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Montenegro and Türkiye: what changed for foreigners

Short developments compiled daily from the official gazette, government and regulator sources, each with its source and what it means in practice.

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MontenegroResidence permits

Montenegro reportedly tightens temporary protection rules for Ukrainians liable for military service

RTCG reports that the Government of Montenegro amended, on 15 October 2026, its Decision granting temporary protection (privremena zaštita) to persons from Ukraine. According to the report, Ukrainians liable for military service (vojni obveznici) who apply will receive temporary protection only if they actually stayed in Ukraine before arriving in Montenegro and have completed their military service or been exempted from it. The report says the change is aligned with Council Implementing Decision (EU) 2026/1912 of 30 July 2026 and does not apply to Ukrainians who already enjoy temporary protection in Montenegro.

What it means for you

As reported, temporary protection for Ukrainians liable for military service who arrive in Montenegro now depends on a prior actual stay in Ukraine and on completed or exempted military service, while current holders stay outside the new restriction.

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TürkiyeCompanies

Türkiye moves the date in the Article 376 Communiqué provisional article from 1/1/2027 to 1/1/2028

Türkiye’s Ministry of Trade (Ticaret Bakanlığı) published an amending communiqué (tebliğ) in the Resmî Gazete of 10 October 2026, No. 33396. It changes the date “1/1/2027” to “1/1/2028” in provisional Article 1 (geçici madde) of the Communiqué on the Procedures and Principles for the Application of Article 376 of Turkish Commercial Code No. 6102, published in the Resmî Gazete of 15/9/2018, No. 30536. The amendment entered into force on its publication date.

What it means for you

Companies in Türkiye that apply Article 376, including foreign-owned ones, now work with the date 1/1/2028 in provisional Article 1 instead of 1/1/2027. The amending text does not restate the content of that provisional article.

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MontenegroResidence permitsWork permits

Montenegro's Government submits a new Law on Foreigners to Parliament under urgent procedure

On 8 October 2026 the Government of Montenegro submitted the Proposal of the Law on Foreigners (Predlog zakona o strancima) to the Parliament of Montenegro (Skupština), registered as EPA 1219. The Government asked for the law to be adopted under the urgent procedure (hitni postupak), and Parliament forwarded the proposal to its Legislative Committee and its Committee on the Political System, Judiciary and Administration. The proposal is in parliamentary procedure and has not been adopted.

What it means for you

The Law on Foreigners (Zakon o strancima) governs foreigners' residence and work permits in Montenegro, so a new law would change the framework that permit holders and applicants rely on. Until Parliament adopts it and it is published, the proposal has no legal effect.

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MontenegroTax

Montenegro's Government sends the Spain double tax treaty to Parliament for ratification

On 6 October 2026 the Government of Montenegro (Vlada) submitted to the Parliament of Montenegro (Skupština) a bill ratifying the treaty between Montenegro and the Kingdom of Spain on the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income (Predlog zakona o potvrđivanju Ugovora). The parliament's page lists the bill's status as in procedure (u proceduri). The treaty's provisions are not reproduced on the bill page, and the bill has not yet been adopted.

What it means for you

For individuals and companies with income in both Montenegro and Spain, the treaty addresses double taxation of income and tax evasion between the two states; the bill opens the parliamentary ratification procedure for it.

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MontenegroBanking & finance

Montenegro consumer credit draft reported to ban loan terms discriminating by citizenship or residence

Investitor.me reports that a draft amending Montenegro's Consumer Credit Act (Zakon o potrošačkim kreditima) would expressly prohibit discriminatory lending terms based on citizenship, residence or other legally protected personal characteristics. According to the report, cutting or cancelling an overdraft would require at least 30 days' notice, and before forced collection lenders would have to offer repayment in 12 equal monthly instalments; the changes aim to align with EU Directive 2023/2225. The text is still a draft and has not been adopted.

