Hiring Foreign Nationals: Employer Guide to the Right to Work Pipeline

The April 2026 amendments to Georgia's Law on Labour Migration carved most foreigner-hiring scenarios out of the Right to Work permit requirement entirely — fully remote foreign employees, directors of Category I/II/III companies, and contractors serving foreign clients no longer trigger the pipeline. This page is for the case that does still trigger it: a Georgian employer hiring a foreign national into a regular employment role, performed in Georgia. If you are in that situation, here is what you need to do.

When This Page Applies

The pipeline below applies when all four of the following are true: the employer is a Georgian legal entity (LLC, JSC, or sole proprietorship); the prospective hire is a foreign national without Georgian permanent residence; the role is a regular employment position under a Georgian employment contract; and the work will be performed inside Georgia. Strip any one of those conditions and you are most likely outside the pipeline.

Three carve-outs introduced by Law №1509 of 15 April 2026 cover the most common alternative arrangements:

• Fully remote foreign employees who do not enter Georgia. If the role is performed entirely from abroad and the employee never sets foot in the country to do the work, no Right to Work permit is required. You can sign the employment contract and run payroll without going through this pipeline at all.
• Directors and supervisory or audit-committee members of Category I, II, or III companies. Most foreign-founded LLCs fall in these size categories. Appointing a foreign director or board member to run the company does not require a Right to Work permit.
• Independent contractors serving foreign clients. A foreign Individual Entrepreneur or freelancer who works for non-resident clients whose business is outside Georgia is exempt — but if the contractor's work is for your Georgian company, that exemption does not apply and they sit back in the regulated category as a self-employed foreigner serving a Georgian market.

The full breakdown of the carve-outs, including the worker-side perspective, is on the Working in Georgia page. If your prospective hire is reading this themselves, that page is the right starting point for them.

Employee or contractor? A real fork

Some hiring decisions can be structured as either an employment relationship or a contractor relationship, and the choice has significant compliance consequences after April 2026. Hiring as an employee triggers the full pipeline below. Engaging the same person as an independent contractor through their own Individual Entrepreneur registration may keep you out of the pipeline entirely if their work qualifies under the foreign-client carve-out (i.e., they have a portfolio of non-resident clients and are not exclusively servicing your Georgian operation). Where the contractor is genuinely independent and serves multiple clients, this is a legitimate structuring choice. Where the relationship looks like employment dressed up as contracting — sole client, dedicated hours, your management direction — Georgian labour and tax authorities will likely treat it as employment regardless of the paperwork. The decision is a real one; the mislabelling is the trap. See the IE and small business page for the contractor structure if that is the cleaner fit for your situation.

The Three-Step Pipeline

For a regular employee hire that does fall under the regime, the process is structured in three sequential steps. Plan the timeline accordingly: from posting a vacancy to having the foreign hire legally working under D1 visa or residence permit, expect several weeks at minimum.

Step 1: Post the vacancy on Worknet (local-market test)

Before applying for a Right to Work permit, you must post the position on the state vacancy portal at worknet.gov.ge for at least 10 working days. The Employment Promotion State Agency reviews the listing during that window and may propose local candidates from its database for you to consider. You have 3 business days per proposed candidate to review and respond.

The response standard matters. Rejecting a state-proposed candidate requires a documented, role-specific reason — for example, that the candidate lacks a verifiable skill, language, or experience requirement that the position genuinely demands. Generic refusals ("not a fit") and rejections grounded in age, gender, or similar non-job-related criteria can be deemed unsubstantiated, which can void the entire local-market-test step and block the foreign-hire application. Writing the vacancy carefully and specifically — listing the actual technical, linguistic, or industry requirements rather than soft generalities — is your best protection: a precisely-scoped job description naturally narrows the local candidate pool to genuinely qualified applicants.

Skip-Worknet conditions. The 10-working-day posting requirement does not apply in three situations: the role's gross monthly salary is at least 15,000 GEL and the prospective hire holds a relevant degree; your company holds International Company status; or your company holds Innovative Startup status. If any of these applies, you can proceed directly to Step 2.

Step 2: Apply for the Special Labour Permit

Once Worknet either yields no suitable local candidate or you qualify for a skip condition, the employer files the Right to Work application at labourmigration.moh.gov.ge. The application is electronic and requires:

• Employer details — legal name, ID or personal number, registered and operating addresses, sector, contact information.
• Submitting officer details — the person filing on behalf of the employer (typically a director or HR specialist).
• Foreign hire details — full name in Latin and Georgian script, date of birth, citizenship, passport copy, and contact information.
• Position requirements — job duties, required education and experience, language and technical requirements relevant to the role.
• Qualifications evidence — the candidate's education certificates, professional certifications, and documented work experience.
• The signed employment contract, with both parties' signatures and the dates of conclusion, entry into force, and end (if fixed-term).
• Confirmation via qualified electronic signature or electronic stamp.

