Status as at 7 September 2026. Status: In process (draft/bill). Instrument: Predlog zakona o izmjenama i dopunama Zakona o strancima (Bill amending the Law on Foreigners), EPA 1181 XXVIII, act no. 24-3/26-3, tabled by the Government of Montenegro on 1 September 2026 and routed to committee on 2 September 2026. The Act it would amend is the Zakon o strancima, "Sl. list CG" nos. 12/18, 3/19, 86/22, 77/24, 3/26 and 33/26.
For two years we have answered the same question the same way: Montenegro has no investment route to residence, and we set out why in does Montenegro have a golden visa. That answer is still correct today. A bill now sitting with two parliamentary committees would change one half of it, and the half it changes is decided by which passport you hold.
What the bill actually says
Article 8 of the bill inserts a new Article 70g, headed Zapošljavanje državljanina EU zbog investiranja u Crnoj Gori — employment of an EU citizen on account of investing in Montenegro. It sits immediately after Article 70v, inside the block of work-related permits, and it is drafted as a sub-type of the existing work ground rather than a new ground of its own.
| Item | New Article 70g as drafted |
|---|---|
| Who may apply | An EU citizen who is a preduzetnik (sole trader) or the owner of a company |
| Investment | At least 250,000 euros in Montenegro |
| What counts | Direct capital into a newly founded or existing company registered in Montenegro; or acquiring an ownership stake in such a company; or depositing funds in an escrow account until they are directed into an approved business venture, with proof of the origin of the money |
| Conditions applied | Article 43(1), points 4 to 8 only |
| Validity | Up to three years, extendable for a further three years |
| Extension filing | At least 30 days before expiry, to the Ministry where the holder stays |
| Extension evidence | Valid passport or an identity card issued by an EU member state authority, plus proof of realised investments |
| Family | Members of the immediate family may join for family reunification |
| Presence required | At least 15 days in Montenegro during the permit |
Read Article 43 against that list and something stands out. Points 4 to 8 are the passport, the absence of an entry ban, the absence of an unconditional prison sentence longer than six months in Montenegro and in the country of origin, and the absence of a national security or public health obstacle. Points 1, 2 and 3 — means of subsistence, secured accommodation, health insurance — are outside the reference. So is point 9, proof that the application is justified, because the €250,000 stands in its place. Every sibling article does it differently: Article 70a for the IT sector, Article 70b for healthcare and Article 70v for household work each require "the conditions of Article 43" without carving anything out.
The rest of the bill is about employers and carriers, and it applies to everyone. Article 1 defines nezakonito zapošljavanje and posebno iskorišćavajući uslovi rada — particularly exploitative working conditions — for the first time. Article 9 splits the penalty provision in two: a new Article 210 fines a company 3,000 to 15,000 euros for helping a foreigner enter, stay or transit unlawfully, a sole trader 3,000 to 12,000 and — the line owners of let property should read — a private individual providing accommodation services 1,000 to 4,000, with 2,000 to 4,000 for any other individual, and a new Article 210a fines an employer 1,000 to 10,000 euros across eleven listed breaches, with a ban on carrying on the activity for up to six months available on top. Both transpose Directive 2009/52/EC; the victim-protection articles transpose Council Directive 2004/81/EC. The Government asks for the urgent procedure under Rule 151, on the ground that this is a Chapter 24 obligation.
What the bill does not say
Four gaps matter for anyone pricing this route. The text sets no minimum shareholding for "owner of a company" — Article 70 uses a 51% threshold for the director route, and Article 70g does not repeat it. It does not say when the money must be in: paragraph 1 asks for proof of investing, paragraph 5 asks on extension for proof of realised investments, and the difference between the two is left undefined. It does not say who approves the "approved business venture" that escrow money is released into, or by what procedure. And it attaches no consequence to the 15-day presence rule; neither Article 83, which lists how a work permit ends, nor the new Article 210a mentions it, and the bill amends neither.
There is also a drafting slip worth flagging before anyone relies on paragraph numbering. Paragraph 5 opens "Uz zahtjev iz stava 3 ovog člana" — with the request from paragraph 3 of this Article — but in Article 70g paragraph 3 is the duration paragraph and the request is in paragraph 4. In Articles 70a, 70b and 70v the same sentence lands correctly, because there the request really is paragraph 3; inserting the definition of investment shifted the count by one. We record the wording as it stands and read no intention into it.
How we read it
Treat this as a bill and not a plan. It has been tabled, it has been sent to the Legislative Committee and to the Committee on the Political System, Judiciary and Administration, and nothing on the parliamentary file as at 7 September 2026 shows it adopted or amended. If it passes in this form it takes effect on the eighth day after publication in the Gazette, which means there is no calendar date to work back from yet.
If you hold an EU passport, the sensible use of the next weeks is preparation rather than filing: the origin-of-funds file, the company or escrow structure, and the question of what "realised" will mean at renewal. If you do not hold one, nothing in Article 70g reaches you, and the routes that do reach you are unchanged — property under Article 56, work or company directorship under Articles 69 and 70. The employer half of the bill, on the other hand, reaches you whatever your nationality, and it is the part we would read first if you have staff in Montenegro.
What did not change
Article 38(1) still sets a closed list of grounds for temporary residence, and the bill does not touch it: family reunification, schooling, exchange programmes, specialisation, research, medical treatment, humanitarian grounds, use and disposal of real estate you own (point 8), religious service, European Voluntary Service, statelessness, work (point 12), digital nomad residence (point 12a), and other cases under statute or treaty. Investment is still not a listed ground, which is why the drafters placed the new permit under work. Article 56's €150,000 tax-base test for the property route is untouched, as is the exemption in Article 56(5) for EU, Icelandic, Liechtenstein, Norwegian and Swiss nationals. So is the €5,000 tax-and-contributions test in Article 70(4), and its matching exemption in Article 70(8). Naturalisation runs under a different Act and is not affected.
How to verify
The parliamentary file is public. Open zakoni.skupstina.me/zakoni/web/app.php/akt/4354 and you will see two documents: the bill itself and the 2 September routing note. The bill is a scanned PDF; the wording quoted here is on pages 5 and 6, and the phrase to search for by eye is "najmanje 250.000 eura". The status field on that page is the one to watch — while it reads "U proceduri" the law does not exist. For the Act being amended, the consolidated text is published by the Government at wapi.gov.me; Articles 43, 56, 70 and 70a to 70v are the ones this bill sits against.
What is worth doing now depends on the passport, and the file that gets built is different in each case; our note on the residence permit routes and their evidence sets out the existing grounds as they stand today. We will follow this bill through committee and update this page with the adoption date and the Gazette number if and when it passes — that trail is kept in Legal Updates.
