When is this template used, and who is it sent to?
The template is useful when a public agency has fully refused your funding application, approved less than you asked for, or not answered at all within the time limit set by law. Under Article 177 of the Code, a breach of the time limit for issuing an act is also treated as a refusal, so the same structure is used for silence, with a small change.
The addressee is determined by Article 178. Unless another rule applies, the complaint is reviewed by the body that issued the act, if it has an official senior to the official or unit that issued the act; for an act of the head of the body, it is reviewed by the higher body. In practice, the simplest step is to look at the text of the refusal: the Code obliges the agency to state in the act where and within what time limit it can be appealed. If that statement is missing, this too is an argument for your complaint, and you should confirm the addressee with a lawyer.
The template is not intended for a refusal by a private insurance company or clinic: such a dispute is resolved in another way, which we cover on the insurance disputes page. For a decision of the referral commission, first and foremost follow the appeal route stated in the decision.
What should you prepare before you start writing?
A good complaint starts with documents, not with text. Before you fill in the template, you should have the following to hand:
- A copy of the refusal. Under Article 181, if the act was handed to you, a copy of it must be attached to the complaint.
- Proof of the date of notification. An envelope, email, SMS or signed receipt showing when you learned of the refusal. The one-month deadline runs from that day.
- Your original application and its registration number, so that it is clear what you asked for and what you submitted.
- The case file. Under Article 99, a party to the proceedings may inspect the case file and request copies, and no fee or obstacle is allowed other than the actual cost of copying and sending. If the refusal is based on an expert opinion or assessment, request it before you prepare the complaint.
- New evidence, if you have any: an updated Form 100, a doctor's opinion, a refusal from another source, a revised cost estimate. A document in a foreign language needs a Georgian translation, which we prepare under the rules for court and legal document translation.
Administrative complaint template
Replace the highlighted fields, and of the conditional phrases in brackets keep the ones that fit your case. The points of the template follow the mandatory elements of Article 181 of the Code. The complaint itself is submitted in Georgian: the Georgian version of this page (language switch at the top) has the original text to copy.
[name of the body that reviews the complaint]
[address of the body]
Complainant: [first name and surname], personal number [personal number], address [address at which you will receive the decision], phone [phone], email [email]
(If you act on behalf of the patient) Patient: [patient's first name, surname and personal number]; grounds for representation: [power of attorney, parenthood or legal representation]
Administrative complaint
on declaring null and void [name of the issuing body]'s [date] No. [number] [type of act: decision, minutes, letter] and on issuing a new act
1. The act appealed. On [date] I submitted an application (registration No. [number]) for funding of [name of the service]. [issuing body], by [date and number of the act], [refused it in full / granted the request in part, in the amount of ...]. I was officially notified of the act on [date of notification] [by post, email, SMS or in person]; accordingly, I am submitting the complaint within the time limit set by Article 180 of the General Administrative Code.
(If the agency is silent, instead of point 1) A decision on the application submitted on [date] (registration No. [number]) should have been taken by [last day of the time limit], but no act has been issued to date. Under Article 177(2) of the Code, this is deemed a refusal to issue an act, and under Article 180(3) no time limit for appeal applies in this case.
2. Factual circumstances. [briefly and in chronological order: diagnosis, doctor's recommendation, service, its cost, which documents you submitted and what another source covered].
3. Why I consider the act unlawful:
a) the act states as the reason for refusal [the reason for refusal, as written in the act], which does not correspond to [provision or fact], because [your argument and the document that proves it];
b) (if applicable) the act contains no written reasoning or does not name the provision on which it was issued;
c) (if applicable) before refusing, the agency did not give me the opportunity to comment on the information on which the refusal is based;
d) (if applicable) I attach [new document], which confirms [what it confirms].
4. (If waiting is dangerous) According to the treating doctor's opinion of [date], postponing [service] [doctor's assessment]; I ask you to review the complaint as quickly as possible.
5. Demand. I request that:
a) [name, date and number of the act appealed] be declared null and void [in full / in part, in respect of ...];
b) a new individual administrative act be issued under which [service] is funded [in full / in the amount of ...].
6. Procedural requests:
a) on the basis of Article 99 of the Code, that I be given the opportunity to inspect the case file and be provided with copies of [list of documents, for example the expert opinion];
b) [that the complaint be reviewed at an oral hearing, the time and place of which I am notified of in advance / I agree to the complaint being reviewed without an oral hearing];
c) (if the deadline has been missed) on the basis of Article 180(4) of the Code, that the time limit for appeal be restored, because [good reason], as confirmed by [document].
Attachments:
1. Copy of the act appealed;
2. Document confirming the date of notification of the act;
3. Copy of the original application with its registration number;
4. [Form 100, doctor's opinion, cost estimate, reply from another source, power of attorney, translation].
Date: [day, month, year]
Signature: [complainant's signature]
How do you fill in the template?
Name the act precisely in the heading
Copy the body, type of act, date and number exactly as they appear in the document. If it has no number, give the date and who signed it; this is a requirement of Article 181, not a formality.
Prove the deadline in point 1
Write the date of notification and its source in one sentence and attach the proof. With this sentence you answer in advance a body that might refuse to review the complaint as out of time.
In point 3, answer the refusal, not the situation
First quote the reason for the refusal, then explain why it is wrong, and finally the document that proves it. One argument per sub-point. Article 181 allows you to rely on the provisions of the European Convention on Human Rights and on the case law of the Strasbourg Court as well, but make such references only in agreement with a lawyer.
Set out the demand in two parts
Having the act declared null and void will not bring you money on its own; that is why the second sub-point asks for a new act to be issued, with the specific service and amount. For a partial grant, ask for the act to be declared null and void only in respect of the refusal.
