Recently, Georgian government has made several significant changes in Labour Migration legislation by amending the Law of Georgia on Labor Migration (“New Law”) and issuing a Resolution N 70, dated 20 February, 2026, (“Resolution”) which regulates the newly introduced procedures that the Georgia-registered companies shall have to undergo, in detail. Both acts – the New Law and the Resolution took effect starting March 01, 2026. Below is provided the brief overview of all major amendments in Labour Migration legislation.

The New Law introduces a new, primary requirement for Labour Immigrants. Starting from March 01, 2026, in order to continue working or providing services in Georgia in compliance with applicable legislation, all Labour Immigrants will be required to obtain:

1. “Right to Work” e.g. Work Permit (“WP”) and
2. D1 Visa or Work Residence Permit (“WRP”) (obtaining D1 Visa/WRP is not mandatory if they already hold another type of residence permit, or their work is fully remote and their presence in Georgia is not required).

Prior to the amendments in Labour Migration legislation, a Labour Immigrant was defined as a Foreign Employee who “entered Georgia for the purpose of employment with a local employer and performed paid labor activities”.

The New Law introduces a more detailed definition of the Labour Immigrant. Under the revised definition, in addition to the Foreign Employee described above, the term Labour Immigrant now also encompasses a foreign employee who works fully remotely (collectively – “Foreign Employees”), as well as a self-employed foreigner (“Self-employed Foreigner”).

The Self-employed Foreigner constitutes a newly introduced subtype of Labour Immigrant. The New Law provides a broad definition of this category, which may include, inter alia, foreign freelancers contracted by a Georgian company, as well as foreign directors, members of the board of directors, and partners/shareholders of a Georgian company.

As the inclusion of partners/shareholders and members of management bodies within this definition may create an additional regulatory burden for Georgian companies in the course of their operations, written clarification was requested from the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia (“Labour Ministry”) regarding the scope and interpretation of the relevant provisions of the New Law. By its Letter No. MOH 1 25 01483701, the Labour Ministry confirmed that foreign members of the management bodies of Georgian companies, as well as foreign partners/shareholders of Georgian companies, fall within the definition of a Self-employed Foreigner.

Transitional Periods

Therefore, starting from March 01, 2026, all the above-mentioned persons – i.e. all Labour Immigrants are required to obtain WP and where applicable, WRP/D1 Visa as well. However, with respect to applicable deadlines, the new Labour Immigration legislation establishes certain exceptions, namely:

The New Law establishes a transitional period for all Labour Immigrants, who prior to March 1, are already registered in Labour Immigration Portal (“Portal”) – a designated website for Labour Immigrants (https://labourmigration.moh.gov.ge/). The persons having an active registration status on this Portal by March 1, shall have a period until January 1, 2027, to comply with new requirements and obtain the above permits (WP and WRP (where applicable)).

As for Self-employed Foreigners (Freelancers, Directors, Partners), the Resolution establishes another transitional period – in relation to them, the enforcement process of the new requirements established by the New Law and the Resolution (“New Requirements”) shall not start until May 1, 2026. This means that in order to comply with the New Requirements, Self-employed Foreigners (Freelancers, Directors, Partners) have to apply for WP before May 01, 2026, through the relevant website (https://self-employment.moh.gov.ge/) (“Portal for Self-employed Foreigners”).

Regulatory Bodies and Liability

The responsible state bodies for the enforcement of the New Requirements are Labour Ministry and its Legal Entity of Public Law – State Agency for Employment Promotion (“Agency”).

As for the relevant liabilities for non-compliance with the New Requirements, engaging a Self-Employed Foreigner or employing a Foreign Employee, who does not hold WP, is subject to a one-time administrative fine in the amount of 2 000 GEL. The fine is imposed separately on each party, namely the Self-Employed Foreigner or Foreign Employee, as well as the Company receiveing the services or employing such individual.

In order to ensure compliance with the New Requirements, the procedures to be undertaken by the Georgian companies and Labour Immigrants are outlined below.

WP Application – General Details

The procedure for submitting a WP application depends on the category of the Labour Immigrant– Foreign Employee or Self-employed Foreigner (Freelancers, Directors, Partners).

In all Labour Immigrants’ cases, WP application should be submitted to the Agency electronically – via Portal. The required supporting documents for the WP application are set out below.

Fees for consideration of WP application by the Agency:

Standard procedure: GEL 200, with a processing timeline of 30 calendar days from the date of receipt of complete documentation.

Expedited procedure: GEL 400, with a processing timeline of 10 business days from the date of receipt of complete documentation.

WP Application Details for Self-employed Foreigners

In order to obtain WP, the Self-employed Foreigners are required to submit the WP Application electronically to the Agency through the Portal for Self-Employed Foreigners, themselves (i.e., not through a company). The documentation that WP Application shall include is provided in Annex 2 of the Resolution.

Following the submission of WP Application and payment of the applicable fee, Self-employed Foreigners are required to attend a video interview with Agency. During the interview, they may be asked to provide information on the scope and nature of their labor or entrepreneurial activities in Georgia, as well as their specific expertise in the relevant field.

