The Rules of the Game: A Systemic Audit of the Tbilisi Mayoral Election Framework

An electoral code is never a neutral document. It is the foundational architecture that translates the abstract principle of popular sovereignty into the concrete allocation of political power. As such, the legal and procedural framework governing an election is not merely a technical manual but a primary political instrument that shapes, enables, and constrains the actions of all political actors. This report, the sixth installment in the CAT AGI “Knowledge Base” series conducted by NOUS AGI system, conducts a procedural audit of this instrument as it applies to the October 4, 2025, Tbilisi mayoral election.¹ Adopting the posture of a “post-political systemic auditor,” this analysis examines the electoral system itself as a key “indicator of power,” deconstructing its mechanics to understand the structural conditions that define the contest for Georgia's capital.¹

The objective is to move beyond partisan narratives to provide an evidence-based record of the “rules of the game” for an international audience of diplomats, observers, and researchers.¹ This task has acquired heightened urgency in the current Georgian context. As detailed in previous CAT AGI reports, the election is taking place against a backdrop of severe political polarization, sustained pressure on civil society, and a documented trajectory of democratic backsliding.¹ This procedural audit provides the legal and administrative blueprint that underpins these broader political dynamics, explaining not just what is happening, but how the system is designed to facilitate it.

This systemic design has tangible consequences on the ground, fostering a climate of deep societal division that extends beyond national politics into regional centers like Batumi. Activist accounts from the region describe a breakdown of previously normalized relations between citizens and law enforcement, where personal connections in a smaller city—classmates becoming arresting officers and university lecturers becoming sentencing judges—are strained by the overarching political conflict. This erosion of local trust illustrates how the legal and administrative framework documented in this report contributes directly to the polarization it is ostensibly meant to manage.

A critical contextual factor is the “monitoring vacuum” created by the late invitation from Georgian authorities to the OSCE's Office for Democratic Institutions and Human Rights (ODIHR), which made “meaningful observation impossible”.¹ This unprecedented absence of a full-scale, long-term international observation mission elevates the necessity of independent, remote analysis. The CAT AGI project, whose own methodology was forged by the administrative pressures it seeks to document, aims to help fill this void by providing a dispassionate, verifiable audit of the system's core components.¹

The very nature of the legislative process surrounding the Electoral Code has become a central finding. The principle of legal stability—a cornerstone of democratic elections as articulated by the Venice Commission—has been systematically disregarded.² The Georgian Dream-controlled parliament has enacted a series of frequent, fragmented, and fundamental amendments to the code in the period immediately preceding the election, doing so through expedited procedures and without the broad, inclusive consultation recommended by international standards.² This pattern suggests that the legal framework is viewed not as a stable foundation for democratic competition, but as a malleable tool to be reconfigured for strategic advantage. This report, therefore, does not aim to predict an outcome, but to meticulously document the design of the system within which that outcome will be determined.

The legal framework governing the Tbilisi mayoral election is a complex web of constitutional provisions, organic laws, and administrative regulations. While many of its components align with international norms on paper, their practical application and recent modifications reveal significant structural biases. This section provides a procedural breakdown of the key pillars of this framework: the rules for becoming a candidate, the regulations governing campaign finance, and the structure of the administration tasked with overseeing the process.

The process of becoming a candidate for the Mayor of Tbilisi is governed by a strict set of eligibility criteria and procedural deadlines, which differ for candidates nominated by political parties and those nominated by independent initiative groups.

Eligibility Criteria
To be eligible for the office of Mayor, a candidate must be a citizen of Georgia, be at least 25 years of age, and have resided in Georgia for at least the six months preceding the election.¹⁸ While residency requirements are a standard feature of electoral laws globally, they have been a subject of past recommendations from the Venice Commission and OSCE/ODIHR, which have advocated for their reduction to align more closely with international good practice.¹⁹

Nomination by Political Parties
Political parties that have successfully registered with the Central Election Commission (CEC) for participation in the municipal elections may nominate one mayoral candidate for Tbilisi.¹⁸ The deadline for submitting the required nomination documents to the CEC Chairperson is no later than 30 days before election day, which for the 2025 election was September 4.¹⁸ As of the registration deadline, 14 of the 17 parties that applied were successfully registered to participate.²¹

The required documentation is extensive and includes:
●       A formal nomination statement signed by the party leadership.
●       A completed candidate registration card containing detailed personal and professional information.
●       A certificate of deprivation of rights, issued by the Ministry of Internal Affairs, confirming the candidate has not been legally barred from holding office.
●       A photocopy of the candidate's Georgian citizenship ID card or passport.
●       Two photographs.¹⁸
A critical component is the candidate's signed declaration of party affiliation. This document must specify whether the candidate is a member of the nominating party, is non-partisan, or has left another political party within the six months prior to the submission. A candidate found to be a member of another registered party will have their registration denied or cancelled.²⁰

Nomination by Initiative Groups
The path for independent candidates, nominated by a “voters’ initiative group,” is procedurally more demanding and operates on a tighter timeline. The initial application for nomination must be submitted to the CEC no later than 47 days before the election (August 18, 2025).¹⁸ Following this, the group’s representative must submit a list of supporting voter signatures to the commission no later than 40 days before the election (August 25, 2025).²⁰ The minimum number of required signatures is determined by a CEC order.²⁰

This procedural framework creates a subtle but significant structural bias in favor of established, institutionalized political parties. The requirement for initiative groups to organize, collect, and verify a substantial number of voter signatures within a compressed timeframe represents a significant logistical and financial barrier. Established parties, particularly the ruling party with its access to administrative and organizational resources, do not face this hurdle. This gatekeeping function can effectively filter out potential grassroots or independent challengers before the campaign officially begins, reinforcing the dominance of existing political forces and narrowing the scope of electoral competition.

