New labor migration rules from March 1, 2026: what the Ministry of Labor has clarified and what remains unclear

On February 9, we received official clarification from the State Agency for Employment Promotion (a branch of the Georgian Ministry of Labor) regarding changes to the Law on Labor Migration, which will come into force on March 1, 2026.

The changes have caused a wide resonance, especially among foreign entrepreneurs and freelancers. Below is what has already been clarified and what questions remain open.

What we managed to clarify

1. Remote employees without a Georgian individual entrepreneur license

(working for a foreign company)

If you:

• work remotely,
• receive income from abroad,
• do not conduct activities related to Georgian customers,

then the provisions of the law do not apply to you.

In this case, a work permit and residence permit are not required.

2. Rentier (income from renting out your own real estate)

If a foreigner receives income exclusively from renting out real estate that they own, they:

• are not considered a migrant worker;
• are not required to obtain a work permit;
• are not required to apply for a residence permit on the basis of employment.

3. Partners and shareholders of Georgian companies

Foreigners who are only partners or shareholders (without performing labor functions and without entrepreneurial activity) also:

• are not subject to the law;
• are not required to obtain a work permit;
• are not required to apply for a residence permit on the basis of employment.

4. Microbusiness (turnover up to 30,000 lari)

A foreigner with microbusiness status is required to:

• obtain a work permit;
• apply for a residence permit.

This creates a practical conflict: the minimum turnover for a residence permit is set at 50,000 lari, while microbusinesses are by definition limited to 30,000 lari.

The mechanism for resolving this situation has not yet been officially clarified.

5. Individual entrepreneurs (IE) working for Georgian customers

The clarification depends on the actual place of work:

• Working from Georgia — a work permit and residence permit are required.
• Working outside Georgia — a work permit and D1 visa/residence permit are only required for the period of actual stay and work in Georgia.

6. Transition period for IE

There is no transition period for new applicants.

The deferral until January 1, 2027 applies only to persons who are already registered in the electronic system labourmigration.moh.gov.ge at the time the changes come into force.

All others are required to obtain the right to work from March 1, 2026.

What questions remain unanswered

1. The “trap” with a turnover of 50,000 lari

It is still unclear how a new company or individual entrepreneur will be able to confirm a turnover of 50,000 lari within 10 days after receiving a work permit.

The agency recommended sending a request to the State Services Development Agency (SDA). There is no official algorithm at this time.

2. The “6 months of absence” rule

It is unclear:

• whether this refers to 6 months of continuous absence,
• or to the total length of stay/absence during the year.

The criteria will be established in a subordinate act of the Government.

3. Technical implementation of procedures

At present:

• there is no detailed procedure for obtaining a work permit;
• the criteria for evaluating applicants have not been published;
• the deadlines for processing applications have not been officially approved.

The regulations are expected to be adopted closer to March 1, 2026.

4. Conflict regarding individual entrepreneurs working with foreign clients

There is a contradiction:

• on the one hand, if an individual entrepreneur works outside Georgia for foreign clients, the law supposedly does not apply;
• on the other hand, such persons must still have a work permit.

An additional request for clarification has been sent on this issue.

Conclusion

To date, some provisions of the law have been officially interpreted, but key technical and procedural aspects remain unclear.

Until the subordinate legislation is approved, legal uncertainty remains, especially for:

• microbusinesses,
• new individual entrepreneurs,
• entrepreneurs with foreign customers.

It is recommended to closely follow official publications and not to delay analyzing your migration model until the last moment.