The Legal Framework for a Foreign Group's Entry
For a foreign group, the analysis of the Georgian gambling market begins with the fundamental prohibition of the Law of Georgia on Organizing Lotteries, Gambling and Profitable Games: the conduct on the territory of Georgia of every type of gambling and/or profitable game, as well as the supply of gambling and/or profitable games, requires a permit in accordance with the Law on Licenses and Permits. Conduct or supply without a permit, as well as non-fulfillment of permit conditions, is considered a violation of the law and entails liability determined by legislation. Only the organization of games envisaged by this law and the distribution of their tickets is admissible.
Within this framework, the group's structural decisions are assessed in two directions: first, which entity will be the permit holder and how it will satisfy the permit requirements, and second, how the group's technological and financial resources — which the law treats as essential products/services — will be placed. Both questions are answered from the conceptual apparatus of the law, so a precise reading of the concepts before structuring is indispensable.
Critical Concepts: Essential Products, Supply, Beneficial Owner
Among the concepts defined in the third article of the law, decisive for a foreign group is the supply of gambling and/or profitable games: the direct or indirect supply of essential products/services, on the basis of a permit, to the organizer of the game and/or to a person outside the territory of Georgia, which may influence or does influence the results of the game. Essential products/services cover the games themselves, the random number generation platform, the jackpot platform, the gaming platform — including the server on which the result of the game is directly determined — the player base, the financial base/system, the management system and gaming machines.
The practical import of these concepts is that even those components of the group that physically remain abroad are treated as essential within the context of the Georgian permit regime if they carry the possibility of influencing the results of the game. In addition, the law defines the concept of the beneficial owner by reference to the law on facilitating the suppression of money laundering and terrorism financing — meaning the transparency of the ownership structure is an integral part of the permit analysis. The sector also knows the concept of an authorization certificate: a certificate issued by the selected person confirming the compliance of the game and of certain essential products/services with the standards introduced by the minister of finance.
The Regulator: Powers and Control of the Revenue Service
Under the seventh article of the law, the issuance of permits for organizing gambling and/or profitable games and for the supply of games, amendments to them, their cancellation and their passage through the official permit registry are carried out by the Revenue Service in accordance with the Law on Licenses and Permits and with this law. The regulator is authorized to verify the reliability of the documents submitted by the permit applicant and their compliance with the other requirements of this law, and in the case of organizing a casino — additionally with the special requirements connected with a casino.
The Revenue Service is authorized to impose control over the fulfillment of permit conditions: during a calendar year, at any time and without quantitative limitation, the state of the permit holder's fulfillment of the requirements may be inspected; the procedure of inspection is established by a joint order of the ministers of finance and of internal affairs. The electronic control system, introduced through a selected person, monitors permit conditions both within the scope of inspections and in ongoing mode — where a violation exists, an inspection is conducted for the period of the current permit as well.
For violation of permit conditions the permit holder is fined by the Revenue Service or by the Ministry of Internal Affairs, while the administration of the imposed fines is carried out by the tax organ under the procedure established by the Tax Code. The fine must be paid within 30 calendar days from the handing over of the individual administrative act — this deadline is part of the group's financial discipline and must be built into liquidity planning.
Delegated Norms and Other Restrictions
The law expressly provides that the Government of Georgia is authorized to establish additional conditions for the issuance of permits for organizing gambling games, for the systemic-electronic organization of casino and slot machine games, and for the supply of games, the non-fulfillment of which is deemed a violation of permit conditions. The minister of finance, for his part, introduces requirements and standards to be met by the essential products/services and any other equipment used by the permit applicant or holder. This means that the specific technical and organizational details are established by subordinate acts and must be verified against the current requirements at every stage of the project.
Among the additional restrictions: the minister of finance determines the services the provision of which is prohibited to a person operating in the gambling sphere outside the territory of Georgia; on floating objects in the internal waters and territorial sea of Georgia the organization of games by persons registered in Georgia is prohibited; and promotional games connected with tobacco products are directly excluded by the law. A foreign group's structure must account for these prohibitions in advance, so that no planned operation turns out to be contrary to the law.
Frequently Asked Questions
Who issues and controls gambling permits?
The Revenue Service. It issues, amends and cancels permits, verifies the submitted documents and imposes control over permit conditions — at any time during a calendar year and without quantitative limitation.
How does the electronic control system function?
For the purpose of controlling permit conditions, the Revenue Service introduces, through a selected person, an electronic control system and monitors the fulfillment of conditions both within inspections and in ongoing mode; where a violation exists, the inspection covers the period of the current permit as well.
What happens when permit conditions are violated?
The permit holder is fined by the Revenue Service or the Ministry of Internal Affairs. The fine must be paid within 30 calendar days from the handing over of the individual administrative act, and the administration of fines is carried out by the tax organ.
Where are the additional conditions and technical standards established?
The law delegates them: additional conditions of permit issuance are established by the Government, while requirements for essential products and other equipment are set by the minister of finance. The specific details are determined by those subordinate acts and must be verified with the regulator.
How We Help on Legal.ge
The Legal.ge team conducts regulatory analyses of the Georgian gambling market for foreign groups: we assess your structure's compliance with the requirements of the law, map the risks connected with supply and essential products, and prepare an indicative plan for obtaining a permit.
Contact us through Legal.ge — we will compare your group documentation with the Georgian legal framework and give you an initial assessment of your licensing strategy.