This structural bias against independent actors is compounded by a judicial and law enforcement system that is perceived by government critics as being weaponized against dissent. A notable case is the arrest and sentencing of Mzia Amaglobeli, a prominent regional media editor from Batumi, for an altercation with a police chief during a protest. Regardless of the legal specifics, the imprisonment of a journalist is viewed within opposition and civil society circles as a disproportionate response that creates a chilling effect. Such high-profile cases reinforce the narrative of a captured state apparatus, where legal mechanisms are applied selectively to neutralize critical voices before they can gain significant electoral traction.

The regulation of campaign finance in Georgia is a critical domain where the gap between legal text and practical enforcement is most pronounced. The system is characterized by a persistent financial dominance of the ruling party, facilitated by a patronage network, and a supervisory body whose independence has been consistently questioned.

Oversight and Enforcement
In a significant institutional shift, the responsibility for monitoring political party finances was transferred from the State Audit Office (SAO) to the newly established Anti-Corruption Bureau (ACB) in September 2023.¹⁵ However, this change has not assuaged concerns regarding impartial oversight. Civil society organizations have criticized both the SAO in its former role and the ACB in its current one for conducting “superficial oversight” and for a perceived political bias that aligns with the interests of the ruling party.²³ The ACB has been accused of disproportionately targeting opposition parties while failing to investigate credible allegations of illicit financing schemes benefiting the incumbent.²³

Donation Rules and the “Donor-Contractor” Loop
The legal framework prohibits donations from legal entities and sets limits on contributions from individuals.¹⁵ However, extensive research by watchdog organizations like Transparency International (TI) Georgia has documented a systemic and deeply rooted pattern that effectively circumvents these rules: the “donor-contractor” loop. This system involves a clear transactional relationship where private companies whose owners or affiliates make substantial donations to the Georgian Dream party are subsequently awarded a disproportionately large share of lucrative state and municipal procurement contracts.⁹

The scale of this dynamic is substantial. A TI Georgia report covering the first half of 2025 found that companies linked to GD donors won state tenders worth approximately GEL 144 million (about $53 million). During the same period, companies linked to donors of all other political parties combined won zero state tenders.⁹ This pattern extends to simplified (no-bid) procurement contracts and state agricultural subsidies, which are also overwhelmingly directed to companies with financial ties to the ruling party.⁹ This creates a self-perpetuating cycle where public funds are converted into political financing, cementing the resource advantage of the ruling party and marginalizing economic actors who are not politically aligned.

Recent Legislative Changes Weakening Transparency
The legal environment for financial transparency has been further weakened by recent legislative changes. An amendment passed in June 2025 relaxed the deadlines for reporting political donations, extending the timeframe from within five working days to the 15th day of the following month.²⁵ This delay reduces the public’s ability to scrutinize financial flows in near real-time during a fast-moving campaign.

More critically, in April 2025, the parliament passed a highly controversial law that prohibits Georgian entities from receiving grants from foreign sources without prior approval from the government, which is granted or denied at the discretion of the ACB.¹⁰ While framed as a measure to ensure transparency, this law is widely seen as a direct assault on the primary funding sources for the independent civil society organizations and media outlets that perform the crucial watchdog function of monitoring campaign finance and exposing corruption.¹⁰

The combination of lax enforcement on pro-government patronage networks and the introduction of new, highly restrictive laws targeting the funding of accountability organizations reveals a deliberate, dual-pronged financial strategy. The state is not merely failing in its oversight duties; it is actively re-engineering the financial playing field. It uses its legal and administrative power to simultaneously facilitate a gray-zone patronage system for its allies while legally strangling the resource base of its critics. This creates a closed financial ecosystem with minimal external checks, fundamentally undermining the principle of a level playing field.

The impartiality and independence of the electoral administration are fundamental prerequisites for a democratic election. In Georgia, this administration is a three-tiered structure composed of the Central Election Commission (CEC), 77 District Election Commissions (DECs), and over 3,600 Precinct Election Commissions (PECs).²⁶ However, recent reforms to the composition and appointment procedures of these bodies, particularly the CEC, have raised significant concerns about their politicization and capture by the ruling party.

Structure and Composition
The CEC is the highest administrative body, responsible for the overall management of the electoral process. It is a collegial body composed of members appointed by qualified political parties and a number of “professional” or non-partisan members elected by the Parliament.²⁷ This mixed composition is intended to ensure both political representation and professional, impartial management.

