Procedural considerations in work permits and expatriate migration in Georgia under the Law on Free Industrial Zones (2007)

Foreign companies establishing operations within a Georgian Free Industrial Zone acquire a distinct legal identity that departs materially from the general employment and migration framework. Under the Law on Free Industrial Zones (2007), an FIZ enterprise is treated as a separate legal entity operating outside the customs territory of Georgia for most trade purposes — but this extraterritorial logic does not extend uniformly to employment law. Expatriate staff seconded to or directly hired by an FIZ company must still satisfy Georgian immigration requirements, and the procedural pathway differs in several respects from the standard inbound employment route.

The Law on Free Industrial Zones (2007) does not create a self-contained work authorisation system. An FIZ enterprise wishing to employ a foreign national must navigate two parallel tracks: the corporate registration and licensing obligations specific to the zone, and the general Georgian migration procedure applicable to all non-citizen workers.

The general rule in Georgian employment and migration law is that a foreign national working in Georgia requires either a work permit or falls within one of the statutory exemptions. Citizens of certain countries — including many OECD members and CIS states — benefit from a 365-day visa-free regime that does not, of itself, confer the right to take up formal employment with a Georgian-registered entity. This distinction between physical presence rights and employment authorisation is frequently misunderstood by foreign companies relocating staff to an FIZ.

An FIZ company's status as a zone enterprise does not exempt it from the obligation to execute a Georgian-law employment contract with resident staff or to comply with the Labour Code of Georgia as it applies to employment relationships performed on Georgian territory. The FIZ regime's principal advantages — customs duty exemption, VAT relief on imported equipment, and the simplified re-export regime — do not modify the employment law obligations that arise from the presence of workers within the zone's physical perimeter.

Note: Foreign companies that treat the visa-free entry period as a proxy for lawful employment authorisation expose both the enterprise and the individual to administrative liability under Georgian immigration legislation. Where the intended assignment exceeds the visa-free threshold or involves formal employment rather than advisory attendance, the appropriate authorisation must be obtained before work commences, not after.

In practice, an FIZ enterprise employing expatriate staff typically proceeds through three sequential steps. First, it must confirm that the proposed hire either qualifies for one of the statutory exemptions — for example, as a founder or director of the FIZ entity, a category that carries its own registration pathway — or must initiate a work permit application through the Public Service Development Agency. Second, the entity must ensure that the employment contract and the individual's immigration status are aligned: a work permit application submitted after the individual has already commenced work within the zone creates a compliance gap that Georgian regulatory practice does not treat as trivial. Third, the FIZ management company administering the relevant zone may impose its own onboarding documentation requirements, which are contractual rather than statutory but are nevertheless a precondition for zone access.

For Russian and CIS-origin companies that have relocated operations to Georgian FIZs as part of a broader restructuring strategy, a practical complication arises in the cross-border dimension. Staff who retain Russian or Belarusian employment contracts but are physically present in Georgia for extended periods face a dual-classification risk: the assignment may constitute a taxable employment relationship in Georgia regardless of where the payroll is maintained. FIZ status does not create a tax shield for individual income sourced from work performed within Georgia's territory.

Where the assignee is a director or authorised representative of the FIZ company rather than an ordinary employee, registration with the relevant registry is required under Georgian corporate law before that individual can exercise management authority on behalf of the entity. This step is distinct from, and must precede, any work permit or residency application.

For in-house counsel managing a multi-jurisdiction workforce with Georgian FIZ exposure, the procedural sequencing — entity registration, director registration, work permit or exemption confirmation, employment contract execution — is the critical compliance checkpoint. Delay at any one stage does not pause the effective commencement of employment obligations under Georgian law.

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Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm advises foreign companies on cross-border matters with a Russia–CIS–South Caucasus dimension, including business relocation, corporate restructuring, and employment compliance in connection with Georgian, Kazakhstani, and Uzbek operations.

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.

— Nino Beridze Contributing Regional Analyst — Georgia, Vetrov & Partners vetrovpartners.com/contributions/ Nino Beridze advises on business relocation, tax structuring, and employment compliance for foreign companies entering the Georgian market. She contributes regional analysis to Vetrov & Partners on FIZ operations, corporate registration, and cross-border migration matters in the South Caucasus.