---
title: "Regulatory Order Challenges"
url: "https://legal.ge/en/service/dispute-resolution-and-litigation-en/regulatory-order-challenges-en"
field: "Dispute Resolution & Litigation"
description: "Challenging a regulator's order in Georgia: suspension, securing and withdrawal under the Code. Legal.ge."
reviewed: "2026-07-09"
updated: "2026-10-15"
publisher: "legal.ge"
---

# Regulatory Order Challenges

> Source: legal.ge, https://legal.ge/en/service/dispute-resolution-and-litigation-en/regulatory-order-challenges-en

Challenging a regulator's order in Georgia is governed by the Administrative Procedure Code: an interested party may appeal an administrative-legal act issued by an administrative organ — including a regulator's order — and the appeal also triggers suspension of the act's operation. The Code simultaneously regulates the object of the appeal, the fate of the enforcement-securing decision, the suspension procedure and the possibility of withdrawing the complaint. This page explains these mechanisms under Articles 176, 177, 184 and 191 of the Code.

## The right of appeal and its limits

Under the first part of Article 177, an interested party may appeal an administrative-legal act issued by an administrative organ. The second part links the violation of the issuance deadline to the same right: the exceeding of the deadline established for issuing the act counts as a refusal to issue and is appealed under the same procedure; under the third part, an administrative organ's conduct not connected with the issuance of an act is appealed likewise. The object of the right is thus threefold: the issued act, a refusal expressed through the exceeding of the deadline, and the organ's separate conduct.

The limit is precise: a decision taken on a question of administrative procedure is not subject to separate appeal, unless this is directly provided by law or the decision independently of the respective administrative-legal act violates a person's right or lawful interest. The exception is two-pronged: either the law directly admits separate appeal, or the procedural decision itself reaches the result of violating the person's right independently of the act — in every other case the dispute must be built on the main act, and the procedural decision is examined within its frame.

The right of appeal is broad and covers not only the formal order but the organ's conduct directly: where a regulator restricts activity by factual conduct instead of an issued act, that conduct is appealed through the same channel. This closes the device where the refusal is expressed not in the form of an act but by the simple exceeding of the issuance deadline.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/dispute-resolution-and-litigation-en/regulatory-order-challenges-en

### Can a regulator's order be appealed?

Yes — as an administrative-legal act.

### When is the act suspended?

From registration of the complaint, subject to exceptions.

### What of the missed deadline?

It counts as refusal and is appealable.

### What of a procedural decision?

Separate appeal only if directly provided by law or it independently violates a right.

### May the complaint be withdrawn?

Yes, before the decision, in writing.