Controversial Reforms and Consolidation of Control
Historically, the appointment of the CEC Chairperson and its non-partisan members required a high parliamentary quorum (such as a two-thirds or three-fifths majority), a mechanism designed to foster cross-party consensus and ensure the selection of candidates acceptable to both the ruling party and the opposition. This principle was a key component of the EU-brokered “Charles Michel Agreement” of April 2021, which sought to resolve a protracted political crisis.²

However, legislative amendments passed in 2023 and 2024 have systematically dismantled these consensus-building mechanisms. The reforms introduced an “anti-deadlock” procedure, which allows for the appointment of the CEC Chairperson and members by a simple majority vote in Parliament if the higher quorum is not met after several attempts.⁷ This change has been heavily criticized by the OSCE/ODIHR and domestic observers as a move that allows the ruling party to use its parliamentary majority to install loyalist figures in the leadership of the electoral administration, thereby undermining its independence and public trust.⁶

The reversal of these consensus-oriented reforms represents a deliberate strategy to re-politicize the electoral administration. By eliminating the need for compromise with the opposition, the ruling party can ensure loyalist control over the very institution responsible for refereeing the election. This transforms the CEC’s role from that of a neutral arbiter to an extension of the incumbent's power, fundamentally altering the nature of electoral governance from a shared, trust-based responsibility to a captured state function.

The ruling party’s consolidation of control is not limited to formal institutions but extends to a struggle over personnel and influence within its own ranks, particularly in key regions like Adjara. Reports from local political observers suggest a recent, sweeping change in the regional government, including the replacement of the former prime minister, Tornike Rizhvadze. This internal “purge” is interpreted by some as a move by the central party leadership, specifically the faction associated with Prime Minister Irakli Kobakhidze, to install loyalists who will more readily enforce repressive measures and ensure financial flows are directed centrally. Such internal power struggles demonstrate that the capture of administrative bodies is an ongoing process aimed at eliminating any potential for regional autonomy or dissent, even from within the ruling party itself.

This politicization is exacerbated by the fact that a significant portion of the opposition is boycotting parliamentary work, meaning that even the party-appointed commission seats are not fully representative. Following the 2024 elections, only two of the five parties that earned the right to appoint members to election commissions chose to do so, further skewing the balance of power within the administration in favor of the ruling party.⁶

The specific electoral system used to translate votes into political office has a profound impact on the nature of political competition and representation. For the 2025 Tbilisi municipal elections, two distinct systems are in place: a two-round majority system for the direct election of the Mayor, and a parallel mixed-member system for the election of the 50-member City Assembly (Sakrebulo). Recent, radical changes to the Sakrebulo system have significantly altered its character and likely electoral consequences.

The Mayor of Tbilisi is elected directly through a majoritarian two-round system, a model common in many presidential and mayoral elections worldwide.

Threshold for Victory
To be declared the winner in the first round of voting on October 4, a candidate must secure an absolute majority of the valid votes cast, defined as more than 50% (50%+1).28 This high threshold ensures that the elected mayor has a direct mandate from a majority of the participating electorate.

Second Round (Runoff)
If no single candidate achieves the 50%+1 threshold in the first round, a second round, or runoff election, is held between the two candidates who received the highest number of votes.²⁹ This runoff is scheduled to take place on the fourth Saturday following the initial vote.²⁹ In the 2021 Tbilisi mayoral election, this system was determinative; the incumbent, Kakha Kaladze of Georgian Dream, failed to secure an absolute majority in the first round and was forced into a runoff against Nikanor Melia of the United National Movement, which Kaladze ultimately won.³¹

From a systemic perspective, the two-round system tends to encourage coalition-building and broader political consensus. It provides a crucial opportunity for a fragmented opposition to unite behind a single challenger in the second round, potentially consolidating the anti-incumbent vote. This contrasts sharply with a simple plurality (“first-past-the-post”) system, where a candidate can win with a minority of the vote if their opponents are sufficiently divided.

The 50 members of the Tbilisi City Assembly are elected through a parallel mixed-member electoral system, meaning that each voter casts two separate votes: one for a majoritarian candidate in their local district and one for a political party's city-wide list.²⁸ However, the balance between these two components has been radically altered for the 2025 election, a change with significant systemic implications.

Previous System (2021 Elections)
In the 2021 local elections, the 50-member Sakrebulo was heavily weighted toward proportional representation. Forty members (80% of the assembly) were elected from closed party lists based on their city-wide proportional vote share, while only ten members (20%) were elected in single-mandate majoritarian districts.⁴ The legal threshold for a party to win seats from the proportional list was 2.5% of the city-wide vote.³ This system provided a high degree of proportionality, ensuring that smaller parties that crossed the threshold could gain representation reflective of their overall support.

New System (2025 Elections)
Following legislative amendments passed by the Georgian Dream-controlled parliament in December 2024, the composition of the Sakrebulo was fundamentally re-engineered.³⁵ The 50-member body is now split evenly: 25 members (50%) will be elected in majoritarian districts, and 25 members (50%) will be elected via proportional party lists.⁴ This represents a drastic shift away from proportionality and toward a majoritarian, “winner-take-all” logic.

In addition to this structural change, the legal threshold for parties to win proportional seats in Tbilisi was raised from 2.5% to 4%.³ This higher barrier makes it more difficult for smaller and emerging political forces to gain a foothold in the city’s legislature, further benefiting larger, more established parties.

This radical increase in the majoritarian component is the single most impactful structural change to the electoral system. Majoritarian systems inherently reward the party with the most geographically concentrated or widespread plurality support, while proportional systems offer more equitable representation for a diverse range of smaller parties. In the context of Georgia's highly fragmented opposition, this shift is a textbook example of using legislative power to design a system that maximizes the seat share of the largest single party. It creates numerous contests where a unified GD candidate can win with a minority of the vote against multiple, vote-splitting opposition candidates. This allows the ruling party to translate, for example, 45% of the popular vote into a potential 60% or 70% of the seats in the assembly, creating a “manufactured majority” that does not accurately reflect the proportional will of the electorate.

