---
title: "Territorial Restrictions and Hotel Complexes"
url: "https://legal.ge/en/service/media-entertainment-and-sports-law-en/territorial-restrictions-and-hotel-complexes-en"
field: "Media, Entertainment & Sports Law"
description: "Territorial restrictions — Articles 5, 11, 35: prohibited institutions, municipal zones, club only in Tbilisi. Legal.ge."
updated: "2026-10-15"
publisher: "legal.ge"
---

# Territorial Restrictions and Hotel Complexes

> Source: legal.ge, https://legal.ge/en/service/media-entertainment-and-sports-law-en/territorial-restrictions-and-hotel-complexes-en

## 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 full text is available on legal.ge after signing in: https://legal.ge/en/service/media-entertainment-and-sports-law-en/territorial-restrictions-and-hotel-complexes-en

### What does the law prohibit territorially?

Organising games and distributing tickets in children’s, medical, educational, cult and administrative institutions, libraries and museums, and in places prohibited by the municipality.

### What is the source of permitted zones?

The decision of the relevant municipal body, which determines zones beyond the places prohibited by law.

### Why is the analysis of a complex partial?

Because the prohibition follows the specific building and its purpose: the permissibility of one building does not extend to the whole complex.

### What is special for a club?

Only the Tbilisi municipality and only a base-permit holder, as a separate object.