Position dated 6 September 2026. Status: In force. Instruments: three pravilnici made by the Ministry of Economic Development under the Zakon o zanatstvu (Crafts Act), Official Gazette of Montenegro 128/2026 of 31 August 2026, register numbers 2232, 2233 and 2234, all signed on 27 August 2026 and all in force on 8 September 2026. The parent statute's gazette chain, as the pravilnici themselves recite it, is 54/09, 64/09 and 89/25.
The question that reaches us in this area is nearly always the same, and it is usually asked the wrong way round. Someone who repairs watches, tunes pianos, restores furniture or does photography wants to know whether they can register the activity in Montenegro and run it from the flat they already rent. The short answer is that a dwelling is now governed by a closed list of 27 trades, so for most people the answer is no. The longer and more useful answer is that a different pravilnik, on a subject that sounds purely technical, says a craft may be carried on without any business premises at all — and that rule is attached to no list.
What the text says
Pravilnik 2234 does the narrow job. Article 2 permits a craft in residential premises only if it appears in Prilog 1 and only if three conditions are met cumulatively: the work can be organised in a space that by its purpose is residential, with no need for special production conditions; the work rests predominantly on manual labour or the use of tools, being artistic or artistic-craft in character, or the making or finishing of small objects, or repair and maintenance carried out "without the use of industrial machines, devices or equipment of larger capacity"; and the process runs without any industrial or serial production. Article 3 adds four negative conditions, of which the fourth is the one neighbours enforce: the work must not impair the residential purpose of the space "nor the peaceful use of other special and common parts of the residential building".
Prilog 1 names 27 trades. Most are traditional — lacemaker, woodcarver, icon painter, maker of Montenegrin gold embroidery, maker and restorer of the gusle, furrier, saddler, hatter, basket weaver, wool carder, seal engraver. Two are not what a reader expects to find there: photographer and optician. Article 4 repeals the 2011 predecessor (gazette 37/11).
Pravilnik 2233 is where the wider rule sits. Article 13(5) provides that a craft "whose nature does not require permanent business premises and which is predominantly carried on at the service user's premises or in the field may be carried on without one's own business premises". Article 13(6) then settles the point that decides inspections: the customer's space "is not considered the craftsman's business premises". Article 13(7) applies the rules on equipment, materials, protective equipment, documentation and waste to that person, while the rules on business premises "do not apply to them". Nothing in Articles 13 to 15 restricts this to a list of trades.
| Element | Instrument and article | What it provides |
|---|---|---|
| Craft in a dwelling | 2234, Art. 2 and Prilog 1 | Only the 27 listed trades, three cumulative conditions |
| Neighbour protection | 2234, Art. 3(4) | No impairment of peaceful use of the building's parts |
| Craft without premises | 2233, Art. 13(5) | Permitted where the nature of the craft does not require them |
| Customer's space | 2233, Art. 13(6) | Not the craftsman's business premises |
| Register | 2232, Art. 3(1)-(2) | Electronic only, kept by the Chamber of Crafts |
| Change of data | 2232, Art. 6(2) | Notification within eight days |
| Second-hand equipment | 2233, Art. 12(3) | Written statement replaces proof of origin |
Pravilnik 2232 rebuilds registration around one address. Article 2(1) defines the electronic register as the platform at www.registarzanatlija.me; Article 3(1) makes it "the only operative form" of keeping the register, and Article 3(2) puts it in the hands of the Zanatska komora Crne Gore (Chamber of Crafts). Article 7 lists the fourteen recorded items, including the floor area of the premises in square metres and the CRPS activity code. Article 10(1) sets the attachments: for natural persons a valid identity card, for legal persons a CRPS extract no older than six months, and proof of payment of a fee to the local secretariat. Article 12(1) runs the application through two administrative phases — the local authority checks completeness and, where it matters for the application, whether the declared craft is one that may be carried on in residential premises, then passes the data to the Chamber, which performs the final verification and, for complex crafts, checks professional qualifications under Article 10 of the Act.