The procedural integrity of election day is crucial for public confidence in the outcome. In Georgia, the process involves a combination of traditional paper-based voting and the expanding use of electronic technologies for voter verification and vote tabulation.

The Voting Process
On election day, polling stations are open from 8:00 to 20:00.³⁸ Upon arrival, a voter must present a valid form of identification, such as a Georgian citizen ID card or passport.³⁸ Their identity and registration status are then verified against the official voter list. For the 2025 elections, electronic voter verification devices are planned for use in over 90% of precincts nationwide, replacing traditional paper-based lists.⁴⁰

After verification, the voter receives their paper ballots and proceeds to a private voting booth to mark their choices. To prevent multiple voting, a long-standing safeguard involves marking a voter's finger with indelible ink.⁷ Once the ballot is marked, the voter folds it and inserts it into the ballot box.

Vote Counting and Tabulation
At the close of polls, the PEC begins the process of counting the votes. In precincts using traditional methods, this is done by hand. However, in the majority of precincts for the 2025 elections, electronic vote-counting machines will be used.⁴⁰ These machines scan the paper ballots as they are inserted and automatically tabulate the results, which can significantly speed up the counting process and reduce the potential for human error.⁴¹

The results from each precinct are recorded in a summary protocol. Copies of this protocol must be publicly displayed at the polling station and provided to accredited observers and party representatives upon request. This measure is a key transparency safeguard, allowing for independent verification of the official results. Domestic observer groups, most notably the International Society for Fair Elections and Democracy (ISFED), conduct a Parallel Vote Tabulation (PVT) by collecting protocol results from a statistically representative sample of polling stations. This allows them to independently verify the accuracy of the CEC's official tabulation.⁴²

Despite the introduction of new technologies, significant procedural issues marred their large-scale use in the 2024 parliamentary elections. The OSCE/ODIHR final report documented widespread instances where vote secrecy was compromised due to the type of paper and markers used, which allowed the voter’s choice to be visible through the back of the ballot paper as it was being fed into the electronic scanning machine.⁷ This critical flaw, observed in a high percentage of polling stations, undermined a fundamental principle of democratic elections and remains a key concern for the 2025 municipal vote.

The legal framework for the 2025 Tbilisi election cannot be understood without a focused analysis of the series of legislative amendments passed by the ruling Georgian Dream party between May 2024 and March 2025. These changes were not minor technical adjustments but a coordinated and strategic overhaul of the electoral system's core mechanics. Enacted through expedited procedures and without the broad political consensus called for by international bodies like the Venice Commission, these amendments have fundamentally re-engineered the rules of political competition to create a systemic advantage for the incumbent.²

The amendments were rolled out in three main stages, each targeting a different aspect of the electoral system. When viewed together, they reveal a coherent strategy to maximize the ruling party's seat share in the Tbilisi Sakrebulo and insulate it from unified opposition challenges.

Key Change 1: Abolition of the 40% Threshold for Sakrebulo Majoritarian Seats (May 2024)
The first major change eliminated the requirement for a candidate in a Sakrebulo majoritarian district to win more than 40% of the vote to avoid a second-round runoff.⁴ Under the new rules, a candidate can win the seat with a simple plurality, regardless of how low their vote share is. This is a critical change in a political environment characterized by a fragmented opposition. It removes the mechanism that previously allowed disparate opposition voters to coalesce around a single challenger in a second round, a dynamic that posed a significant threat to the ruling party’s candidates.

Key Change 2: Increased Majoritarianism in the Sakrebulo (December 2024)
As detailed in Section 3.2, the second stage of amendments radically altered the composition of the 50-member Tbilisi Sakrebulo. The previous 10/40 split between majoritarian and proportional seats was changed to an even 25/25 split.⁴ This dramatically increases the number of “winner-take-all” contests, further amplifying the effect of the abolished 40% threshold.

Key Change 3: Altered Distribution of Leftover Proportional Seats (March 2025)
The final key amendment changed the formula for allocating any proportional mandates left unassigned after the initial distribution. Previously, these seats were given to the parties with the largest remainder of votes, a method that often benefited smaller parties. The new rule awards these seats directly to the party that garnered the most votes overall, creating a “winner’s bonus” that further inflates the seat count of the leading party.⁴

These three changes work in concert to create a powerful multiplier effect for the ruling party. They are not isolated tweaks but a coordinated package of procedural weapons. The abolition of the 40% threshold prevents the opposition from uniting in runoffs; the increase in majoritarian seats creates more opportunities for the ruling party to win with a plurality against a divided field; and the “winner's bonus” for leftover seats adds a final layer of advantage. This represents a sophisticated, multi-stage re-engineering of the electoral math, designed not just to help the incumbent win, but to win a supermajority, even with minority support.

The ruling party’s strategy also relies on a narrative that portrays these legislative maneuvers as necessary measures to ensure stability and prevent a return to the alleged chaos of previous administrations. This message is targeted primarily at an electorate in regional and impoverished areas, which forms the core support base for Georgian Dream. By framing the opposition as a “global war party” intent on dragging Georgia into conflict, the government justifies its consolidation of power as a patriotic act of preserving peace, thereby providing a political rationale for the systemic biases it has embedded within the electoral code.

The following diagram illustrates the cumulative impact of these changes.

