. REVERA will continue to monitor developments and provide updates as further clarifications become available.

Authors: Melano Svanidze, Nino Zautashvili.