Insolvency manager's failure to publish the required report (Art. 165¹⁰)

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What is the fine under Article 165¹⁰?

The first part carries a fine of 500 GEL. Where the same act is committed repeatedly, the second part carries 1,500 GEL. Both are fixed amounts rather than ranges, so there is no room under this article to negotiate the figure down.

The report was published, only late. Is that a breach?

Article 165¹⁰ does not itself set a deadline; it refers to the failure to comply with the obligation. The answer therefore depends on what obligation existed in the particular proceedings and how the conduct is described in the protocol. Evidence establishing the date of publication is the central document in such a dispute.

Why was I fined 1,500 GEL rather than 500?

1,500 GEL is the penalty under the second part and applies only where the act is committed repeatedly. Check which earlier fact the decision relies on for that finding and whether it is documented. That earlier fact is what these cases most often turn on.

Does the report have to cover both matters?

The article names two: the debtor's financial condition, and the selected form of realisation of the property. If the allegation concerns only one of them, establishing that scope is the first thing to do, because which of the two is in issue is what defines the case.

Does the fine affect my standing as manager?

Article 165¹⁰ provides for a fine and nothing else — it does not itself provide for removal or any other consequence. Whether anything further follows is determined outside this article and has to be assessed separately.

4 min·22 Aug 2026

Who Article 165¹⁰ applies to

Article 165¹⁰ of the Georgian Code of Administrative Offences has a narrow addressee: its first part regulates the conduct of the insolvency manager. It is not concerned with the outcome of the insolvency proceedings, and it is not concerned with the merits of the manager's commercial decisions. It targets one specific procedural duty — the publication of a report.

That duty is, in substance, a transparency instrument. The debtor's financial position, and the form chosen for realising the estate, are precisely the two matters on which creditors, the debtor and the other participants in the process build their own decisions. If the information is not published, those participants cannot follow what is happening to the estate, and it is that gap which the law attaches administrative liability to.

It is also worth bearing in mind that the duty is not an internal matter for the manager alone. For a creditor or for the debtor, an unpublished report means a shortage of exactly the information on which they have to base their own decisions — about the realisation of the estate, or about their own claim. A case of this kind therefore tends to unfold in a wider context than a single isolated administrative episode.