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In Georgia, oversight of employee registration is becoming significantly more systematic.
The Revenue Service verifies whether employees who are actually working are properly registered. The Labor Inspectorate checks the registration of foreign workers. The Ministry of Internal Affairs has been granted the authority to identify violations of labor migration laws and, in some cases, to issue fines on the spot.
And as of September 1, 2026, a foreign national’s employment without a work permit will be directly included in the procedure for considering their deportation from Georgia.
For businesses, this means one simple thing: it is no longer enough to simply pay taxes correctly and have some kind of contract with an employee. Government agencies can verify the entire chain—who is actually working, how the employment relationship is formalized, whether the employee is registered, and whether the foreign national is authorized to perform that specific job.
The Revenue service is already actively auditing employees
On August 14, the Revenue Service reported that in the first seven months of 2026 alone, audits of the Employee Registry revealed 4,580 violations across various sectors of the economy.
The Revenue Service specifically emphasized that the accuracy of the information in the Employee Registry is under strict monitoring.
In other words, this is no longer just a formal obligation that exists only “on paper.”
The Revenue Service is, in fact, verifying whether the information in the tax system matches who is actually working at the company.
Who must be registered with the Revenue Service
Employees who have an employment relationship with an employer are entered into the Register of Employees. The main criterion here is not the job title—nor even just the name of the contract—but the actual nature of the relationship.
If a person works within a company’s structure, performs specific duties, reports to an employer, and receives compensation as an employee, it is necessary to assess separately whether this relationship constitutes an employment relationship.
Therefore, simply changing the name of the document from an “employment contract” to a “service agreement” does not, in and of itself, resolve the issue.
At the same time, a true independent contractor—who independently organizes their own work and provides a service to the company as a separate contractor—is not necessarily an employee. Each case must be evaluated based on the actual circumstances.
Particular attention should be paid to interns. If the internship consists of training and observation, that is one situation. However, if the “intern” is actually performing the regular duties of an employee, the risk of the relationship being classified as an employment relationship is significantly higher.
When an employee must be entered into the registry
The rules are established by Ministry of Finance Order No. 996. Information about an employee must be entered via rs.ge before the employment relationship begins. Not after the first salary payment. Not after the probationary period ends. Not at the end of the month before filing the tax return. Rather, it must be done by the time the employee has actually started work.
The registry also specifies the employee’s status: active, suspended, or terminated.
The “suspended” status applies if an employee is temporarily not performing their duties, the employment relationship continues, and the suspension period exceeds 90 calendar days.
Changes to this information must generally be entered into the registry within 5 business days. If an employee returns to work and their status becomes active again, the change must be reflected no later than the date work resumes.
What Is the fine for an unregistered employee?
Article 288⁵ of the Tax Code provides for a fine of 200 lari for each employee whose information has not been submitted to the Employee Registry.
The amount of the fine itself may seem relatively small.
But what’s far more important is this: the 4,580 violations detected over seven months show that the Revenue Service is indeed conducting such audits.
And when it comes to foreign employees, a lack of registration with the Revenue Service may turn out to be just one of several problems.
Foreign employees: There are essentially two different systems
It is important not to confuse these two obligations.
The first is tax-related. If a foreign national is an employee of a Georgian company or sole proprietor, it is necessary to verify whether they are required to be registered in the Revenue Service’s Register of Employees.
The second is immigration-related. It must be determined separately whether the Georgian Law “On Labor Migration” applies to the foreign national and whether they are required to have:
- registration in the labor migration system;
- the right to work;
- an appropriate visa or residence permit;
- or whether one of the exceptions provided for by law applies.
These are two distinct systems.
Registering an employee on rs.ge does not grant them the right to work in Georgia. Furthermore, having the right to work does not relieve the employer of the obligation to properly register the employee with the Revenue Service.
Not every foreign national needs a work permit
The law provides for a fairly extensive list of exceptions.
For example, the Law “On Labor Migration” does not apply the general rules to a number of categories of foreign nationals, including certain holders of special statuses and residence permits, employees of diplomatic missions, certain categories of executives at large enterprises, and other cases provided for by law. A separate exception is also provided for short-term professional activities.
Therefore, the issue cannot be reduced to the formula: “If a foreigner works, then a permit is required.”
First, it is necessary to determine the status of the specific individual and the nature of their activities.
However, the existence of an exception to the requirement to obtain the right to work does not mean automatic exemption from all other registration obligations.
Short-term work lasting up to four months—is also not “unregistered work”
Starting in July 2026, short-term professional activities by foreign nationals will be regulated separately. Such activities may be carried out for a total of up to four months within a calendar year.
In certain cases, such work does not require a standard work permit.
However, before work begins, the local employer or service provider must register the foreign national in the system: labourmigration.moh.gov.ge. Furthermore, the registration must receive the appropriate confirmation status.
