Operators researching a Montenegrin gaming licence still find guidance describing a concession granted by contract. That model was abolished in 2025, the replacement is an administrative approval, and the transitional period for moving from one to the other expired earlier this year.
Article numbers below come from the Zakon o igrama na sreću, adopted by the Skupština on 31 July 2025, promulgated on 1 August 2025 and published in "Službeni list Crne Gore" br. 091/25 of 6 August 2025, read on 5 September 2026.
A source caveat we are putting up front rather than in a footnote. The consolidated edition we read carries an express publisher's note: because of the redesign of the Official Gazette's website, the electronic edition signed with an advanced electronic signature can no longer be downloaded, and the text presented is informative in character, created from hard-to-read images of Official Gazette no. 91 of 6 August 2025 as displayed on the Gazette's site on 11 August 2025 — with the note adding that the exact text, page number and publication date will be updated when the printed form appears. We have therefore treated the substantive provisions below as reliable enough to describe the architecture and to quote figures, and we would verify any single figure against the printed Gazette before it is relied on in a filing. That is a limitation of the public source, not of the statute.
What actually changed
Article 107 repealed the previous Zakon o igrama na sreću ("Službeni list RCG" br. 52/04, and "Službeni list CG" br. 13/07, 61/13, 37/17, 3/23 and 125/23) on the day the new Act entered into force. Article 108 brought the new Act into force on the eighth day after publication.
Under the old regime, the right to organise games was granted by a concession contract. Under the new one it is granted by an approval — a decision of the Government or of the administrative authority, depending on the game. That is not a change of label. A concession is negotiated and contractual; an approval is applied for, granted on statutory conditions, entered in a register and capable of being withdrawn under the Act.
Who may hold an approval, and who issues it
Article 21(1) confines the activity to joint-stock companies and limited liability companies with their seat in Montenegro whose principal activity is gambling and betting, meeting the conditions the Act prescribes. A foreign operator does not obtain a Montenegrin approval as a foreign entity; it incorporates, and the corporate purpose has to be right.
The issuing authority splits by game type:
| Game | Approval issued by |
|---|---|
| Casino games | The Government, on the Ministry's proposal (Art. 21(2)) |
| Betting games and games in slot clubs | The administrative authority for games of chance (Art. 21(4)) |
Article 21(3) has the Ministry's proposal built on documentation prepared by the administrative authority. Article 21(5) then adds a step operators frequently miss: after the approval is issued, the authority issues a separate decision for each reported location. The approval authorises the activity; the location decisions authorise the premises.
Article 21(6) requires the authority to keep an electronic register of operators entered on the basis of an approval, with entry and removal made ex officio under Article 21(7). Article 21(8) preserves the special conditions as to premises, staff and equipment prescribed by law, on top of the general conditions.
The capital thresholds, and the deposits that sit behind them
The Act sets a separate minimum share capital for each activity, requires it to be maintained throughout the validity of the approval, and — this is the provision that changes the arithmetic for a multi-vertical operator — requires the capital to be held cumulatively where the operator holds rights for more than one game.
| Activity | Minimum share capital | Ongoing deposit |
|---|---|---|
| Casino (Art. 34) | €250,000 | Daily risk deposit in the casino cash desk of at least €150,000 for seven tables, plus €30,000 for each further five tables (Art. 34(4)) |
| Betting (Art. 50) | €200,000 | Daily risk deposit of at least €300 per betting shop on each day games are organised (Art. 50(4)) |
| Games in a slot club (Art. 62) | €200,000 | Daily cash-desk deposit where the club has electronic roulette |
| Closed-type tombola (Art. 75) | €75,000 | Monthly return with the final calculation of results, due by the 15th of the current month for the previous month (Art. 75(3)) |
Articles 34(3), 50(3) and 62(1) each carry the same cumulation rule: an operator entitled to organise another game under Article 6(1) must also hold the prescribed capital for that other game. Two verticals therefore mean two capital requirements, not the higher of the two.
The 150-metre rule, and who has to prove it
Article 22(1) prohibits premises where lottery games and special games of chance are organised from being less than 150 metres from educational institutions — primary and secondary schools, schools for artistic education, education and resource centres, and student dormitories.
Article 22(2) defines how that distance is measured, and the definition is stricter than a walking route: it is the straight air line from the nearest point of the institution's building to the nearest entrance to the premises where the games are organised.