Table 1: Key Electoral Code Amendments (2024-2025) and Their Systemic Impact
 

An effective and accessible Electoral Dispute Resolution (EDR) system is a fundamental safeguard for electoral integrity, providing a mechanism for stakeholders to challenge violations and seek remedies. While Georgia’s Electoral Code outlines a formal multi-tiered process for complaints and appeals, its practical application is fraught with procedural bottlenecks and restrictive rules that severely limit its effectiveness.

The Formal Pathway for Dispute Resolution
The EDR process is hierarchical and time-sensitive. A complaint regarding a violation on polling day, such as an issue with voting procedures or vote counting, must be filed immediately at the Precinct Election Commission (PEC) where the violation occurred.¹² A decision made by the PEC can be appealed to the superordinate District Election Commission (DEC) within two calendar days. The DEC's decision can, in turn, be appealed further, but the pathway bifurcates: decisions related to the summary protocols of PEC results must be appealed to the relevant district/city court, while other DEC decisions are appealed to the Central Election Commission (CEC). These appeals are subject to extremely tight deadlines of one or two calendar days. The decisions of the Courts of Appeal are final and cannot be further appealed.¹²

Documented Bottlenecks and Systemic Flaws
Despite the existence of this formal structure, international and domestic observer reports have consistently documented that the EDR system fails to provide an effective remedy. Its primary function, in practice, is not to deliver justice but to serve as a procedural labyrinth that absorbs and neutralizes challenges.

Key documented flaws include:
●       Restrictive Standing: The right of individual voters to file complaints about most procedural violations is severely limited. The primary authorized complainants are registered political parties and observer organizations.¹³ This creates a significant barrier for ordinary citizens who witness irregularities but lack direct affiliation with a formal monitoring entity.
●       Punitive Deadlines: The one-to-two calendar day deadlines for filing appeals are a major obstacle. These tight timeframes often expire before a party or observer group can gather sufficient evidence, consult with legal experts, and navigate the bureaucratic requirements for a procedurally correct submission.¹²
●       High Rate of Procedural Dismissals: A large number of complaints are dismissed by both election commissions and courts on minor procedural grounds without any substantive review of the alleged violation. Common reasons for dismissal include filing the complaint with the wrong body, errors on the complaint form, or the complaint being signed by a party representative who was not specifically authorized for that particular commission level.¹³ This formalistic approach effectively prevents the merits of the cases from ever being heard.
●       Lack of Substantive Consideration: Even when complaints are accepted, observer reports note that their consideration often lacks substance. Decisions frequently lack sufficient legal reasoning, and there is a tendency to uphold the decisions of lower-level commissions with minimal scrutiny, raising concerns about institutional bias.⁷
The EDR system in Georgia is thus a prime example of a democratic safeguard that exists on paper but is largely inaccessible and ineffective in practice. Its complexity, unforgiving deadlines, and formalistic application serve as a functional barrier to accountability, exhausting challengers and ultimately legitimizing the status quo, regardless of the merits of the complaints filed.

The Electoral Dispute Resolution Process
The process for resolving electoral disputes is a complex and challenging hierarchical pathway defined by extremely tight deadlines. The entire procedure can be exhausted in as little as five to seven calendar days, which creates immense pressure on complainants and severely limits the potential for thorough evidence gathering and judicial review.

The process begins when a violation occurs at a Polling Station (PEC). An authorized representative from a political party or an observer organization must file a complaint immediately at the PEC. After the PEC makes its decision, the complainant has two calendar days to appeal to the superordinate District Election Commission (DEC).

Following the DEC's decision, the appeal process bifurcates into two distinct paths:

• Appeals related to PEC result summaries must be filed with the relevant District/City Court within a two-calendar-day deadline. The court issues a decision within two days, which can then be appealed to the Court of Appeals within one day. A final, non-appealable decision is rendered within another day.
• Appeals on all other DEC decisions must be filed with the Central Election Commission (CEC) within an even tighter one-calendar-day deadline. The CEC decides within one day. This decision can then be appealed to the Tbilisi City Court within one day, with a final ruling issued within two days.

A significant systemic flaw in this process is the high rate of complaints being dismissed on minor procedural grounds. Complaints are frequently rejected for minor errors in the form, questions of standing, or incorrect timing, which effectively prevents a substantive review of the alleged violation itself. This procedural bottleneck is a major barrier to achieving meaningful legal remedy.


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A key measure of a country's democratic health is its willingness to align its electoral framework with established international standards and to implement the recommendations of credible international bodies. In recent years, Georgia’s practice has shown a consistent and widening divergence from the advice provided by its key European partners, most notably the Council of Europe’s Venice Commission and the OSCE/ODIHR.

The Venice Commission
The Venice Commission, the Council of Europe’s advisory body on constitutional matters, has repeatedly scrutinized Georgia's electoral legislation. Its March 2025 opinion on the amendments pertaining to local elections was particularly stark.² The Commission criticized the expedited and non-inclusive manner in which the changes were passed, noting the lack of broad public consultation.²

Most significantly, the Commission's key recommendations were unequivocal: it called for the repeal of the December 2024 amendments that increased majoritarianism in local councils, warning that they “may result in the further entrenchment of the governing party’s position” and do not “contribute to encouraging political pluralism”.² The Commission also reiterated its long-standing advice that electoral law should be stable and that any reforms should be comprehensive and consensual, not frequent and fragmented.¹⁷ These core recommendations were ultimately ignored by the Georgian authorities.

