If your company had foreign nationals on the payroll before March 2026, nothing has changed for them yet. That is the problem. The transition window closes on 1 January 2027, a decision on each application takes up to 30 calendar days, and every employer in the same position is working to the same date. A deadline that looks like five months of slack is really about two, and the queue in front of it is the part nobody has priced in.
What the transition window actually is
The Special Labour Permit became mandatory on 1 March 2026. Applying that overnight to every company already employing foreign staff would have made several thousand employment relationships unlawful on a Sunday morning, so the rules carved out a window: relationships that already existed before that date have until 1 January 2027 to be brought inside the regime.
The window is a delay, not a dispensation. It does not reduce what the company has to prove, it does not lower the turnover threshold, and it does not survive past its date. On 2 January 2027 there is no difference between an employee who has been with you since 2019 and one who started last week.
One thing to settle before you rely on the window at all: you need to be able to evidence that the employment predates 1 March 2026. Registration with the Revenue Service and payroll filings do that cleanly. If the arrangement was informal before this year, treat your position as the tighter one and file early rather than argue the point at the counter.
Who is inside the window
| Situation on 1 March 2026 | Position |
|---|---|
| Foreign national already employed by a Georgian company | Inside the window. Permit required by 1 January 2027, filed by the employer |
| Foreign national hired after that date | No window. Permit before the first paid day |
| Employed before that date, moving to a new employer now | No window for the new relationship. Permit first |
| Investment residence permit holder | Exempt from the regime entirely |
| Permanent resident | Exempt from the regime entirely |
| Diplomatic or consular staff, accredited journalist, refugee or asylum seeker | Outside the regime under their own rules |
| Foreign national in Georgia with no Georgian employer | Not in the window, and nothing to file against this date |
That last row covers most people who arrive at this page, so it is worth stating plainly. This deadline is an employment provision. It attaches to the relationship between a Georgian employer and a foreign national on its books, and the obligation sits on the employer. Somebody running an Individual Entrepreneur for foreign clients, or working remotely for a company with no Georgian presence, has no employer here, needs no permit, and has no filing to make against 1 January 2027. Which relationships engage the permit at all is set out in who needs a work permit in Georgia.
An Individual Entrepreneur trading with Georgian clients is inside the labour permit regime, but on a different trigger and not on this timetable. If that is your position, the question is what your client base actually looks like, and it is worth a consultation on the facts rather than a date read off a table. Where somebody on your books is engaged as an IE rather than employed, the obligation is not the company's, and the self-employed labour permit route is theirs to weigh against their own facts.
Why the real deadline is autumn, not December
Work backwards from 1 January 2027 and the comfortable-looking gap disappears quickly.
| Milestone | Date |
|---|---|
| Permit must be held by | 1 January 2027 |
| Latest filing on the 30-day standard track | 1 December 2026, decision due 31 December |
| Latest filing that survives one refusal and a refile | Early October 2026 |
| Start assembling evidence | August to September 2026 |
A complete application filed on 1 December 2026 has its decision due on the last day of the year, with no slack for a document request, a clarification or a public holiday. That is not a plan, it is a bet.
The refusal case is the one that decides the date. Refusals in this regime are rarely about eligibility in principle. They are about the file: turnover evidence that does not reconcile with what the tax authority holds, a description of the role that does not match the activity actually performed, or missing documentation that has to be requested from abroad. Fixing any of those and refiling costs another full decision cycle, and there is only one full cycle between early October and the deadline. That is where the October date comes from, and it is why the grounds a labour permit gets refused on are worth reading before you file rather than after.
The GEL 400 expedited fee, around $155, buys a decision in ten working days instead of 30 calendar days, and it is the lever to pull if you are late. Treat it as an emergency measure rather than as a plan, for the reason in the next section.
Queue risk, honestly stated
Every employer in the transition window shares a single date. That is unusual and it matters.
Ordinary immigration deadlines are staggered, because they attach to each applicant's own permit expiry. The demand on the counter is therefore roughly flat, and processing standards hold. A transition deadline attaches to a calendar date instead, which means demand is not flat at all: it is low all year and then concentrated into the final weeks by every company that read 1 January 2027 as a December problem.
