Legal Updates

Seventeen rule changes in Montenegro and Türkiye in September 2026: which bind you today, and which wait for 2027

17 legal changes we wrote up in September 2026 for Montenegro and Türkiye: nine in force, four adopted but not yet applied, four still bills.

Rohat Kahraman· 2 October 2026· 4 min readUpdated · 2 October 2026
September 2026 legal updates — 17 changes in Montenegro and Türkiye with their in-force and application dates

As of 2 October 2026. Status: set row by row — In force; Adopted, not yet in force; or In process (draft/bill). Scope: the 18 status notes we wrote from official texts between 1 and 30 September 2026. The bill and the adopted version of the Border Control Act share one row, which leaves 17 instruments. Gazette references and article numbers sit in each row's own note.

Most questions that reached us in September made the same mistake. They treated the publication date, the date of entry into force and the date of application as one date. They are often three. Montenegro's new structural rulebook entered into force on 12 September 2026 and does not apply until 12 March 2027. The criminal code amendment went the other way: no eight-day buffer at all, six days from the vote to force. One table, sorted by the date that actually binds you, is the reason this summary exists.

The September table

NoteInstrumentStatus on 2 October 2026Date that binds you
1 SepForeigners Act bill, new Art. 70g (EPA 1181)In process (draft/bill)None yet; in parliament
3 SepCMB Communiqué III-42.1.b, remote ID by passport (TR)In force3 September 2026
4 SepStructural rulebook, Sl. list 130/2026In forceApplies 12 March 2027
4 SepDNA and fingerprint data protocol (EPA 1184)In process (draft/bill)None
5 SepMoney market fund withholding, Decision 11734 (TR)In force5 September 2026
7 SepConfiscation of criminal proceeds act, 131/2026In force8 September 2026
9 SepPolice data act, 132/2026Adopted, not yet in forceApplies 17 March 2027
9 SepCriminal procedure amendment, 132/2026In force17 September 2026
9 SepTransfer tax, life partners, 132/2026In force10 September 2026
14 SepData protection act, 133/2026Adopted, not yet in forceApplies 19 March 2027
18 SepWritten letter of rights form, 135/2026In force17 September 2026
19 SepEuro model package, six billsIn process (draft/bill)1 January 2027 per the bills
20 SepCriminal code amendment, 137/2026In force22 September 2026
22 SepEU judicial cooperation act, 137/2026Adopted, not yet in forceEU accession day
25 SepEnding visa waiver treaties (TR, RU, BY)In process (draft/bill)Turkish treaty: not before 24 March 2027 on our count
29 SepLegalisation commission rulebook, 140/2026In force25 September 2026
14 and 30 SepBorder Control Act (EPA 1193), adopted 29 SepAdopted, not yet in forceEighth day after gazette; none yet

What binds you today

If you are detained in Montenegro, two texts now work together. The criminal procedure amendment has required since 17 September 2026 that your rights be given in writing and in a language you understand, and rulebook 135/2026, in force the same day, published the form itself. When we first wrote it up, the amendment sat in the "adopted, not yet in force" row. It has moved.

Buying property? Law 131/2026 orders a freezing order over suspected criminal proceeds to be entered in the cadastre. A note on the list nepokretnosti is no longer a detail a seller can wave away. Owners with a pending legalisation file have, since 25 September, carried the cost of the on-site commission (140/2026).

On the Turkish side, foreign investors can now open brokerage and crypto accounts remotely with a passport (III-42.1.b), and company gains on money market funds have carried 10% withholding since 5 September 2026 (Decision 11734).

Adopted, but not yet applied

The data protection act (133/2026) entered into force on 19 September 2026. Its fine ceiling of €2,000,000 or 4% of worldwide turnover, whichever is higher, applies from 19 March 2027. The police data act runs on the same six-month gap, closing on 17 March 2027.

The EU judicial cooperation act came into force on 29 September. Its last article ties application to the day Montenegro joins the EU, so a European Arrest Warrant does not run directly in Montenegro today; cases still go through the 2018 act (85/18) and the extradition treaties.

