Georgia's real estate sector has attracted substantial foreign capital over recent years. New legislative measures affecting property transfer and land registration have now introduced obligations that international owners and investors cannot afford to overlook. Failure to act before the applicable deadlines may result in title complications, blocked transactions, or financial penalties under Georgian property and civil legislation.
Recent amendments to Georgian real estate regulation tighten the requirements for foreign nationals and foreign-owned entities holding or acquiring property in Georgia. The changes affect how title deeds are registered, how due diligence must be conducted before property transfer. Additionally. What documentation foreign owners must submit to the Sakartvelosa Sadjaro Reestri (National Agency of the Public Registry of Georgia). Foreign owners of Georgian real estate should treat the end of 2025 as the operative compliance horizon for existing holdings.
This alert covers what has changed, which categories of owner are affected, and the immediate steps required to protect title and preserve transaction capacity in Georgia.
What changed and when it takes effect
Georgia's legislature amended its investment and land-ownership rules under a package of measures touching property legislation, conveyancing procedures, and the land register. The core change tightens restrictions on foreign nationals and foreign-registered legal entities acquiring or retaining agricultural land and certain designated real estate categories.
Under Georgian property legislation, a foreign natural or legal person is broadly defined by reference to habitual residence, place of incorporation, and the nationality of controlling shareholders. The amended rules extend scrutiny to beneficial ownership structures. A foreign-controlled Georgian entity – one where a non-resident holds a qualifying interest – may now fall within the same restrictive regime as a directly foreign-owned entity.
A secondary change concerns the conveyancing process itself. Notarial deed requirements have been strengthened. A notarialuri aqti (notarial deed) executed before a Georgian notary is now the mandatory instrument for all property transfers involving a foreign party. Informal or foreign-notarised documents will no longer be accepted at the land register for title registration without local notarisation.
The measures formally entered into force on 1 January 2025. Transitional provisions for existing holdings are tied to a grace period that expires at the close of the 2025 calendar year. Owners who have not taken remedial steps by that date risk having their entries on the land register flagged as non-compliant – a status that can block sale, mortgage, and lease transactions.
For a broader view of how Georgian real estate law interacts with tax obligations on property income and capital gains, see our overview of tax law in Georgia.
Who is affected and what triggers compliance obligations
The amended rules apply most directly to three categories of foreign property owner.
Foreign natural persons holding title to agricultural land or land within restricted zones face the most immediate exposure. The legislation identifies specific land categories – agricultural, border-adjacent, and certain state-designated zones – where foreign ownership is either prohibited or subject to prior approval.
Foreign legal entities incorporated outside Georgia and holding Georgian real estate must verify that their ownership structure is consistent with current law. Entities incorporated in Georgia but controlled by foreign nationals above a defined shareholding threshold are treated as foreign persons for these purposes.
Georgian holding structures with foreign beneficial owners require the most careful due diligence review. Where a Georgian limited liability company or joint-stock company holds land on behalf of a foreign investor, the beneficial ownership analysis now determines regulatory status. Practitioners in Georgia note that multi-layered structures assembled before the 2025 amendments are particularly vulnerable to reclassification.
The threshold for the beneficial ownership analysis is set at a qualifying majority interest. Minority foreign shareholdings below that threshold do not, in isolation, trigger the restriction – but combined holdings across related parties may aggregate to the qualifying level under Georgian corporate and property legislation.
To receive an expert assessment of your property ownership position in Georgia, contact us at info@ferrazwhitmore.com.
Immediate actions required before the compliance deadline
Foreign property owners in Georgia should take the following steps without delay.
- Conduct a title deed audit. Verify that each title deed recorded in the land register accurately reflects the current ownership structure. Discrepancies between the registered owner and the actual beneficial owner are a frequent source of compliance exposure.
- Perform full due diligence on land category. Confirm whether each parcel falls within the restricted categories under Georgian land legislation. Agricultural and border-zone classifications are not always apparent from historical transfer documents.
- Review all notarial deeds for Georgian-law compliance. Any property transfer completed using a foreign-notarised instrument should be assessed for re-execution before a Georgian notary. The land register will not accept non-compliant instruments for future dealings.
- Map beneficial ownership against the qualifying threshold. Foreign investors holding Georgian real estate through local entities must document the shareholding chain and confirm that no aggregation issue arises under the amended rules.
- File any required notifications or approval applications promptly. Where prior approval from the relevant Georgian authority is required for continued foreign ownership, the grace period running to end-2025 limits the available window to prepare and submit those applications.
International investors with Georgian real estate holdings should also review our dedicated resource on real estate law in Georgia for a comprehensive view of the acquisition and registration process.
Comparable regulatory tightening has occurred in other CIS jurisdictions. Our alert on real estate regulation changes in Russia outlines parallel developments for investors active across the region.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our real estate and cross-border investment practice supports foreign property owners, institutional investors, and corporate groups managing assets across CIS and high-growth markets, including Georgia. As a law firm in Georgia matters, we provide coordinated legal support spanning property due diligence, land register filings, notarial deed review, and regulatory compliance under Georgian property and investment legislation. Our team includes practitioners experienced before Georgian registration authorities and in cross-border conveyancing across civil law systems. Engaging a lawyer in Georgia with cross-border experience is especially important where beneficial ownership structures or restricted land categories are involved. To discuss your Georgian property holdings and compliance position, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.