Special Labour Permit System (2026) – What Do We Need to Know About Employing Foreigners?

Our client companies that have foreign employees often ask us questions regarding the upcoming labor migration rules. On June 26, 2025, the Parliament of Georgia adopted a package of amendments to the labor migration laws. Starting March 1, 2026, the simple registration system is being replaced by a strict, mandatory two-stage permitting process.

In this article, we will simply explain what the “Special Labour Permit” entails, who is exempt, and what you should consider to avoid financial penalties.

Who Does the New Regulation Apply To?

Obtaining the Special Labour Permit is mandatory for foreign nationals without Permanent Residence (PR) who are engaged in activities for financial gain. Specifically, this applies to:

• Labor Migrants: Foreigners working for local Georgian employers.
• Self-Employed Foreigners: Individuals registered as Individual Entrepreneurs (IE) or partners in Georgian companies.
• Digital Nomads/Remote Workers: Those working remotely for a Georgian entity. Any link to a Georgian employer triggers the permit requirement.

Who is Exempt?

The law provides specific exemptions. You do not need this permit if you fall into one of these categories:

• Holders of Investment Residence Permits and Permanent Residence Permits.
• Refugees, asylum seekers, and accredited journalists.
• Remote workers whose work is performed exclusively for foreign entities with no local economic footprint.

What Are the Stages of the Process?

Starting in March 2026, legalizing your work status follows a strict sequence:

1. Stage 1: The Special Labour Permit. The local employer submits the application for employees, whereas self-employed foreigners apply on their own behalf. The Ministry of Labor, Health, and Social Affairs reviews the application, which takes up to 30 calendar days.
2. Stage 2: Immigration Status (Visa or Residency). Once the permit is granted, the applicant must apply for an immigration status. If the applicant is outside Georgia, they must apply for a D1 Immigration Visa within 30 days. If they are already in Georgia, they must apply for a Work Residence Permit or IT Residence Permit within 10 days.

Critical Requirements & Rejection Risks

The Ministry may reject or revoke a permit based on several critical factors:

• Labor Market Needs: Applications can be rejected if the foreigner’s qualifications do not match market needs or if the profession is classified as “restricted” to protect local labor.
• Turnover Threshold: The underlying residency often requires the employing company to have an annual turnover of at least 50,000 GEL per foreign employee.
• Administrative Delays: Renewal applications must be submitted at least 30 days prior to expiration. Late filings will lead to administrative rejections.

What Happens in Case of Rule Violations?

The 2026 rules introduce significantly higher penalties for non-compliance:

• Unauthorized Work: Foreigners working without a permit and employers hiring them face a fine of 2,000 GEL for the first offense.
• Repeated Violations: For repeated offenses, fines may be doubled or tripled.
• Administrative Breach: Failing to notify the Ministry regarding a contract termination can result in fines ranging from 1,000 to 2,000 GEL.

What Should Already Employed Foreigners Do?

For foreigners who are already working and registered in the Ministry’s database before March 1, 2026, there is a transition period. These individuals have until January 1, 2027, to obtain the new Special Labour Permit and align their residence status with the new rules. In order to fully benefit from the transition period for employees already working for the company, employers must ensure that these employees are registered on the Migrant Portal, as required by law. Otherwise, starting March 1, 2026, they will be required to obtain a labor permit.

How “Ants” Can Help Your Business

Navigating these changes requires meticulous timing to ensure no gaps in legal status. Given the 30-day processing times and strict 10-day residency filing windows, early preparation is the only way to avoid administrative rejections and fines. Our experienced team provides:

• Full Process Management: We handle the end-to-end coordination between the Ministry of Labor and the Public Service Hall (House of Justice).
• Advance Organization: Even if your employees are already registered under the old system, we help organize all documentation in advance to ensure a seamless transition to the new Work Permit and Residency status.
• Compliance Audit: We review your current employment contracts and prepare the necessary documentation to ensure they meet the 2026 legal standards before you apply.

Contact us today so we can assist you in managing this process and ensuring full compliance for your business or employment.