What Constitutes the Supply of Gambling and Promotional Games
A game provider is the segment of the gambling business that delivers technological content to operators — games, platforms and infrastructure. Article 3 of the Law of Georgia on Organising Lotteries, Gambling and Promotional Games defines this activity precisely: the supply of gambling and promotional games means the direct or indirect provision of essential products or services, on the basis of a supply permit, to the organiser of the game and/or to a person outside the territory of Georgia, which may influence or does influence the results of such games — with or without the participation of the supplier. A supplier is a person who carries out such supply.
The whole customs zone of this regime follows from that definition: if your product influences game results, even in a purely technical role, you already operate in the supplier regime and need a supply permit. The law also separately defines the authorisation certificate — a certificate issued by the selected person confirming the conformity of a game and of certain essential products or services with the standards established by the Minister of Finance of Georgia.
Essential Products and Services
Article 3 lists in detail what falls within the concept of essential products or services, and that list mirrors the modern supplier business model exactly: gambling and promotional games, including games organised in systematic-electronic form; the random number generation platform; the jackpot platform — the highest category of the draw and the rules for determining and distributing its initial and growing amounts; the gaming platform, including the server or servers on which the result of the game is directly revealed; the player base; the financial base or system; the management system — the internal management or control system of the organiser and the supplier; and gaming machines.
The practical conclusion is clear: a server on which the game result is revealed, just like a random number generator or a jackpot system, is essential product. Therefore the documentation for a supplier permit rests precisely on describing and certifying these elements, and they also become objects of the electronic control system.
The Supply Permit: Conditions, Term and Restrictions
Article 11 includes the supply of gambling and promotional games among the activities subject to permitting, as a separate sub-item. A permit under this article is issued only to an entrepreneur registered in Georgia, and the law sets the term of a lotto or bingo permit and of a permit for supplying gambling and promotional games at 5 years.
The decisive restrictions sit here as well: the transfer of a permit under this article to another person is prohibited; a permit is not issued where recognised tax debt exists; and it is prohibited to issue a supply permit to a person whose representative, founder or partner, or beneficial owner, has been convicted or previously convicted of a deliberate economic crime, including in the sphere of financial activity, or of a deliberate serious or especially serious crime, unless the conviction has been expunged or extinguished. Under the same law, the Government is authorised to establish additional conditions for issuing the supply permit, and the Minister of Finance may introduce requirements and standards for essential products and other devices.
Documentation Required for the Permit
Article 24-1 defines the documents that, in addition to the general documentation provided for by the Law on Licences and Permits, you must submit to the Revenue Service. These are: the list and detailed description of the games and/or essential products or services to be supplied; the authorisation certificate; certificates on the criminal record of the permit seeker’s representative, founder or partner, and beneficial owner — issued by the competent authority of the country of which that person is a citizen; and a document confirming the origin of the funds needed to pay the permit fee, for whose accuracy the permit seeker is responsible.
In addition, the Service is entitled to request any other document or information needed to consider the application and adopt a decision. Preparing the application is therefore not a formality: the completeness of the list and the detail of the descriptions directly determine the length of the process and the risk of refusal.
Changes During the Supply and Ongoing Control
Obtaining the permit is only the beginning. Where the game supplied and/or the essential product or service substantially changes — the jackpot payout rule changes, existing games are modified in any way, or new games are added — you are obliged to notify the Revenue Service of the change and submit an authorisation certificate; without consent, supplying the substantially changed game or product is prohibited. A change is substantial if it may affect the player’s stake, the amount of winnings, the architecture of the game, the combinatorial lines, the random number generation platform, or the jackpot payout system.
Relations with organisers are regulated too: the supplier must submit to the Revenue Service a copy of the contract concluded with the permit-holding organiser no later than 3 days from its conclusion, and where the contract is amended, notify the Service within 2 days of the change and submit a copy of the amendment document. The supplier must also pay in a timely manner the fee due to the selected person — the fee that serves the deployment and operation of the electronic control system.
Frequently Asked Questions
Who can hold a supplier permit?
Only an entrepreneur registered in Georgia. Transfer of the permit to another person is prohibited, and convictions of the management, founders or beneficial owners for deliberate economic or serious crimes block the permit.
For what term is a supply permit issued?
For 5 years, like lotto and bingo permits. Where recognised tax debt exists, the permit is not issued at all.
When is the Revenue Service’s consent to a change required?
When a game or essential product substantially changes: a new jackpot rule, modified or added games. Supplying such changes without consent is prohibited.
What happens after concluding a contract with an operator?
A copy of the contract must be submitted to the Revenue Service no later than 3 days from conclusion, and amendments must be notified within 2 days together with a copy of the amendment document.
How We Help on Legal.ge
We will prepare the full package for a supplier permit — from the description of games and essential products to the coordination of criminal record certificates — assess whether your structure meets the permit conditions, and guide you through the consent process for substantial changes. Contact us on Legal.ge to assess your transition into the supplier regime.