Georgia's 2026 Work Permit Exemptions: What Applies to Foreign Founders

When Georgia's Government Ordinance No. 70 took effect on March 1, 2026, the headlines that traveled abroad sounded ominous. A new mandatory work authorization regime. Penalties for unauthorized work. A formal compliance obligation that didn't exist before. For foreign founders running Georgian operations, foreign freelancers serving foreign clients, and remote workers based in Tbilisi or Batumi, the immediate question was: do I now need a work permit I didn't need a month ago?

Six weeks later, on April 15, 2026, the Georgian Parliament adopted Law №1509, amending the Law on Labour Migration. The amendments added new exemption grounds to Article 1(4), paragraphs (g) to (m) in the English text on Matsne. They also created a new legal institution at Article 13⁹: short-term professional activity, which can be performed without the right to work. Law №1815 of June 2026 added paragraph (n). In July 2026, the Government amended Ordinance No. 70 with implementing detail that matters to founders.

The combined effect is more nuanced than the headlines. Georgia introduced a mandatory work authorization regime, and the exemptions take a number of common founder configurations out of it. But each exemption turns on specific facts, and the July 2026 rules added conditions to two of the grounds founders rely on most.

This article walks through who needs the permit, who's exempt, and how we confirm which side of the line you sit on.

What Ordinance No. 70 actually requires#

The mandatory regime applies narrowly. Ordinance No. 70 establishes that foreign nationals without permanent residence in Georgia must obtain the right to work before performing two specific kinds of activity. The right is issued by the State Employment Support Agency, a public-law body under the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs. The two kinds of activity are:

• Compensated work for a Georgian employer under an employment contract
• Self-employed, freelance, or entrepreneurial activity for financial gain in Georgia

If your activity falls into one of these categories and no exemption applies, the right to work is mandatory. Georgian employers apply for their foreign employees through the labourmigration.moh.gov.ge portal. The July 2026 amendments replaced the original vacancy-posting step with employer-side conditions, including:

• A minimum annual turnover of GEL 50,000 per foreign hire, waived for businesses registered within the last three months that employ no more than three foreigners
• For larger foreign headcounts, an annual quota agreed with the Agency in advance

The Agency decides within 30 calendar days of a complete application, or within 10 working days on the expedited route, which carries a higher government fee. When an employment contract ends early or is modified, the employer must report the change within 5 calendar days.

Self-employed foreigners apply through the same portal, personally: the July 2026 amendments don't allow a self-employed applicant to file through a representative. They then attend a mandatory video interview with the Agency. Article 3(c²) of the Law defines the "self-employed alien" broadly: someone who carries out labour activity in Georgia for financial benefit, including trade, services or other activities as an independent contractor. Self-employed applicants face a similar turnover test, through their company or IE. If that definition fits you, you need the right to work unless an exemption applies.

The narrow construction matters. Ordinance No. 70 does not create a general "all foreigners working in Georgia need a permit" rule. It creates an authorization regime for two specific configurations: employed by a Georgian employer, or running a self-employment activity for financial gain inside Georgia. Whether a particular founder sits inside the regime or in one of the exemption grounds depends on the actual configuration: the activity, the clients, the company and the residence position.

Work authorisation is not a residence permit. The right to work concerns the activity; a residence permit concerns your stay. Holding one doesn't automatically give you the other, although some residence permits — such as the investment residence permit — take the holder outside the Law, as set out below. We assess both together.

The exemption grounds that matter to founders#

Law №1509 added paragraphs (g) to (m) to Article 1(4) of the Law on Labour Migration, and Law №1815 added (n). The English lettering on Matsne differs from the Georgian original; this article uses the English lettering. The four grounds most relevant to our reader profile are (j), (k), (l) and (h).

Paragraph (j): work for a Georgian employer done entirely from abroad. If your work for a Georgian employer is performed completely outside Georgia and doesn't require you to enter the country, the Law does not apply to it. It covers an employment relationship with a Georgian employer where the work genuinely happens outside Georgia.

Paragraph (k): services for non-resident clients tied to activities outside Georgia. This is the ground most relevant to foreign freelancers and IT contractors. If you render services to non-resident clients (foreign companies, foreign individuals) and the work is connected to that non-resident's activities outside Georgia, the Law does not apply to that activity. Typical (k) configurations include a developer working for German software companies, a marketing consultant working for European agencies, or a contractor billing clients in Singapore. The implementing rules add a condition that matters for IE holders. Ordinance No. 70, as amended in July 2026, excludes from this ground an individual entrepreneur who needs a residence permit to stay in Georgia lawfully.

Paragraph (l): management, governance, or audit committee roles at Category I, II, or III enterprises. This covers managerial or governing activity under the Law on Entrepreneurs at an enterprise in Category I, II or III under the Law on Accounting, Reporting and Audit, and activity on an audit committee. Category IV is not listed. It is the smallest class: an entity that meets at least two of three tests, namely assets up to GEL 1 million, revenue up to GEL 2 million and up to 10 employees. Under the July 2026 rules, the Agency checks the category against data from the accounting supervision service. A company not identified there as Category I, II or III (or as a public interest entity) is treated as Category IV. A director of a small or newly formed company should not assume (l) applies.

Paragraph (h): short-term professional activity. This is the ground that pairs with Article 13⁹, discussed below.

Paragraphs (f), (g) and (i). Paragraph (f) predates the 2026 amendments and covers holders of a valid investment residence permit. Paragraph (g) covers holders of a special residence permit issued at the written initiative of a member of the Government. Paragraph (i) covers people working for public institutions or state-owned enterprises. These grounds apply to narrower configurations.

