Does the director of a company in the Tbilisi Free Industrial Zone need a work permit?

With the introduction of new labor migration rules in Georgia, the question of whether company directors need a work permit has become relevant not only for ordinary LLCs but also for businesses operating in Free Industrial Zones (FIZ). The FIZ Law grants companies a special tax and legal regime; however, this does not automatically exempt a foreign director from labor migration requirements.

Short answer

A foreign director of a company in an FIZ will most often need a work permit if they actively manage the business in Georgia and do not have a permanent residence permit or another legal exemption. The company’s status within the FIZ does not, in and of itself, exempt the director from the requirements of labor migration law.

Why the confusion arises

Companies in the FIZ possess a number of “extraterritorial characteristics”:

• a special legal and tax regime;
• unique operating rules within the zone;
• separate customs and regulatory infrastructure.

Because of this, it sometimes appears that the director’s activities should be regulated separately. However, labor migration in Georgia is assessed not by the company’s tax status, but by the actual performance of paid work and the director’s legal status.

What the law says

The new law on labor migration applies to:

• foreign workers without a permanent residence permit;
• paid employment and entrepreneurial activities effective March 1, 2026;
• self‐employed foreigners.

Key definitions in the law:

• Local employer — a legal entity registered in Georgia;
• Self‐employed alien — a foreigner without a residence permit who engages in paid work for profit;
• Labor immigrant — a foreigner working for a local employer without a residence permit.

Thus, a foreign director who actually manages a company in Georgia falls under the scope of the law regardless of whether the company is registered in the Free Industrial Zone.

When a work permit is required

A work permit is required if:

• the director is a foreign national;
• they do not have a permanent residence permit;
• they actually manage the company in Georgia;
• he receives remuneration or participates in financial activities.

An exemption is possible if:

• management is carried out entirely from abroad;
• he has a permanent residence permit;
• a direct exemption established by law or an international agreement applies.

Why FIZ Status Does Not Grant Exemption

The FIZ Law regulates the tax and organizational aspects of companies operating in the zone, but does not grant foreign directors a separate immigration status. Consequently, FIZ benefits do not equate to an exemption from labor migration requirements.

When a permit is required

• A foreigner lives in and manages a company in the SEZ — a permit is required.
• Regularly stays in Georgia and conducts business — most likely, a permit is required.
• Manages the company from abroad — often not required, but needs to be verified.
• Has a permanent residence permit — usually not required.
• Company in the FIZ, director without preferential status — required.

The key factor is the director’s actual activity in Georgia, not the company’s address.

Risks of not having a permit

Starting March 1, 2026, the law links the legality of employment to the right to work. Violations may result in:

• fines (e.g., GEL 2,000 for the first violation);
• inspections by the Labor Inspectorate and the Ministry of Internal Affairs;
• difficulties in subsequently obtaining a D1 visa or residence permit;
• increased compliance risks for the company.

Practical recommendations

For companies in the Free Industrial Zone, it is safer to assume that a foreign director must obtain a work permit until an official exemption for FIZs is introduced:

• Verify the director’s status (residence permit, exemptions).
• Determine the place of actual management.
• If operations are conducted from Georgia — prepare a package of documents for a D1 or work permit.
• Do not confuse FIZ tax incentives with immigration rights.
• Monitor changes in legislation.

The role of TBILISI.FIZ.GE

TBILISI.FIZ.GE helps:

• determine whether a work permit is required for a specific management model;
• develop a strategy for obtaining a work permit or residence permit;
• assess the risks for the director and employees;
• prepare the company’s legal position in the event of disputes.

FAQ