Choose the form of review
Under Article 199, the body may review a complaint without an oral hearing when there are grounds for refusing a hearing or all parties agree. If the case is complex and you need to explain it, ask for a hearing; if time matters more, give your consent in writing.
Hand it in and register it
Bring the complaint in two copies or send it through the official electronic channel; your copy must bear the registration number and date. Under Article 204, no state duty or other charge may be imposed for reviewing a complaint.
How do you adapt the template to different situations?
| Situation | What to change in the template | Provision |
|---|---|---|
| Full refusal | The template as is; full funding in the demand | GAC, Article 181 |
| Partial grant | The approved amount in point 1; in the demand, annulment only in respect of the refusal and funding of the difference | GAC, Article 203 |
| The agency is silent | The silence variant instead of point 1; issuing of the act in the demand; a copy of the application instead of a copy of the act | GAC, Articles 177, 180 |
| You missed the deadline for a good reason | Sub-point "c" of point 6 and a document proving the reason, for example a hospitalisation certificate | GAC, Article 180 |
| A representative writes the complaint | The third paragraph and a copy of the power of attorney in the attachments | GAC, Article 181 |
GAC: General Administrative Code of Georgia. The rules of a specific programme may set their own deadline or appeal body; in that case they take precedence.
What are the most common mistakes?
- Counting the deadline from the date of the act. The one month runs from official notification. Counting from the date of the act rushes you unnecessarily, while forgetting the day of notification can, on the contrary, make you miss the deadline.
- "Please reconsider" instead of a specific demand. The body can amend the act, declare it null and void or declare it invalid; if you do not write which you want, the outcome will be unclear too.
- A new document is mentioned but not attached. Every document on the list of attachments must be in the package.
- Hoping that the complaint suspends the refusal. Under Article 184, a complaint normally suspends the act being appealed, but not where suspension would increase state or municipal expenditure. In a funding case, filing a complaint does not by itself release any money.
- Going straight to court. Under Article 2 of the Administrative Procedure Code, except for exceptions provided by law, the court will not accept a claim if you have not used the opportunity to file a complaint once.
- One complaint in two places. Under Article 182, the body will not review a complaint if proceedings on the same issue are already under way at a higher body, or a case on the same dispute between the same parties is pending in court.
What happens after the complaint is filed?
The body decides whether to accept the complaint within 5 days and, before refusing to accept it, must give you the opportunity to comment. It reviews the complaint itself within one month; if more time is needed to establish the circumstances, it must take a reasoned decision to extend the time limit within 7 days of the start of the proceedings and notify you immediately, and the extension may not exceed one month. The decision on the complaint is itself an individual administrative act.
If you are not satisfied with the outcome, or the body has missed the review deadline, you file a claim in court within one month of notification of the decision or of the deadline expiring. The types of claim and interim orders are described in the guide to appealing a refusal. If the refusal was based on a defective package, consider a corrected application in parallel: for the referral commission, the application template will help, and the programme rules are in the referral programme guide.
Frequently asked questions about the complaint template
Can the template also be used against a refusal by the referral commission?
The structure works, but you need to confirm the addressee and the route first. The commission is set up within the Solidarity Fund, which is a non-commercial legal entity, and assessing the legal nature of its decision and which body reviews a complaint against it is a matter for a lawyer. First read what the decision says about appeals and follow those instructions. If there are no such instructions, file the complaint within the deadline with the body that notified you of the decision, and at the same time ask where it should be reviewed.
Can I send the complaint by email?
The Code requires a complaint to be in writing, and what matters is that the fact and date of filing can be proven. Many agencies have an official electronic channel that assigns a registration number automatically; where such a channel exists, use it. If you send it by ordinary email, attach a scanned copy of the signed complaint and ask for confirmation of receipt. In the last days of the deadline, the most reliable options are handing the complaint in person or sending it by registered post, because in both cases the date is recorded in a document.
The refusal is very short and gives no reason. What should I write in point 3?
That is your first argument. The Code requires a written individual act to state its reasons, including the provision on which it was issued. Sub-point "b" of the template is meant for this case. At the same time, use point 6 to request access to the case file and copies: the real reason for a refusal is often in an expert opinion or an assessment document, and under Article 53, where the law provides for an expert opinion, its content must be reflected in the reasoning of the act. If you receive the materials before the complaint is reviewed, you can submit additional comments, because the body is obliged to give you the opportunity to express your opinion.
If I made a mistake in the complaint, can I correct it?
Yes. Until the body takes its decision, you can submit additional comments and documents in writing, quoting the registration number of the same case. The Code obliges the body to give the interested party the opportunity to express its opinion. What matters is that you file the addition separately, with a clear heading, and do not give the impression that you are sending a new, independent complaint, because parallel proceedings on the same issue can become a ground for not reviewing the complaint. If the mistake concerns the deadline or the addressee, it is better to consult a lawyer immediately.
Will the complaint be upheld if I use the template?
No template can guarantee that. It ensures that the complaint is formally complete and that the body finds no reason to leave it unreviewed, but the outcome depends on the strength of your arguments and documents. If the programme does not cover your service at all, a complaint rarely changes the outcome and another source is more realistic. You can ask a lawyer to compare the text of the refusal and your package with the programme rules and tell you whether a dispute is worth it.
Sources and official pages
- General Administrative Code of Georgia (Articles 52-53, 99, 101, 177-184, 194, 199, 202-204): matsne.gov.ge/ka/document/view/16270 (accessed 2026-10-12)
- Administrative Procedure Code of Georgia (Articles 2, 22): matsne.gov.ge/ka/document/view/16492 (accessed 2026-10-12)
- Government of Georgia Resolution No. 321 of 2022, on the referral commission at the Solidarity Fund: matsne.gov.ge/ka/document/view/5494642/0 (accessed 2026-10-12)