Position dated 4 September 2026. Status: In force. Instrument: Zakon o izmjenama i dopuni Zakona o legalizaciji bespravnih objekata (Law amending and supplementing the Law on Legalisation of Unpermitted Buildings), Official Gazette of Montenegro 117/2026, published 7 August 2026, in force 15 August 2026. Base statute: Gazette 91/25 and 18/26.
When we published our checklist on the 14 August 2027 deadline we said plainly that we had not read the 117/2026 text in the original, and asked readers to have Article 48 confirmed before planning around it. We have now read it — not a press summary, but the text the Assembly adopted on 31 July 2026 and its President signed, filed as document 27-1/26-8/13. Two things came out of that reading: one date is confirmed, and one widely repeated rule is not in the law at all.
What the adopted text says
The amending law has three articles. That is the whole of it.
Article 2 is the one everyone is waiting for: in Article 48 paragraph 1 of the base statute, the words "u roku od 12 mjeseci" ("within 12 months") are replaced by "u roku od 24 mjeseca" ("within 24 months"). Nothing else in Article 48 is touched.
Article 1 rewrites parts of Article 14, which governs the commission that examines an unpermitted building. Its paragraph 5 previously required one member to be a representative of the Cadastre of geodetic profession; it now requires that one member be a licensed geodetic engineer. Paragraph 10 is restated so that commission members and the secretary have a right to remuneration. Then two new paragraphs are added, and the first of them is the one that costs you money: "Troškove izlaska na lice mjesta i pregleda bespravnog objekta snosi vlasnik bespravnog objekta" — the owner of the unpermitted building bears the cost of the site visit and the inspection. The second new paragraph leaves the Ministry to prescribe the record's content, the scope of the work, the amount of those inspection costs, and the remuneration of the commission.
Article 3 sets entry into force on the eighth day after publication. Published 7 August, in force 15 August 2026 — which matches the gazette's own entry.
How the clock actually runs
Article 48(1) of the base statute reads: the owner of an unpermitted building that is not registered in the real-estate cadastre must initiate the registration procedure "within [the period] from the day this law enters into force". The period is what the amendments keep changing; the starting point has never moved. The base statute was adopted on 31 July 2025 and enters into force on the eighth day after publication in Gazette 91/2025, which puts it at 14 August 2025.
| Instrument | Gazette | Period in Article 48(1) | Ends |
|---|---|---|---|
| Base statute | 91/25, in force 14 August 2025 | six months | 14 February 2026 |
| First amendment | 18/26 | twelve months | 14 August 2026 |
| Second amendment | 117/2026, in force 15 August 2026 | twenty-four months | 14 August 2027 |
| Cadastre annotations, Article 51 | 91/25, untouched | thirty-six months | about 14 August 2028 |
We did not need to re-read 18/26 to be sure of the middle row. Article 2 of the new law quotes the wording it replaces — "12 mjeseci" — so the statute itself records what the text said on the day it was amended.
What happens if the period is missed is in Article 48(2), and no amendment has softened it: for buildings where the registration procedure was not initiated in time, the space-protection inspector "dužan je da donese rješenje o uklanjanju objekta" — is obliged to issue a decision to remove the building. Note also that the Article 51 clock for the Cadastre's own annotations stayed at thirty-six months. The two dates have now drifted a year apart.
What the text does not say
It says nothing about incomplete filings. The claim circulating since early August — that the amendment removed the option of preserving the deadline with an incomplete request, so the as-built survey must go in with the request rather than after it — has no counterpart in the adopted law. The words "zahtjev", "nepotpun" and "elaborat" do not appear in it. We wrote that claim into our own checklist, attributed to reporting by investitor.me of 3 August 2026, and flagged it as unconfirmed. It is now confirmed as not being in this statute.
That is not the same as saying the practice does not exist. It may come from a ministerial rulebook, from a cadastre instruction, or the report may simply be wrong. We cannot show which today, and we will not guess. What we can say is that anyone relying on that rule should ask to be shown the provision it rests on.
Our reading
The date is safe to plan against; the cost is the thing to re-plan. Until this amendment the on-site inspection was part of the authority's process. It is now billed to the owner, at an amount the Ministry has yet to set — so for anyone holding an unregistered building the sensible move is to file early, while the fee is unfixed and the commission's calendar is empty, rather than in the queue that will form in the first half of 2027.
The second practical change is quieter. Requiring a licensed geodetic engineer on the commission rather than a Cadastre representative shifts who signs off on the survey side, and licensed engineers are a finite resource in a year when everyone files at once. If your building is one of those the July 2025 imagery decides, the survey work is the long pole; start it now. Our owner's checklist on the 14 August 2027 deadline sets out the filing itself, and we are updating its incomplete-request passage in light of this reading.
What did not change
Article 48(1)'s starting point is still the base statute's entry into force, not the date of any amendment: the twenty-four months run from 14 August 2025, not from August 2026. The evidentiary rule in Article 7 stands — a building not visible on the July 2025 satellite and aerophotogrammetric imagery cannot be registered, and Article 48(3) and (4) keep the prohibition and the annulment duty. Article 48(2)'s removal decision is unchanged. Article 51's thirty-six-month cadastre clock is unchanged. And this amendment does not create any general "legalisation application deadline"; Article 48 is about initiating cadastre registration for a building that is not registered.
How to verify
The adopted text is on the Assembly's own site, in the file for EPA 1097 XXVIII: zakoni.skupstina.me/zakoni/web/app.php/akt/4268. Open the last document in the list, numbered 27-1/26-8/13 and dated 31 July 2026 — that is the law as passed, and it is three articles long. Read Article 2 for the twelve-to-twenty-four-month substitution, and Article 1 for the sentence beginning "Troškove izlaska na lice mjesta". The base statute is in the file for EPA 600 XXVIII: zakoni.skupstina.me/zakoni/web/app.php/akt/3763, where Article 48 gives the period and Article 51 the thirty-six months.
If you want to see why the adopted text differs from the bill as tabled, the same file holds the trail: an amendment of 23 July was withdrawn on 30 July, a second was tabled the same day, and the committee accepted it in modified form on 31 July, at which point it became part of the bill without a separate vote. We follow this file as it develops under Legal Updates.
