What are the main steps in data protection and localisation requirements in Georgia?

Foreign companies establishing operations in Georgia must address data protection and localisation requirements under Georgian legislation before they begin processing personal data. The core framework is the Law of Georgia on Personal Data Protection, which was substantially revised to align with GDPR-based standards and is supervised by the Personal Data Protection Service — the dedicated regulatory authority in Georgia.

The principal compliance steps are as follows.

• Establish a lawful basis for processing. Georgian data protection law requires that every processing activity rests on an identified legal ground — consent, contractual necessity, legitimate interest, or a statutory obligation. Foreign companies should document the basis for each category of data they intend to collect or process within Georgia.

• Assess localisation obligations. Certain categories of personal data — including sensitive categories such as health, biometric, and financial data — are subject to localisation requirements under Georgian law, meaning they must be stored on servers located within Georgia or in jurisdictions recognised as providing adequate protection. Companies should map their data flows before infrastructure decisions are finalised.

• Register with or notify the Personal Data Protection Service. Depending on the nature and scale of processing, foreign companies operating in Georgia may be required to notify the Service or register specific processing activities. The threshold for notification and the procedural requirements should be confirmed with qualified Georgian counsel, as the applicable rules can vary by sector and processing type.

• Appoint a data protection officer or responsible person where required. Entities processing data at scale, or processing sensitive categories, typically need to designate a responsible individual. This person serves as the contact point for the Personal Data Protection Service.

• Implement technical and organisational measures. Georgian law — consistent with the GDPR framework it follows — requires companies to implement appropriate security measures proportionate to the risk of their processing activities. This includes access controls, data minimisation practices, and incident response procedures.

Practical implication. Failure to comply with Georgian data protection requirements exposes foreign companies to supervisory investigations and administrative penalties. For inbound investors, data compliance is increasingly a condition of operating in regulated sectors such as financial services, healthcare, and telecommunications.

For advice on data protection and localisation requirements in Georgia, or to coordinate cross-border Georgia–Russia regulatory compliance across jurisdictions, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Nino Beridze Contributing Regional Analyst — Georgia · Business Relocation & Tax Structuring vetrovpartners.com/contributions/

Nino Beridze advises foreign investors and relocated businesses on Georgian regulatory requirements, including company formation, tax structuring, and regulatory licensing in Georgia. She contributes regional analysis to Vetrov & Partners on Georgian law matters and coordinates with Russian-qualified counsel on cross-border instructions.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. For matters governed by Georgian or other foreign law, the firm collaborates with trusted counsel in the relevant jurisdiction — including qualified Georgian practitioners. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.