The Employment Promotion State Agency began issuing these permits in March 2026. It has never processed a deadline surge, because there has not been one yet, so nobody can tell you from experience how the 30-day standard behaves in November and December 2026. We are not going to guess at it. What we will say is that the expedited track and the standard track both run through the same organisation, so the fee that buys speed in a quiet month is the fee everyone else will also be paying in a busy one.
The asymmetry is what settles it. Filing early costs the company nothing beyond doing the work sooner. Filing late costs it the ability to fix a problem, and possibly the ability to keep somebody employed in January.
The second deadline nobody has told you about
If an employee's residence permit expires in the first months of 2027, the effective deadline for their labour permit is earlier than 1 January.
Georgian law requires a residence permit application 40 calendar days before lawful stay expires, and applications inside that window are refused review rather than delayed. The labour permit has to be granted before the work residence permit application can be filed at all. Stack the two: a residence card expiring on 1 March 2027 needs its application in by 20 January, which needs a labour permit decision in hand before that, which on the standard track means filing in December at the very latest. Counting backwards from the expiry date is a two-stage calculation for anybody on the work route.
The window does not soften that, because the two rules do different jobs. The transition window is time to regularise staff you already had. It is not a waiver of the prerequisite. Work and IT residence permits have required a granted labour permit underneath them since 1 March 2026, and a renewal on either route is assessed against that requirement rather than against the transition date. So an employee whose renewal falls due during the window needs the labour permit sequenced ahead of it, and their own expiry date, not 1 January 2027, is the date that governs the company's timetable for them.
Government authorisation for labour activity in Georgia. Required to employ foreign staff, to trade as an IE with Georgian clients, or to apply for a work or IT residence permit.
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What to do if you employed foreign staff before March 2026
Run this across the whole foreign headcount at once rather than per employee. The company's turnover evidence is the same document set for every application, and assembling it twice is wasted work.
- List the foreign nationals who were already on the books before 1 March 2026. Those relationships are the ones the deadline attaches to. Anyone hired since then should already hold a permit.
- Confirm the company qualifies. GEL 50,000 of annual turnover per foreign employee, or GEL 35,000 for educational and medical institutions, tested against your Revenue Service filings rather than against your management accounts. The figure is per foreign employee, so the test tightens with every name on the list.
- Check each employee's own permit dates first. Where a residence permit renewal lands before mid-2027, that date governs for that person, not the transition deadline.
- Assemble the evidence in August or September. Turnover documentation and tax filings are the slow part, and anything that has to come from another country is slower still.
- File on the standard track by early October. The expedited fee stays available if something goes wrong.
- Then the employee files the residence permit into the window that approval opens, at the Public Service Development Agency rather than the agency that issued the labour permit.
The full company-side picture, including the start-up relief for businesses under three months old and who is responsible for which document, sits in the employer's guide to hiring foreigners.
What happens if you miss it
The transition window closing does not create a special penalty. It removes the protection from the ordinary one.
From 1 January 2027, employing a foreign national without a Special Labour Permit carries GEL 2,000 on the company and a separate GEL 2,000 on the worker, both doubled on a repeat. Those are statutory lari figures set by the government resolution introducing the regime, so they do not drift with the exchange rate. With four unauthorised staff the company's own exposure on a first finding is GEL 8,000.
The penalty is not the serious part. Where an employee's residence permit rests on their job, unauthorised work undermines the basis it was granted on, which puts revocation into play and can cost you the hire rather than just the fine. Since October 2025 Georgia has also run an illegal-presence database with expanded biometric collection and wider inspection powers behind it, so the state's view of who is working here is assembled centrally now. What the fines actually lead to is a status problem rather than a money problem, and the labour permit regime is only one of the changes that landed across 2026.
How we handle transition-window cases
We work the calendar backwards from each employee's own dates rather than from the headline deadline, because for a meaningful share of a foreign headcount it is the residence permit renewal, not 1 January 2027, that actually binds.
From there it is a triage: which staff are in scope, whose numbers carry the application, what evidence exists today and what has to be requested. Preparing and filing the labour permit is the straightforward half. Getting turnover documentation to reconcile with what the Law on the Legal Status of Aliens and Stateless Persons and the implementing rules expect to see is the half that decides the outcome, and it is the half that takes longer than companies budget for.
Key takeaways
- A Georgian employer with foreign nationals already employed before 1 March 2026 must hold a Special Labour Permit for each of them by 1 January 2027.
