Effective 9 July 2026, the Government of Georgia introduced amendments to the country’s labour migration framework through updated Resolution №321 (the Resolution), building upon the earlier Resolution №70 of 20 February 2026. The amendments eliminate the labour market test, introduce annual employer quotas, expand exemptions from right-to-work requirements, and establish a new framework for short-term professional activities.
This article outlines the key changes introduced by the Resolution and assesses their practical compliance implications for employers, foreign nationals, and other stakeholders operating within Georgia’s labour migration framework.
Scope: Who Must Obtain the Right to Work
The Resolution identifies two categories of foreign workers who must obtain the right to work in Georgia:
- Labour immigrants — foreign nationals employed by a local Georgian employer in a paid position; and
- Self-employed foreigners — those engaged in trade, services, independent contracting, or other entrepreneurial activities in a specific field from which they derive financial benefit.
Notably, the Resolution removes the previous requirement for self-employed foreigners who are partners to a business to obtain the right to work, thereby simplifying the position of foreign equity holders engaged in passive ownership without direct operational involvement.
Expanded Exemptions from Right-to-Work Requirements
In addition to pre-existing exemptions (refugees, persons with international protection, diplomatic personnel, accredited foreign media workers, and holders of active investment residence permits), the Resolution significantly broadens the categories of foreign nationals exempt from the requirement to obtain the right to work. The newly exempt categories include:
- Foreign nationals holding a special residence permit granted at the initiative of a Georgian Government member;
- Those engaged in short-term professional activities (discussed separately below);
- Those employed in public or state-owned enterprises;
- Remote workers employed by a Georgian employer who are not required to enter Georgia to perform their duties;
- Foreign nationals employed by or providing services to a non-resident entity where the work relates to that entity’s operations outside Georgia;
- Those involved in conservation, restoration, or rehabilitation of cultural heritage sites;
- Foreign nationals with the right of temporary stay under Article 60 of the Law of Georgia on the Legal Status of Aliens and Stateless Persons; and
- Senior executives, directors, or audit committee members of significant Georgian companies (first-, second-, or third-category enterprises under the Law of Georgia on Accounting, Reporting and Auditing, or public interest entities).
The expansion of these exemptions reflects a more flexible and targeted approach to regulating foreign employment, particularly with respect to remote workers, senior corporate leadership, and individuals involved in cultural heritage activities. Employers engaging foreign nationals who fall within these categories should document the applicable exemption and retain supporting evidence.
New Framework for Short-Term Professional Activities
The Resolution introduces a dedicated framework for short-term professional activities, defined as employment of a labour immigrant not exceeding four months in total within one calendar year, calculated from the effective date of employment. The total duration of such employment must not exceed the foreign national’s period of lawful stay in Georgia.
To qualify, the employer must register the foreign employee via the electronic portal at www.labourmigration.moh.gov.ge, providing information on the local employer, the employee, and the effective and end dates of employment. Registration is mandatory and free of charge.
It’s important to note that short-term professional activities expressly exclude professions on the list defined by the Law of Georgia on Labour Migration for which the right to work may be granted within specified quotas, including courier services, passenger transportation, and tour, mountain, alpine, and ski guide services. Employers intending to engage foreign nationals in these excluded professions must follow the standard right-to-work application procedure regardless of the intended duration of employment.
Annual Quotas Replacing the Labour Market Test
One of the most significant changes introduced by the Resolution is the complete elimination of the labour market test, replaced by an annual quota system. The quota requirement is triggered where a local employer plans to employ more than five foreign nationals in a calendar year, or where foreign nationals exceed five per cent of the employer’s total workforce (except where five per cent of the workforce amounts to fewer than five persons).
In such cases, the employer must, at least ten working days before applying for the right to work, obtain the State Employment Support Agency’s (the Agency) electronic approval of an annual quota via the designated portal.
To obtain quota approval, the employer must submit a document from the LEPL Revenue Service confirming annual turnover of not less than GEL 50,000 per foreign national seeking the right to work, reduced to GEL 35,000 for educational institutions or medical facilities. The Agency determines the annual quota, and the employer may submit right-to-work applications within that quota during the calendar year. The quota may be increased upon a substantiated request; conversely, where an employer does not fully utilise its allocated quota, the Agency may reduce the quota for the following year.
This mechanism provides employers with greater predictability in workforce planning while incentivising efficient use of allocated quotas.
Application Process and Documentation Requirements
All applications for the right to work must be filed through the electronic system at www.labourmigration.moh.gov.ge, managed by the Agency. The Agency must issue a decision within 30 calendar days under the standard procedure, or within 10 working days under an expedited procedure.
Key documentation requirements include a Turnover Certificate from the LEPL Revenue Service confirming annual turnover of not less than GEL 50,000 per foreign national (or GEL 35,000 for educational institutions and medical facilities). This requirement does not apply where the employer employs no more than three foreign nationals and no more than three months have elapsed since the employer’s establishment or registration.
For employers that are not registered as VAT payers, an alternative documentation route is available: such employers must submit a certificate confirming non-VAT-payer status from the Revenue Service, together with a certificate from an authorised body confirming turnover of not less than GEL 50,000 (or GEL 35,000) per foreign national over the preceding continuous twelve calendar months. The same three-employee and three-month exemption applies.
These turnover-based requirements are designed to ensure that employers have sufficient financial capacity to support foreign workers, a compliance layer relevant to businesses already navigating work-related residence permits for IT professionals and other specialised categories.
Position Changes and Employment Agreement Amendments
Where a labour immigrant wishes to change the position covered by the right to work, or a self-employed foreign national wishes to change the field of employment or entrepreneurial activity, a new right to work must be obtained through the standard application process.
However, amendments limited to position level, salary, or work schedule do not require obtaining a new right to work or submitting information via the electronic system.
In summary, the Resolution represents a significant modernisation of Georgia’s labour migration framework, replacing the administratively burdensome labour market test with an annual quota system and broadening the categories of exempt foreign nationals to reflect contemporary employment realities. The expanded exemptions for remote workers, short-term professional activities, and senior executives signal a more flexible regulatory approach, while the turnover-based financial requirements and streamlined electronic application process add clarity and structure to the compliance landscape.
Employers and foreign nationals engaged in or contemplating employment activities in Georgia must proactively familiarise themselves with the new requirements, ensure timely registration and quota applications where applicable, and monitor any further implementing guidance issued by the Agency to ensure full compliance within this reformed framework.