Status date: 18 October 2026. Status: Practice observation. Instrument: Zakon o strancima (Law on Foreigners), Articles 56(4)-(5) and 217b, both inserted by Zakon o izmjenama i dopunama Zakona o strancima, Official Gazette of Montenegro (Službeni list CG) no. 3/2026, published 9 January 2026, in force since 17 January 2026. The statutory text is in force. The practice described below is not based on a published instruction: it is what refusal reasons and conversations with the administration show. We have not seen a dated ministry document announcing it.
If you bought a flat or a house in Montenegro and obtained temporary residence on that basis before 17 January 2026, you renew the card every year. The €150,000 threshold introduced in January was not written for your renewal, and the Act says so in a separate article. Recently, practice has moved away from that article. For owners who hold Turkish, Russian, Belarusian or Saudi passports the calendar is tighter still, because the visa decree's visa-free period for those nationalities ends on 31 October 2026.
What the Act says
The value requirement sits in Article 56(4): "Dokaz o vrijednosti nepokretnosti iz stava 1 ovog člana je rješenje o utvrđivanju poreza na promet nepokretnosti koje izdaje organ lokalne uprave nadležan za naplatu poreza, čiji iznos osnovice za oporezivanje nije manji od 150.000 eura." In English: proof of the property's value is the real-estate transfer tax assessment issued by the local-government body responsible for collecting the tax, with a tax base of not less than €150,000. It is the municipality's assessed base that counts, not the price in your contract. Article 56(5) exempts citizens of EU member states and their family members of any nationality, and citizens of Iceland, Liechtenstein, Norway and Switzerland.
The same amending law states who the requirement does not reach. Article 217b, inserted by Article 89 of the amending law, reads: "Strancu kojem je prije dana stupanja na snagu ovog zakona, izdata dozvola za privremeni boravak radi korišćenja i raspolaganja pravom na nepokretnosti koju posjeduje u Crnoj Gori, postupak po zahtjevu za produženje dozvole za privremeni boravak podnijetom nakon dana stupanja na snagu ovog zakona, okončaće se u skladu sa Zakonom o strancima („Službeni list CG", br. 12/18, 3/19, 86/22 i 77/24)."
In English: where a foreigner was issued temporary residence for the use and disposal of a right to real property they own in Montenegro before this law entered into force, an application to extend that permit filed after the entry into force shall be decided under the Law on Foreigners as published in Official Gazette nos. 12/18, 3/19, 86/22 and 77/24.
That cross-reference is the Act as it stood before January, and that text contains no value requirement. The words requiring proof of value from the local tax body were added to Article 56(1) by Article 24 of the January amendment. Article 217b sets no time limit. It does not say "first renewal only". The only test is the date your permit was issued. The "one-year transition period" that circulates online has no basis in the text. Applications that were already pending on 17 January are covered separately by Article 217a(2), which sends them to the old Act as well.
| Situation | €150,000 proof of value | Basis |
|---|---|---|
| First property-based application after 17 January 2026 | Required | Art. 56(4) |
| Permit issued before 17 January 2026, renewal filed now | Not required under the text | Art. 217b |
| Application started before 17 January 2026, still undecided | Not required under the text | Art. 217a(2) |
| EU, EEA or Swiss citizen and family members | Never required | Art. 56(5) |
What is happening in practice
Renewal applications from foreigners who obtained property-based residence before 17 January 2026 are being refused on the ground that the property's tax base is below €150,000. In conversations with the administration, the message is that the requirement will now be applied to these holders too. We have not seen a written, published instruction from the Ministry of Interior (MUP) setting out that approach, nor any reasoning that explains how Article 217b is being read in these files.
The text looks at the date the permit was issued and sends the renewal to the old Act. The refusal reasons apply today's Article 56(4). That gap between the two is a matter for the administrative courts. Which remedy applies, and the deadline for it, is stated in the legal-remedy instruction at the end of the refusal (pouka o pravnom lijeku). The time limit for bringing a claim before the Administrative Court (Upravni sud) is 20 days from service of the decision (Zakon o upravnom sporu, Article 17(1)).