What it means for you

For foreigners who borrow from lenders in Montenegro, the reported draft would make citizenship and residence expressly prohibited grounds for different credit terms, while differences based on objective criteria would remain possible.

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MontenegroWork permitsCompanies

Montenegro bill proposes cutting maximum fixed-term employment from 24 to 12 months

On 1 October 2026 a parliamentary group (poslanički klub) submitted to the Parliament of Montenegro (Skupština Crne Gore) a bill amending the Labour Act (Zakon o radu). The bill replaces "24 months" with "12 months" in Articles 37, 47 and 54, cutting the maximum duration of fixed-term employment contracts (ugovor o radu na određeno vrijeme) with the same employer. The bill is in parliamentary procedure and, if adopted, would enter into force on the eighth day after publication in the Official Gazette of Montenegro (Službeni list Crne Gore).

What it means for you

If adopted, foreign nationals employed in Montenegro on fixed-term contracts, and the companies that employ them, would reach the limit on fixed-term work with the same employer after 12 months instead of 24. The bill is a proposal and changes nothing until Parliament adopts it.

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TürkiyeReal estate

Türkiye amends Real Estate Trade Regulation: protocol to set secure payment system exemptions and usage fee

The Ministry of Trade's amendment to the Regulation on Real Estate Trade (Taşınmaz Ticareti Hakkında Yönetmelik) was published in Resmî Gazete No. 33387 on 1 October 2026 and entered into force on publication. Under the rewritten fifth paragraph of additional Article 1, the secure payment system (güvenli ödeme sistemi) runs under a protocol between the Ministry of Trade, the Ministry of Environment, Urbanisation and Climate Change and an integrator, which sets the sales excluded from the system, the pilot application, the usage fee and how it is shared. The amendment also replaces the date 1/7/2026 in paragraph 10 of provisional Article 1 with 1/12/2026.

What it means for you

For foreigners buying or selling property in Türkiye, which sales fall outside the secure payment system and what using it costs are now set in the protocol rather than in the regulation itself.

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MontenegroTaxBanking & finance

Montenegro's Tax Administration starts automatic exchange of US account data under FATCA

Montenegro's Tax Administration (Poreska uprava) announced on 30 September 2026 that it has carried out its first automatic exchange of financial account information with the US Internal Revenue Service (IRS) under the FATCA agreement. The exchange, sent through the IDES system, covered reporting periods from 2014 to 2025 and includes account holders' identification data, year-end balances and income from interest, dividends and sales of financial assets. The authority also stated that it is working on applying the OECD Common Reporting Standard (CRS).

What it means for you

Account data of US taxpayers held at Montenegrin financial institutions now reaches the IRS on a regular, systematic basis rather than only on individual request. Under CRS, the Tax Administration will also receive data from partner states on accounts that Montenegrin tax residents hold abroad.

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TürkiyeReal estateBanking & finance

Türkiye to move the mandatory start of the secure payment system for property sales to 1 December 2026

Türkiye's Ministry of Trade (Ticaret Bakanlığı) announced on 28 September 2026 that a forthcoming amendment to the Regulation on Real Estate Trade (Taşınmaz Ticareti Hakkında Yönetmelik) will reset the mandatory start date of the Secure Payment System (Güvenli Ödeme Sistemi) to 1 December 2026. Under the amendment of 29 April 2026, where all or part of a property price is paid in cash, by bank transfer or by electronic funds transfer, it is to be paid through this system, which makes title and price change hands simultaneously. The ministry says banks' technical infrastructure is still being built and a pilot is planned once it is ready.

What it means for you

For foreigners buying or selling property in Türkiye, the obligation to route the sale price through the Secure Payment System is set to apply from 1 December 2026, once the announced regulation amendment is made.

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TürkiyeCompaniesWork permits

Türkiye amends its Remote Working Regulation to allow hybrid work defined in the employment contract

Türkiye's Ministry of Labour and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı) published an amendment to the Remote Working Regulation (Uzaktan Çalışma Yönetmeliği) of 10 March 2021 in the Resmî Gazete of 25 September 2026. A paragraph added to Article 9 allows the parties to agree that part of the work is done at the workplace and part remotely; the days the employee works at the workplace and remotely, and the working hours, are then set in the employment contract. The amendment entered into force on its publication date, 25 September 2026.

