Financial statements in Georgia: who files, who gets published

Since 2016 Georgia has built its accounting transparency regime on the model of the EU Accounting Directive, and the result is remarkable for the region: a central portal, four size categories, a statutory duty to publish. Anyone concluding that their small Georgian LLC is too small to be meant is mistaken — and anyone expecting to read their Georgian counterparty’s numbers freely will be disappointed in nine cases out of ten. Both follow from the same law.

Legal form decides, not size

Before any threshold becomes interesting, a different question needs settling: are you covered by the law at all? Article 2(1)(ე) defines the term “subject” — and it treats legal forms differently:

• Legal persons under private and public law — always a subject, regardless of size. The Georgian LLC is covered, even as a single-member company with no turnover
• The only exclusions are budget organisations under the Georgian Budget Code and the National Bank of Georgia
• Branches of foreign enterprises and sole traders — only if they meet the criteria of categories III to I

The cross-reference in (ე) names letters “უ” through “ქ” — categories III, II and I. Letter “ტ”, category IV, is not named. A sole trader who stays below category III size is therefore simply not a subject of this law: no duty to prepare accounts, to file, or to retain records under this law. The counter-check sits in Article 3(6) sentence 3, which grants a sole trader who is not a subject under (ე) the category IV standard as a right rather than an obligation. Such sole traders must therefore exist.

For our clients this is the real headline: identical activity, identical turnover, two entirely different sets of duties — depending on whether you are set up as an LLC or as a sole trader. If you are still deciding, the remaining trade-offs are in sole trader or LLC; the tax side is covered in Georgia’s 1 % tax.

Four categories — and why you will probably stay in the bottom one

Classification follows three criteria: balance sheet total, revenue, and average number of employees. What matters is meeting at least two of the three. Balance sheet total and revenue are measured at the end of the reporting period; the employee figure, by contrast, is an average during the period — not a balance sheet date value.

Category	Balance sheet total	Revenue	Employees (avg.)
IV	≤ GEL 1m	≤ GEL 2m	≤ 10
III	≤ GEL 10m	≤ GEL 20m	≤ 50
II	≤ GEL 50m	≤ GEL 100m	≤ 250
I	> GEL 50m	> GEL 100m	> 250

The thresholds are set in lari; only the exchange rate moves. At the National Bank’s official rate of 22 August 2026 (EUR 1 = GEL 3.0585) the category IV limits are roughly EUR 327,000 of assets and EUR 654,000 of revenue; category I begins above roughly EUR 16.3m and EUR 32.7m respectively. Over the past eighteen months the rate ranged between EUR 0.32 and 0.34 per lari — treat the euro figures as a band, not a fixed number.

The point at which most summaries go wrong: the categories are not four equal-ranking boxes but a cascade. Category III presupposes that the company “is not a category IV enterprise”; category II, that it “is not a category III or IV enterprise”. Testing therefore runs from the bottom up — and whatever sticks at the bottom does not rise.

And even a company that outgrows the band does not move immediately: the category changes only once at least two of the three criteria have gone unmet at the end of two uninterrupted reporting periods (Article 3(11)). Exception: where the category jumps by two or more steps against the prior period, the new classification bites without a transition year (Article 3(12)). For groups the same thresholds apply on a consolidated basis, i.e. after eliminating intra-group balances — Georgia did not adopt the gross variant with uplifted thresholds that the EU Directive permits as an option (Article 3(14) and (15)).

