Georgia’s citizenship exception asks what an investment contributes

Georgia’s organic law on citizenship provides for grants made outside the ordinary naturalisation route. The article carrying that power names investment among the circumstances the President may weigh, and describes the investment by what it contributes to the economy rather than by an amount. The same article addresses its language and history requirement, by an express cross-reference, to persons under one of the three grounds it lists.

What the article provides

The Organic Law of Georgia on Georgian Citizenship was adopted by the Parliament of Georgia on 30 April 2014 and published on 13 May 2014. Ordinary naturalisation sits in one part of it. The exception examined here is Article 17.

Article 17(1) gives the President of Georgia the power to grant citizenship by way of exception to a citizen of another country “who has made a contribution of exceptional merit to Georgia”, and separately to an alien “based on state interests”. The two limbs are written as alternatives, and it is the second that the article goes on to expand. The provision confers a power; it says nothing about how often the power is used.

Article 17(2) provides that when those state interests are evaluated, “inter alia”, three kinds of circumstance “shall be taken into account”. Both phrases do work. The consideration is mandatory, and the list is expressly not closed, so a circumstance outside the three is not excluded by the article.

The first covers a foreign citizen who considers Georgia to be their homeland, where that person or an ancestor resides in an occupied territory of Georgia, is internally displaced from it, or emigrated at some point for political opinions or because of hard social and economic conditions. The second covers a foreign citizen making or having made an investment in Georgia “that contributes or has contributed substantially to the development of the state economy”. The third covers success in sport, science or art, coupled with a willingness to carry on that activity on behalf of Georgia.

What the investment limb asks

The adverb in the second limb is easy to attach to the wrong noun. Grammatically, “substantially” modifies “contributes or has contributed”. It qualifies the contribution the investment makes, or has made, to the development of the state economy, rather than the amount invested. How large a sum has to be before its contribution counts as substantial is a question the provision does not answer, and nothing in it says that the size of an investment is irrelevant to that judgement.

Within Article 17 the test is never reduced to a figure. The article sets no amount, in any currency.

Article 17(5) addresses proof. To verify the fact of the investment, it provides, the body reviewing the case “shall request information from a competent body”. Read end to end, Article 17 does not name that body and does not state the standard it applies. Whether the rest of the statute supplies either was not established here.

Article 17 sets no quota. Nothing in it caps the number of grants in a year, by ground or in total.

The language requirement is addressed to one group

Article 17(3) requires knowledge of the state language of Georgia, and of the history of Georgia and the basics of law, “within the limits determined for granting citizenship of Georgia by way of exception”.

It is not addressed to applicants generally. By its own terms it applies to “a person under paragraph 2(a) of this article” — the homeland and displacement ground.

The cross-reference is to a description of a person, not to a choice an applicant makes. On the text, someone who answers that description is within paragraph 3 whether or not an investment is also in issue, and the provision does not by its terms reach a person outside it. It does not follow that a person invoking the investment ground faces no language requirement: Article 17(3) is one provision, and nothing read here shows what the rest of Georgian law requires, or what a reviewing body does in practice.

Article 17(4) disapplies paragraph 3 for a person whose physical, psychological, intellectual or sensory disorder makes it impossible to check compliance.

One of two doors to dual citizenship

Article 3(2) states that there shall be a single citizenship in Georgia. Article 3(3) then provides that a citizen of Georgia may at the same time be a foreign citizen “only in cases provided for in Articles 17 and 21-1 of this Law”.

Article 17 is therefore one of exactly two places in the statute where holding another nationality alongside Georgian nationality is permitted. That is a permission under Georgian law, and it says nothing about whether the other country allows its own nationality to be retained.

Which text was read

The page carrying the English text of Article 17 is the consolidation of 7 March 2025, and the Legislative Herald prints a warning on it: this is not the final edition. The final consolidation is dated 25 June 2026, and its page states that the consolidated version is being updated. No English text of that version is published.

The Herald’s own list of consolidated versions shows exactly two after 7 March 2025. Organic Law No 881-IIმს-XIმპ of 26 June 2025, published 7 July 2025 and in force from 1 October 2025, amends Articles 12 and 13. Organic Law No 1820-Vმს-XIმპ of 25 June 2026, published 29 June 2026 and in force from 1 September 2026, adds a paragraph to Article 29 providing that an appeal to court against a decision under that article does not impede the competent body of the Ministry of Internal Affairs from considering or enforcing the expulsion of a foreigner. Neither amends Article 17.

If that list is complete, the wording of Article 17 has not changed since the text read here. This article makes no claim about the legal authority of the English rendering itself.

Article 17 carries two earlier amendments, No 3260 of 21 July 2018 and No 3627 of 1 November 2023.

What this article does not establish

It does not establish how many people have been granted citizenship under Article 17, in any year or under any ground. No figures were read for this article, and whether any are published was not checked.

It does not establish the practice of any Georgian authority. Every reading above is a reading of the provision as written.

It does not establish anything about the judgment of the Court of Justice of the European Union of 29 April 2025. Georgia is not a member of the European Union and that judgment does not bind it.