Article 22(3) places the evidential burden on the operator: the report establishing compliance is drawn up and certified by a licensed geodetic organisation engaged by the operator. Article 22(4) allows the authority, when issuing the approval, to order an expert survey on the point.
For anyone selecting a site, that sequence reverses the usual order of work. The geodetic report is not a formality produced after the lease is signed; it decides whether the lease is worth signing.
Online gaming carries a fixed monthly fee, not only a revenue share
Article 79 requires an operator of internet games to notify the authority of the games it organises online and to submit the rules for each such game; under Article 79(4), the operator may begin only after the consent and the decision for organising internet games have issued. Article 80 prohibits organising internet games without the authority's approval.
Article 83 sets the fees, and the structure is the same for two verticals:
- Online betting (Art. 83(1)–(3)): a fixed part of €10,000 per month, payable by the 15th of the month for the current month; plus a variable part of 15%, calculated monthly on a base consisting of total stakes less payouts, payable by the 15th of the month for the previous month.
- Virtual casinos and virtual slot machines (Art. 83(4)–(6)): a fixed part of €10,000 per month on the same due date, plus a variable part of 15% on the same base and the same due date.
Article 83(7) requires the monthly record with the final calculation of results, and proof of payment of the monthly fee, to be delivered to the authority in both electronic and printed form by the 15th of the month for the previous month.
The fixed component is what changes the business case. An online operator pays €10,000 a month per vertical regardless of turnover, so the break-even calculation for entering the market is not a function of margin alone.
The transition — and why it is already behind us
This is the part that dates most published guidance.
Article 105(1) required companies whose principal activity is gambling and betting to align their operations with a listed set of provisions — including Articles 5, 14, 15, 22, 27, 28, 61, 82, 84 and 85, Article 20(1) point 26, Article 32(10) and Article 48(1) point 4 — within 270 days of entry into force. Article 105(2) required them to apply to the authority for an approval under the new Act at least 90 days before that period expired.
Article 106 dealt with the concessions themselves, in three steps. Companies holding a concession under the old Act could continue for at most 270 days from entry into force (Article 106(1)). Concession contracts whose term expired inside that window were deemed extended to the end of it (Article 106(2)). And after the 270 days, concession contracts concluded under the old Act are deemed terminated (Article 106(3)). Article 106(4) gives casino operators who paid a one-off fee under a concession a right to a proportionate refund for the period from obtaining an approval under the new Act to the end of the concession term.
Article 104 completes it: proceedings begun before entry into force are concluded under the new Act, not the old one.
Applying Article 108 to the publication date of 6 August 2025 puts entry into force on 13 August 2025. On that basis the 270-day period ran to about 10 May 2026, and the Article 105(2) application deadline fell around 9 February 2026. We set out the arithmetic rather than only the result, because it depends on the publication date carried by a source that its own publisher describes as informative — but on any reading of Article 108, both dates are in the past as at September 2026.
The practical consequence for anyone entering the market now is twofold. There is no concession to acquire — an acquisition structured around taking over a legacy concession contract is buying an instrument the statute treats as terminated. And because Article 104 sends even proceedings begun before entry into force to be concluded under the new Act, there is no residual route by which an old-regime application matures into an old-regime right.
That also changes what due diligence on a target looks like. The question is no longer what the concession contract says and how long it has to run; it is whether the target holds an approval issued under this Act, whether the Article 21(5) location decisions exist for every site it operates, whether it is entered in the Article 21(6) register, and whether the Article 34, 50, 62 or 75 capital has been maintained rather than merely subscribed at the outset.
One thing we are not attributing
The Government's document register also carries a Proposal of a Law amending the Law on Games of Chance, together with an opinion on it, proposed amendments and conclusions. We have not read that Proposal for this page and we attribute no change to it. Anyone structuring an entry should check whether it has been promulgated before fixing figures.
Before you commit to a site or a corporate structure
If you are assessing a Montenegrin gaming entry — casino, betting, slot clubs or online — send us the intended verticals, the corporate structure you are considering, and any site you are looking at, and we will map which approval route under Article 21 applies, what Articles 34, 50, 62 and 75 require in aggregate capital for that combination, whether the site can satisfy Article 22 before a lease is signed, and what Article 83 means for the monthly cost of an online vertical. The banking side of these files is the one that usually decides timing, and it is set out in why a crypto company cannot get a bank account; the adjacent licensing regimes are in Montenegro's crypto register and payment institutions and e-money; and how we run licensing files sits with our fintech, crypto and financial licensing practice.