Category IV does not mean “no duties”

This is where the most expensive misunderstanding sits. What the bottom category is spared is exclusively the upper tier. The foundations apply regardless of size:

• Double-entry bookkeeping, mandatory (Art. 4(8))
• Accounting policy, chart of accounts, internal control system — scalable to complexity, but not dispensable (Art. 4(5))
• Accounts prepared at least once a year (Art. 5(2))
• Under the standard SARAS sets for category IV, whose application is mandatory (Art. 3(6))
• Retention for six years, and at the subject itself (Art. 4(18))
• Filing by 1 October — with no size-based exemption (Art. 9(2))
• Statutory audit (Art. 6(3))
• Management report (Art. 7(1))
• Publication by the authority (Art. 9(3))

One duty is regularly overlooked: who may do the bookkeeping is limited by law. Article 4(3) lists four permissible routes exhaustively — an employed accountant, a professional service accountant, an accounting firm, or an audit firm. The middle two are defined by registration: anyone taking on bookkeeping as a professional service must register in the state register within one month of starting (Article 13¹(3)); the transitional period for incumbent providers expired on 1 July 2023. An unregistered freelancer is none of these four routes.

To be straight about it: the sanction hits the service provider, not you — Article 26 pointedly does not list Article 4. Your exposure is not a fine but accounts from an impermissible source, and a provider who can drop out of the register at any time. SARAS publishes sanction acts against accountants on its own website for at least five years — a usable due diligence tool when choosing one.

What is added above category IV

Accounting standard. Public interest entities and category I report under full IFRS; categories II and III under IFRS for SMEs, with the right to move up to full IFRS voluntarily; category IV under the SARAS standard (Article 3(8)). Category III may in addition file in simplified form (Article 9(7)) — a genuine relief that is rarely mentioned. Whether category IV may move up voluntarily is not clear-cut: Article 3(10) grants the option, while Article 5(1) is drafted more narrowly. Anyone who needs this for a foreign parent or a bank should settle it in advance.

Statutory audit. Audit is mandatory for public interest entities and for enterprises and groups of categories I and II (Article 6(1)). Categories III and IV and non-entrepreneurial legal persons are exempt (Article 6(3)). Both sentences carry a proviso for divergent rules — relevant above all in prudential regulation for banks and insurers; for small companies we found no such counter-provision.

Management report. This deserves a close look, because almost every summary in circulation goes wrong here. The management report is modular: Article 7(1) obliges public interest entities and categories I and II to produce one — but its three components each have their own addressees.

1. 01

   Business review — for all three groups

   Analysis of development, results and position, principal risks and uncertainties, plus development plans, research, branches and risk management (Art. 7(3) and (6)).

2. 02

   Corporate governance statement — only for listed issuers

   Article 7(4) refers exclusively to Article 2(1)(ყ.ა). An unlisted bank, an insurer or a category I enterprise does not owe one.

3. 03

   Non-financial reporting — only for the largest

   Only a public interest entity that matches the size of a category I enterprise and averaged more than 500 employees during the reporting period (Art. 7(5)).

Non-financial reporting follows the “comply or explain” pattern familiar from the EU: where no policy exists on the environment, social matters, employment, human rights or anti-corruption, that must be stated clearly and explained in the report (Article 7(8)). It is not substantively attested — the auditor merely checks whether the information is present (Article 7(10)).

Payments to government. Rarely mentioned, but central for extractive mandates: public interest entities and category I enterprises whose activity involves the exploitation of mineral resources or logging in natural forests report on payments to the state — the threshold is GEL 100,000 per payment type, individually or in aggregate, and the recipient concept extends to foreign state bodies (Article 8).

Who gets published — and what reportal.ge actually shows

Article 9(3) is built as a rule-and-exception sentence, and that is stronger than it first sounds: the authority is obliged to publish the filed reports and audit opinions — except the accounts of category IV enterprises. Category III is not caught by the exception and is therefore under the same statutory publication duty as I, II and public interest entities. This is not administrative practice and not discretion, but mandatory law.

Two details that appear in almost no account of the regime:

• The clock runs from filing, not from the deadline — one month. File in March and you are online in early April, not in October.
• Category IV is not sealed without exception. Article 9(3²) removes audit firms that are themselves category IV enterprises from the non-publication rule. Their accounts are published.

