Most Foreign Founders Don't Need a Georgian Work Permit.

When Georgia's Government Resolution №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 Labor Migration. The amendments added six new exemption sub-clauses to Article 1(4) — Z, T, I, K, L, and M — and created an entirely new legal institution at Article 13⁹: short-term professional activity, which can be performed without work authorization at all.

The combined effect of Resolution №70 and Law №1509 is more nuanced than the headlines. Yes, Georgia introduced a mandatory work authorization regime. And yes, most foreign founders don't need to apply for one. The exemptions cover the configurations most foreign-client professionals, foreign-employer remote workers, and LLC directors actually run.

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

What Resolution №70 actually requires#

The mandatory regime applies narrowly. Resolution №70 establishes that foreign nationals without permanent residence in Georgia must obtain work authorization from the Employment Promotion State Agency — the issuing authority within the Ministry of Labour — before performing two specific kinds of activity:

• 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 authorization is mandatory. The process for Georgian employers hiring foreign nationals: post the vacancy on the Worknet platform for at least 10 working days, document that no suitable local candidate was available, submit an electronic application through the migration system. Standard processing runs 30 calendar days; expedited processing runs 10 working days. The service fee is capped at 500 GEL under Article 13⁴(8) of the Law on Labor Migration. When an employment contract ends or is modified, employers must report the change within 5 calendar days.

For self-employed foreigners conducting paid activity in Georgia, the application runs through the same system. If the configuration genuinely places you in the "self-employed foreigner" category as defined in Article 3, sub-clause "G2" — independent contractors in trade, services, or other activities pursued for financial gain — you need the permit unless an exemption applies.

The narrow construction matters. Resolution №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 company, or running a Georgian self-employment activity for financial gain inside Georgia. Most foreign founders, on closer examination of their actual configuration, fit into one of the exemption categories — not into the regime that requires the permit.

The six exemption sub-clauses#

Law №1509 added sub-clauses Z, T, I, K, L, and M to Article 1(4) of the Labor Migration Law. Each exempts a specific configuration from the work authorization requirement entirely. The four most relevant for our reader profile are K, L, M, and T.

Sub-clause K — fully remote work for a Georgian employer where physical presence isn't required. If your work for a Georgian company is performed entirely remotely — no Georgian office, no on-site requirement, the activity does not require physical presence in Georgia — you're exempt. This was added to remove a friction point for Georgian startups and tech companies running distributed international teams, but it applies broadly to any genuinely-remote employment relationship with a Georgian employer.

Sub-clause L — services for non-resident clients tied to activities outside Georgia. This is the exemption that covers most foreign freelancers and IT contractors. If you're rendering services to non-resident clients (foreign companies, foreign individuals) and the work is connected to that non-resident's activities outside Georgia, you're exempt. A Berlin-based developer working for German software companies, an Israeli marketing consultant working for European agencies, a remote contractor billing US clients — the typical foreign-client freelancer configuration sits cleanly inside sub-clause L.

Sub-clause M — management, governance, or audit committee roles at Category I, II, or III enterprises. Foreign nationals serving as directors, board members, or audit committee members at Georgian companies classified under the Accounting, Reporting and Audit Law's Category I, II, or III enterprises are exempt. This covers most LLC directors and Virtual Zone LLC governance roles. The exemption is structural — Category classification depends on the company's revenue, asset base, and employee count, but most foreign-founded LLCs in our typical client profile fit within the relevant categories.

Sub-clause T — short-term professional activities as defined by government decree. This is the exemption that pairs with the new Article 13⁹ framework discussed below. Specific activities will be enumerated in a separate decree.

Sub-clauses Z and I — special residence permit holders authorized at the written initiative of a Georgian government member, and persons working for public institutions or state-owned enterprises. These exemptions apply to narrower configurations.

The exemptions are not self-applying. The burden of proving an exemption applies falls on the individual or their employer. Documentation matters: an employment contract that explicitly establishes the fully-remote nature of the work for sub-clause K, contractual evidence of the non-resident-client structure for sub-clause L, corporate governance documents confirming the Category classification for sub-clause M. When you assess your configuration against the exemption framework, document the basis.

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 work authorization 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 "labor immigrant" or a "self-employed foreigner" under Georgian law. The classification carries significant implications for taxation, registration, and immigration status.

The specific list of qualifying activities, duration limits, and classification criteria will be determined by a separate government decree. Until that decree is published, the operational reality of Article 13⁹ is incomplete — the framework exists in the law, but the qualifying activities and time limits await regulatory specification.