What it means for you

Foreign-owned employers in Türkiye and foreigners employed there under a Turkish employment contract now have an express rule for hybrid work: the workplace and remote days and the working hours are fixed in the employment contract.

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MontenegroTaxCompanies

Montenegro bill proposes QDMTT alignment and a 15-month filing deadline for the global minimum tax

On 23 September 2026 a group of MPs submitted to the Parliament of Montenegro a bill amending the Law on the Global Minimum Corporate Income Tax (Službeni list CG 33/26), which sets a 15% minimum effective rate for groups with consolidated revenue of at least €750 million. The bill recasts the domestic top-up tax as a qualified domestic top-up tax (kvalifikovani domaći dopunski porez) under Council Directive (EU) 2022/2523 and sets the return deadline at 18 months for the first year and 15 months thereafter. It is in parliamentary procedure and would take effect on publication in the Official Gazette.

What it means for you

If Parliament adopts the bill, Montenegrin entities of foreign multinational groups in the €750 million scope would have 15 months instead of 18 to file top-up tax returns after the first year.

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MontenegroResidence permitsWork permits

State audit reported to find Montenegro issued 44% more residence and work permits than its 2025 quota

Vijesti reports that Montenegro's State Audit Institution (DRI) has published its final audit of integrated migration management for 2021 to 2025, finding that the Ministry of the Interior (MUP) has not sufficiently secured an effective migration management system. The Government set a 2025 quota of 28,988 temporary residence and work permits, while 40,567 were issued, 44% above the quota; 107,506 foreign nationals stayed in Montenegro that year, 29,714 with permanent residence (stalni boravak) and 67,807 with temporary residence (privremeni boravak). The Ministry is to send the DRI an action plan by 19 October 2026.

What it means for you

The audit describes a permit system running well above the Government's own annual quota and calls for quotas matched to actual labour market demand; that quota is the mechanism deciding how many residence and work permits are available to foreigners in a year.

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TürkiyeBanking & finance

Türkiye's banking regulator reported to have revoked Bank Mellat's operating licence

Daily Sabah reported on 20 September 2026 that Türkiye has revoked the licence of Bank Mellat, one of Iran's largest private banks, through a decision published in the Official Gazette (Resmî Gazete). According to the same report, the Turkish banking regulator relied on article 71b of the banking law, under which an entity's "continued operation poses a threat to the rights of depositors and participation fund holders and to the security and stability of the financial system". The report gives no detail on how existing accounts and payments at the bank in Türkiye are to be handled.

What it means for you

If the licence has been withdrawn as reported, the bank is no longer authorised to operate in Türkiye, which directly concerns foreign residents and foreign-owned companies that hold accounts with it or route payments through it.

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TürkiyeReal estateBanking & finance

Türkiye's secure payment system for property sales reported to become mandatory on 1 October 2026

Ekonomim (Dünya) reports that the secure payment system (Güvenli Ödeme Sistemi) for property purchases and sales in Türkiye will be applied compulsorily from 1 October 2026. According to the report, the sale price is held in a secure account until the title deed transfer (tapu devri) is completed and is transferred automatically to the seller's account once the transfer takes place, with the banking system and land registry transactions working in an integrated way through an application of the Ministry of Trade (Ticaret Bakanlığı). The report was published on 20 September 2026.

What it means for you

For a foreign buyer or seller of property in Türkiye, the reported change concerns how the purchase money moves: the price would sit in a secure account tied to completion of the title deed transfer rather than passing directly between the parties at the registry.

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These notes are general information, not legal advice, and do not create a lawyer–client relationship. Each note reflects the source text on its publication date; check the current official text and your own situation with a lawyer before acting.