Montenegro stopped accepting applications for its economic citizenship program on 31 December 2022. Nothing has replaced it, and no application has been receivable since that date. What is still open is the paperwork of the old intake: the Ministry of Internal Affairs was still issuing decisions on applications filed before the deadline as recently as 2024, and a small number remain in processing.
The distinction that matters to a buyer is between a program that is closed and a legal basis that is still standing. Montenegro’s program is closed. The enabling provision in its citizenship law has not been repealed, and in November 2025 the European Commission asked Montenegro to repeal it. Anyone holding out for a relaunch is betting against that request.
What the program was
The scheme sat on Article 12 of the Law on Montenegrin Citizenship, which allows a person whose admission is of special significance to the state, scientific, economic, cultural, sporting or other interest of Montenegro to acquire citizenship exceptionally, without meeting the ordinary conditions. On that basis the Government of Montenegro adopted, at its session of 22 November 2018, the Decision on the criteria, manner and procedure for the selection of persons who may acquire Montenegrin citizenship by admission for the realisation of a special investment program of special significance for the commercial and economic interest of Montenegro. It was published in the Official Gazette of Montenegro No. 79/18 on 7 December 2018.
Article 18 of that Decision set its own life span: it applied from 1 January 2019 to 31 December 2021. It was amended in 2020, published in Official Gazette No. 12/20 of 11 March 2020, transferring the work to the Investment Agency and extending admission to family members under 18. It was extended for a further twelve months by amendments published in Official Gazette No. 143/21, which moved the closing date to 31 December 2022.
Article 16 capped the whole exercise. Over the life of the program, decisions admitting applicants to Montenegrin citizenship could be issued on no more than 2,000 applications.
What it cost while it ran
Article 10 of the Decision set three separate money conditions, and they were cumulative.
- Procedure costs, paid to the account of the competent authority: EUR 15,000 for the applicant, EUR 10,000 for each family member up to four family members, and EUR 50,000 for each further family member beyond that.
- EUR 100,000 into escrow for the development of less developed units of local self-government, under Article 18 of the Law on Regional Development.
- An investment into escrow of at least EUR 450,000 for a development project in the capital city of Podgorica or the coastal region, or at least EUR 250,000 for a development project in the northern or central region other than Podgorica.
The applicant could not select any project. Article 11 defined a qualifying tourism project as the construction of a hotel or mixed complex of five stars in the coastal region or Podgorica, or at least four stars in the northern or central region, requiring a minimum investment of EUR 15,000,000 in the coastal region or Podgorica or EUR 5,000,000 in the north or center, employing at least 80 people in the first case or 25 in the second, and containing at least 60 accommodation units or 35 respectively. The Government fixed the list of eligible projects. Article 12 extended the definition to agriculture and processing industry projects on lists set by the competent ministries.
Applications ran through licensed intermediaries. A mediation agent paid EUR 50,000 a year for its license, held for one year and renewable twice. The international due diligence agent’s license was free. Under Article 17, false statements or concealed facts led to loss of citizenship with no right to a refund of anything paid.
What happened after the deadline
Closing intake did not empty the pipeline. The European Commission’s Montenegro Report of 4 November 2025 records that in 2024 the Ministry of Internal Affairs issued 1,282 decisions granting Montenegrin citizenship under the investor citizenship scheme, comprising 385 applicants and 899 family members, all on applications submitted before the scheme expired on 31 December 2022. Twenty-one applications were still being processed at the time of the report.
The same report gives the nationality breakdown of those 1,282 grants: 709 citizens of the Russian Federation, 42 of Belarus and 29 of Saudi Arabia. It asks Montenegro to perform the necessary security checks while analyzing the remaining applications, and to revoke citizenship granted under the scheme to persons subject to international restrictive measures.
The status today
The Commission’s recommendation in that report is the clearest statement of where the file stands. In its words, to ensure compliance with EU law, Montenegro should repeal the legal basis allowing for the redevelopment of an investor citizenship scheme, on the ground that such schemes breach EU law and carry risks related to security, money laundering, tax evasion, terrorist financing, corruption and infiltration by organized crime.