The state fee is 200 GEL for a 30-calendar-day decision or 400 GEL for an expedited 10-working-day decision. The employer pays the fee; payment is made by card on the portal at submission. Both fee tiers sit below the statutory cap of 500 GEL.

The Employment Promotion State Agency reviews the application against the position description and the candidate's qualifications. If anything is incomplete or unclear, the Agency can request corrections within a 10-day window. The decision (granted or denied) is delivered electronically to the employer. If denied, a fresh application can be submitted after a one-month wait.

Step 3: D1 visa or work residence permit

A granted Right to Work does not by itself authorize the foreign hire to start working. The permit becomes legally operative only when paired with one of two activation paths, both initiated by the employee within tight deadlines:

• From abroad: D1 immigration visa within 30 calendar days. The employee applies at a Georgian embassy or consulate. D1 is a long-standing immigration-visa category; under the 2026 framework it is the abroad-route activation path for Right to Work.
• Already in Georgia: residence permit within 10 calendar days. The employee applies for a work residence permit (or, if they qualify, an IT residence permit) in person at a Public Service Hall.

The IT residence permit track has more generous validity (up to three years initially) for specialists who can demonstrate at least two years of IT work experience and an annual income of at least USD 25,000.

Sector Quotas

A small number of sectors are subject to annual quotas on foreign-national employment. If your hire's role falls into one of these sectors, the quota is the first thing to check — applications above quota are not granted regardless of other factors.

• Couriers, passenger-transport drivers (taxi), and tour guides. The 2026 quota for these professions is 0. Foreign-national hiring in these roles is effectively prohibited for the year.
• Mountain and ski guides. The 2026 annual quota is 200 across the country.
• All other sectors. No quotas apply; the standard pipeline is the only constraint.

Ongoing Duties After the Permit Is Granted

The Right to Work permit is not a one-and-done filing. Three ongoing obligations apply for as long as the employment relationship continues.

Termination notification within 5 calendar days. When an employment contract with a foreign national ends or is materially modified — termination, resignation, or change of role — the employer must report it to the Ministry's electronic system within 5 calendar days. Missing this deadline creates compounding compliance risk because the Ministry of Labour's and the Public Service Development Agency's databases are synchronized: a stale labour record will surface when the employee next interacts with the residence-permit system.

Renewal at least 30 calendar days before expiry. Standard Right to Work permits are issued for between 6 months and 1 year initially, renewing annually for the first 5 years and on 1-to-5-year cycles thereafter. The employer must submit the renewal application at least 30 calendar days before the current permit expires, with updated information about the employee and the working conditions.

Role changes require a new permit.A Right to Work is granted for a specific position at a specific employer. Promotions, transfers between departments, or material changes in scope can require a fresh application rather than a simple update — particularly if the new role's qualifications or duties differ meaningfully from those documented in the original filing. Plan for this when budgeting for organizational changes.

Penalties

Working without authorization is a fineable offence on both sides of the relationship. For a first violation, both the foreign individual and the Georgian employer face a fine of 2,000 GEL each. A second offence brings the fine to 4,000 GEL, and subsequent offences to 12,000 GEL. Active enforcement of these penalties began after 1 May 2026; this is no longer a paper rule.

Transition for Pre-March-2026 Hires

Foreign nationals who were already employed under contract and registered in the Ministry of Labour's unified migrant-worker registry before 1 March 2026 have until 1 January 2027 to obtain Right to Work permits and residence permits under the new rules. The transition window is generous, but should not be left to the final weeks of December — the Public Service Halls predictably back up at year-end.

For new hires after 1 March 2026, no transition applies. The pipeline above runs from day one of the hiring decision.

What to Do Next

• If your prospective hire is reading this themselves, point them at Working in Georgia for the worker-side flow — including the carve-outs, the residence permit pathways, and what to expect at the Public Service Hall.
• If you are hiring local Georgian staff (not foreign nationals), see the general hiring employees page, which covers labour-code basics, payroll, leave, and termination.
• If a contractor relationship is the better fit for your situation, the IE and small business page covers what the foreign individual's side of that arrangement looks like.
• For official portals — Worknet, the labour migration application portal, the Employment Promotion State Agency, and the Public Service Development Agency — see Useful Links.