Chapter VIII of the Law of Georgia on Arbitration (hereinafter “LOA“) governs the recognition and enforcement of both domestic and foreign arbitral awards. The LOA is based on the UNCITRAL Model Law on International Commercial Arbitration. The Civil Procedure Code of Georgia (hereinafte ”CPCG“) contains supplementary provisions on enforcement proceedings. With respect to foreign arbitral awards, the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (hereinafter “New York Convention“) is also applicable.

Yes. Georgia has been a contracting state of the New York Convention since 1994. Georgia did not make any reservation under Article I (3).

Applications for the recognition and enforcement of domestic arbitral awards must be filed before the Courts of Appeal and applications for the recognition and enforcement of foreign arbitral awards must be filed before the Supreme Court of Georgia.

Pursuant to Article 44(2) of the LOA and Articles 356²⁰-356²¹ of the CPCG, enforcement proceedings are initiated by filing a written petition with the competent court.

The applicant must submit the duly authenticated original award or a duly certified copy thereof, and the original arbitration agreement or a duly certified copy thereof. If either document is not in Georgian, a duly certified Georgian translation must also be provided.

There are no additional requirements for the court to have jurisdiction over an application for recognition and enforcement.

Court fees for enforcement-related applications are fixed amounts regulated by the CPCG, rather than based on the amount in dispute. They apply to both domestic and foreign arbitral awards. Pursuant to Article 39(1)(a2) of the CPCG, the fee for an application for the recognition and enforcement of an arbitral award is GEL 150 (approx. 48 euros) and pursuant to Article 39(1)(e1) the fee for an application for the recognition and enforcement of interim measures is GEL 50 (approx. 16 euros).

The general rule is that the losing party shall bear the costs of the enforcement proceedings.

Proceedings are adversarial. Pursuant to Article 356²¹(21) of the CPCG, the enforcement application is served on the party against whom enforcement is sought, which has seven days to file its objections based on the grounds set out in Article 45(1)(a) of the LOA.

According to Article 356²¹(2) of CPCG, applications for the recognition and enforcement of an arbitration award are reviewed without an oral hearing. A court may order an oral hearing, if so required and if it facilitates establishing the facts of the case.

As already mentioned, pursuant to Article 44(2) of the LOA and Article 356²¹ of the CPCG, the applicant must submit the duly authenticated original award or a duly certified copy thereof, and the original arbitration agreement or a duly certified copy thereof. This applies to both domestic and foreign awards.

Pursuant to Article 356²¹ of the CPCG, if the arbitration award or the arbitration agreement is not in the Georgian language, the applicant shall also submit a duly certified Georgian translation of the document.

As recognition and enforcement applications are filed with the Courts of Appeal or the Supreme Court, any legal representative must be a member of the Georgian Bar Association. As an exception, only before the courts of first instance, parties may represent themselves or they may be represented by non-lawyers (Articles 93-94 of CPCG).

Service of judicial documents in Georgia is regulated by Articles 70-78 of the CPCG. Generally, documents are served by postal mail, though the court retains discretion to choose another form of service. If judicial summons could not be served on the addressee the first time they were sent, the summons shall be sent again to the person at least once to the same address or to a different address known to the court. If the location of a party is unknown or it is practically impossible to serve judicial summons in any other way, the court may, by its ruling, approve service by publication.

With respect to parties outside Georgian jurisdiction, Georgia is a party to the Hague Convention of 15 November 1965 on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters. Service upon parties located in contracting states to the Convention shall be effected in accordance with its provisions. In particular, pursuant to Articles 5 and 6 of the Convention, service shall be effected through the designated Central Authority of the receiving state, which shall complete a certificate confirming the method, place and date of service. Service is deemed effected upon the issuance of such certificate.

The procedures for the enforcement of domestic and foreign arbitral awards are substantially the same, with the primary difference being the competent court. As already mentioned, the applications for awards rendered in Georgia are filed with the Courts of Appeal, while foreign awards fall under the exclusive jurisdiction of the Supreme Court of Georgia.

Georgian law provides for the recognition and enforcement of both final arbitral awards and interim measures. Pursuant to Article 21(1) of LOA, an interim measure issued by an arbitral tribunal is binding and must be enforced by filing an application to a court, regardless of the country in which the interim measure was rendered.  

Pursuant to Article 45(1) of LOA, which mirrors the grounds of Article V of the New York Convention:

“Recognition or enforcement of an arbitration award, irrespective of the country in which it is rendered, may be refused only if:

a) the party against whom the award isrenderedapplies to the court and furnishes proof that:

a.a) a party, when executing the arbitration agreement, was legally incapable or was a beneficiary of support and a guardian was appointed for this party with relation to the issues under the arbitration agreement, but the support has not been obtained, or the said agreement is not valid or is null and void under the law to which the parties have subjected it or, failing any indication thereon, under the law of the state where the award was rendered;

a.b) the party was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings or was otherwise unable to present his/her case;

a.c) the arbitration award is rendered on a dispute that was not submitted to the arbitral tribunal by the parties, or the arbitration award contains decisions on matters beyond the scope of the request submitted to the arbitral tribunal. Provided that, if the decisions on matters submitted to arbitration can be separated from those not so submitted, only that part of the award which contains decisions on matters submitted to arbitration may be recognized and enforced;

a.d) the composition of the arbitral tribunal or the arbitral procedure did not comply with the agreement of the parties, or in the cases of absence of such an agreement, did not comply with the law of the country where the arbitration took place;

a.e) the arbitration award has not yet become binding on the parties or has been set aside or suspended by a court of the country in which, or under the law of which, the award was made;

b) the court finds that:

b.a) the subject-matter of the dispute may not be settled by arbitration under the legislation of Georgia;

b.b) the award is in conflict with the public order.”

