Every company registered in Georgia has two separate reporting relationships with the state, and confusing them is one of the most common mistakes we see. The first is with the Revenue Service: monthly declarations, VAT, payroll, everything that happens on rs.ge. The second is with SARAS, the Service for Accounting, Reporting and Auditing Supervision, and it involves exactly one obligation: submit your annual financial statements by October 1 of the year following the reporting period.
That second obligation is the one businesses miss. It does not arrive monthly, no accounting software reminds you about it, and plenty of company owners, especially foreign owners who set up an LLC for the tax benefits, learn it exists only when the fine arrives. The fine starts at 500 GEL, runs to 10,000 GEL depending on your company's size, and doubles if you ignore the warning that comes with it.
This guide covers who must file, how the four SARAS categories work, what each category actually submits, which companies need an audit, what missing the deadline costs, and a realistic preparation timeline that starts now, in July, not in the last week of September.
What SARAS is, and why this is not an RS.ge filing
SARAS is the Georgian government body created under the 2016 Law on Accounting, Reporting and Auditing to supervise how companies prepare and publish financial statements. Its purpose is transparency: aligning Georgian corporate reporting with international standards so that regulators, banks, investors, and counterparties can see numbers that reflect reality.
The practical consequences for you are three. First, the annual financial statements are a separate submission from anything you file with the Revenue Service; being perfectly current on rs.ge does not satisfy SARAS. Second, the statements are filed through SARAS's own online portal, in Georgian, using the reporting forms for your category. Third, once submitted, your report is published on reportal.ge, where reports of first, second, and third category companies are publicly accessible to anyone. Fourth category reports are released only on a justified written request, but they are still on file with the state.
The obligation covers LLCs, joint-stock companies, and other enterprises registered in Georgia, regardless of whether the company was profitable, active, or even trading. A dormant LLC with no revenue still has a filing obligation. This is the detail that catches holding companies and side-project entities most often.
The four categories: where your company fits
The law sorts every enterprise into one of four size categories using three indicators: total assets, annual revenue, and average number of employees. Your category is determined by the two-out-of-three rule: you belong to the category whose thresholds you meet on at least two of the three indicators.
First category: exceeds at least two of 50 million GEL in total assets, 100 million GEL in annual revenue, and 250 employees. These are large corporates and major operators.
Second category: does not reach the first category, but exceeds at least two of 10 million GEL in assets, 20 million GEL in revenue, and 50 employees.
Third category: does not reach the second category, but exceeds at least two of 1 million GEL in assets, 2 million GEL in revenue, and 10 employees.
Fourth category: stays under at least two of 1 million GEL in assets, 2 million GEL in revenue, and 10 employees. This is the overwhelming majority of businesses in Georgia, including almost every foreign-owned service LLC, Virtual Zone company, and small trading business we work with.
Alongside the size categories sits a separate label: Public Interest Entities (PIEs), companies whose securities trade on an exchange, banks, microfinance organizations, insurers, and investment funds. PIEs carry the heaviest requirements regardless of size.
Category determines everything downstream: which accounting standard your statements follow, whether you need an audit, and how large the penalty is if you miss the deadline. Determining the category correctly is therefore not a formality. A company that misjudges the boundary, for example around the 2 million GEL revenue line between third and fourth category, prepares the wrong statements under the wrong standard and can still be treated as non-compliant after "filing on time."
What each category actually submits
The reporting burden scales with the category.
First category and PIEs prepare full IFRS financial statements: balance sheet, statement of profit and loss, cash flow statement, statement of changes in equity, and notes, plus a management report, all audited.
Second category companies report under IFRS for SMEs (they may voluntarily apply full IFRS), also with a mandatory audit.
Third and fourth category companies use the simplified standards established by SARAS for their category. For a typical fourth category company, this is a compact set of forms: an abbreviated balance sheet and income statement built from your accounting records. Simple, but not automatic. The forms have to reconcile with your books, and if your books were maintained casually during the year, September becomes an accounting reconstruction project rather than a filing exercise.
Everything is submitted electronically through the SARAS portal in Georgian. For international owners this matters practically: even if your internal reporting is in English, the filed statements are not.
Who needs an audit
Mandatory audit applies to first category, second category, and all Public Interest Entities. The audit must be performed by an independent, registered audit firm, and the auditor's opinion is submitted together with the statements and published with them.
Third and fourth category companies are exempt from mandatory audit. They can commission one voluntarily, which is sometimes worth doing before a financing round or a sale, but the law does not require it.
The audit requirement is the reason second category companies cannot leave preparation to September. Auditors need finished statements to audit, they get booked up ahead of the deadline, and an audit of a company with 20+ million GEL in revenue is not a two-week engagement. If your company crossed into the second category during 2025 and this is your first mandatory audit, the engagement letter should have been signed months ago; if it is not, that is the single most urgent item on your list.
