The Legal Basis for Expanding a Network of Betting Points
Expanding a network of branches and betting points in the Georgian gambling business is not a purely commercial decision: every step of that expansion sits inside the permit framework established by the Law of Georgia on Organising Lotteries, Gambling and Promotional Games. Under Article 7 of that law, the issuance of permits for organising gambling and promotional games and for supplying gambling games, the introduction of amendments to such permits, their revocation and the entry of the relevant data into the official permit registry are carried out by the Revenue Service, in accordance with the Law of Georgia on Licences and Permits and with the gambling law itself. In practical terms, this means that every new point, cash desk or branch you add to your network requires formalised communication with a state authority, and the way that communication is structured determines whether the expansion remains compliant.
The same article empowers the Revenue Service to verify the reliability of the documents submitted by a permit seeker and their compliance with the requirements established by the law. A network expansion plan should therefore be built from the outset around documentation that will survive verification at the level of permit conditions; otherwise each new outlet becomes a source of risk, and its opening may trigger fines and other permit-related measures.
Changing the Location of Gaming Objects
Where your expansion involves changing the location of totalizator, lotto and bingo objects, Article 13 defines the documents that the organiser of promotional games must submit to the Revenue Service. These are: the contract between the permit holder and the person preparing the tickets, which must indicate the quantity and numbering of the tickets to be prepared; the conditions for organising the promotional game (the regulations), or, for a game organised in systematic-electronic form, the rules of such a game; a sample of the ticket; and an authorisation certificate confirming the conformity of the essential products or services to be used with the standards established by the Minister of Finance of Georgia.
For a change in the location of a casino, a gaming machine hall or a gambling club, Article 21 is more concise: the organiser of the gambling game must submit to the Revenue Service the conditions for organising the relevant game (the regulations). In addition, where a totalizator cash desk is being arranged, the organiser must, before amending the regulations, provide the Service with information about the address or addresses of the immovable property intended for the cash desk, an obligation anchored in other provisions of the law. Every change of location is also reflected in the permit registry, since that procedure falls within the competence of the Revenue Service.
Consent or Notification: The Two Regimes of Change
Articles 13 and 21 divide amendments into two distinct regimes, and across a network this distinction is decisive. Where changes are made to the general rules of the game, to the list of games and to their detailed descriptions — for gambling games, to the rules of the games conducted in a casino, gaming machine hall or gambling club, to the list and the descriptions — the organiser must apply to the Revenue Service for consent before implementing the change, and may implement it only after consent is obtained. For all other changes, notification suffices: information about the change must be provided to the Revenue Service no later than 1 day before the change is implemented.
For games organised over the internet there is an additional obligation: a notice about the change must be posted on the website dedicated to the game within 2 days of its introduction. A special regime also applies to changes in the number of POS terminals or in the essential products and services used: the holder of a totalizator permit must notify the Revenue Service of such a change no later than 2 days before implementing it and must submit an authorisation certificate where terminals or essential products are replaced or added. Where a totalizator is organised in systematic-electronic form, the rules of the game are submitted separately for consent, in line with the relevant provisions of the law.
The Stage-Based Regime of Promotional Draws
If your expansion touches promotional draws, take account of the stage-based restrictions: before the completion of one stage of a promotional draw it is prohibited to introduce changes into the draw regulations, except changes to the quantity and numbering of the tickets. The organiser must provide the Revenue Service with information about such a change no later than 1 day before implementing it. It is likewise prohibited to conduct two or more stages simultaneously under a single permit for organising a promotional draw.
For every new stage of a promotional draw the organiser must obtain the consent of the Revenue Service by submitting the draw regulations, a sample of the ticket and the contract with the person preparing the tickets, which reflects the quantity and numbering of the tickets to be prepared. Violation of these requirements is treated as a violation of permit conditions and becomes a ground for liability.
Oversight, Fines and the Payment Deadline
Network expansion also means an intensified oversight regime. Under Article 7, the Revenue Service may impose control over the fulfilment of permit conditions: during a calendar year, at any time and without quantitative limitation, the state of the permit holder’s compliance with the requirements established by the law and other normative acts may be inspected. The procedure for such inspection is established by a joint order of the Minister of Finance and the Minister of Internal Affairs of Georgia.
In addition, the Revenue Service is authorised, through a selected person, to introduce an electronic control system in accordance with Georgian legislation, and to monitor the fulfilment of permit conditions both within the framework of inspections and in ongoing mode — including, where a violation has occurred, conducting an inspection of compliance with permit conditions for the period of a currently valid permit as well. A permit holder who violates permit conditions is fined by the Revenue Service or by the Ministry of Internal Affairs of Georgia. The fine must be paid within 30 calendar days from the moment the individual administrative-legal act imposing the fine is handed to you, and the administration of such fines follows the rules established by the Tax Code.
Frequently Asked Questions
Does every new betting point require a separate permit?
The law regulates changes within existing permits: introducing amendments to permits and entering them into the registry is the competence of the Revenue Service. Adding a new object is treated as a change that requires either consent or timely notification, and the list of documents depends on the type of game involved.
Which changes require the consent of the Revenue Service?
Consent is required for changes to the general or current rules of the games, to the list of games and to their descriptions. For other changes it is enough to provide information no later than 1 day before implementation, and for games organised over the internet the notice is also posted on the game website within 2 days.
Within what period must a fine for violating permit conditions be paid?
The fine is payable within 30 calendar days from the handover of the individual administrative-legal act imposing it. The fine may be imposed both by the Revenue Service and by the Ministry of Internal Affairs.
Can several stages of a promotional draw run in parallel?
No. Conducting two or more stages simultaneously under a single permit is prohibited. Moreover, before the current stage is completed no changes may be made to the regulations, except changes to the quantity and numbering of the tickets.
How We Help on Legal.ge
Our team supports the full cycle of network expansion: we assess which regime applies to each planned change — consent or notification — prepare the documentation for submission to the Revenue Service, map the risks of your network against the requirements of the electronic control system, and assist in fine-related matters, including payment deadlines and appeal possibilities. Contact us on Legal.ge for an individual legal assessment of your expansion plan.