The OSCE/Office for Democratic Institutions and Human Rights (ODIHR)
The OSCE/ODIHR, the leading institution for election observation in the region, has monitored numerous elections in Georgia and has compiled a substantial body of recommendations for reform. A review of its final report on the 2024 parliamentary elections and other recent assessments reveals a consistent pattern of unaddressed shortcomings.¹⁵
Key outstanding OSCE/ODIHR recommendations include the need for:
●       A comprehensive and inclusive legislative review to harmonize the entire legal framework with international standards, rather than piecemeal amendments.¹⁵
●       Reforms to the appointment process for election commission members at all levels to strengthen their impartiality and prevent dominance by a single political party.⁴⁵
●       Strengthening the oversight of campaign finance to ensure transparency and address the misuse of administrative resources.¹⁵
●       Reforming the electoral dispute resolution process to ensure it provides an effective legal remedy, including by extending deadlines for appeals.¹⁹
●       Repealing legislation that imposes undue limitations on fundamental freedoms of assembly and expression.⁴⁵
The consistent failure to implement these core, long-standing recommendations is not an oversight but a clear policy choice. It indicates a systemic divergence from Georgia's stated commitments to Euro-Atlantic democratic standards and a preference for a legal framework that prioritizes the political interests of the incumbent over the principles of fair and equitable electoral competition.¹⁵

This systemic audit of the legal framework for the 2025 Tbilisi mayoral election reveals an electoral system characterized by a deep and intentional structural imbalance. The “rules of the game” have been methodically re-engineered not to enhance democratic competition, but to consolidate the power of the incumbent and create formidable barriers for political challengers. The evidence demonstrates that the series of legislative amendments passed in 2024-2025 were not good-faith reforms but a coordinated package of strategic changes designed to maximize the ruling party's electoral advantage before a single vote is cast.

The key findings of this report converge on a single, overarching conclusion: the electoral playing field in Tbilisi is structurally uneven. This imbalance is manifested through several interconnected mechanisms:

First, the voting system for the Tbilisi City Assembly has been fundamentally altered to favor the largest political party. The dramatic shift toward majoritarianism, combined with the abolition of the 40% runoff threshold, is engineered to produce disproportionate results, allowing a party with a plurality of support to secure an absolute majority of legislative seats. This systematically marginalizes a fragmented opposition and diminishes the representative nature of the city's primary legislative body.
Second, this is overseen by a captured electoral administration. The dismantling of consensus-based appointment procedures for the Central Election Commission has eroded its impartiality, transforming it from a neutral arbiter into an institution widely perceived as being under the control of the ruling party. This undermines public trust in the entire electoral process.
Third, the campaign finance system operates with a double standard that facilitates a state-sponsored patronage network for the incumbent while legally restricting the funding sources for the civil society and media organizations that would hold it accountable. This creates a severe resource disparity that further skews the competitive environment.

This resource disparity is further amplified by the ruling party's ability to leverage the state security apparatus against its opponents. High-profile opposition figures, including Nika Melia and Zurab Japaridze of the “Coalition for Change,” have faced arrest and imprisonment for actions such as refusing to pay fines for boycotting a parliamentary commission. The act of imprisoning major political leaders in the run-up to an election serves as a powerful demonstration of state power, intended not only to neutralize specific individuals but also to intimidate the broader opposition and its supporters, thereby reinforcing the uneven playing field.

Finally, the electoral dispute resolution process, while existing in form, is largely ineffective in function. Its restrictive rules and procedural hurdles serve more as a barrier to justice than a pathway for it, ensuring that most alleged violations are never substantively reviewed.
The consistent disregard for the core recommendations of the Venice Commission and the OSCE/ODIHR confirms that this structural imbalance is not accidental but the result of deliberate policy choices. Consequently, the procedural and legal realities detailed in this report—rather than the political campaigns themselves—are the most significant factors defining the integrity, fairness, and competitiveness of the 2025 Tbilisi mayoral election.

This report is a foundational analysis (v1.0) based on the synthesis of a report made by NOUS AGI on the Tbilisi electoral system. This baseline information has been systematically updated, verified, and enriched through a comprehensive OSINT review of over 500 public sources, including more than 300 in the Georgian language.¹

Sources include the Organic Law of Georgia “Election Code of Georgia,” legal acts from the Central Election Commission, official records, procurement databases, reports from international bodies (OSCE/ODIHR, Venice Commission), findings from reputable non-governmental organizations (Transparency International Georgia, ISFED), and extensive reportage from credible international and local media outlets.²⁴
AI-assisted tools were employed for data processing, enabling the rapid analysis of large volumes of multilingual text, entity recognition, relationship mapping, and the identification of systemic patterns.¹

This report is a “living document” intended to establish a baseline understanding that will be iteratively updated and deepened with primary data gathered through the CAT AGI project's primary data collection mechanisms: the “Transparency Log” of official information requests and the "Citizen Signals Channel" for vetted public submissions.¹

