How to document purchases from individuals in Georgia starting December 1, 2026
A restaurant buys vegetables at a market, a café purchases homemade cheese from a farmer, a hotel buys furniture from a private individual, and a shop purchases goods from individuals for resale.
Starting December 1, 2026, Georgia will apply a new electronic recordkeeping procedure to certain transactions of this kind. However, an electronic purchase act will not be mandatory in every case: the rules depend on the buyer's status, the documents issued by the seller, and the applicable tax regime.
Contents
- What changes on December 1, 2026
- Which Documents Can Replace the Electronic Purchase Act
- What Individual Entrepreneurs with Small Business Status Should Do
- Why Food Traceability Matters for Restaurants
- Can a Paper Purchase Act Be Used?
- What If the Seller Does Not Provide Documents?
- Deadlines for the Electronic Purchase Act
- Risks of Improper Documentation
- Comparison of three purchasing models
- Practical Recommendations
- Frequently asked questions
What changes on December 1, 2026
On October 30, 2026, the Head of the Revenue Service of Georgia issued Order No. 24839, approving a special form and procedure for recording purchases of goods from individuals.
The order was published on November 2, 2026. The order itself took effect on the date of signing, while the new procedure applies to relevant business transactions from December 1, 2026.
The new rules are also connected with Order No. 332 of the Minister of Finance of Georgia, dated October 26, 2026, which entered into force on November 1, 2026.
A new document
Certain purchases must be documented using anact of purchase of goods from an individual(ფიზიკური პირისგან საქონლის შესყიდვის აქტი).
The buyer prepares the act in the Revenue Service's electronic system. The seller can then confirm or reject it.
The new electronic procedure does not remove the obligation to issue other documents where required by law.
Which documents can replace the new electronic purchase act
It is important to distinguish documents that expressly remove the need for a special electronic act from supplementary evidence of the transaction and payment.
Documents expressly recognized by the new order
If the seller issues one of the documents specified in the order within the required period, an additional electronic purchase act is not required.
| Document | When It Is Used |
|---|---|
| Goods waybill | When goods are supplied with a waybill issued in accordance with the prescribed tax procedure. |
| Special tax invoice for petroleum products | For relevant transactions involving petroleum products. |
| Tax document | When the supply is documented using a document provided for under the Tax Code. |
Example
A restaurant buys vegetables from a registered entrepreneur. The seller issues a goods waybill to the restaurant.
In this case, no additional electronic act for purchasing goods from an individual is required.
Contract, receipt, and goods acceptance certificate
A purchase may also be supported by:
- a sale and purchase agreement;
- a goods acceptance certificate;
- a receipt from the seller;
- a bank statement.
For an LLC, a contract and receipt may serve as evidence that a transaction occurred, but they do not remove the special documentation requirement where it applies.
Individual entrepreneurs with Small Business Status: separate rules
A fundamentally different rule applies to entrepreneurs holding Small Business Status.
Order No. 24839 provides that such entrepreneurs may use the new electronic purchase acton a voluntary basis.
If the purchase is made in the course of an activity taxed under the Small Business regime, an electronic purchase act is not mandatory.
Special recordkeeping journal
Article 91 of the Tax Code provides for the maintenance of a special recordkeeping journal.
The journal records:
- the name of the purchased goods;
- the unit of measurement and quantity;
- the date of expenditure;
- the amount paid;
- details of the supporting document, if available;
- any necessary notes.
The journal may be maintained on paper or electronically.
Example from the official instructions: potatoes and onions
Annex No. 3 to Order No. 999 includes an example in which an individual entrepreneur with Small Business Status purchases potatoes and onions at a market without documents supporting the expenditure.
| Goods | Quantity | Amount | Document |
|---|---|---|---|
| Potatoes | 1 sack | 30 GEL | Not specified |
| Onions | 10 kg | 9 GEL | Not specified |
This example illustrates that the special journal is an independent tax recordkeeping tool for Small Businesses.
Example: purchasing food for a café
Suppose an individual entrepreneur with Small Business Status, who is not registered for VAT, purchases the following goods at a market on December 5, 2026:
| Goods | Quantity | Amount |
|---|---|---|
| Tomatoes | 10 kg | 40 GEL |
| Cucumbers | 5 kg | 15 GEL |
| Herbs | 3 kg | 12 GEL |
| Total | — | 67 GEL |
If the seller has not provided documents, the entrepreneur records the purchase in the special journal, including the goods, quantity, date, and amount.
If a waybill, primary document, or goods acceptance certificate is available, its details may also be entered in the journal.
Important for small businesses
A Small Business is taxed on its taxable income under the special regime, rather than on the difference between revenue and expenses.
Accordingly, the cost of purchased food does not directly reduce the tax base for the 1% rate.
Why recording a purchase in a journal is not enough for a restaurant
Restaurants, cafés, and other food business operators must also comply with food traceability requirements.
A business must be able to identify the supplier from whom a particular batch of food products was purchased.
Relevant information includes the supplier's details, actual address, and the date the products were received.
Therefore, businesses regularly purchasing food from individuals are advised to maintain a separate supplier register.
Can an ordinary paper purchase act be used?
Yes, provided the special electronic purchase act is not mandatory for the particular buyer and transaction.