What the text leaves open
Article 217b sends the whole renewal procedure to the old text, and that has two side effects. We read both from the statute, not from any practice. First, the requirement to show that tax obligations were met during the permit (Article 64(4)) also arrived in January, so on a literal reading it does not apply to a 217b renewal. Second, the old text only said "no later than 30 days" before expiry; the "no earlier than 60 days" limit was added in January too.
There is one situation 217b does not cover. It speaks of an extension (produženje). If your permit has already expired and you apply again, that is a new application, not an extension, and on our reading Article 56(4) applies in full. Keeping the permit alive is the real protection.
Our reading
The statutory text is clear: on the renewal of a property permit issued before 17 January 2026, proof of a €150,000 base cannot be required. Because practice is going the other way, we suggest building the application so that it satisfies both texts. File no earlier than 60 and no later than 30 days before expiry (Article 64(1)); that window also meets the old deadline. Include a document showing that your first permit was issued before 17 January 2026 (the card or the decision) and cite Article 217b expressly in the application. Add proof that your property taxes are paid, even though the literal reading does not require it. If a refusal arrives, note the date of service, because the deadline runs from that day. This note is a reading of Montenegrin legislation; in a specific file, an administrative claim and representation are work for an advokat registered with the Bar Association of Montenegro (Advokatska komora Crne Gore).
The entry calendar matters too. Under the visa decree (Uredba o viznom režimu), visa-free stays for citizens of Türkiye and Saudi Arabia (Article 1a) and of Russia and Belarus (Article 3a) run only until 31 October 2026, and the Government has said a visa will be required from 1 November. Terminating the bilateral visa-waiver agreements with Türkiye, Russia and Belarus is a separate process, and the two texts may overlap for a while; we set that out in our note of 25 September. An owner from one of those countries whose permit is not renewed may need a visa to reach their own home after 1 November, unless they hold a valid Schengen, US, UK, Canadian, Australian, Japanese, New Zealand or Irish visa or residence permit, which allows up to 30 days within the document's validity.
Refusals are also about to carry heavier consequences. The amendments to the Law on Foreigners adopted by parliament on 15 October 2026 (EPA 1181) had not appeared in the Official Gazette by 18 October and will enter into force on the eighth day after publication. Under the new Article 109, a decision refusing temporary residence will itself set a deadline to leave. Under the new Article 112, an entry ban becomes mandatory for anyone who does not leave within that deadline, starting at one year depending on the circumstances.
What did not change
Your title to the property is not affected; a refusal concerns residence, not ownership. Permits issued under the old Act remain valid until they expire (Article 218a). For first-time property applications after 17 January 2026, the €150,000 requirement is in force and is not what this note is about. The rule that a temporary permit ends after more than 30 days abroad (Article 65(1), point 3) applies equally to old and new holders.
The new Law on Foreigners bill the Government sent to parliament on 8 October 2026 (EPA 1219) keeps the €150,000 requirement but would apply only from the day Montenegro joins the EU, and it contains no transitional rule on how today's permits carry over. The only amendment to the Act since January, Official Gazette no. 33/2026 of 10 March 2026, changed the heading of Article 175a and nothing else; Articles 56 and 217b are untouched.
How to verify
The amending law as published is on the Official Gazette register page. In the page viewer, page 9 shows Article 24 (the paragraphs added to Article 56), pages 39 and 40 show Article 89 (Articles 217a and 217b), and page 40 shows the entry-into-force clause (Article 92). For the consolidated text with all amendments, search for "Član 217b" in the consolidated Law on Foreigners on gov.me. The single article of the March amendment is on its own register page. You can follow publication of EPA 1181 on the parliament's act page 4354.
The general conditions of the property route are in our guide to residence through property. EPA 1181 is covered in our note of 16 October, and the new bill in our note of 9 October. Who still enters without a visa after 1 November is set out in our Montenegro visa guide. If the ministry publishes a written position, or a court decision on the point is published, we will update this note; other developments appear under Legal Updates.
