Pursuant to the Gambling Law (as defined below), gambling, or ‘game of chance’, is defined as any game (1) whose outcome depends entirely or partially on chance; (2) offering monetary winning.

Georgia recognizes and regulates all major gambling verticals, including land-based casinos, slot machine halls, land-based and online betting, online casinos, and lotteries.

Georgia’s gambling regulatory framework is multifaceted, comprising several key legal acts. The primary legislation governing the industry is the Law on Organising Lotteries, Games of Chance and Other Prize Games (2005) (“Gambling Law“).

Additional laws regulating procedures and rules for gambling businesses include:

• Law on Licence and Permit Fees (2003)
• Law on Gaming Business Fees (2006)
• Law on Advertising (1998)
• Law on Facilitating the Suppression of Money Laundering and Terrorism Financing (2019) (“AML Law“)

Subsidiary legislation further regulates specific aspects of gambling operations (e.g. technical regulations and specific ongoing compliance obligations).

Regulatory oversight of gambling in Georgia is distributed among several authorities:

• The Revenue Service under the Ministry of Finance (“the Regulator”): Primary regulator responsible for licensing and enforcement of gambling laws
• Financial Monitoring Service of Georgia: Oversees compliance with anti-money laundering regulations
• Georgian National Communications Commission: Acts as the advertising regulator for the gambling sector
• Random Systems Georgia (a commercial entity): Appointed to monitor technical compliance and implement best practices.

Yes, licenses for both land-based and remote operations are available, except for lotteries (monopoly based on tender).

a) What is the duration of a licence?

5 years across all verticals.

b) What types of licences are available?

Georgia offers two main categories of licenses: universal (for land-based and online operations) and online-only licenses.

Land-based verticals (each allowing respective online operations):

• Casino license
• Slot machine hall license
• Betting license

Online-only verticals:

• Online casino license
• Online slots license

Additionally, casino license or slot machine hall license holders may obtain a separate poker club license.

c) Are there different types of licences for B2C and B2B operators?

Yes, B2B operators are subject to a separate B2B license to supply games, gaming platforms, RNG software, and other ‘essential products or services’.

d) Do software suppliers need to be licensed?

Yes, software suppliers must obtain a B2B license. Alternatively, supply may be provided via licensed aggregator platforms.

All major gambling verticals are licensed in Georgia, with no specific restrictions on the types of gambling products allowed. However, the Gambling Law prohibits insider betting.

Unlike some other markets, betting on non-sporting events (such as election outcomes) is permitted in Georgia.

Only Georgian companies may obtain a gambling license. Applicants must demonstrate appropriate local presence and operational capability.

Application procedure involves submitting documents and information to the Regulator, payment of application fees and providing the Regulator with the requested clarifications.

Required documentation for license applications varies by license type, but generally includes:

• Extract from corporate register
• Rules of games to be organized
• Certificates for platform and games (or third-party certificates and licensing agreements)
• Technical documentation of the platform
• Proof of funds for license fees
• Explanation of operational capabilities (registration, responsible gambling features, etc.)

Application fees are negligible, but licensees must pay substantial annual license fees:

Land-based verticals (including respective online operations):

• Casino license: Up to approx. USD 1.8 million (location-dependent), plus USD 40,000 for joint online casino license
• Slot machine hall license: Up to approx. USD 370,000 (location-dependent), plus USD 40,000 for joint online slot license
• Betting license: Up to approx. USD 370,000 (location-dependent)

Online-only verticals:

• Online casino license: approx. USD 1.8 million
• Online slots license: approx. USD 370,000

Quarterly gambling business fee – up to approx. USD 110,000 for online licenses tied with land-based licenses and separate online casino licenses

One-time fee of approx. USD 370,400 – for separate online slots licenses

Refer to item 11 for additional licensee requirements.

While there is no personal licensing requirement for all employees, individuals in significant control roles must undergo thorough vetting. Key individuals, such as directors and financial controllers, must meet eligibility requirements. These include:

• Providing clean criminal records, especially concerning financial crimes
• Demonstrating sufficient knowledge of the gambling industry and its operations.

Gambling advertising is permitted in Georgia, but with significant restrictions. The key regulatory rules are as follows:

Out-of-Home and Digital-Out-of-Home advertising:

• Primarily allowed on licensed facilities (e.g., casinos)
• Additionally permitted in international airports and at border customs checkpoints

Television and Radio:

• Generally prohibited from 6 AM to 12 AM, however,
• An exception exists for broadcasts of high public interest during prohibited hours, provided they include clear warnings about content unsuitable for minors
• Paid broadcasting channels can air gambling ads at any time if protected by a mandatory PIN code or blocking system accessible only to adult subscribers

Online advertising – permitted on licensed operators’ websites.

Sponsorships – permitted and widely used as an alternative advertising tool.

General advertising restrictions:

• Advertisements cannot promote gambling as an easy way to make money
• They must not target minors
• All ads must adhere to responsible gambling standards

Violations may result in both fines and license suspension.

Georgian legislation does not specifically regulate the activity of marketing affiliates. However, these affiliates are required to adhere to the general advertising rules that apply to the gambling industry.

