The Catalogue of Water Permits
The permit side of water use is resolved by the catalogue of permit types in the licensing law, and in that catalogue three types are provided for surface-water objects: the permit for the abstraction of water from a surface-water object; the permit for the discharge of water into a surface-water object; and the combined permit for the use of a surface-water object. These three types reflect precisely the three possible relations with a water object — abstraction, discharge, and both together. An important detail: these norms enter into force from 1 September 2027 — in the current period, activities affecting water are resolved through the environmental-decision regime, and the transition to the permit catalogue is a planned change. This transitional period must be shown openly: the page describes both the current frame and the prospective types.
The Application and Documentation
A permit seeker submits to the issuer a written application, submitted under the procedure established by the General Administrative Code; the application contains an indication of the desired permit type and a list of attached documents. A private-law legal entity and an individual entrepreneur attach extracts from the public registry; a natural person — copies of identification documents; a public-law legal entity — certified copies of founding documents. The application is accompanied by proof of payment of the permit fee, whose amount is determined by the separate law on fees. Additional permit conditions are established by law or, on its basis, by a normative act of the government or a decision of a municipality’s representative organ.
The procedural deadlines are likewise statutory: to establish the factual circumstances within another organ’s competence, the issuer transmits copies of the application no later than 3 days; the other organ adopts a decision no later than 15 days from the submission of the copies, with extension possible by motion no later than 5 days from receipt; the decision is sent to the issuer no later than 17 days. If within the term neither confirmation nor refusal occurs, the additional conditions are deemed satisfied. Upon a change of data the holder must notify within 7 days.
The General Issuance Rule
The issuer adopts its decision under the simple administrative proceeding — apart from the separately described exceptions. This means no public familiarisation or hearing is held, and the procedure is comparatively fast.
The Challenge of the Transition
The entry into force of the water permits from 2027 creates a transition period: the current environmental-decision regime and the prospective permit catalogue rest on differing logics — the first on impact assessment, the second on a concrete action (abstraction or discharge). In planning a project this difference must be considered: today’s requirements rest on one frame, and after 2027 the system of the three permit types takes over.
Practical Recommendations
First, establish the type of your activity — abstraction, discharge or combined — it determines the prospective permit type. Second, take account of the 2027 transition: assess which regime operates on your planning horizon. Third, prepare the documentation precisely — the indication of the permit type in the application is mandatory. Fourth, remember the deadlines on another organ’s facts — 15/5/17 days, and 3 days before transmission.
Pay special attention also to the fact that the catalogue defines surface-water objects as the object of the permit — meaning rivers, lakes, reservoirs and other surface waters, not underground or sea water. This definition is practically significant: if your activity concerns an underground water object, its regulation is resolved by other norms and this catalogue does not extend to it.
During the transition it is recommended that investors and project planners take the requirements of both regimes into account simultaneously. Today’s environmental decision rests on a broad assessment of impact; from 2027 the action is defined concretely through the three permit types. Since planning horizons often exceed a year, the two regimes succeed one another, and knowing their requirements in advance determines the project’s time and financial frame.
Finally, although the simple administrative proceeding is comparatively fast, the deadlines of examining the case are protected by law and their violation is appealable. The issuer’s duties are strictly established — from checking the documentation to issuing the decision — and the deadline of each stage is separately determined. This means that obtaining a water permit, however simple formally, still demands planning of time and completeness of documentation.
Frequently Asked Questions
Below we answer the questions most frequently asked about water permits.
How many types of permit exist?
Three — within the time frame of transfer; in the transition period the catalogue unites the current and prospective types.
Who decides on issuance?
The general issuance rule is determined by the decision of a representative organ.
What happens on a change of ownership?
The permit holder must notify within 7 days.
How quickly is a permit issued?
It depends on the completeness of documentation; up to 3 days before transmission an action is required.
How We Help on Legal.ge
A water permit is measured by the completeness of documentation and the observance of deadlines. The lawyers of Legal.ge assist in preparing the application and planning the transition period. Submit a request on the site and receive qualified assistance.