Foreign agents law in Georgia: policy transfer from Russia or the West?

Foreign agent laws have become a recurring instrument of semi-authoritarian governments across Eurasia, raising questions about their origins and political purposes. This article examines Georgia’s 2024 ‘Law on Transparency of Foreign Influence’ through both discourse analysis of political debate and comparative analysis of legislative texts. The law provoked two sharply opposed interpretations. The ruling Georgian Dream government, supported by Russian officials, presented it as a moderate transparency measure modelled on Western practice and essential for safeguarding sovereignty. By contrast, opposition parties, civil society actors and Western leaders argued that it reflected Moscow’s influence, undermined Euro-Atlantic integration and enabled political repression. A comparison of Georgia’s statute with the US Foreign Agents Registration Act and Russia’s Foreign Agents Act shows that while it borrowed the transparency vocabulary from Western precedents, its institutional design and political effects aligned more closely with Russian practice. By 2025, most non-governmental organizations (NGOs) were refused registration and ceased operations, replicating the Russian trajectory. The findings demonstrate how contested policies can selectively draw on multiple models, highlighting the importance of hybridization and authoritarian learning in policy transfer research.