The Border Control Act passed 43-0 on 29 September. On 2 October there is neither a promulgation decree nor a Službeni list reference; the latest issue, 142/2026, carries no law. The rule that a child under 16 crossing on an ID card with one parent needs the other parent's consent (Art. 64) is therefore not yet applied at the border.

Still bills

The Article 70g bill would create a residence permit for a €250,000 investment, open to EU citizens only. Parliament's page still reads "U proceduri" on 2 October. We had not seen the six euro model bills on parliament's "U proceduri" list by the same date.

Ending the visa waiver treaties is a government decision, not a completed termination. Article 11 of the Turkish treaty keeps it alive for six months after written notice; the Russian treaty ends 90 days after the other side receives notice (Art. 11(4)).

What did not change

None of the September texts moved the 1 November 2026 visa date for ordinary Turkish passports. The Foreigners Act in force still lists no investment ground for residence; Art. 70g is only a bill. We saw no text touching Türkiye's USD 400,000 citizenship-by-investment threshold.

How to verify

Every published Montenegrin text can be found in the Službeni list search by issue number: 130, 131, 132, 133, 135, 137 and 140 of 2026. For parliamentary texts, open the act page on zakoni.skupstina.me. The "Status" field lags the vote by days; the Listing glasanja in the document list is what proves adoption. Turkish texts are in the Resmî Gazete archive: issue 33359 of 3 September and issue 33361 of 5 September 2026.

In October we are watching two things: the Border Control Act's gazette reference and the committee stage of Art. 70g. When either row changes, the table will be updated on our Legal Updates page. If your file turns on one of these texts, our Montenegro visa guide is a good place to start before you write to us through the contact page.

Legal basis

  • Zakon o oduzimanju imovinske koristi stečene kriminalnom aktivnošću — čl. 95, čl. 96Sl. list CG 131/2026, 07.09.2026Official text
  • Zakon o izmjenama i dopunama Zakonika o krivičnom postupku — čl. 99Sl. list CG 132/2026, 09.09.2026Official text
  • Zakon o zaštiti podataka o ličnosti — čl. 106Sl. list CG 133/2026, 11.09.2026Official text
  • Zakon o izmjenama i dopunama Krivičnog zakonika Crne Gore — čl. 74Sl. list CG 137/2026, 21.09.2026Official text
  • Zakon o pravosudnoj saradnji u krivičnim stvarima sa državama članicama Evropske unije — čl. 193, čl. 194Sl. list CG 137/2026, 21.09.2026Official text
  • Zakon o graničnoj kontroli (usvojen) — čl. 64, čl. 95EPA 1193 XXVIII, usvojen 29.09.2026; Sl. list: nije objavljen (02.10.2026)Official text
  • Predlog zakona o izmjenama i dopunama Zakona o strancima — čl. 70gEPA 1181 XXVIII, U proceduri (02.10.2026)Official text
  • Tebliğ III-42.1.b (uzaktan kimlik tespiti) — m.1-4Resmî Gazete 03.09.2026, Sayı 33359Official text
  • GVK geçici 67 tevkifat oranları hakkında Karar (11734) — m.1, m.2Resmî Gazete 05.09.2026, Sayı 33361Official text

Frequently asked questions

Did Montenegro pass investment residence in September 2026?

No. Art. 70g sits in bill EPA 1181 and was still "U proceduri" in parliament on 2 October 2026. As drafted, the €250,000 route is open to EU citizens only.

When do the new Montenegrin data protection fines start?

Law 133/2026 entered into force on 19 September 2026 and applies from 19 March 2027 (Art. 106). The ceiling is €2,000,000 or 4% of worldwide turnover, whichever is higher.

Is the new child consent rule already applied at the border?

No. The Border Control Act was adopted on 29 September but has not been published in the Službeni list. It enters into force on the eighth day after publication (Art. 95).

Does the European Arrest Warrant now work in Montenegro?

Not yet. The act entered into force on 29 September 2026, but its final article defers application to accession day. Until then, cases run under the 2018 act and the extradition treaties.

Which September change affects property buyers most directly?

Law 131/2026, in force since 8 September 2026: a freezing order over suspected criminal proceeds must now be registered in the cadastre, so it shows on the title extract.