The Two Storeys of Territorial Regulation
Before placing a gaming object in a hotel complex, the territorial question unfolds into two storeys. The first storey is general and comes from Article 5: in Georgia only the organisation of lotteries, gambling and promotional games provided for by this law, and the distribution of their tickets, is allowed. This means that before territorial analysis begins, the format of the game must itself fit within the law’s catalogue.
The second storey is the list of specific places: Article 35 prohibits the organisation of lotteries, gambling and promotional games (except promotional draws) and the sale/distribution of their tickets in children’s, medical and educational institutions, in cult buildings, children’s sanatoria, libraries, museums, and the administrative buildings of state government and municipal bodies, as well as in places prohibited by decision of the relevant municipal body.
The Layer of Municipal Decisions
By its second paragraph, Article 35 also grants a power to the relevant municipal body: it is authorised to determine the places — territorial zones, buildings — where the organisation of gambling and promotional games (except promotional draws) is possible, beyond the places prohibited by the first paragraph. Therefore the study of an object’s location is always built on two sources: the law’s categorical list and the decisions of the local authority.
The practical consequence: “placement in a complex” is not one question but an analysis of the specific building and its functional purpose. A hotel building and a medical or educational space connected to it fall into different regimes, and the permissibility of one part of the complex does not extend to the whole territory. The exception must also be remembered: the promotional draw is freed from these prohibitions — its ticket is free and it is treated as a consumer marketing instrument; therefore a contest action in the hotel lobby and a table game sit in different territorial regimes.
The Exceptional Geography of the Gambling Club
Article 11 also contains a territorial exception: a permit for organising a gambling club is issued only in the municipality of the city of Tbilisi, to the holder of a casino and/or gaming machine hall permit, and the club must be arranged as a separate object. In the club context, territorial analysis thus narrows down to the level of a single city.
Other rules of the same article are tied to geography as well: in the organisation of systematic-electronic games, the change of internet address and of the object’s location is possible only through amendments in the official permit registry. In general, the current structure is built so that the geographical parameter is considered an essential element of the permit, and its change is a status procedure, not an internal administrative decision.
The Algorithm for Checking a Hotel Complex
When planning a gaming project on a hotel complex, the order of checks is as follows. First: determine the format of the game and its corresponding permit in the catalogue of Article 11. Second: examine the specific building against the prohibited list of Article 35 — whether it is a children’s, medical, educational, cult or administrative building, or a library, museum or sanatorium. Third: verify the decisions of the relevant municipal body — both as to permitted zones and as to additional prohibitions. Fourth: the specific rules of the format — for example, the Tbilisi criterion for a club.
The case of seaside and wellness-hotel complexes deserves a separate note: the sanatorium function is directly mentioned among the prohibited categories, so planning a gaming zone around such a complex demands special caution — the formal purpose of a building and its real function often do not coincide, and the regulator looks precisely at the real function. Observing this algorithm ends with the conclusion being fixed in documents: copies of municipal acts, confirmations of the building’s purpose and a schematic plan of the location — this is the file that becomes the first assignment in communication with the regulator.
Frequently Asked Questions
Where are games categorically prohibited?
In children’s, medical and educational institutions, cult buildings, children’s sanatoria, libraries, museums and administrative buildings, as well as in places prohibited by municipal decision.
Who determines the permitted zones?
The relevant municipal body — beyond the list prohibited by the law, at the level of territorial zones and buildings, by its own decisions.
Can a club be opened outside Tbilisi?
No — a gambling club permit is issued only in the Tbilisi municipality, and only to the holder of a casino and/or gaming machine hall permit.
What happens when an object relocates?
A change of location is a status procedure: in systematic-electronic organisation, the change of internet address and location occurs only through an amendment in the permit registry.
How We Help on Legal.ge
We will conduct a full territorial audit of the location: the law’s list, municipal acts, a functional analysis of the building and the specific rules of the format. Contact us on Legal.ge — a territorial mistake is the most expensive one, because it is discovered at the construction stage.