Client alert: change affecting construction permits and approvals in Georgia under the Law on Promotion and Guarantees of Investment Activity

Alert: Change affecting construction permits and approvals in Georgia under the Law on Promotion and Guarantees of Investment Activity Effective: August 2027

Georgia has amended the implementation framework governing construction permits and approvals for foreign investors operating under the Law on Promotion and Guarantees of Investment Activity. The change alters the documentation and approval sequencing that foreign-owned entities must follow before commencing construction or capital improvement works on Georgian territory.

Foreign companies holding or pursuing construction permits in Georgia — including those who registered investment projects under the Law on Promotion and Guarantees of Investment Activity to obtain its procedural protections — are directly affected. Under the revised framework, approvals that were previously obtained at a consolidated stage may now require sequential confirmation from multiple Georgian regulatory bodies before a construction permit is issued. Projects already in the approvals pipeline are not automatically grandfathered: permit applications submitted but not yet determined will need to comply with the amended sequencing requirements. Foreign investors who assumed that prior approvals remained sufficient to proceed to construction should verify that position before committing further capital expenditure.

Recommended action:

• Identify all Georgian construction permit applications currently in progress and confirm their procedural status under the amended framework.
• Where an investment project is registered under the Law on Promotion and Guarantees of Investment Activity, verify whether the stabilisation clause in your investment agreement covers the amended approval sequencing — coverage varies by agreement vintage and project category.
• Obtain updated Georgian regulatory counsel before submitting or progressing any permit application, particularly for projects involving foreign-owned or foreign-controlled entities.

Vetrov & Partners coordinates Georgian regulatory and licensing matters through its network of trusted local counsel. For an initial assessment of how this change affects your project, contact the team.

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Vetrov & Partners is a boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm advises foreign companies on cross-border regulatory and licensing matters, coordinating with trusted local counsel in Georgia and across the South Caucasus and Central Asian region.

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– Nino Beridze Contributing Regional Analyst — Georgia, Vetrov & Partners vetrovpartners.com/contributions/

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.