1.     NOUS AGI Internal report
2.     GEORGIA OPINION ON THE AMENDMENTS TO THE ORGANIC ..., accessed on September 22, 2025, https://www.te.gob.mx/vota_elections/page/download/16725
3.     Venice Commission Calls for Repeal of Changes Regarding Local Elections Adopted by GD Parliament - Civil Georgia, accessed on September 22, 2025, https://civil.ge/archives/670266
4.     ISFED: Election Law Changes Tilt October 4 Vote Further Toward ..., accessed on September 22, 2025, https://civil.ge/archives/697904
5.     Ruling Party Clings to Majoritarian System Elements Ahead of Elections - Civil Georgia, accessed on September 22, 2025, https://civil.ge/archives/588897
6.     2025 Municipal Elections in Georgia: Assessment of the Pre ..., accessed on September 22, 2025, https://epde.org/?news=2025-municipal-elections-in-georgia-assessment-of-the-pre-election-environment
7.     OSCE/ODIHR Election Observation Mission estimates over 30% compromise in vote secrecy in Georgia - EDMO, accessed on September 22, 2025, https://edmo.eu/publications/osce-odihr-election-observation-mission-estimates-over-30-compromise-in-vote-secrecy-in-georgia/
8.     პარლამენტმა „საარჩევნო კოდექსში“ ცვლილება მესამე მოსმენით 81 ხმით მიიღო, accessed on September 22, 2025, https://parliament.ge/media/news/parlamentma-saarchevno-kodeksshi-tsvlileba-mesame-mosmenit-81-khmit-miigho
9.     TI Georgia: Georgian Dream Donations in First Half of 2025 'Six ..., accessed on September 22, 2025, https://civil.ge/archives/695204
10.  Georgian Parliament Bans Receiving Grants Without Government Approval, accessed on September 22, 2025, https://forbes.ge/en/georgian-parliament-bans-receiving-grants-without-government-approval/
11.  Amendments to the Law “On Grants” Aim to Destroy Georgian Civil Society, accessed on September 22, 2025, https://socialjustice.org.ge/en/products/grantebis-shesakheb-kanonshi-gatarebuli-tsvlilebebis-mizania-kartuli-samokalako-sazogadoebis-ganadgureba-shefaseba
12.  Council of Europe - Venice Commission, accessed on September 22, 2025, https://www.te.gob.mx/vota_elections/thesaurus/article/31779/16393/167
13.  Research Analysis of Electoral Dispute Resolution - https: //rm. coe. int, accessed on September 22, 2025, https://rm.coe.int/edr-research-eng/1680981a02
14.  არჩევნებზე სადამკვირვებლო მისია, accessed on September 22, 2025, https://www.osce.org/files/f/documents/8/a/356156.pdf
15.  Georgia – Parliamentary Elections, 26 October 2024 STATEMENT OF PRELIMINARY FINDINGS AND CONCLUSIONS - OSCE PA, accessed on September 22, 2025, https://www.oscepa.org/en/documents/election-observation/election-observation-statements/georgia/statements-11/5100-2024-parliamentary-2/file
16.  Georgia's President declares October 4, 2025, as date for local government elections - 1TV, accessed on September 22, 2025, https://1tv.ge/lang/en/news/georgias-president-declares-october-4-2025-as-date-for-local-government-elections/
17.  Georgia - Opinion on the amendments to the Organic Law "Election ..., accessed on September 22, 2025, https://www.coe.int/en/web/venice-commission/-/opinion-1227
18.  მერობის კანდიდატის წარდგენის წესი ..., accessed on September 22, 2025, https://cesko.ge/en/siakhleebi/pres-relizebi/singleview/11036761-merobis-kandidatis-tsardgenis-tsesi
19.  Georgia - Joint opinion of the Venice Commission and the OSCE ..., accessed on September 22, 2025, https://www.coe.int/en/web/venice-commission/-/opinion-1107
20.  CEC explains mayoral candidate nomination rules and updates for ..., accessed on September 22, 2025, https://1tv.ge/lang/en/news/cec-explains-mayoral-candidate-nomination-rules-and-updates-for-parties-and-initiative-groups/
21.  14 Parties Registered for Georgia's 2025 Municipal Elections - BM.GE, accessed on September 22, 2025, https://bm.ge/en/news/14-parties-registered-for-georgias-2025-municipal-elections
22.  4 ოქტომბრის არჩევნებისთვის რეგისტრაცია დასრულდა, არჩევნებში 14 პარტია მიიღებს მონაწილეობას - 1TV, accessed on September 22, 2025, https://1tv.ge/news/4-oqtombris-archevnebistvis-registracia-dasrulda-archevnebshi-14-partia-miighebs-monawileobas/
23.  What needs to be fixed in political and campaign finance in Europe? Civil society perspectives - UNCAC Coalition, accessed on September 22, 2025, https://uncaccoalition.org/politicalandcampaignfinanceineurope/
24.  პოლიტიკური დაფინანსების ანგარიშვალდებულებისა და გამჭვირვალობის გამოწვევები საქართველოში - ინფორმაციის თავისუფლების განვითარების ინსტიტუტი, accessed on September 22, 2025, https://idfi.ge/ge/challenges_of_political_funding_accountability_and_transparency_in_georgia