Penalties for offering, facilitating, or marketing unlawful gambling in Georgia can be severe and include:

• Fines of up to GEL 20,000 (approximately USD 7,300)
• License revocation
• Imprisonment for up to five years

It’s important to note that liability primarily falls on two groups:

• Operators who breach licensing conditions
• Individuals engaging in the illegal operation of games of chance

Notably, gamblers themselves do not bear any legal liability for accessing illegal gambling facilities or websites. This approach focuses enforcement efforts on the supply side of illegal gambling rather than on individual players.

Licensees in Georgia must meet several critical requirements:

Legal structure:

• Must be Georgian companies
• No PO Box or shell companies allowed
• Must meet economic substance requirements
• Shareholders can be Georgian or foreign, either corporate entities or natural persons

Personnel integrity:

• Key persons, shareholders, and beneficial owners must have clean police records

Financial transparency:

• Funds used for operations must have a proven, legitimate source

Technical compliance:

• Gambling platforms and games must be certified and technically ready to intergation into the Regulator monitoring system

Operational requirements:

• Must implement an appropriate system to manage AML risks
• Must ensure compliance with responsible gambling rules.

Operators in Georgia are designated as reporting entities under the AML Law and must comply with several key requirements:

Initial KYC (Know Your Customer) checks:

• Conduct identity verification at registration
• Screen for Politically Exposed Persons (PEPs)
• Perform sanctions screening

Enhanced Due Diligence:

• Conduct additional due diligence when a gambler’s account turnover exceeds GEL 5,000 (approximately USD 1,800)

Ongoing monitoring:

• Ensure continuous monitoring of gamblers’ transactions

Reporting obligations:

• Report suspicious transactions to the Financial Monitoring Service of Georgia

The level of the responsible gambling requirements in Georgia is manageable and generally less developed in comparison with the provisions of European operators.

The minimum age for participation in gambling activities is 25 for Georgian citizens and 18 for foreign citizens.

Gamblers may request inclusion into a self-excluded persons list and set deposit limits.

The licensees are required to provide relevant information on their websites and in gambling facilities, ensuring it is easily accessible to players. Furthermore, games of chance may not be positioned or advertised as a way to form income.

When applying for a license in Georgia, operators must disclose information about their direct and indirect shareholders, as well as the beneficial owners of the licensee. While Georgian legislation does not specify a particular notification threshold for ownership changes, in practice, all changes in direct shareholding and ultimate beneficial ownership (UBO) must be reported.

AML Law defines a UBO as any natural person holding at least a 25% interest in the license, or possessing an equivalent amount of voting or controlling rights. This definition aligns with common international standards for identifying significant control or influence within a company.

The regulator has the authority to:

• Appoint a company to operate a centralized monitoring system
• Monitor licensees’ compliance with the Gambling Law through spot checks, venue inspections, and requests for documents and data
• Establish additional rules, restrictions, and requirements for licensees
• Impose fines, generally up to GEL 20,000 (approximately USD 7,300) and, in some cases, up to GEL 150,000.

Enforcement actions taken by the regulator can be challenged in court.

Currently, there are several taxes payable depending of the vertical of operation:

For online verticals:

• GGR tax – 15% – applicable to all online verticals operators, except online betting
• Tax on deposits – 7% – withheld from the amounts deposited by gamblers on the online betting operators websites.

For land-based verticals:

• Slot machine halls: 15% GGR tax
• Betting shops and land-based casinos are exempt form GGR tax

Starting from 1 December 2024, the GGR tax rate will be modified:

• 5% GGR on revenues generated from foreign players;
• 15% GGR on revenues generated from local players.
• For online betting operators whose websites target foreign players, the taxable amount is GGR (not total bets made) and such GGR will be taxed at 5%.

Winnings tax:

• Foreign players: No tax on winnings from December 1, 2024 (currently 5%).
• Georgian players: 5% tax on winning withdrawal amounts in slot machine halls and online casinos.

No major changes to the Gambling Law are anticipated. However, updates to the legislation are expected, particularly in relation to aligning with international best practices concerning advertising and responsible gambling.

A major development in Georgian gambling legislation involves the introduction of “foreigners-only” gambling websites under Georgian online gambling licenses, allowing operators to run two websites using a single license. These websites must be separate for Georgian and foreign gamblers. This model, although more restricted, is similar to white-label operations, which allow multiple domains under one license.

It is anticipated that the Georgian government, in collaboration with the regulator, will issue additional subsidiary legislation and rules to expand the requirements for such operations. Furthermore, there are ongoing discussions about refining advertising laws, introducing new responsible gambling regulations and modification of requirements related to server location.

The Georgian market is well-established and balanced. The most significant risk would be the introduction of overly restrictive advertising regulations or the imposition of overly stringent rules, such as unreasonably low betting limits. However, such changes are unlikely in the near future.

Georgia offers several attractive features for gambling start-ups:

• An established and stable legal framework
• A balanced financial environment, where higher license fees are offset by reasonable gambling taxes
• Georgia serves as a hub for prominent B2B suppliers, particularly slot developers and live-studio operators.
• A business-friendly climate with low formalities and reduced bureaucracy
• A highly engaged gambling audience with a strong interest in operators’ offerings
• A more affordable workforce compared to other countries in the European region.