For now, what's clear: Georgia recognized that a substantial category of foreign professional activity (consultancy visits, conference participation, temporary project work, board meetings, training delivery) doesn't fit either the long-term employment frame or the self-employment-in-Georgia frame. Article 13⁹ creates a third path for those configurations.

Mapping your configuration#

For most readers of this article, the question isn't "do I need a work permit" but "which exemption applies to me, and how do I document it?" Common configurations and the exemption framework that fits each:

Foreign-client freelancer or IT contractor (operating as IE+SBS, foreign clients, foreign-paid revenue): Sub-clause L typically applies. The work is rendered to non-resident clients, the activities are connected to those clients' operations outside Georgia. Documentation: contracts with foreign clients, invoicing records showing foreign-paid revenue. The IE+SBS structure itself doesn't require additional work authorization beyond the exemption framework.

Foreign director of a Georgian LLC (Virtual Zone, International Company, FIZ): Sub-clause M typically applies for directors of Category I, II, or III enterprises. Documentation: corporate governance records confirming the Category classification, the director's appointment documents.

Remote employee of a foreign company (foreign employer, foreign payroll, working from Georgia): Neither Resolution №70 nor the exemption framework directly addresses this configuration in most circumstances. The remote employee is not employed by a Georgian company (so the "compensated work for a Georgian employer" trigger doesn't apply), and they're not running self-employed activity in Georgia (their employer abroad pays them; they don't operate a Georgian business). The work permit regime generally doesn't reach this configuration. The relevant compliance considerations sit in tax residency and visa/entry status, not in the work authorization framework.

Remote employee of a Georgian company, working from abroad: Sub-clause K applies — fully remote work for a Georgian employer where physical presence is not required.

Foreign founder visiting Georgia for short-term project work, board meetings, or consulting visits: Article 13⁹ likely applies once the government decree specifies the qualifying activities. Until the decree is published, the practical compliance position depends on the specifics of the visit; documenting the temporary, project-based, non-labor-market nature of the activity preserves the future application of the framework.

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 work authorization position depends on whether they're operating in a director role (sub-clause M may apply) or in an operational capacity that qualifies as self-employed activity in Georgia.

Foreign founder physically in Georgia, running a Georgian operation with no exemption applying: The work authorization regime applies. The application process is operational rather than punitive, but it requires planning into the engagement timeline.

What's still in regulatory motion#

The April 2026 amendments answered most of the structural questions raised by Resolution №70's March 2026 introduction. A few questions remain in motion.

The Article 13⁹ qualifying activities decree has not yet been published. Until it is, the operational reality of the short-term professional activity framework is incomplete — the law authorizes the category, but the specific activities, duration limits, and documentation requirements await government decree. Foreign professionals planning short visits to Georgia for project-based, event-based, or temporary engagements should monitor for the decree.

The expanded definition of "self-employed foreigner" at Article 3, sub-clause "G2" captures more foreign professionals within the regulated category than the prior version did. This makes the exemption framework more important — without it, more configurations would default into the authorization requirement. With it, most foreign founders can confirm their exemption basis without entering the permit regime.

Enforcement priorities will become clearer over time. The Employment Promotion State Agency will announce its enforcement focus through practice rather than through advance announcements. Foreign founders operating cleanly within an exemption framework, with documentation supporting the exemption, are well-positioned regardless of how enforcement evolves.

How to confirm your position#

The exemption framework is structured but not always self-evident. A few practical steps for foreign founders evaluating their position:

Map your specific activity against the six exemption sub-clauses (Z, T, I, K, L, M) and the new Article 13⁹ short-term professional activity framework. Most foreign founder configurations land in one of the categories — sub-clause L for foreign-client freelancers, sub-clause M for LLC directors, sub-clause K for fully-remote employees of Georgian companies, Article 13⁹ for short-term visits.

Document the basis for the exemption. Contracts with foreign clients (sub-clause L), corporate governance records and Category classification (sub-clause M), employment contracts establishing fully-remote work nature (sub-clause K), records of the temporary and project-based nature of the visit (Article 13⁹).

Confirm the documentation holds up under review. The exemptions are structured as legal categories; configurations that look like an exemption but don't fully fit may face challenge during enforcement. Borderline configurations — particularly those that combine foreign and Georgian elements, or that have changed over time — warrant careful structuring.

For most readers, the answer is straightforward and the documentation is in place already. For configurations where the framework is less obvious, scoping the position before any enforcement question arises is the cleaner approach.

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

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