Failure to do so may result in the activity no longer being considered short-term professional work, and liability for working without the appropriate authorization may arise.
Furthermore, if the relationship between the company and the foreign national is an employment relationship, the separate issue of registering the employee with the Revenue Service remains.
As of September 1, the consequences of working without a permit have become significantly more severe
Labor migration legislation provides for a fine of 2,000 lari for working without the right to engage in employment.
If a foreign employee works without the appropriate authorization, a fine of 2,000 lari may be imposed on the local employer—for each such foreigner separately.
The foreign employee may also be fined 2,000 lari.
A foreigner engaged in self-employment without the necessary authorization is also subject to a fine of 2,000 lari. Penalties increase for repeat violations.
However, as of September, a financial fine is no longer the only risk.
The Ministry of internal affairs is now directly involved in regulating labor migration
In August 2026, amendments were made to the regulations governing the Ministry of Internal Affairs. The Central Criminal Police Department, the Patrol Police, and the Migration Department, among others, were granted the authority to identify violations of labor migration laws and impose administrative sanctions.
In addition, Ministry of Internal Affairs Order No. 104 of August 20 explicitly included within the Migration Department’s jurisdiction measures to identify violations of the Law “On Labor Migration” and to impose administrative penalties.
The Department was also granted explicit authority to conduct operational and investigative activities in the area of illegal migration and to identify foreigners residing in the country without legal grounds.
Thus, labor migration is no longer an issue handled exclusively by the Labor Inspectorate.
Fines can now be issued on the spot
Ministry of Internal Affairs Order No. 99 of August 19, 2026, took effect on September 3, 2026. It introduced a special fine receipt form for violations of the Law “On Labor Migration.”
If the violation falls under Articles 16¹ or 16⁶ of the law and no additional administrative investigation is required, an authorized Ministry of Internal Affairs officer may review the case on the spot and impose a fine.
This procedure applies regardless of whether the violator agrees with the imposed sanction.
Article 16¹ primarily concerns working without a work permit.
Article 16⁶ concerns violations of the conditions of an already issued work permit. For example, if a foreign employee changes employers or a self-employed foreign national changes the type of activity for which the work permit was issued without obtaining the appropriate update. The fine is 2,000 lari.
Working without a permit can now trigger deportation proceedings
An even more significant change took effect on September 1. Ministry of Internal Affairs Order No. 105 of August 25, 2026, explicitly added a ground for deportation to the rules governing deportation proceedings: a foreign national engaged in employment without the right to work.
This does not mean that any foreign national will be automatically deported immediately upon detection of the violation. The procedure works differently.
After identifying the relevant ground, the Migration Department investigates the circumstances within 10 business days. If there is evidence supporting the grounds for deportation, the Department files a petition with the court. It is then up to the court to decide whether to deport the foreign national or to deny deportation.
Nevertheless, the significance of this change cannot be overstated. Previously, many viewed the risk of working without proper authorization primarily as an administrative fine. Now, it can also constitute an immigration risk for the foreign national themselves.
Appealing a fine will not necessarily halt the immigration proceedings
Another important rule has been in effect since September 1.
Appealing a decision to impose administrative liability for violations provided for by law does not prevent the consideration of a work immigrant’s deportation and does not suspend the enforcement of a deportation decision that has already been issued.
In other words, the strategy of “first challenging the fine, so that nothing will happen until the court rules on it” is no longer reliable.
Administrative proceedings and immigration proceedings can proceed in parallel.
If the deportation proceedings have already begun
Order No. 105 regulates the foreign national’s conduct during the proceedings in much greater detail.
At the request of the Migration Department, the foreign national must surrender his or her travel document. In exchange, he or she is issued a receipt confirming the surrender of the document.
In cases provided for by law, fingerprints and palm prints may be taken, and photographs may be taken.
The foreign national is also required to maintain contact with the Migration Department, provide the required information and documents, and report their current address and contact information.
Failure to appear at the Ministry of Internal Affairs, providing false contact information, having no known place of residence, or leaving the specified place of residence without notice are now explicitly taken into account when assessing the risk that a foreign national may abscond.
This is relevant, among other things, when deciding whether to detain a foreign national and place them in a temporary detention center.
Inspections are already underway
The Ministry of Internal Affairs’ new powers are not the only sign of tighter controls. The Revenue Service has already reported thousands of violations identified in the employee registry. In addition, the Labor Inspectorate has begun requesting information from companies about their foreign employees.
Several of Espero’s clients have already received such requests. In some cases, the deadline for submitting the documents was as short as two business days.
Therefore, it is no longer wise to expect that there will first be a lengthy “transition period” and that inspections will begin sometime later.
They are, in fact, already underway.