Read plainly, that tells a prospective applicant two things. The program is not merely dormant pending a decision to reopen it, and the direction of official pressure is towards removing the possibility rather than restoring it. Montenegro opened accession negotiations with the European Union, and this sits in the accession file.
The Montenegrin Investment Agency, which administered the program, still carries an economic citizenship link on its homepage. Following that link on 23 August 2026 returns a page not found error in both the Montenegrin and the English versions of the site. That is an observation about the agency’s website rather than about the law, and it is recorded here because a live link to a dead page is how a closed program keeps looking open.
What this is not
- It is not paused. The Decision expired by its own terms on 31 December 2022 rather than being suspended, so there is no suspension for anyone to lift.
- It is not still accepting applications through an agent. The licensed mediation agents existed only to file under the Decision, and the Decision no longer applies.
- The 2,000 cap is not why it ended. The cap was never reached. Intake stopped on the calendar date written into Article 18 as amended.
- A quoted EUR 250,000 or EUR 450,000 Montenegro package in 2026 describes nothing receivable. Those were the escrow thresholds of a Decision that stopped applying more than three years ago.
- Decisions still being issued are not a reopening. They dispose of applications filed before the deadline, and their existence says nothing about whether a new file can be started.
Where that leaves someone who wanted this route
Montenegro attracted a particular buyer: one who wanted a European passport at a Caribbean price and could tolerate a real estate commitment. There is no direct substitute for that combination anywhere in Europe today, and it is worth saying so rather than steering the enquiry sideways.
What does still exist, in programs whose legal instruments we can read on the day of the enquiry, sits mainly outside Europe. Our country pages for Dominica, St Kitts and Nevis, Grenada, Saint Lucia, Antigua and Barbuda and Vanuatu set out what each of those states actually publishes. They are named here because they exist, not because they are equivalents; each answers a different question from the one Montenegro answered.
Serka acts as independent counsel on investment migration files and is not an agent, representative or licensed intermediary of Montenegro or of any other program state. Where a client already paid into a Montenegrin file before the deadline and has not received a decision, the live questions are documentary and procedural rather than promotional, and they are the ones we work on.
Sources
Every figure and date on this page comes from the Government of Montenegro’s own published documents or from the European Commission, retrieved on 23 August 2026.
| What it supports | Source | Retrieved |
|---|---|---|
| The Decision of 22 November 2018, the EUR 15,000 / 10,000 / 50,000 procedure costs, the EUR 100,000 escrow, the EUR 450,000 and EUR 250,000 regional thresholds, the project definitions, the EUR 50,000 agent license, the 2,000 cap and the 1 January 2019 to 31 December 2021 term | Government of Montenegro, Odluka o kriterijumima, nacinu i postupku izbora lica koje moze steci crnogorsko drzavljanstvo prijemom radi realizacije posebnog programa ulaganja, gov.me | 23.08.2026 |
| Article 12 of the Law on Montenegrin Citizenship as the legal basis, publication in Official Gazette 79/18 of 07.12.2018, the 2020 amendment in Official Gazette 12/20, and the extension to 31 December 2022 by Official Gazette 143/21 | Ministry of Internal Affairs of Montenegro, Informacija o realizaciji posebnog programa (ekonomsko drzavljanstvo), 18 May 2022, gov.me | 23.08.2026 |
| Expiry on 31 December 2022, the 1,282 decisions issued in 2024 split 385 applicants and 899 family members, the 21 applications still in processing, the nationality breakdown, and the recommendation to repeal the legal basis | European Commission, Montenegro 2025 Report, SWD(2025) 754 final/2, Brussels, 4 November 2025, enlargement.ec.europa.eu | 23.08.2026 |
Related pages
- Citizenship by investment: the global overview
- Malta: the framework was repealed after the 2025 EU judgment
- Cyprus: terminated in 2020, and the enabling section deleted in 2025
- North Macedonia: a discretionary route, not a program
- Austria: there was never a program to close
Serka Law Firm advises internationally on investment migration files, wherever the file is. Tell us what you were promised on Montenegro, by whom and on which date, and what you paid; whether any of it was capable of delivery after 31 December 2022 follows from those dates. Serka Law Firm answers at info@serkalaw.com and on WhatsApp at +90 530 127 59 35.