Following video-interview, if successful, Self-employed Foreigner shall be granted a WP for a term of at least 6 months and no more than 12 months. The duration of the granted WP may depend on the term of the contract between Self-Employed Foreigner and the Georgian company, or on the individual’s involvement in the company’s entrepreneurial or labor activities. However, irrespective of the above factors, WP term cannot exceed 1 year.

A Self-Employed Foreigner may request the extension of WP, by addressing the Agency via Portal for Self-employed Foreigners with the up-to-date WP application, at least 30 days prior to the expiration of the existing permit. In connection with the extension, the individual is not required to undergo the video interview described above.

WP Application Details for Foreign Employees

Based on the New Law, WP obtaining procedure for the Foreign Employees who are already registered in Portal prior to March 01, 2026 (“Current Foreign Employees”) differs from the new Foreign Employees who will be employed after the entry into force of New Law (“New Foreign Employees”). However, given the absence of established practice in this regard, the possibility that the Agency may interpret the procedure differently, thereby subjecting all Foreign Employees to the new, more complex procedure, cannot be fully excluded.

Procedure for Current Foreign Employees:

In order to obtain a WP for its Current Foreign Employee, who is already registered in Portal prior to March 1, 2026, the Employer electronically – via Portal, provides the Agency with the WP application of the Employee. The Employee’s WP application shall include the relevant documentation provided in Annex 1 of the Resolution. Following the submission and acceptance of the WP Application and the payment of the applicable submission fees by Employer, if WP Application is successful, the Foreign Employee will be granted a WP for the duration of the employment term specified in their employment agreements but not exceeding one year.

Procedure for New Foreign Employees:

Unless one of the specific exemptions listed below (“Specific Exemptions”) applies, the newly introduced procedure requires that, prior to deciding to employ a Foreign Employee, a Georgian company must first publish the relevant vacancy on the newly introduced website (www.worknet.moh.gov.ge).

Within 10 calendar days following the publication of the vacancy, the Agency will provide the employer, through the same website, with suggested non-foreign persons for the position. If the employer decides to reject the proposed candidates, it must submit substantiated explanation for such rejection within 3 calendar days. Within 3 calendar days of receiving the employer’s substantiation, the Agency will issue a decision either to continue or terminate the WP procedure (see the “Additional Regulations” section for further details).

If the Agency decides to continue the procedure, the Employer becomes entitled to apply for a WP for its future employee by submitting the employee’s WP application together with the supporting documentation listed in Annex 3 of the Resolution, electronically to Agency via the Portal.

In both of the above cases, following the submission of the WP Application and the payment of the applicable submission fees by the Employer, if WP Application is successful, the Foreign Employee will be granted a WP for the duration of the employment term specified in their employment agreements but not exceeding one year.

The Employer may request an extension of the Foreign Employee’s WP by submitting an updated WP application for the employee to the Agency via the Portal, at least 30 days prior to the expiration of the existing WP. The current reading of the New Law suggests that, in the extension procedure, the Employer will not be required to follow the procedure applicable to New Foreign Employees, including the vacancy placement requirement and the related steps described above.

Specific Exemptions

Newly introduced procedure for New Foreign Employees does not apply to the New Foreign Employees that fall under the below Specific Exemptions:

1. New Foreign Employees to be employed by the Employers having International Company Status under the Tax Code of Georgia or Innovative Startup Status under Law of Georgian on Innovations.
2. New Foreign Employees that are international experts in education field.

• New Foreign Employees to be employed at the positions with gross monthly salary of no less than GEL 15,000 that require higher education in a field relevant to the work to be performed. (However, under specific circumstances – based on “the needs of the local labor market” as stated by the Resolution, the Agency maintains discretion not to apply this exemption to the New Foreign Employees that meet the above criterion: GEL 15 000 salary threshold and higher education requirement).

New Foreign Employees that fall under the above Specific Exemptions, apply for WP in accordance with the procedure established for Current Foreign Employees.

WRP / D1 Visa Application Details

Within 10 days following the granting of WP, if Labour Immigrant is present in Georgia at the material time, all Labour Immigrants must apply LEPL of Ministry of Justice of Georgia – State Services Development Agency (“State Service Agency”) for WRP, unless they already hold another type of residence permit, or perform work fully remotely without requiring physical presence in Georgia. The WRP is issued by State Service Agency within 30 days from the receipt of complete documentation and is granted for the duration of the WP term.

Within 30 days following the granting of WP, if the Labour Immigrant is outside of Georgia at the material time, all Labour Immigrants must apply to the Ministry of Foreign Affairs of Georgia for a D1 Visa, unless they already hold another valid type of residence permit or perform work fully remotely without requiring presence in Georgia. The D1 Visa is issued by Ministry of Foreign Affairs for the duration of WP term.

Additional Regulations

If the Agency refuses to issue a WP following the examination of WP application, or terminates WP proceedings on the grounds of a) failure to provide complete WP application (including supporting documentation) within the established timelines or b) failure to provide sufficient justification to rejecting the candidates suggested by the Agency, Labour Immigrant will be prohibited from re-applying for a WP for a period of 1 month.

With respect to Self-Employed Foreigners, one of the grounds for cancellation of a WP is the individual’s departure from the territory of Georgia for a continuous period exceeding 6 months. At present, neither the New Law, nor the Resolution clarifies how this provision applies to the Self-Employed Foreigners, whose work is fully remote and whose physical presence in Georgia is not required.