What companies should check right now
For employers who hire foreign nationals, it makes sense to conduct a brief internal audit:
- Compare the people who are actually working at the company with the list of employees on file with the Revenue Service;
- Verify whether employees were registered with the Revenue Service before the start of their employment and whether their statuses are up to date;
- separately compile a list of all foreign employees, contractors, directors, partners, and interns who are actually working;
- determine for each foreign national whether the Law “On Labor Migration” applies to them and whether there is an applicable exemption;
- If a work permit is required, verify its existence, validity period, employer, and the type of activity for which it was issued;
- Verify the registration of foreign nationals in the labourmigration.moh.gov.ge system, including cases of short-term professional activity;
- Ensure that the individual’s actual activities correspond to their contracts, registration, and issued permits.
The situation is particularly dangerous when documents exist in name only but describe a different work arrangement. For example, a person is registered as an independent contractor but actually works in the office every day according to the employer’s schedule. Or, a work permit was obtained for one employer, but the person is already working elsewhere. Or a foreign national is registered with the Revenue Service as an employee, but their eligibility to work has not been verified at all.
It is precisely these discrepancies that become most apparent when government databases are cross-checked against actual work activities.
What has changed overall
The changes of recent months form a unified system: actual work → employee registration → a foreign national’s right to work → oversight by the Revenue Service, the Labor Inspectorate, and the Ministry of Internal Affairs → administrative fine → deportation proceedings, if warranted.
Therefore, hiring a foreign employee in Georgia in 2026 can no longer be viewed solely as a matter of accounting or income tax payment. It is simultaneously a tax, labor, and immigration issue.
And the sooner a company verifies its actual situation against its own documents and government registries, the less likely it is to discover a problem only after receiving a request from an inspector or a visit from a regulatory authority.
Questions and answers
Do I need to register an employee with the Revenue Service before paying their first paycheck?
Yes. The information must be entered into the Register of Employees before the employment relationship begins, not before the first paycheck is issued.
What is the penalty if an employee is not registered with the Revenue Service?
200 lari for each unregistered employee.
Do I need to register a foreign employee with the Revenue Service?
If the employee has an employment relationship with a Georgian employer, foreign citizenship alone does not exempt them from the rules of the Employee Registry. However, you must also verify compliance with labor migration laws.
If a foreign employee is registered on rs.ge, is a work permit no longer required?
No. These are separate procedures.
RS is the tax registry for employees.
The right to work and registration in the labor migration system are governed by separate legislation.
Do all foreign nationals now need a work permit?
No. The law provides for a number of exceptions. In addition, the general labor migration regime applies primarily to foreign nationals who do not have a permanent residence permit in Georgia. There are other exempt categories as well. Therefore, status must be verified on a case-by-case basis.
Can a foreign national work in Georgia for up to four months without a permit?
For certain short-term professional activities, there is an exception that allows a foreign national to work for a total of up to four months in a calendar year without the usual work permit.
However, before beginning such work, the foreign national must be registered in the labor migration system, and their registration must be confirmed.
If a service contract is signed instead of an employment contract, is registration unnecessary?
Not always.
If the person is a genuinely independent contractor, the relationship may not be considered an employment relationship.
But if the “service contract” is actually a cover for the employee’s regular work, the name of the contract alone does not protect the employer.
For a foreign national, a separate issue arises: even a genuine independent contractor may fall under the definition of a self-employed foreign national and be subject to the requirements of labor migration law.
What is the fine for a foreign national working without a work permit?
The base fine is 2,000 lari.
An employer may be fined 2,000 lari for each affected foreign employee, and the employee may be fined an additional 2,000 lari.
A fine of 2,000 lari applies to self-employed foreigners. The amounts increase for repeat violations.
Can a fine now be issued directly during an inspection?
Yes. Effective September 3, 2026, for violations of Articles 16¹ and 16⁶ of the Law “On Labor Migration,” if no additional administrative investigation is required, an authorized officer of the Ministry of Internal Affairs may review the violation and issue a fine on the spot.
Does working without a permit automatically result in deportation?
No.
Working without the right to engage in employment is grounds for considering deportation.
The Migration Department reviews the grounds and, if there is sufficient evidence, files a petition with the court. The court then decides whether to deport the foreign national or deny the deportation request.
Is it possible to stop the deportation process simply by appealing a fine?
Not necessarily.
As of September 1, appealing certain administrative sanctions under the Law “On Labor Migration” does not prevent the consideration of a deportation case and does not suspend the enforcement of a deportation decision that has already been issued.
What should a company do if it is unsure whether its foreign employees are properly registered?
It is best to review the situation before the next inspection: the status of each foreign national, the basis for their stay in Georgia, whether a work permit is required, registration in the labor migration system, data from the Revenue Service, and whether the documents match the actual work performed.
It is especially important to do this now, since the Revenue Service, the Labor Inspectorate, and the Ministry of Internal Affairs already have enforcement mechanisms in place, and the new rules have taken effect.