Will a work permit be required for the director of a company in FIZ in Georgia in 2026?
Following the update to Georgia’s labor migration regulations, the issue of work permits has become relevant not only for ordinary companies but also for businesses operating in Free Industrial Zones (FIZ). Despite the special legal and tax regime of such zones, the requirements of migration legislation continue to apply to their participants.
Short answer
In most cases, a foreign director of a company in an FIZ requires a work permit if he or she actually conducts business activities in Georgia and does not have a permanent residence permit or another legal exemption. The company’s status in an FIZ alone does not exempt it from these requirements.
Why the confusion arises
Free Industrial Zones have a number of distinctive features:
- a special tax regime;
- separate rules for conducting business;
- special customs conditions.
These factors create a sense of “extraterritoriality.” However, labor migration is regulated by a different principle — based on a person’s actual activities in the country, rather than the company’s status.
How labor migration is regulated
Current legislation applies to foreigners without a permanent residence permit who:
- work for Georgian companies;
- engage in entrepreneurial activities;
- earn income within the country.
Starting March 1, 2026, the rules will also apply to self‐employed foreigners.
The law identifies several key categories:
- local employer — a company registered in Georgia;
- self‐employed foreigner — a person earning income from business activities;
- labor migrant — a foreigner working for a local employer.
Thus, a foreign director who effectively manages a business in Georgia falls under these regulations regardless of whether the company is a resident of the FIZ.
When a director of a foreign‐owned company needs a work permit
A work permit is generally required if:
- the director is a foreign national;
- he does not have a permanent residence permit;
- he is physically present in Georgia;
- he manages the company, signs documents, conducts negotiations, and receives income.
When a permit may not be required
In certain cases, the requirements may not apply:
- the director manages the company entirely from abroad;
- he has a permanent residence permit;
- a special exemption applies under the law or international agreements.
Why the Free Industrial Zone (FIZ) does not exempt from requirements
The Law on Free Industrial Zones regulates the tax and organizational aspects of business but does not establish immigration benefits for directors. This means that:
- The FIZ is a special regime for the company;
- but not a separate status for a foreign executive.
Therefore, general labor migration rules must be applied.
Common scenarios
- The director lives and works in Georgia — a permit is required
- Visits regularly and manages the business — a permit is most likely required
- Manages from abroad — may not be required
- Holds a permanent residence permit — different rules apply
- Company in the FIZ — does not affect the need for a permit
The main criterion — actual business activity in the country.
Risks of not having a permit
Controls have been tightened since 2026. Possible consequences:
- fines (including fines starting at 2,000 GEL);
- inspections by regulatory authorities;
- difficulties obtaining visas and residence permits;
- additional compliance risks for the business.
Practical recommendations
To mitigate risks, companies should:
- verify the director’s immigration status;
- determine where management is actually carried out;
- prepare the necessary documents for authorization in advance when operating from Georgia;
- not confuse tax incentives for SIEs with immigration rules;
- monitor changes in legislation.
Are exceptions possible in the future?
In theory, the government could introduce special conditions for the Special Economic Zone. However, there are currently no such regulations, so businesses should adhere to the general requirements.
Conclusion
If the director of a company in the Free Industrial Zone is actually working from Georgia and does not have a permanent residence permit, they generally need to obtain a work permit. The zone’s special status does not override labor migration requirements.