What missing the deadline costs
The penalty structure is set per category.
- Fourth category: 500 GEL
- Third category: 1,000 GEL
- Second category: 5,000 GEL
- First category: 10,000 GEL
The mechanics matter as much as the amounts. Missing the deadline triggers a written warning together with the fine, and the warning sets a correction window of one to six months. Fail to submit within that window and the penalty doubles. So a fourth category company that ignores the problem entirely is looking at 1,500 GEL for a filing that its accountant could have produced from clean books in a few days, and a second category company is looking at 15,000 GEL.
The cash fine is also not the whole cost. Your compliance record with SARAS is visible in practice wherever your financials are checked: banks reviewing a loan application, investors running due diligence, large customers vetting suppliers, and tender committees all look for the reportal.ge publication. An unfiled or late report reads as a governance red flag exactly at the moments when your company is trying to look credible.
How to prepare: working backwards from October 1
The companies that have a painful September are the ones that treat this as a September task. Here is the sequence we run for our own clients, starting from mid-July.
July: confirm your category and scope. Pull total assets, annual revenue, and average headcount for the reporting year and apply the two-out-of-three rule. If you are near a boundary, resolve it now, because it changes what you prepare. Check whether anything during the year changed your position: crossing 2 million GEL in revenue, an acquisition, headcount growth.
August: close the books and draft the statements. Reconcile bank accounts against the ledger, clear suspense items, confirm that what was declared to the Revenue Service during the year matches the accounting records, and produce draft statements in your category's format. Discrepancies between rs.ge declarations and the books are the most common source of delay, and August is when they are still fixable calmly.
Early September: review, audit, translate. Second category and above: your auditors should already be mid-engagement by now. Everyone else: a second pair of eyes on the draft statements, and preparation of the Georgian-language forms for the portal.
Mid-September: submit. Not September 30. The portal, like every government portal on the planet, is slowest and most error-prone in the final days, and a rejected submission on September 30 is a missed deadline. Filing two weeks early costs nothing and removes the entire class of last-minute risk.
If it is already late September and none of this has happened, the honest advice is triage: a rough-but-reconciled filing submitted on time beats a perfect filing submitted late, because the penalty attaches to lateness, not to elegance. And if the deadline has already passed, act inside the correction window from the warning; the doubled penalty is the avoidable part.
The mistakes we see every year
A few patterns account for most of the penalties we help clients clean up. Owners assume their accountant "handles everything," while the accountant's engagement covers monthly RS filings only, and neither side owns the SARAS submission. Dormant and near-dormant companies skip filing on the logic that there is nothing to report, which the law does not accept. Companies self-classify into the fourth category by feel, without actually running the two-out-of-three test after a growth year. And foreign owners discover in the last week that the statements must go in through a Georgian-language portal their team cannot navigate.
Every one of these is cheap to prevent in July and expensive to fix in October.
FAQ
Does my company have to file with SARAS if it had no activity this year?
Yes. The obligation attaches to registered enterprises, not to active ones. A dormant LLC with zero revenue still submits statements for the reporting year, in the simplified fourth category format. Non-filing is penalized the same way regardless of activity.
Is the SARAS report the same as my annual tax declaration?
No. Tax declarations go to the Revenue Service through rs.ge and follow the Tax Code. The annual financial statements go to SARAS through its own portal and follow the Law on Accounting, Reporting and Auditing. Being fully compliant on one does not satisfy the other, and the deadlines are different.
How do I know which category my company is in?
Apply the two-out-of-three rule to total assets, annual revenue, and average employee count. Under 1 million GEL in assets, under 2 million GEL in revenue, and fewer than 10 employees on at least two of those three, and you are fourth category, like most small and foreign-owned companies in Georgia. Near a boundary, have it determined professionally, because the category dictates your reporting standard, audit obligation, and penalty exposure.
What is the penalty if I miss October 1?
A written warning plus a fine of 500 GEL (fourth category), 1,000 GEL (third category), 5,000 GEL (second category), or 10,000 GEL (first category). The warning gives you a correction window of one to six months; miss that too and the penalty doubles.
Does a small LLC need an audit?
No. Mandatory audit applies to first and second category companies and Public Interest Entities. Third and fourth category companies file unaudited statements, though a voluntary audit can be worth it before fundraising or a sale.
Can EFS Group handle the whole submission?
Yes. We determine your entity category, prepare the statements in the correct format for your category, coordinate the audit where one is required, and submit through the SARAS portal ahead of the deadline. For our monthly accounting clients, the books are already reconciled, which makes the annual filing a routine step instead of a project.
Need Help?
October 1 is closer than it feels, and the preparation work lives in July and August, not September. Schedule a free call with EFS. We will confirm your category, tell you exactly what your company needs to file, quote a fixed fee, and get it submitted early. No obligation.