Status as at 9 October 2026. Status: In process (draft/bill). Instrument: Predlog zakona o strancima (Bill on Foreigners — a complete new Act, not an amendment), EPA 1219 XXVIII, act no. 24-3/26-4. The Government fixed the text on 8 October 2026 without a sitting, by written consent of a majority of ministers under Article 10 of the Decree on the Government, and sent it to parliament the same day asking for the urgent procedure. The Act it would eventually replace is the Zakon o strancima, "Sl. list CG" nos. 12/18, 3/19, 86/22, 77/24, 3/26 and 33/26.
A 174-page bill called "Law on Foreigners" lands on the parliamentary website, and the question we get within hours is the obvious one: does my residence permit change, and when? The answer sits in a single sentence at the very end of the text, and it is shorter than most people expect.
What the bill says
Article 278 is the only article in the bill's final chapter. It reads, in our translation: this Act enters into force on the eighth day after publication in the Official Gazette, "and shall apply from the day of Montenegro's accession to the European Union". Every rule in the 278 articles is therefore parked until a date the bill does not set and nobody can set by statute. Adoption, if it comes, gives Montenegro an EU-shaped immigration code on paper. Your permit file is still decided under the current Act.
Read against today's law, the provisions most of our readers rely on look like this:
| Topic | Current Act (applies today) | Bill EPA 1219 (applies from EU accession) |
|---|---|---|
| Residence through property | Art. 56: ownership or at least 1/2 co-ownership, tax-base ruling of at least €150,000, EU/EEA and Swiss nationals exempt from the value test | Art. 70: same wording, same €150,000, same exemption |
| Absence abroad during a temporary permit | Art. 65(1)(3): permit ends after more than 30 days outside Montenegro | Art. 88(1): no absence ground among the four listed |
| Permanent residence | Art. 86: five years; absences up to 10 months in total or once up to 6 months | Art. 158: five years; each absence shorter than 6 consecutive months and no more than 10 months in total |
| Short stay | 90 days in 180 | Art. 41: 90 days in any 180, counted under the Schengen Borders Code |
| Work | Separate residence and work permit | Art. 89: single permit, up to one year, renewable for up to two |
Some of the new material reads straight from EU directives: the EU Blue Card, intra-corporate transfers, researchers' mobility, a long-term resident permit labelled "rezident za dugotrajni boravak – EZ" (Art. 165). Under Article 87(2) a single permit is not withdrawn merely because the job ended, unless unemployment has run longer than three months (or six, after two years in the country). Article 167 ends permanent residence after 12 consecutive months outside the EU, or six years outside Montenegro.
What the bill does not say
The text contains no clause repealing the current Act and no transitional provisions. We searched it end to end; the last chapter is Article 278 and nothing else. So the bill does not tell you whether a permit issued under Article 56 today becomes an Article 70 permit on accession day, whether the count towards permanent residence carries over, or what happens to an application pending on that date. We would expect parliament or the Government to fill that gap by amendment. We cannot show that it will.
The bill also does not carry the €250,000 investment permit for EU citizens that the separate amending bill EPA 1181 would add as Article 70g. Neither "250.000" nor "investiranje" appears anywhere in the new text. EPA 1181 is still in procedure and, if adopted, would amend the current Act, the one that applies until accession.
How we read it
Plan under the current Act. The 30-day absence rule in Article 65 still decides whether your temporary permit survives a long trip, and nothing in this bill softens it before accession. If you hold property, the €150,000 tax-base ruling remains the document that carries the file, both now and in the text that would follow. For anyone thinking past accession, the useful signal is continuity: the property ground survives the rewrite almost word for word, and the absence rule that most often catches owners is not repeated.
What did not change
Today, nothing in the law you are dealing with has changed. The current Act applies in full; the visa decree's 1 November 2026 changes run on their own track; naturalisation is a separate Act. The bill's closed list of temporary-residence purposes in Article 45 still has no investment ground — property is point 9, the digital nomad permit point 12, work point 13. The digital nomad permit in Article 80 keeps two years plus two and the six-month gap before a new one, and permanent residence still requires basic knowledge of the Montenegrin language (Article 160).
How to verify
Open the parliamentary file at zakoni.skupstina.me/zakoni/web/app.php/akt/4392. The "Status" field reads "U proceduri"; it will change to "Usvojen" if the bill is adopted. The scanned bill is the first document; a searchable version is the Government's own file at wapi.gov.me — search "danom pristupanja" for Article 278 and "150.000 eura" for Article 70. The current Act is at wapi.gov.me; compare its Article 65 with Article 88 of the bill.
If your file is moving now, it is moving under the current rules, which we set out on our residence permit services page; the earlier EU-only €250,000 bill explains the other text in parliament. We will follow EPA 1219 through committee and record each step in Legal Updates.