What the text does not say
Three gaps matter more than the rest, and we would rather name them than write around them.
The first is the identity document. Article 10(1) and Obrazac 1 both require "a valid identity card" from a natural person. Neither says what a foreign applicant without a Montenegrin identity card attaches instead — a residence card, a passport, or nothing. That answer is not in these three texts, and we have not read the Act's own provisions on who may register, so we cannot state it here.
The second is money and time. The fee is described only as "a fee to the local secretariat"; the amount lives in municipal decisions we have not read, so no figure appears in this note. Nor do these pravilnici give the Chamber a deadline to decide. Article 12(2) obliges the local authority to notify defects and set a period to cure them, but no article sets a period for the registration itself.
The third is a drafting fault worth knowing about before you rely on the privacy wording. Article 4(3) says data that is not publicly available is accessible only to authorised persons of the Chamber "and the bodies from Article 16 of this pravilnik". Article 16 is the commencement provision — a single sentence about the eighth day. The pravilnik has sixteen articles and none of them lists any bodies. The cross-reference has no target. Article 3(3) separately gives the Ministry its own access account, so the practical position is probably narrower than the drafting suggests, but on the face of the text the reference leads nowhere.
Our reading
If your activity genuinely travels — you go to the client, the site or the machine — read Article 13(5) of pravilnik 2233 first and treat the dwelling question as a distraction. The no-premises route is not conditioned on a list, and Article 13(6) removes the argument an inspector would otherwise make about the customer's address. What you keep instead is a documentary duty: Article 12(4) requires the paperwork on your equipment to be held at the premises or in electronic form and produced to the inspectorate on request, which for a person with no premises means it has to exist digitally and be reachable on the spot.
If you are buying tools rather than importing them with paperwork, Article 12(3) is the provision to remember. For second-hand, older or inherited equipment with no proof of origin, a written statement by the craftsman about its origin and technical soundness is enough, or a finding by an authorised person or service where periodic inspection is prescribed for that equipment. That is an unusually practical concession and it is easy to miss in a technical pravilnik.
And if you do fall inside the 27, note where the residential question is actually tested: Article 12(1)(1) of pravilnik 2232 puts it with the local authority at the first phase, not with the Chamber at the second. The dwelling argument is won or lost at the municipality. Where the structure sits alongside a company rather than a sole trader, our company formation page sets out how we work through the registration chain.
What did not change
These are implementing rules, not a new Crafts Act. The Act itself — its definition of who may perform a craft, its treatment of complex crafts and the qualification requirement in its Article 10 — is untouched by them and is referred to, not rewritten. Registration in CRPS remains a separate matter with its own decision, recorded in the craft register rather than replaced by it. Pravilnik 2233 Article 3(3) preserves every stricter regime: where a special law sets harder conditions for a particular craft, those conditions still apply. The hygiene and technical categories in Articles 21 to 24 — hairdressing, cosmetics, bakery, confectionery and butchery on one side, technical, service and construction trades on the other — carry the obligations they carried under the general law, including HACCP where food is handled. Only two older pravilnici fall away: gazette 76/10 and gazette 37/11.
How to verify
Open the issue itself at sluzbenilist.me/registri/397652 — "Službeni list Crne Gore, broj 128/2026" of 31 August 2026 — and take the three acts numbered 2232, 2233 and 2234 in the list. Each act page shows the gazette's own typeset pages; on 2234 the whole instrument is two pages, with Prilog 1 and its 27 entries on the second. The record for each gives publication on 31 August 2026 and entry into force on 8 September 2026, which matches the final article of each text requiring the eighth day.
One thing to check with your own eyes rather than through a search engine: the register address in Article 2(1) is registarzanatlija.me, not a gov.me address. When we opened it on 6 September 2026 it answered, but the page delivered nothing except the Chamber's title, so we cannot show from it that public search is working yet. A site that responds is not the same as a service that runs. We follow this file under Legal Updates.