Public interest entities additionally carry a self-publication duty, on their own website or in a print publication (Article 9(5)) — an either/or, not both, and with no statutory deadline. Conversely, the competent supervisory authority may, in agreement with SARAS, restrict publication of the management report information where disclosure would endanger the financial stability of the entity or of the sector (Article 7(13)).

How thin the published layer really is shows in the portal statistics for reporting year 2024:

The register is broad; the published tier is narrow. Anyone checking a typical Georgian mid-sized company will find it — but not its numbers. Punctuality is revealing too: according to the SARAS annual report 2025, category IV filed on time in 94 % of cases and category III in 88 %, while category I managed only 73 % and category II 60 %. The largest companies are the latest. These are authority figures; the report does not state the denominator for the overall 95 % rate it also cites, which is why we do not rely on that figure here.

Deadlines: 1 October — and what it is not

Filing is due by 1 October of the following year, and not as a target but as a long-stop: the text requires filing “immediately, but no later than” that date (Article 9(2)). Where the financial year differs from the calendar year, a nine-month deadline from the end of the reporting period applies instead (Article 9(4)) — the operative date for subsidiaries of foreign groups with a divergent balance sheet date.

What must be filed is whatever the law imposes on that particular subject, and it goes in together, in one submission. For categories III and IV that is normally the financial statements alone; the management report, the payments report and the audit opinion only arrive higher up.

When nothing is filed

The fine scale in Article 26(1) follows the category and draws no distinction between late and missing filings — both fall into the same block of conduct:

Category	Base amount	roughly
IV	GEL 500	EUR 163
III	GEL 1,000	EUR 327
II	GEL 5,000	EUR 1,635
I and public interest entities	GEL 10,000	EUR 3,270

These are base amounts, not ceilings. The route there is staged: SARAS may issue a written warning instead of the fine, setting a deadline that must not be shorter than one month; only its fruitless expiry leads to the fine. If the requirement set alongside the fine goes unmet, the amount may double. And where filing is missed in two consecutive reporting periods, SARAS may impose a further five times the category amount (Article 26(2)). Whether the steps accumulate or replace one another is left open by the wording — so we describe the ladder without asserting a total. The audit obligation has its own route, with a statutory grace period of not less than one and not more than six months (Article 26(3)).

Three points that put the modest amounts in perspective:

1. The fine does not discharge the duty (Article 23(3)). You pay and you still file.
2. The grace privilege for category IV has expired. Up to and including reporting period 2023 the authority could only issue written warnings against category IV (Article 28(23)). From period 2024 that no longer applies.
3. Selection is risk-based, fed among other things by Revenue Service data (Article 26(4)). The hope that nobody notices among 80,000-plus companies does not hold — the tax data is the selection basis.

Directors, incidentally, bear no personal liability under this law: Article 26 sanctions the company alone. The only person-level sanction — a ban on holding functions for up to three years — applies solely at public interest entities.

The other direction: checking a Georgian counterparty

What you can establish about a Georgian company without an account and without a fee is more than most expect — just rarely the numbers:

1. 01

   Identity and status in the company register

   The basic search at enreg.reestri.gov.ge by identification code, name or legal form returns name, legal form and status free of charge. The evidentiary extract is priced on a scale between GEL 13 and 75 depending on channel and turnaround; an English version adds a flat GEL 26.

2. 02

   Size class, auditor and group structure via reportal.ge

   Without signing in: category, legal form, principal activity, available reporting years, audit firm with engagement partner and SARAS register number, plus parent and subsidiary companies with shareholding percentages.

3. 03

   Tax position via rs.ge

   Queryable by identification number are, among others, VAT registration, tax liens and preferential tax regimes. Both services are captcha-protected; we verified that they are reachable, not the results they return.

4. 04

   The numbers — if the category allows

   From category III the accounts sit in the portal, readable with a portal account. For category IV, Article 9(3) sentence 2 gives any person a right to request them under the procedure established by the authority — the law requires neither a written form nor a stated reason.

