Over the course of 2025, Georgia fundamentally transformed its system of administrative sanctions for public assemblies, replacing modest administrative penalties with a regime of exceptionally high fines and lengthy detention that international human rights bodies have repeatedly warned raises serious concerns regarding compatibility with the right to peaceful assembly.

The February 2025 Amendments of the Administrative Offences Code increased assembly-related fines roughly tenfold and quadrupled the maximum period of administrative detention. The October 2025 Amendments went further still, removing the fine alternative altogether for the most serious assembly-related offences and making administrative detention the only sanction available. However, in this case, a special category of people who cannot be subjected to administrative detention became subject to fixed administrative fines.[1]

 I. A Persistent Pattern:

Escalating Fines and Detention for Assembly/Manifestation-Related Conduct (2025–2026)

February 2025: A Tenfold Increase in Fines and Quadrupled Detention

February 2025 Amendments to the Code of Administrative Offences (CAO) raised fines for violating the rules on organizing and holding assemblies from approximately GEL 500 to up to GEL 5,000 for participants and GEL 15,000 for organizers, an increase by a factor of ten in some cases. The same amendments quadrupled the maximum period of administrative detention available for assembly-related offences, from 15 to 60 days.[2]

Penalties for petty hooliganism, disobedience to a lawful police order, and insulting a police officer or public official were increased in parallel, and a new offence was created penalizing verbal insults or offensive conduct directed at politicians and public officials, itself punishable by a fine of up to GEL 5,000 or up to 60 days of detention.

The tenfold increase in fines under Article 174¹ of the Code of Administrative Offences raises serious concerns as to their proportionality. Fines of up to 5,000 GEL for participants and 20,000 GEL for organasers far exceed Georgia's average monthly income and are liable to deter individuals from participating in or organasing peaceful assemblies.[3]  As noted by the Venice Commission, sanctions of this magnitude have a significant chilling effect on the exercise of the rights to freedom of peaceful assembly and expression.[4]

Enforcement in Practice: Mass Fines and Individual Hardship

The impact of the new fine’s regime has been immediate and widespread. Civil society organizations reported that by March 2025, Georgian authorities had already issued approximately GEL 2 million in protest-related fines, with thousands of demonstrators fined GEL 5,000 each for allegedly blocking roads, frequently on the basis of surveillance footage and facial-recognition technology.[5]

Many of those fined reported learning of the sanction only after enforcement proceedings had already begun, with inadequate notice and limited opportunity to contest the penalty. Unpaid fines have reportedly led to frozen bank accounts, restrictions on property, and obstacles to crossing state borders.[6] Civic activist Gota Chanturia accumulated 73 separate fines totaling GEL 315,000 for alleged participation in road-blockages during protests. According to his testimony, the cumulative fines destroyed his family's financial security.[7]

This cumulative effect is compounded by a structural gap: unlike the Criminal Code, the Code of Administrative Offences (CAO) contains no rule permitting the absorption or partial aggregation of multiple sanctions, so each separate alleged violation generates a separate, full fine. Nor are the CAO credit periods already spent in administrative detention against a later fine, a safeguard that does apply under criminal sentencing.[8]

October 2025: Removing the Alternative to Detention

The October 2025 Amendments removed the possibility of imposing a fine altogether for the assembly-related offences under Article 174¹(9) of the Code of Administrative Offences: carrying weapons, explosives or hazardous objects, or participating in an assembly terminated at the request of the Ministry of Internal Affairs, leaving administrative detention of up to 60 days as the sole available sanction. A second category under Article 174¹(10), covering conduct such as wearing a mask, blocking roads, or obstructing the work of police, is now punishable solely by 15 days of detention (20 days for organizers).

Disproportionate Impact on Protected Groups

Article 32(3) of the Code of Administrative Offences exempts pregnant women, mothers of children under twelve, minors, and persons with severe or significant disabilities from administrative detention. Because the October 2025 Amendments eliminated the fine as an alternative sanction for Article 174¹ offences, these protected groups are now subject to a flat fine of GEL 5,000 (GEL 15,000 for organizers) for any violation, however minor – including simply wearing a mask or carrying a laser pointer at an assembly.

Fines That Exceed Criminal Penalties

The Public Defender's review of court decisions found that, in 82% of the cases examined, fines imposed as criminal penalties were lower than or equal to the GEL 5,000 administrative fine imposed on demonstrators – despite the Criminal Code setting a minimum fine of GEL 2,000, or GEL 500 where the offence carries a maximum sentence of three years' imprisonment.[9]

In other words, administrative sanctions imposed for non-violent conduct in the context of peaceful assemblies may exceed fines imposed for certain criminal offences.[10]

II.                 Conclusions and Recommendations

Georgia’s 2025 amendments to the Code of Administrative Offences have led to a significant escalation in administrative fines for assembly-related conduct, resulting in disproportionately high penalties for minor or non-violent violations in the context of peaceful protest. The routine imposition of high-value fines, combined with the absence of meaningful safeguards against their cumulative application across multiple alleged infractions, has created a system in which financial penalties function in practice as a deterrent to participation in peaceful assemblies rather than as proportionate regulatory measures.

It is recommended to:

v  Ensure that administrative sanctions remain proportionate, individualized, and consistent with international human rights standards;

v  Introduce safeguards against the disproportionate accumulation of multiple fines arising from broadly defined or repeated alleged violations;

v  Ensure that the imposition and enforcement of high-level administrative fines are subject to prompt, effective, and independent judicial oversight, with full access to remedies and suspensive effect where appropriate.