The 299(c) freeze: an appeal that keeps paying
Georgia reassesses property annually, and each spring the county mails an Annual Notice of Assessment that opens a 45-day appeal window. What many owners do not know is what happens to the value after an appeal concludes.
Under O.C.G.A. 48-5-299(c), when a value is established through the appeal process, that value is generally frozen for the next two tax years as well, three years of certainty in total. The freeze can be lost if the property changes, for example through additions or a change in use, or if the owner files a return asking for a different value, but for a stable building it means a resolved appeal sets the number for three years.
For commercial owners this changes the math on appealing. The question is not only whether this year's value is too high, but whether locking a defensible value for three years is worth establishing now, particularly in counties that have been raising commercial values aggressively. It is also why the year the freeze expires is worth putting on a calendar: counties commonly revalue when the freeze comes off.
Two honest cautions. First, the freeze follows a completed appeal process, and the board of equalization that hears Georgia appeals may increase, decrease, or leave a value unchanged under O.C.G.A. 48-5-311, so filing without evidence carries real exposure. Second, the freeze holds the value, not the tax: millage rates still move every year.
HB 581: the floating homestead exemption
House Bill 581, passed in 2024 alongside a statewide referendum, created a statewide floating homestead exemption beginning with the 2025 tax year. For homesteaded property, it effectively caps how fast the assessed value can rise each year, tied to an inflation rate, so a hot market no longer flows straight through to a homeowner's assessment.
Three things to understand about its limits:
- It applies to homestead property. Commercial buildings, rental property, and second homes are outside it. For non-homestead property, the annual notice and the 45-day appeal window remain the whole game.
- Counties, cities, and school districts could opt out through a public process in early 2025, and a number did. Whether the exemption applies to your home depends on what your county and school district decided, and their notices reflect it.
- It caps growth, not level. If the starting value is too high, the cap preserves a too-high number. The way to challenge the level remains the appeal process.
The bill also allowed local governments that keep the exemption to adopt a new local sales tax, called FLOST, to offset property tax revenue, which is why some owners saw sales tax questions on 2025 ballots.
What this means in practice
For a commercial owner, HB 581 changes little directly, but it changes the environment: with homestead growth capped in many counties, the pressure to find revenue can shift toward commercial values, which makes reviewing the annual notice more important, not less.
For any owner, the 299(c) freeze is the quiet asset in the Georgia system. A value established on evidence holds for three years while neighboring parcels float with the market.
When your Annual Notice of Assessment arrives, check the value, not just the estimated tax, and note the 45-day deadline printed on it. If you want the value checked against the county's own records inside the window, start a free analysis. If the number is already fair, we will tell you, and nothing gets filed.
More on the process end to end in the Georgia guide, and county dates in the deadlines reference.