Labour Migration: What Has Changed Since 1 March

The new labour migration regime, which entered into force on 1 March 2026, has already been amended on several occasions within a period of merely seven months. In April, the Parliament adopted amendments to the Law under an expedited procedure. In July, the Government revised Resolution No. 70 and the rules governing residence, and a further package of amendments entered into force on 1 September.

In general terms, a number of categories (persons working remotely, the public sector and the heads of large companies) have been released from the obligation to obtain a permit. Conversely, for those who remain subject to the permit requirement, the procedure has become more detailed and more stringent.

This article examines the changes introduced since March: which rules no longer apply in the form in which they were originally adopted, which entirely new rules have been introduced, and which rules remain unchanged.

Amendments to the March Rules

Several rules that applied as of 1 March are currently applied differently.

Foreign directors

In March, it was understood that a foreign director (for example, a citizen of the United Kingdom or the United States) was in all cases required to hold the right to engage in labour activity (the “Work Authorisation”). Resolution No. 321 released from this obligation the heads and audit committee members of public interest entities and of Category I–III entities. Accordingly, the decisive factor today is the category of the entity. The Agency determines such category on the basis of the data held by the Service for Accounting, Reporting and Auditing Supervision (reportal.ge). Where a company is not listed therein as a Category I–III entity or as a public interest entity, it shall be deemed a Category IV entity, and its director shall be required to obtain both the Work Authorisation and an extract from the Registry. The majority of small businesses fall within Category IV; consequently, for most foreign directors the obligation remains in effect in practice.

Determination of the size category

The size category of an entity shall be determined on the basis of three criteria (the total value of assets, revenue and the average number of employees) for the 2016 reporting period and subsequent periods, since the Law of Georgia “On Accounting, Reporting and Auditing” (hereinafter the “Law”) entered into force in 2016. Where, as at the end of the 2016 reporting period, an entity meets at least two of the three aforementioned criteria, it shall be deemed an entity of the corresponding size category.

The size category of an entity shall first be determined for the reporting period ended 31 December 2016. Where the reporting period of an entity does not coincide with the calendar year, its size category shall first be determined as at the closing date of the first reporting period ended after 24 June 2016. Where an entity was incorporated after the reporting period ended 31 December 2016, its size category shall first be determined on the basis of the data for the first reporting period completed following its incorporation.

Change of size category in subsequent periods

Where, as at the end of two consecutive reporting periods, an entity no longer meets at least two of the three criteria established for the determination of the size category, the size category of the entity shall change. In other words, where, as at the end of two consecutive reporting periods, an entity no longer corresponds to the size category under which it submitted its most recent reports, its size category shall change, and it shall submit its reports in accordance with the requirements applicable to the category determined on the basis of the data for the most recently completed reporting period.

The foregoing principle shall not apply to an entity whose size has increased by two or more categories as compared with the preceding reporting period. In such a case, the size category of the entity shall change within the current reporting period, and the entity shall submit its reports in accordance with the requirements applicable to the category determined on the basis of the data for the most recently completed reporting period.

Remote work

Initially, the exemption applied solely to persons working fully remotely for a local employer. Government Resolution No. 1509 elevated this exemption to the level of the Law and added a second exemption: The Work Authorisation is likewise no longer required for a person working for a non-resident (for example, a foreign company), provided that such work relates to the non-resident’s activities outside the territory of Georgia.

Short-term activities

In March, it was sufficient that the activity did not exceed four months and that the employer registered the foreign national free of charge. At present, the four-month period is calculated on a cumulative basis within a calendar year. The registration must be confirmed by the Agency before the commencement of work. Where such confirmation has not been obtained, where the person is staying in the country unlawfully, or where the profession is subject to a quota, the activity shall no longer be treated as short-term, and liability shall be imposed on both the employee and the employer.

Quota approval

Under the March rules, the quota was required to be approved 10 days prior to the application for a permit; it must now be approved 10 working days prior thereto. It has been clarified that the 5% threshold shall not apply where the number of employed persons is fewer than five. The quota is set by the Agency. The employer may submit a reasoned request for an increase of the quota, and where the employer has not used the quota in full, the Agency may reduce its quota for the following year.

Turnover requirement and newly established companies

The turnover requirement of GEL 50,000 (GEL 35,000 for educational and medical institutions) initially applied to all companies, including newly established ones. Consequently, between 1 March and 9 July a new company was, in practice, unable to employ a foreign national. Pursuant to Resolutions No. 321 and No. 317 of the Government of Georgia, a company that has existed for less than three months may employ up to three foreign nationals without confirmation of turnover. To benefit from this exemption, it is sufficient to submit a certificate on the number of foreign nationals employed by the company, evidencing that their number does not exceed three. However, a work residence permit issued on this basis shall be valid for six months only, after which the turnover must nevertheless be confirmed should the holder wish to extend the permit.

