Georgia’s labor migration reform moves into implementation

Amendments to Georgia’s Law on Labor Migration entered into force in June 2025, significantly reshaping the rules governing how foreign nationals may work in the country. The reforms broadened the law’s scope beyond traditional employment relationships, introducing obligations not only for hired employees but also for self-employed foreigners, entrepreneurs, and company directors.

The regulatory framework was further clarified on February 20, 2026, when the Government of Georgia adopted Resolution No. 70 approving the Rule on Granting the Right to Work to Labor Migrants and Self-employed Foreigners. This bylaw provides the procedural framework needed to implement the 2025 legislative amendments, setting out application procedures, timelines, and enforcement mechanisms.

While the regulation is intended to strengthen oversight of labor migration, it has already prompted discussion within the business community about its broad scope of application, clarity, proportionality, and potential implications for foreign investment and international talent mobility.

Expanding the scope of labor migration regulation

One of the most notable features of the 2025 amendments is the introduction of the concept of a “self-employed foreigner,” defined broadly as any foreign national without permanent residence status who carries out economic activity in Georgia for financial gain. Subsequent clarification confirmed that this category includes company partners and registered directors.

Under the regulation, both categories of labor migrants—foreign nationals employed by Georgian companies and self-employed foreigners—must obtain a work permit from the Employment Support State Agency under the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health, and Social Affairs of Georgia.

Self-employed foreigners must apply directly to the agency. The procedure may involve a video interview and, in cases involving entrepreneurial activity, submission of a business plan outlining projected investment, expected turnover, financial resources, and other supporting information.

As Nino Suknidze of Suknidze & Partners explains: “The regulation’s scope is understood to extend beyond employment relations. Directors and partners/shareholders, who are not employees, should not have to undergo procedures established for labor migrants in order to carry out management or entrepreneurial activities.”

Labor market testing for foreign employees

For foreign employees, the regulation introduces a structured labor market test designed to prioritize local candidates. Before applying for a work permit for a foreign national, employers must publish the vacancy on the state employment portal for at least ten business days.

During this period, the Employment Agency may propose Georgian candidates for the position. If an employer declines a proposed candidate, it must provide a reasoned explanation. Should the agency consider the explanation insufficient, the proceeding may be terminated.

Notably, this requirement may apply even if an employment agreement with a foreign candidate has already been signed.

The regulation provides certain exemptions, including for companies holding international company status, innovative startup entities, some international education specialists, and positions offering salaries exceeding GEL 15,000 per month. However, authorities retain discretion to require the standard procedure even in some of these cases.

Permit validity and compliance obligations

Once a work permit is granted, foreign nationals residing abroad must apply for a D1 visa within 30 days, while those already in Georgia must apply for a residence permit within 10 days. Failure to meet these deadlines may result in cancellation of the work permit.

Processing typically takes 30 calendar days, with expedited processing available for an additional fee. Work permits are generally issued for periods ranging from six months to one year, while IT professionals may receive permits valid for up to three years.

The regulation also introduces a cancellation rule affecting self-employed foreigners who remain outside Georgia for more than six months. For directors and investors who frequently travel or manage companies remotely, this provision may create practical compliance challenges.

Sophie Natroshvili of BGI notes: “The six-month absence rule may not align with the realities of international corporate governance. Not every director or investor is physically present in Georgia on a continuous basis.”

Transitional timelines and sectoral quotas

The regulation also establishes transitional deadlines for compliance. Those labor migrants, registered with the platform before March 1, 2026, must obtain both a work permit and residence permit by January 1, 2027, while self-employed foreigners already operating in Georgia must comply earlier, by May 1, 2026.

Another notable innovation is the introduction of annual quotas in certain sectors. Courier services, passenger transportation (including taxi drivers), and tourist guide services currently have quotas set at zero, while mountain and ski guides are permitted under a quota of 200 positions.

Although these quotas primarily target low-skilled migration, they signal a broader shift toward a more managed and selective migration policy.

Remaining uncertainties

Despite the regulation’s procedural detail, several interpretative questions remain.

One of the most significant concerns relates to non-resident directors and shareholders. As Salome Meunargia of LPA Law Firm observes: “It remains unclear whether occasional board participation or strategic oversight by a non-resident shareholder constitutes ‘labor activity’ requiring authorization under Georgian law.”

Similarly, the regulation does not explicitly address supervisory board members or advisory directors, leaving companies to interpret whether these roles fall within the definition of self-employment.

Additional uncertainty arises in relation to foreign nationals who qualify as Georgian tax residents—typically after spending 183 days in the country within a consecutive twelve-month period—but provide services exclusively to foreign clients outside Georgia.

Kate Mamasakhlisi of Suknidze& Partners explains: “There is uncertainty as to whether foreigners residing in Georgia employed by foreign entities are also required to obtain the right to work.”

Questions also arise about digital nomads and remote employees of foreign companies residing in Georgia. Zakaria Shvelidze of EY notes: “Georgia has built a reputation as a flexible destination for remote professionals. Any interpretation that inadvertently captures digital nomads under a strict permit regime should be carefully assessed.”

A shift toward managed migration

The February 2026 regulation effectively transforms the June 2025 legislative amendments into a comprehensive migration compliance regime. Vacancy posting requirements, permit procedures, sectoral quotas, and expanded enforcement powers represent a significant evolution in Georgia’s migration policy.

While the objective of formalizing labor migration is clear, the overall effect signals a shift toward a more structured—and potentially more restrictive—system. As Zakaria Shvelidze concludes: “Effective migration management is important. The critical issue is ensuring clarity and proportionality so that regulation strengthens, rather than constrains, Georgia’s attractiveness for investors and skilled professionals.”

In the coming months, AmCham, together with the Investors Council and the broader business community, is expected to continue consultations to ensure that implementation achieves its regulatory objectives without undermining entrepreneurship, investment, or Georgia’s competitiveness as a business destination.