The Licensing Boundaries of a Live-Dealer Studio
A live-dealer studio is that model of the gambling business where a studio located in Georgia serves foreign operators through live streaming: dealers, cameras, studio infrastructure and the online channel of the games. The licensing assessment of this model begins at the crossing of two articles. Article 5 provides that the conduct of all kinds of gambling and promotional games on the territory of Georgia, as well as the supply of gambling and promotional games on the territory of Georgia, requires a permit in accordance with the Law on Licences and Permits. Conduct or supply without a permit is a violation of the law and entails liability.
Article 3, in turn, defines what supply is: 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 influences or may influence the results of such games. From this follows the central question of the studio model: where does the supply take place — on the territory of Georgia or outside it.
The Export Model and Its Georgian Layer
A studio that serves only foreign operators and does not supply games to the Georgian market operates outside the law’s permit catalogue: its service is directed at persons abroad, and Georgian territory is for it a labour and production layer. It is precisely this model that has made the live-dealer studio a Georgian export product: a Georgian environment, a Georgian team and an international clientele. However, under the same law the Minister of Finance is authorised to determine the services whose provision is prohibited to a person operating in the gambling business sphere abroad — so the lawfulness of the export model must be re-verified periodically.
The model’s Georgian layer also requires compliance with other rules: labour relations with dealers and technical staff, industrial safety, tax residency and the payment procedure. The law also contains a maritime ban: on all floating objects in the internal waters and territorial sea of Georgia, persons registered in Georgia are prohibited from organising gambling or promotional games.
When the Permit Regime Switches On
Once a studio supplies games to the territory of Georgia — begins serving Georgian operators — the model changes: such supply falls directly under Article 5’s requirement and requires a supply permit. Article 11 provides that the supply of gambling and promotional games is on the list of activities subject to permitting, a permit under this article is issued only to an entrepreneur registered in Georgia, and the supply permit is issued for a term of 5 years.
The supply-permit regime also means that the studio’s essential products — the gaming platform, the random number generation platform, the jackpot system, the player base, the financial system and the management system — pass into the regime of authorisation and of the electronic control system. That is the price which entry into the Georgian market demands, and it must be calculated in the business plan in advance.
Practical Rules of Structuring
When structuring an export studio, three rules are central. First: segmentation of the clientele — identify which contracts serve foreign operators and which may be treated as supply on the territory of Georgia; the boundary is often invisible, for example where Georgian servers or access by Georgian players are involved. Second: documentary precision — the territorial scope and content of services in contracts must be described so that manageability is preserved. Third: readiness for a change of regime — if the business decides to enter the Georgian market, the bureaucratic cycle of obtaining the permit must be calculated in advance.
Separate attention belongs to the international context: the studio’s clients are connected to regulators of other jurisdictions, and their requirements — licences, technical audits, data protection — are passed on to the studio by contract. Meeting such requirements is often precisely the competitive advantage of the export model.
Frequently Asked Questions
Does an export studio need a Georgian permit?
If the studio serves only foreign operators and no supply takes place on the territory of Georgia — the permit catalogue does not cover it; once supply to the Georgian market begins, a supply permit becomes mandatory.
For what term is a supply permit issued?
For 5 years, and only to an entrepreneur registered in Georgia.
Can the studio’s services abroad be prohibited?
The law empowers the Minister of Finance to determine such prohibited services, so the question must be re-verified against the current state of regulation.
What does the maritime ban mean?
On floating objects in Georgia’s internal waters and territorial sea, Georgian persons are prohibited from organising games — this boundary must also be taken into account in the export model.
How We Help on Legal.ge
We will assess your studio model through the prism of the lawfulness of supply, separate the export and Georgian fields of activity, prepare the contract structure and, where necessary, the full cycle of obtaining the supply permit. Contact us on Legal.ge — the export model remains lawful only through continuous verification.