Georgia work permits: multiple employers, remote work and the limits of the new regime

An October 15 practitioner report raises questions about multiple employers and remote work. The current statute contains important exclusions and separate residence requirements.

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What the new report establishes

On 15 October 2026, BM published concerns from GLCC lawyer Enri Abuladze about the administration of Georgia’s foreign-worker authorisation system. The examples concern work for several companies and foreign employees visiting Georgia while normally working remotely. These are attributed practitioner observations; the report does not contain an administrative case file or a court judgment establishing a universal interpretation.

The practical question is therefore narrower than whether every foreign visitor needs a work permit: which activity, employer and physical location bring a person within the current Labour Migration Law? Nationality alone cannot answer it. Permanent residence, other statutory exclusions and the actual commercial arrangement also matter.

Read the exclusions before choosing an application

Article 1 of the Labour Migration Law defines the regulated activity and exclusions. Among them are fully remote work for a local employer where the work does not require entry into Georgia, and work or services for a non-resident connected with that non-resident’s activities outside Georgia. These are different exclusions. A contract with a foreign company should be examined against the second provision; calling a job “remote” is not a substitute for checking its conditions.

For example, an employee who normally remains abroad but travels to Georgia to perform local duties may no longer fit the first exclusion during those duties. Conversely, the text concerning services for a non-resident requires its own analysis and should not be ignored merely because the contractor uses a laptop in Tbilisi. Evidence of the client’s residence, business activity, deliverables and where services are directed is more useful than a generic job title.

Multiple companies and self-employment

Article 13⁵(7) ties an employee’s work authorisation to a particular local employer. Two companies in the same holding remain separate employers if the contracts and legal entities are separate. The commercial group name cannot itself enlarge the permit. By contrast, the same paragraph describes a self-employed person’s authorisation by specialty or activity sector. It does not establish a general rule requiring one authorisation for every customer. Misclassifying an employment relationship as contracting can create additional risk.

Article 13⁴ places the employee application with the local employer after the employment contract is concluded; a self-employed person applies directly. This makes an accurate contract and identification of the responsible applicant central to compliance. An intermediary’s promise that one document covers all future work should be checked against the scope of the actual decision.

Work authorisation and residence must be coordinated

Under Article 13⁵, a person outside Georgia generally must apply for a D1 visa within 30 calendar days after obtaining the right to work; a person already in Georgia generally must apply for the relevant work or IT residence permit within 10 calendar days. Paragraph 2 contains exceptions, including an existing Georgian residence permit and the specified fully remote arrangement. These are application deadlines, not guarantees that immigration status is granted.

Lawful entry and stay remain governed by the separate Law on the Legal Status of Aliens and Stateless Persons. A work application should not be assumed to extend a visitor’s permitted stay. Article 13⁵(8) allows a court challenge within one month of notification, while paragraph 9 warns that the challenge itself does not create a right to work or postpone departure or removal.

A practical file for employers and incoming workers

  • Map each contracting entity, its residence, the workplace and the duties performed during visits.
  • Identify the precise statutory exclusion, if any, and retain the evidence supporting it.
  • Match the proposed work to the employer or sector named in the authorisation.
  • Calendar work, visa and residence deadlines separately; obtain a written decision when disputing an authority’s interpretation.

The October report justifies closer scrutiny of practice, but a blanket “all remote workers need permits” conclusion would omit enacted exclusions. For the consequences of an adverse immigration decision, see our analysis of removal safeguards.

Legal check date

Sources and law checked on 15 October 2026. Later developments are not reflected automatically. Application of the rules depends on the individual facts.

Sources and legal references

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