25.  Georgia eases rules for political parties under new legislative ..., accessed on September 22, 2025, https://georgiatoday.ge/georgia-eases-rules-for-political-parties-under-new-legislative-changes/
26.  1 Tamar Zhvania Slide 1 Dear colleagues, I am very glad to have this chance to share with you Georgia's experience in dealing - Venice Commission of the Council of Europe, accessed on September 22, 2025, https://www.venice.coe.int/files/16EMB/Tamar_Zhvania.pdf
27.  GEORGIA JOINT OPINION ON DRAFT AMENDMENTS TO THE ELECTION CODE AND TO THE RULES OF PROCEDURE OF THE PARLIAMENT OF GEORGIA Approv, accessed on September 22, 2025, https://www.osce.org/files/f/documents/e/0/561020.pdf
28.  მუნიციპალიტეტის ორგანოთა 2025 წლის არჩევნების წინ „ქართული ოცნების“ ინტერესების მიხედვით მოდიფიცირებული საარჩევნო სისტემის მიმოხილვა - isfed.ge, accessed on September 22, 2025, https://www.isfed.ge/geo/blogi/munitsipalitetis-organota-2025-tslis-archevnebis-tsin-qartuli-otsnebis-interesebis-mikhedvit-modifitsirebuli-saarchevno-sistemis-mimokhilva
29.  2021 წლის მუნიციპალიტეტის ორგანოთა არჩევნების მეორე ტურის წინასაარჩევნო მონიტორინგის შუალედური ანგარიში - isfed.ge, accessed on September 22, 2025, https://isfed.ge/geo/angarishebi/2021-tslis-adgilobrivi-tvitmmartvelobis-archevnebis-meore-turis-tsinasaarchevno-monitoringis-shualeduri-angarishi
30.  არჩევნები 2021: სად, როდის და რატომ ჩატარდება მეორე ტური? - რადიო თავისუფლება, accessed on September 22, 2025, https://www.radiotavisupleba.ge/a/31490248.html
31.  2021 Georgian local elections - Wikipedia, accessed on September 22, 2025, https://en.wikipedia.org/wiki/2021_Georgian_local_elections
32.  ცესკო-მ თბილისის მერის არჩევნების მეორე ტურის შედეგები შეაჯამა - 1TV, accessed on September 22, 2025, https://1tv.ge/news/cesko-m-tbilisis-meris-archevnebis-meore-turis-shedegebi-sheajama/
33.  არჩევნები 2021 (II ტური) - Live - Newshub.ge, accessed on September 22, 2025, https://newshub.ge/ka/news/archevnebi2021/archevnebi-2021-ii-turi---live
34.  Tbilisi City Assembly - Wikipedia, accessed on September 22, 2025, https://en.wikipedia.org/wiki/Tbilisi_City_Assembly
35.  პარლამენტმა „საქართველოს საარჩევნო კოდექსში“ ცვლილებებს მესამე მოსმენით მხარი დაუჭირა, accessed on September 22, 2025, https://www.parliament.ge/media/news/parlamentma-sakartvelos-saarchevno-kodeksshi-tsvlilebebs-mesame-mosmenit-mkhari-dauchira
36.  კანონპროექტის მიხედვით, 2025 წლის თვითმმართველობის არჩევნები ჩატარდება იმ წესით, რა წესითაც 2017 წლის თვითმმართველობის არჩევნები ჩატარდა - 1TV, accessed on September 22, 2025, https://1tv.ge/news/kanonproeqtis-mikhedvit-2025-wlis-tvitmmartvelobis-archevnebi-chatardeba-im-wesit-ra-wesitac-2017-wlis-tvitmmartvelobis-archevnebi-chatarda/
37.  2025 Georgian local elections - Wikipedia, accessed on September 22, 2025, https://en.wikipedia.org/wiki/2025_Georgian_local_elections
38.  როგორ ვაძლევთ არჩევნებზე ხმას ელექტრონულად - ვიდეოინსტრუქცია - 1TV, accessed on September 22, 2025, https://1tv.ge/news/rogor-vadzlevt-archevnebze-khmas-eleqtronulad-videoinstruqcia/
39.  Elections FAQ | Georgia Secretary of State, accessed on September 22, 2025, https://sos.ga.gov/page/elections-faq
40.  7 კვირა არჩევნებამდე - 17 პარტია პროცესში, "საერთაშორისო სტანდარტები" ეუთოს მისიის გარეშე - რადიო თავისუფლება, accessed on September 22, 2025, 3%94/33501192.html
41.  Untitled - უმაღლესი საარჩევნო კომისია, accessed on September 22, 2025, http://www.sec.ge/uploads/journal_7.pdf
42.  ხმების პარალელური დათვლის (PVT ... - isfed.ge, accessed on September 22, 2025, https://www.isfed.ge/geo/presrelizebi/211003034618khmebis-paraleluri-datvlis-PVT-shedegebi
43.  How to complain — Human Rights Guide, accessed on September 22, 2025, https://www.humanrightsguide.ge/en/themes/civic-participation/voting/how-to-complain
44.  ODIHR Final Report Reiterates Multiple Concerns over October 26 Elections, Calls for Concrete Action - Civil Georgia, accessed on September 22, 2025, https://civil.ge/archives/647319
45.  ODIHR electoral recommendations database, accessed on September 22, 2025, https://paragraph25.odihr.pl/search?page=1&projectBeneficiary=Georgia&yearOfElection=2016&yearOfElection=2024
46.  ეუთოს დემოკრატიული ინსტიტუტებისა და ადამიანის უფლებების ოფისი, accessed on September 22, 2025, https://www.osce.org/files/f/documents/8/8/578194_0.pdf
47.  INTERNATIONAL ELECTION OBSERVATION MISSION Georgia - Organization for Security and Co-operation in Europe | OSCE, accessed on September 22, 2025, https://www.osce.org/files/f/documents/3/0/579346.pdf

1. 48.  2025 | cesko, accessed on September 22, 2025, https://cesko.ge/ge/archevnebi/2025