As the wording “irrespective of the country in which it is rendered” implies, these grounds apply to both domestic and foreign awards.

Georgian legislation does not define the concept of public policy. However, Georgian courts have addressed this issue in several decisions.

The Tbilisi Court of Appeals, in its decision of 25 March, 2014 (case N2ბ/4963-12) determined that “the interpretation of the contractual provisions reflected in the arbitration award, the assessment of evidence, and the qualification of the legal relationship cannot be reviewed by referring to public order, because public order does not include any kind of violation, but rather the disregard of fundamental principles of law; i.e., in other words, in order for an arbitration award to be annulled on the grounds of conflict with public order, it must conflict with higher values; otherwise, public order will turn into an appeal mechanism for arbitration awards. Such approach is contrary to the purpose of the Law of Georgia on Arbitration – to ensure finality of arbitration awards.”

The Supreme Court of Georgia, in its decision of 20 January 2022 (case Nა-5322-შ-127-2020) drew a distinction between material and procedural public policy. The Court held that procedural public policy primarily concerns the fairness of the proceedings, while material public policy relates to the substance of the decision. The Supreme Court equated public policy (ordre public) with the fundamental legal principles of Georgia.

More recently, the Supreme Court of Georgia, in its decision of 28 October 2025 (case Nა-2887-შ-72-2025) concluded that “public policy is a set of fundamental economic, legal, moral, political, religious and social standards of all states and international organizations (extra-national community).” The Court confirmed that not every violation of law or inconsistency with domestic law constitutes a violation of public policy, and that the relevant question for enforcement purposes is not whether the award as a whole violates public policy, but whether the enforcement of the award would by its nature constitute such a violation.

Pursuant to Article 356²¹(6) of CPCG, a ruling on the enforcement of an arbitration award shall be final and may not be appealed. Therefore, it will be immediately enforceable.  

As already mentioned, a ruling on the recognition and enforcement of an arbitration award is final and may not be appealed. Accordingly, no direct appellate remedy is available against a decision recognising an arbitral award. A party may apply for suspension of enforcement under Article 36 of the Law of Georgia on Enforcement Proceedings, which provides an exceptional procedural avenue at the enforcement stage.  

No remedies are available against a court decision refusing to recognize and enforce an arbitral award under Georgian law.  

Set-off claims are not specifically addressed in the arbitration-related legislation. However, the Civil Code of Georgia contains a general rule concerning set-off, which provides that “counterclaims between two persons may be terminated by setoff if these claims have become due” (Article 442(1)). 

Pursuant to Article 45(1)(a.e) of LOA, recognition or enforcement of an arbitration award, irrespective of the country in which it is rendered, may be refused only if the party against whom the award is rendered applies to the court and furnishes proof that the arbitration award has not yet become binding on the parties or has been set aside or suspended by a court of the country in which, or under the law of which, the award was made. Therefore, this provision is discretionary rather than mandatory – the court retains the power to recognize and enforce an award notwithstanding its annulment at the seat.

As for the remedies available where an award is set aside after a Georgian court has already issued a recognition decision, the LOA does not provide an express mechanism. However, pursuant to Article 423(1)(d) of the GCCP, a court decision that has entered into legal force may be challenged by way of a request to reopen proceedings based on newly discovered circumstances, where a judgment or decision that formed the basis of the original ruling has subsequently been annulled. On this basis, an award-debtor could apply to the Supreme Court to reopen the recognition proceedings following the annulment of the underlying award at the seat. However, no known case law exists in Georgia on this specific issue at this time.

Interim measures against assets are regulated under the CPCG, and a party may seek such measures to ensure the effective enforcement of a decision. Pursuant to Article 198(2), such measures may include: a) attachment of the property, securities or money belonging to the award-debtor and held by the award-debtor or another person; b) injunction against the award-debtor to prevent them from taking certain actions; c) enforcement measure ordering the award-debtor to transfer certain property items to a bailiff in the form of sequestration (compulsory administration of property).  

Security for costs is not specifically addressed in the LOA. However, as for security generally, Georgian law provides two main scenarios:

First, pursuant to Article 18(4) of the LOA: if the arbitral tribunal decides that, under the given circumstances, respective interim measures should not have been granted, the party requesting an interim measure shall be liable for any costs and damages caused by such interim measures. The arbitral tribunal may award the party to whose detriment the interim measures were taken the costs and damages that it incurred.

Second, Article 45(3) of the LOA provides that where an application to set aside or suspend an award has been filed with the competent court, the court may adjourn its decision for up to 30 days and may, upon the request of the applicant, order the other party to provide appropriate security.