- The obligation and the filing sit on the employer, and the application rests on the company's turnover.
- Hiring after 1 March 2026 means no window at all. The permit comes before the work.
- Foreign nationals with no Georgian employer are not in the window, and an IE with Georgian clients sits on a different trigger with no deadline attached to this date.
- A 30-day decision makes 1 December the mathematical deadline and early October the practical one.
- Budget for one refusal and a refile. There is room for exactly one between October and the cutoff.
- Every affected employer shares a single date, and the issuing agency has never faced a surge against it.
- An employee's residence permit expiring in early 2027 pulls their real deadline forward through the 40-day rule.
- After the deadline the ordinary fines apply: GEL 2,000 on the company, GEL 2,000 on the worker, doubled on repeat.
Frequently asked questions
What is the deadline for the Special Labour Permit in Georgia?
1 January 2027, for foreign nationals who were already employed by a Georgian company before 1 March 2026. Anyone hired since then needed the permit before starting, with no transition period at all. The date is fixed and applies to every affected employer simultaneously rather than running from each person's own permit expiry.
When should I actually file for my Georgian labour permit before the 2027 deadline?
Early October 2026 on the standard track. A decision takes up to 30 calendar days, so 1 December is the last date that can technically produce an approval in time, and it leaves no room to correct a document or answer a query. October gives you one full cycle in reserve if the first application is refused.
Who is covered by the Georgian work permit transition period?
Employment relationships that already existed on 1 March 2026, between a Georgian employer and a foreign national on its books. The employer carries the obligation and makes the filing. Foreign nationals with no Georgian employer are not covered, because they need no permit in the first place, and investment residence permit holders and permanent residents are exempt from the regime rather than covered by the window.
What happens if I miss the 1 January 2027 labour permit deadline in Georgia?
The ordinary penalties apply from that day: GEL 2,000 on the company and a separate GEL 2,000 on the worker, doubled on a repeat, and they attach per employment relationship rather than per inspection. Beyond the fine, where the employee's residence permit rests on the job, unauthorised work undermines its basis, which raises revocation and is much slower to unwind.
Can I pay for a faster Georgian labour permit decision before the deadline?
Yes. The expedited government fee is GEL 400, around $155, for a decision in ten working days, against GEL 200 and 30 calendar days on the standard track. It is the right lever if you are late, but it runs through the same agency as everything else, so it is a poor substitute for filing early.
Do I need a labour permit in Georgia if my residence permit is valid until 2028?
If a Georgian company employs you, yes, and the validity of your residence card makes no difference to the transition deadline. The two permits are separate instruments issued by separate agencies: your residence permit lets you be in Georgia, and the labour permit is what authorises the employment. If no Georgian company employs you and your income comes from abroad, no labour permit is due at all and the 2027 date does not apply to you.
Does the transition window mean I can renew my Georgian residence permit without a labour permit?
No. The two rules do different jobs. Work and IT residence permits have required a granted labour permit underneath them since 1 March 2026, and a renewal on either route is assessed against that requirement. The transition window is time for an employer to regularise existing staff, not a waiver of the prerequisite, so sequence the labour permit ahead of the renewal.
I stopped working in Georgia. Do I still need a Special Labour Permit by 2027?
No. The permit authorises an employment relationship, so once the employment has ended there is nothing left to authorise and nothing for a former employer to file. Living in Georgia on savings, a foreign pension or passive investment income does not engage the requirement, and neither does working remotely for clients or an employer outside the country.
How long does a Special Labour Permit take in Georgia?
Up to 30 calendar days on the standard track, or ten working days on the expedited fee, measured from a complete application. Incomplete filings restart the clock in practice, because the decision period runs on what the agency has in front of it rather than on when you first walked in.
Will the Georgian labour permit deadline be extended?
Nothing published suggests it will, and planning around an extension that has not happened is an expensive way to be right. The date has been fixed since the regime was introduced in February 2026. Treat 1 January 2027 as final until a further resolution says otherwise.
Does my employer file the Georgian labour permit or do I?
Your employer, where there is an employment relationship, because the application rests on the company's turnover and tax filings. You cannot start that part of the process for them. Self-employed people who need a permit, meaning an Individual Entrepreneur with Georgian clients or somebody applying for a work or IT residence permit, file on their own income and business activity instead.
