Will a work permit be required for a director at a Free Industrial Zone in Georgia in 2026?

Following the update to Georgia’s labor migration regulations, the issue of whether a work permit is required has become relevant for companies operating in Free Industrial Zones (FIZ). Although these zones have a special legal and tax regime, this does not automatically exempt foreign directors from the requirements of migration law.

Short Answer

In most cases — yes, a foreign director of a company in an FIZ needs a work permit if they are actually conducting business in Georgia and do not have a permanent residence permit or another legal basis for exemption. The company’s status in an FIZ alone does not grant an automatic exemption.

Why the confusion arises

FIZ have a number of features that create the impression of a “separate jurisdiction”:

• a special tax regime;
• simplified business conditions;
• separate customs and regulatory rules.

Because of this, many assume that employment within FIZs is regulated differently. However, the law on labor migration is based not on the company’s status, but on the fact that a foreigner is engaged in paid work in Georgia.

What the labor migration law covers

Current legislation applies to foreign nationals without a permanent residence permit who:

• work for a Georgian company;
• engage in entrepreneurial activities;
• earn income within the country.

Starting March 1, 2026, the rules will also directly apply to self‐employed foreigners.

Key terms:

• local employer — a company registered in Georgia;
• self‐employed foreigner — a person earning income from activities in the country;
• labor migrant — a foreigner working for a Georgian employer.

Thus, a foreign director managing a company in Georgia generally falls under these regulations regardless of whether the company operates in a FIZ, a Virtual Zone, or under standard jurisdiction.

When a director in a special economic zone needs a permit

A permit is generally required if:

• the director is a foreign citizen;
• he does not have a permanent residence permit;
• he is physically present in Georgia;
• he actually manages the company (signs documents, conducts negotiations, oversees operations, and receives income).

When a permit may not be required

In certain cases, a permit is not required:

• 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 Zones law does not exempt from requirements

The Free Industrial Zones Law regulates:

• the establishment and management of zones;
• tax incentives;
• organizational aspects of business operations.

However, it does not establish immigration exemptions for foreign directors. This means that a Free Industrial Zone is a tax and business regime, not a separate immigration status.

The main criterion is actual operations in Georgia, not the company’s legal status.

Risks of operating without a permit

Starting in 2026, enforcement will be stepped up. Possible consequences include:

• fines (starting at 2,000 GEL and higher for repeat violations);
• inspections by regulatory authorities;
• difficulties in obtaining residence permits and visas;
• additional compliance risks for businesses.

Practical recommendations

Directors and owners should:

• verify their immigration status;
• determine where management is actually carried out;
• when working from Georgia, prepare documents for a permit or residence permit in advance;
• not confuse tax benefits for foreign investors with immigration rules;
• monitor changes in legislation.

Are there any exemptions for foreign directors?

Theoretically, yes. Special conditions or simplified procedures may be introduced in the future. However, there are currently no such provisions in the law, so companies should follow the general rules.

Conclusion

If a foreign director actually manages a company from Georgia, it is safer to assume that a work permit is required. Until the legislation includes exceptions for foreign directors, the general labor migration regime applies.