For example, an individual entrepreneur with Small Business Status may additionally prepare a paper document confirming the purchase.
Sample paper purchase act
GOODS PURCHASE AND ACCEPTANCE CERTIFICATE
Date: December 5, 2026
Buyer: Individual Entrepreneur [Full name, identification number]
Seller: [Full name, personal identification number]
Seller's address: [address]
Place of purchase: [market, address]
Goods:Tomatoes
Quantity: 10 kg
Price: 40 GEL
Goods:Cucumbers
Quantity: 5 kg
Price: 15 GEL
Total:55 GEL
The goods have been delivered to and accepted by the buyer. Payment has been made in full in cash.
Seller's signature: ____________________
Buyer's signature: ____________________
For an LLC subject to the mandatory electronic procedure, this paper document does not replace the electronic act required under Order No. 24839.
What if the seller refuses to provide documents?
Scenario 1. The seller is willing to confirm the transaction
For a restaurant operating as an LLC, if no prescribed alternative document is available, the buyer prepares an electronic purchase act.
The seller confirms it using the mechanism provided under the new procedure.
Scenario 2. The seller is willing to sign a paper document
An individual entrepreneur with Small Business Status may use a paper primary document together with the special journal.
For an LLC, such a document alone does not replace a mandatory electronic purchase act.
Scenario 3. The seller provides no details at all
A Small Business may enter the purchase in its special journal without a separate document.
However, a restaurant may then have difficulty establishing the origin of the products.
When must the electronic purchase act be issued?
| Action | Deadline |
|---|---|
| Issuing the act by the buyer | By the end of the month following the month of purchase. |
| Confirmation or rejection by the seller | Within the two months following the month of the transaction. |
| Date the new procedure starts applying | December 1, 2026 |
Example
If a restaurant purchased food on December 5, 2026, the act must be issued by January 31, 2027.
The seller may confirm or reject it within the prescribed two-month period.
An act sent to the seller is not the same as a confirmed act.
What are the potential consequences of improper documentation?
For an ordinary company, an expense that is not supported by documents may have implications for corporate profit tax purposes where the law requires documentary evidence.
Separate liability rules apply to transporting goods without the required documents and to unrecorded inventory.
For Small Businesses, the central issue is properly recording purchases in the special journal.
Restaurants must also be able to establish the origin of the food products they purchase.
Comparison of three purchasing models
| Issue | Restaurant (LLC) | Individual Entrepreneur (General Regime) | Individual Entrepreneur (Small Business) |
|---|---|---|---|
| Electronic act when purchasing from an individual without prescribed documents | Mandatory | Mandatory | Voluntary |
| Can a paper document be prepared? | Yes, as supplementary documentation | Yes, as supplementary documentation | Yes |
| Special Small Business journal | Not applicable | Not applicable | Mandatory |
| Can a purchase be recorded without a separate document from the seller? | Not applicable | Not applicable | Yes, under the special regime |
| Food traceability | Yes | Yes | Yes |
| VAT rules where the relevant status applies | Yes | Yes | Yes |
Our recommendations for restaurants, cafés, and other businesses
From December 1, 2026, purchases from individuals can be divided into three categories:
- purchases for which the seller issues the required tax documents;
- purchases from individuals that require an electronic purchase act;
- purchases for which the electronic purchase act is optional.
In practice
- LLCs and individual entrepreneurs under the general regime should arrange for electronic acts to be prepared and confirmed by sellers, unless an exception applies;
- individual entrepreneurs with Small Business Status should continue maintaining their special journal and may use electronic acts voluntarily;
- restaurants and cafés must separately ensure that food suppliers can be identified and the origin of products traced.
For recurring purchases, it is advisable to establish a list of verified suppliers in advance, collect the necessary identification details, and agree on documentation procedures.
Frequently asked questions
No. The procedure depends on the buyer's status and whether the seller has issued one of the prescribed alternative documents.
For Small Businesses, the new electronic act is optional. However, the obligation to maintain the special recordkeeping journal remains.
Yes, if the seller has issued the prescribed goods waybill or another expressly recognized document within the required period.
No, if the special electronic procedure is mandatory for the transaction. A receipt can confirm that a transaction took place, but it cannot replace the required electronic act.
The special Small Business journal allows a purchase to be recorded even in the absence of a separate document supporting the expenditure.
In addition to tax recordkeeping, restaurants must comply with food traceability requirements and be able to establish the origin of the purchased products.
Key takeaways
- The new special procedure applies to relevant transactions from December 1, 2026;
- For LLCs and individual entrepreneurs under the general regime, an electronic act may be mandatory;
- If the seller issues a prescribed alternative document within the required period, an additional act is unnecessary;
- For individual entrepreneurs with Small Business Status, the electronic act is optional;
- Small Businesses must continue maintaining their special recordkeeping journal;
- A paper act may serve as supplementary evidence but does not always replace the required electronic document;
- Restaurants must comply not only with tax rules but also with food traceability requirements.
Revenue Service Order No. 24839 of October 30, 2026
Minister of Finance Order No. 332 of October 26, 2026
Minister of Finance Order No. 279 of July 24, 2018
Government Resolution No. 577 on Food Traceability
This material is based on the legislation cited in the original article. The source material was reviewed as of November 6, 2026.