The exemptions are not self-applying. Documentation matters, and each ground needs its own:

• For (j): an employment contract that establishes the work is done entirely outside Georgia.
• For (k): contractual evidence of the non-resident-client structure.
• For (l): evidence of the company's category.

Whichever ground applies, the basis should be documented — we prepare that file with you.

The new Article 13⁹: short-term professional activity#

Law №1509's most structurally innovative change was the creation of Article 13⁹, a purpose-built framework for foreign nationals visiting Georgia for short-term professional purposes. Under Article 13⁹, a foreign national may perform short-term professional activity without the right to work and without a corresponding residence permit, provided three conditions are met:

• The activity takes place within a temporary visit
• It does not constitute long-term employment in the local labour market
• It is tied to a specific short-term project, event, or service

A person performing short-term professional activity under Article 13⁹ is explicitly not classified as a "labour immigrant" or a "self-employed alien". The activity sits outside the right-to-work regime.

Article 13⁹ leaves the list of activities, their duration, the qualifying criteria and the monitoring procedure to a Government ordinance. The July 2026 amendment to Ordinance No. 70 supplied part of that detail:

• Short-term professional activity may not exceed four months in total in a calendar year, and never more than the person's lawful stay.
• The Georgian employer or service organiser must register the person on the labourmigration.moh.gov.ge portal before the activity starts.
• Without a registration confirmed by the Agency, the activity doesn't count as short-term professional activity. The same applies if the person is in Georgia without a lawful basis, or if the activity is one subject to an annual quota.

The framework is aimed at professional activity that doesn't fit either the long-term employment frame or the self-employment-in-Georgia frame: work linked to a specific short-term project, event or service. Whether a particular visit qualifies depends on those conditions, so it's worth checking before the trip rather than after.

Mapping your configuration#

The useful question is often not only "do I need a work permit" but "does an exemption apply to me, and how do I document it?" Common configurations and how the framework treats each:

Foreign-client freelancer or IT contractor (operating as IE with Small Business Status, foreign clients, foreign-paid revenue): Paragraph (k) is the ground to test, since the work is rendered to non-resident clients and connected to their operations outside Georgia. The residence condition in Ordinance No. 70 then decides the outcome: under it, an IE who needs a residence permit to stay in Georgia lawfully is excluded from (k) and should plan for the right to work. Documentation: contracts with foreign clients, invoicing records showing foreign-paid revenue, and your residence position. Small Business Status is a tax status; it doesn't settle the work-authorization question either way.

Foreign director of a Georgian LLC (Virtual Zone, International Company, FIZ): Paragraph (l) applies only if the company is in Category I, II or III. A small company below the Category III thresholds is Category IV, and the implementing rules treat any company not identified as Category I, II or III as Category IV. Its director needs another ground or the right to work. Documentation: evidence of the company's category and the director's appointment documents.

Employee of a foreign company (foreign employer, foreign payroll, working from Georgia): Paragraph (k) covers labour activity for a non-resident as well as services. An employee whose work relates to the foreign employer's activities outside Georgia therefore falls within it. Such an employee is also neither employed by a Georgian employer nor running a self-employed activity in Georgia. The relevant compliance considerations sit mainly in tax residency and visa/entry status.

Employee of a Georgian company, working from abroad: Paragraph (j) applies: work for a Georgian employer done entirely from outside Georgia, with no need to enter the country.

Foreign founder visiting Georgia for short-term project work, board meetings, or consulting visits: Article 13⁹ may apply if the visit meets the conditions in Ordinance No. 70:

• A specific short-term project, event or service
• No more than four months in total in a calendar year
• Prior registration by the Georgian host on the labour migration portal

Board meetings and similar governance visits may also fall under paragraph (l) where the company is in Category I, II or III.

Foreign founder running an LLC that hires Georgian-paid local staff: The hiring side triggers different obligations. The Georgian employees are subject to Georgian payroll regardless of the founder's status. The founder's own position depends on what they actually do. A director role may fall under paragraph (l) if the company is in Category I, II or III. An operational role may qualify as self-employed activity in Georgia.

Foreign founder physically in Georgia, running a Georgian operation with no exemption applying: The work authorization regime applies. We prepare and support the application, so it fits into your setup timeline.

What's still in regulatory motion#

The April and July 2026 amendments answered many of the structural questions raised when Ordinance No. 70 took effect in March 2026. A few remain in motion.

Article 13⁹ calls for a list of qualifying short-term activities. Ordinance No. 70 now sets the duration cap and the registration procedure but does not enumerate qualifying activities. Whether a specific activity qualifies is therefore still assessed case by case.

The broad definition of "self-employed alien" in Article 3(c²) captures many foreign professionals within the regulated category. That makes the exemption grounds important, and makes it worth confirming, case by case, whether one applies before relying on it.

Enforcement priorities will become clearer over time, through the State Employment Support Agency's practice. Foreign founders operating within an exemption, with documentation supporting it, are well positioned however enforcement evolves.

How we confirm your position#

We map your activity, clients, company and residence position against the exemption grounds and the Article 13⁹ rules, and tell you whether an exemption applies — with the documentation that supports it:

• Contracts with foreign clients for (k), together with your residence position if you hold an IE
• Evidence of the company's category for (l)
• An employment contract establishing that the work is done entirely outside Georgia for (j)
• The confirmed portal registration for Article 13⁹ visits

Where no exemption applies, we prepare the application file, brief you or your Georgian employer on the portal filing, and coach self-employed applicants for the Agency's mandatory video interview. Borderline configurations — mixed foreign and Georgian elements, or structures that have changed over time — get a careful written assessment rather than an assumption.

After the July 2026 changes, this matters particularly for IE holders who need a residence permit and for directors of Category IV companies. A free consultation is the place to start.

Read more about the Work Permit framework on the Residency pillar page.

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