New Rules for Hiring Foreign IT Talent in Georgia

New Rules for Hiring Foreign IT Talent in Georgia: A Guide for the IT Industry

Legal Overview (Effective March 1, 2026)

Legal Overview Prepared By

Nato Natenadze, Labour Law Expert - IBL Law Office, Former First Deputy Head of the Labour Inspection Service

David Kldiashvili, Managing Partner – IBL Law Office

Georgia's technology sector has become a regional hub for foreign developers, engineers, product managers and startup founders. However, from March 1, 2026, hiring foreign IT talent will no longer be a purely HR decision. It becomes a regulated migration law process requiring the relevant permit.

For technology companies, competitiveness will no longer depend solely on attracting talent. From March 1, 2026, it will also depend on obtaining the right to work from the relevant authority.

1. Does the New Labour Migration Law Apply to the IT Sector?

Yes — universally. Regardless of special tax or investment regimes such as:

  • Virtual Zone Person status;
  • International IT Company status;

the obligation to obtain a Right to Work applies across all economic sectors.

This means:

  • Virtual Zone status does not exempt a foreign specialist from obtaining a Right to Work;
  • International IT Company status does not replace migration authorization requirements;
  • A foreign developer working remotely for a Georgian company may still qualify as a labour immigrant under the law.

2. Which individuals or roles in the IT sector are subject to the new labour migration regulations?

The amendments apply to foreign nationals without permanent residence in Georgia, including:

  • Foreign developers and engineers employed by Georgian IT companies;
  • Foreign consultants and remote contractors working for Georgian entities;
  • Self-employed IT specialists (freelancers, DevOps engineers, UX/UI designers, etc.);
  • Directors and partners of Georgian IT companies.

A particularly high-risk scenario arises in "mixed status" cases — where a foreign national is simultaneously: Founder/partner; Director and Technical specialist. In such cases, proper legal classification of the actual relationship becomes decisive for compliance.

3. The Right to Work

The Right to Work is an individual administrative act issued by the LEPL State Agency for Employment. It grants a foreign national the lawful right to:

  • Work for a specific local employer;
  • Perform remote employment;
  • Carry out independent (self-employed) activity.

Service organizer - a natural or legal person who enters into any agreement with a self-employed foreigner, resulting in financial benefit for the foreigner. This is especially important for platforms or intermediaries, as the liability risk may also apply to them in certain cases.

Key Compliance Points for IT Companies:

  • The Right to Work is issued for a specific employer and specific position;
  • Change of position typically requires renewal or a new administrative procedure;
  • Change of employer generally requires reassessment and reauthorization;
  • Work may not legally commence before authorization is granted.

4. Labour Immigrant vs. Self-Employed Foreigner

The law distinguishes between:

  • A) Labour Immigrant - A foreign national employed by a local employer or engaged in remote employment.
  • B) Self-Employed Foreigner - A foreign national carrying out activity in Georgia for financial benefit, including as: Independent contractor, Partner and Service provider.
  • C) The law also introduces the concept of a Service Organizer — a natural or legal person entering into a transaction with a self-employed foreigner resulting in financial gain for the foreigner.

5. The "Three-Document Rule" for Lawful Work

From March 1, 2026, lawful activity in Georgia will practically depend on three elements:

  1. Employment Agreement (for labour immigrants);
  2. Right to Work;
  3. D1 immigration visa or relevant residence permit (labour, IT, or other lawful status).

6. IT Residence Permit

Eligibility to Obtain IT Residence Status:

  • A registered IT labour immigrant (and family members);
  • An IT entrepreneur holding small business status (and family members);
  • A person authorized to represent or manage an International IT Company (and family members).

Minimum Requirements:

  • At least 2 years of IT experience;
  • Documented income during the previous year of at least USD 25,000 equivalent in GEL, reflected at least twice within the year, with a minimum 30-day interval between payments.

7. High-Risk Areas

From a compliance perspective, the most common exposure points are:

  • Allowing a developer to start work before obtaining the Right to Work;
  • Failing to reflect termination or amendments in the Labour migration system;
  • Changing position without renewing authorization;
  • Assuming IT residence status automatically permits employment.

8. Supervision and Sanctions

Oversight is multi-layered:

  • State Agency for Employment Promotion — issues and monitors the Right to Work;
  • Labour Inspection Service — verifies legality of employment relationships and contractual classification;
  • Ministry of Internal Affairs — supervises visa and residence legality.

Primary Financial Risk:

From March 1, employment without a valid Right to Work may result in:

  • GEL 2,000 fine imposed on the employer per foreign national;
  • GEL 2,000 fine imposed on the foreign national;
  • Repeated violation — doubled; subsequent violation — tripled.

Summary

For technology companies scaling internationally, compliance will directly impact:

  • Operational continuity;
  • Investor confidence;
  • Reputational stability;
  • Risk exposure during audits or due diligence.

In the new regulatory environment, legal structuring of foreign hiring is no longer administrative formalism — it is a component of corporate governance.

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For consultations or inquiries regarding labour migration compliance, please contact our office.