What this means for your Georgian company

For the typical structure among our clients — an LLC with six-figure euro revenue and no staff in Georgia — the answer is: you are category IV, you will probably stay there, and that means all the base duties without the publicity. Bookkeeping to the SARAS standard, double-entry recording, retention for six years, filing by 1 October — but no audit, no management report, and your numbers do not appear in the portal.

What does remain visible: existence, identification number, size class, legal form, activity, and the people acting. Anyone who confuses “my numbers are not public” with “nothing about me can be found” is mistaken.

The law leaves two questions open that every founder has. It never defines the term reporting period, so the first reporting period of a company incorporated mid-year cannot be derived from this law. And it contains no provision ending the filing duty on dormancy or liquidation — Article 5(8) points the other way, requiring disclosure of an ongoing liquidation in the accounts. If you no longer need a company, wind it up properly rather than leave it sitting.

FAQ

Does my small Georgian LLC really have to file annual accounts?

Yes, with no size-based exemption. Article 9(2) obliges every "subject" to file by 1 October of the following year, and legal persons are subjects regardless of size. The only exemption in Article 9 covers non-entrepreneurial (non-commercial) legal persons — not small companies. What the smallest category is spared is only the upper tier: no audit, no management report, no publication by the authority. The filing itself remains.

Does this apply to me as a sole trader with the 1 % status?

On the wording, no. Article 2(1)(ე) counts sole traders and branches of foreign enterprises as subjects only if they meet the criteria of categories III to I — category IV is deliberately absent from that cross-reference. Article 3(6) sentence 3 confirms it: a sole trader who is not a subject under Article 2(1)(ე) is merely entitled to use the category IV standard, not obliged to. Your bookkeeping duties then follow tax law alone. Important: this is a reasoned reading of the wording, not an official ruling — and it is less certain for branches than for sole traders, because the portal does list branches under category IV.

Can I look up my Georgian business partner's accounts?

That depends on their category, and for most partners the answer is sobering. From category III upwards SARAS publishes the accounts by force of law within one month of filing. Category IV is exempt — and that is roughly nine in ten filers. On top of that comes a hurdle the register does not reveal: search on reportal.ge works without registration, but the statement documents themselves sit behind a login. Without a portal account you see existence, category, legal form, auditor and group structure — not the numbers.

What does it cost if I miss the deadline?

The base amount follows the category: GEL 500 for category IV, 1,000 for category III, 5,000 for category II, 10,000 for category I and for public interest entities (Article 26(1)). That is no scare story — GEL 500 is around EUR 163. What deserves attention is the escalation: the authority may first issue a written warning with a deadline of at least one month, then impose the fine, double it if the requirement remains unmet, and — where filings are missed in two consecutive periods — impose a further five times the category amount. And the fine does not discharge the duty (Article 23(3)).

Is 1 October the same deadline as my tax return?

No, and the two are often confused. 1 October is the deadline towards SARAS, the accounting supervisory authority, under Article 9(2) of this law. Your tax filings run separately through the Revenue Service and rs.ge, on their own schedule. Two addressees, two calendars. If your financial year differs from the calendar year, a nine-month deadline from the end of the reporting period replaces 1 October (Article 9(4)).

We are mothballing the company. Does the filing duty end?

The law contains no provision ending the duty on dormancy or liquidation — and Article 5(8) points the other way: it requires an ongoing liquidation to be disclosed in the accounts themselves. That requirement would be pointless if nothing had to be filed during liquidation. Anyone who no longer uses a Georgian company should wind it up in an orderly way rather than leave it sitting.

This article reflects the consolidated Georgian original of Law No. 5386-IIს (last amended by Law No. 1464 of 1 April 2026) and is not legal or tax advice. Only the Georgian text is authoritative; the English translation in circulation is several years old and outdated in places. Where this article interprets rather than cites, that is flagged. As at 22 August 2026.