Change of position or terms of employment

Under the March rules, any change of the terms of employment or of the position without prior approval was subject to a fine. Resolution No. 321 clarified this rule: a change of the field of activity requires a new Work Authorisation, whereas a change of the level of position, salary or working schedule does not. In the latter case, the employer is only required to reflect the amendment to the employment contract in the system.

Deficiencies and documents

Pursuant to Resolution No. 321, the applicant has 10 calendar days and a single opportunity to remedy a deficiency: where the deficiency is not fully remedied at the first attempt, the Work Authorisation shall be refused. Furthermore, at the time of submission of the application, the passport must remain valid for at least six months.

Amendment to the documents to be submitted in connection with the temporary residence permit for persons employed in the field of information technology. A temporary residence permit for persons employed in the field of information technology is issued to labour immigrants and to foreign nationals registered in Georgia as individual entrepreneurs holding small business status who have obtained the Work Authorisation and who carry out activities in the field of information technology as determined by Resolution of the Government of Georgia, and to members of their families, as well as to a person authorised to manage and represent an international company operating in the field of information technology who has obtained the Work Authorisation, and to members of such person’s family.

A person authorised to manage and represent an international company operating in the field of information technology shall be obliged to submit to the Agency a document certifying his or her authority to manage and represent such international company operating in the field of information technology.

Entirely New Provisions

**New exemptions (Law on Labour Migration, amendments of 15 April 2026) ** The Law and, accordingly, the obligation to obtain the Work Authorisation no longer apply to the following persons:

• Holders of a special residence permit, where the permit has been issued upon the written initiative of a member of the Government;
• Persons employed by a legal entity of public law or by an enterprise with State participation;
• Persons working for a non-resident, where the activity relates to the non-resident’s activities outside the territory of Georgia. This exemption shall not apply to a self-employed person who requires a residence permit in order to remain in the country;
• Persons engaged in the conservation, restoration or rehabilitation of cultural heritage monuments; heads and audit committee members of public interest entities and of Category I–III entities.

Where an applicant falls within an exempt category established by the Law and nevertheless applies for the Work Authorisation, the Agency shall leave the application without consideration, and the fee shall not be refunded. It is therefore advisable to verify, prior to filing an application, whether the Work Authorisation is required at all.

**C5 visa for remote workers (Law on the Legal Status of Aliens and Stateless Persons, as amended on 15 April 2026) ** A new category C5 visa has been introduced into the Law on the Legal Status of Aliens. It is intended for persons entering for tourism purposes who work exclusively for a non-resident (for example, remotely for a foreign company).

• It is issued for a term of up to five years, with the right of multiple entry;
• It extends to the holder’s spouse and minor children;

Work on the local labour market under a C5 visa is not permitted. Work for a local company continues to require the Work Authorisation.

**Amendments in force since 1 September (amendments of 25 June 2026 to the Law on the Legal Status of Aliens and Stateless Persons and to the Law on Labour Migration) **

• An appeal against a fine no longer suspends expulsion. An appeal by a labour immigrant against a monetary penalty shall not suspend the consideration of the issue of expulsion or the enforcement of the relevant decision.
• This is one of the most stringent changes introduced since March.
• Persons holding the right of temporary stay. The Law on Labour Migration no longer applies to persons holding the right of temporary stay under Article 60 of the Law on the Legal Status of Aliens.
• Appeals against decisions of the Agency may be filed within 10 calendar days. An appeal shall not automatically suspend expulsion.
• D6 visa. Applies to minors enrolled in general, vocational or higher educational institutions. It is issued for one year and is extended until the completion of school or until the holder attains the age of majority. It may also be issued to the parents and minor siblings.
• Study residence permit. It is now granted to adults only. Three new grounds for termination have been added: the lapse of 90 days from the suspension of student status; the accumulation of less than one third of the required credits; and absence from the country for more than 183 days. The educational institution is under an obligation to notify the Agency.
• Spouse residence permit. Initially issued for one year, then extended for two years at a time, up to a total of five years. Thereafter, the holder shall be granted a permanent residence permit.

Immediate Action Required of Businesses

1. Verify on reportal.ge the category to which your company belongs. This determines whether a foreign director requires the Work Authorisation.
2. Draw up a list of all foreign employees and determine, in respect of each of them, whether the Work Authorisation is still required or whether the employee falls within a new exemption (remote work, work for a non-resident, etc.).
3. For any employees who are still working on the basis of a former registration with the Ministry of Health, initiate the procedure without delay. Both the Work Authorisation and a residence permit must be obtained before 1
4. January 2027, and the issuance of the Work Authorisation may take up to 30 days.
5. Register short-term visits (consultants, trainers, technical personnel) in the system prior to the commencement of work and await confirmation from the Agency. Ensure that the annual limit of four months is not exceeded.
6. Upon a change of the field of activity, apply for a new Work Authorisation. Record any change of salary, working schedule or level of position in the system.
7. Plan the quota approval at least 10 working days prior to the application for a permit.

This article is provided for information purposes only and reflects the legal position as of October 2026.