British employers sending staff to Montenegro tend to ask the permit question first. It is the wrong first question, because the permit answer is unremarkable and the contributions answer is not.
Montenegro sits on HMRC's list of countries with a reciprocal social security agreement. That means a UK employer sending an employee to work temporarily in Montenegro may be able to keep that employee paying UK National Insurance rather than contributing in Montenegro — and there is a specific form for it.
UK nationals were recorded at 156 workers in Montenegro in 2025, within a foreign workforce of 40,567 from 107 countries.
Legal position stated as at 3 September 2026.
The reciprocal agreement, and where Montenegro sits on the list
HMRC maintains a list of countries with which the UK has a reciprocal social security agreement. Montenegro appears on it, among the republics of the former Yugoslavia — the agreement is inherited rather than newly negotiated, and it sits alongside Bosnia-Herzegovina, Croatia, North Macedonia and Serbia on the same footing.
The practical effect HMRC describes is direct: where you send an employee to work temporarily in one of these countries, they may be able to continue paying contributions to the UK instead of to the country they are sent to.
The form: CA9107
The instrument that evidences this is a Certificate of Coverage, issued by HMRC on application using form CA9107.
Three points about it are worth internalising before a mobilisation:
- It is applied for, not assumed. Being on the list creates eligibility; the certificate creates the evidence. An employee working in Montenegro without one is not automatically protected by the agreement in a dispute about where contributions were due.
- It is evidence for both sides. Its function is to demonstrate to the Montenegrin authorities that the terms of the agreement apply, which is exactly what you want in hand before a labour inspection rather than after one.
- It depends on the posting being genuinely temporary. The agreement addresses temporary working, not the permanent staffing of a Montenegrin operation by people notionally on a UK payroll.
Where Brexit does and does not change the analysis
British employers frequently reason by analogy to the EU position, and the analogy misleads in both directions.
It does not help. UK nationals hold no EU-derived rights in relation to Montenegro, and Montenegro is in any case not an EU member state, so there is nothing there to inherit. Under Article 66(1) of the Zakon o strancima, work is permitted only on a residence-and-work permit or a work registration certificate. There is no exception for UK nationals, and none for EU nationals either — so the comparison offers no advantage in either direction.
It does not hurt, on the point that matters most. The reciprocal social security agreement with Montenegro is a bilateral instrument inherited from the former Yugoslavia. It does not depend on EU membership and Brexit did not disturb it. On the contributions question, a UK employer is in the same position now as before.
Entry is again a separate question from work. Whatever the visa position for a British passport-holder, Article 34 governs stays of up to 90 days in any 180-day period; it is a stay rule, and it confers nothing on the work side.
The basis decision, which the certificate does not resolve
The Certificate of Coverage answers where contributions are paid. It does not answer on what basis the person may work, and those are separate questions under Montenegrin law.
Three bases exist and only one leaves the quota untouched:
| Basis | Provision | Consumes quota? |
|---|---|---|
| Residence-and-work permit — employment, seasonal, posted worker | Art. 40(3) | Yes |
| Work registration certificate — up to 90 days in one year, listed categories | Art. 85 | No |
| No permit or certificate at all — eight listed situations | Art. 67(1) | No |
For UK activity in Montenegro the Article 85 route deserves a hard look before a quota case is filed by default. It covers, among others, a founder, member of a management or governing body or executive officer of a company, and services requiring higher education or specific specialist knowledge and experience with prior consent of the competent authority. A short supervisory or technical deployment frequently fits, and it does not draw on the 2026 quota of 28,988.
Documents
The UK and Montenegro are both parties to the 1961 Hague Apostille Convention — Montenegro by succession, in force 3 June 2006 — so an apostille is sufficient for UK public documents. Certified translation into Montenegrin is a separate step.
The Montenegrin half, briefly
The filing mechanics, the quota, the eight no-permit situations under Article 67(1) and the full Article 85 list are set out in our guide to foreign worker employment in Montenegro and the quota page.
Sequencing
- Apply for the CA9107 certificate as soon as the posting is decided. It is evidence you want before arrival, not after.
- Decide the Montenegrin basis — Article 85 certificate or a permit under Article 40(3). This is the quota question.
- Apostille and translate any documents the file needs.
- The Montenegrin permit (for permit bases), then the contract-and-insurance registration within 24 hours of issuance, counted from the permit date rather than the arrival date.
What this page does not tell you
It does not set out the scope of benefits under the inherited agreement, which is narrower in older instruments than in modern ones — for what the agreement covers beyond contributions, take advice. It does not tell you the maximum period of temporary working; that is a matter for HMRC and the agreement. And it does not decide the Article 85 question, which turns on the substance of the engagement.
RoNa Legal is a registered employment intermediary under activity code 78.10 and a legal adviser. We do not supply, lease or second workers, and we are not an employer of record. We build the Montenegrin file and coordinate with licensed agencies where the structure requires one.
Send us the engagement structure before staff travel — the contributions decision and the basis decision are separate, and getting one right does not fix the other. Our services are set out on the services page and a file can be opened through the contact page.
More on the employer side: how the annual work permit quota is allocated, hiring Italian staff, hiring Chinese workers and our work permit and recruitment service.
