Montenegro's Shifting Immigration Landscape: What Foreign Property Buyers Need to Know About Pending Legislative Changes

For two decades, I've watched Montenegro evolve from a newly independent nation to a serious EU candidate country. I began working in Montenegro's property market in 2005 as a private speculator, even before the country's independence, and in all that time, I've rarely witnessed the level of legislative uncertainty that foreign property buyers and small business owners face today.

Since July, Montenegro's Parliament has been wrestling with proposed amendments to the Law on Foreigners—changes that could fundamentally alter how international buyers obtain and maintain residency. What began as a straightforward government proposal has morphed into a moving target, with parliamentary amendments introduced as recently as mid-December that appear to soften some of the more contentious requirements.

The confusion is considerable, and it matters. For anyone considering Montenegro property investment, understanding where these proposals currently stand—and where they're likely headed—has become essential.
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The Legislative Timeline: From Proposal to Parliamentary Limbo

The current uncertainty began on July 24, 2025, when Montenegro's government submitted its initial draft amendments to the Law on Foreigners. The timing wasn't accidental. As Montenegro pushes toward EU accession—potentially as early as 2028—harmonizing immigration procedures with European standards has become a critical benchmark.

On November 12, the government adopted amendments at a Cabinet session, introducing two headline changes that immediately caught international attention:

‍First, a minimum property value threshold of €200,000 for residency through real estate ownership—though this requirement does not apply to citizens of EU member states or certain other European countries including Iceland, Liechtenstein, Norway, and Switzerland. For non-EU nationals (including UK, US, and Australian citizens), the €200,000 minimum would represent a significant change from previous practice, where no formal minimum existed and properties as affordable as €50,000 could qualify for residency.

‍Second, a requirement that foreign company owners or managing directors holding more than 51% of shares must employ at least three full-time staff—two of whom must be Montenegrin citizens—to extend their residency permits.

But here's where it gets interesting. Parliamentary documents dated December 11, 2025—visible in recent social media posts from migration analysts—suggest that amendments (amandmani) are being proposed that could substantially modify the government's original framework.

These parliamentary amendments appear to propose replacing the three-employee requirement with an alternative: foreign business owners could instead demonstrate they've paid at least €5,000 annually in combined taxes and social security contributions. If adopted, this would shift the test from employment generation to fiscal contribution—a fundamentally different approach.
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What We Know (and Don't Know)

As of mid-December 2025, here's the current state of play:

‍Confirmed: The government has formally adopted the €200,000 minimum property value for non-EU nationals (this requirement does not apply to EU citizens or nationals of Iceland, Liechtenstein, Norway, and Switzerland) and the three-employee requirement (with two being Montenegrin citizens) for business-based residency. These provisions have cleared the Cabinet level.

‍In flux: Parliament is now reviewing the government's proposals and considering amendments. The €5,000 annual tax contribution alternative has been proposed but not yet voted upon. Additional amendments regarding IT specialists and healthcare workers are also under consideration.

‍Unknown: When Parliament will vote on the final version, what the transition period will look like, and whether existing residence permit holders will be grandfathered under current rules or given time to comply with new requirements.

The legislation has not been formally adopted into law. It remains in parliamentary procedure, which in Montenegro's current political climate—marked by coalition fragility and occasional procedural standoffs—means timelines are difficult to predict.
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Understanding the Government's Rationale

To make sense of these proposals, it helps to understand the pressure Montenegro's government faces.

The numbers tell part of the story. According to Interior Minister Danilo Šaranović, nearly 98,000 foreigners currently reside in a country of 633,000 citizens. In Budva alone, more than 21,000 foreign residents live in a municipality with just 26,500 locals according to the census. The minister has publicly stated that roughly 21,000 of these foreign residents are Russian nationals—a significant concentration that has raised both practical and geopolitical concerns as Montenegro moves toward EU membership.

The government's stated goal is eliminating what officials call "paper companies"—shelf entities created solely to obtain residency with no genuine economic activity. Fair enough. But the blunt instrument of a three-employee minimum has triggered substantial pushback from legitimate small business owners who genuinely contribute to the economy but operate lean teams, particularly in professional services, consulting, and digital businesses.

Enter the proposed €5,000 tax contribution alternative. While still unconfirmed, this approach would arguably better distinguish between shell companies (which generate minimal tax revenue) and genuine economic contributors (who may employ few people but pay substantial taxes on professional income). A software consultant earning €60,000 annually would pay considerably more than €5,000 in income tax and social contributions, even without employing anyone.
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The €200,000 Property Threshold: Reading Between the Lines

The property value requirement has generated less controversy than the employment provisions, but its implications merit attention.

At €200,000, Montenegro isn't setting an unusually high bar by European standards. Greece's golden visa requires €250,000 (and recently increased to €500,000 in Athens and major islands). Portugal suspended its program entirely. Spain requires €500,000 for residency through property investment.

But Montenegro previously had no formal minimum property value requirement for residency. Buyers purchased properties ranging from €50,000 to well over €100,000 and successfully obtained residency based on property ownership. The introduction of a €200,000 threshold represents a significant shift from this previous practice.

The November 12 government announcement included a one-year transition period for existing property owners to "bring their status in line with new legal provisions." What this means in practice remains unclear. Must they purchase additional property to reach €200,000? Will they lose residency if they don't? The legislation doesn't yet specify, though common sense (and Montenegro's historical approach) suggests grandfathering is likely for those who already hold valid residency permits.

For new buyers, however, the message is increasingly clear: budget for €200,000 minimum if residency is part of your calculation.
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The Broader Context: EU Accession and Immigration Policy

These proposed changes don't exist in isolation. They're part of Montenegro's broader effort to close the 33 negotiating chapters required for EU membership.

Chapter 24—Justice, Freedom, and Security—specifically addresses immigration policy. The European Commission's 2025 Rule of Law Report notes that while Montenegro has made progress on various fronts, certain legislative alignment processes slowed in early 2025 due to "domestic political challenges."

Translation: Montenegro's governing coalition is fragile, parliamentary procedures are sometimes contentious, and passing complex legislation can take longer than technocratic timelines suggest.

This matters for anyone trying to time their purchase. The legislation could pass within weeks. Or it could face delays, amendments, counter-amendments, and protracted debate. In Montenegro's current political configuration, predicting parliamentary timelines with confidence isn't realistic.

What we can say is this: the direction of travel is clear. Requirements will tighten. The only question is precisely how, and when.
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What This Means for Property Buyers Today

If you're considering Montenegro property investment, the current legislative flux creates both urgency and complexity.

‍The timing question is real. Even if final legislation includes transition periods—likely, in my view—there's no guarantee buyers will be grandfathered if they haven't already purchased and applied for residency under current rules.

‍Budget accordingly. Regardless of parliamentary amendments, the €200,000 threshold for non-EU nationals appears solid. Properties under this value may still be excellent investments, but buyers from the UK, US, Australia, and similar countries should not assume they'll qualify for residency without meeting the new minimum.

‍Substance matters more than structure. Whether the final requirement is three employees or €5,000 in annual tax contributions, Montenegro is clearly moving away from tolerating passive arrangements. Anyone establishing a company for residency purposes should ensure it has genuine economic activity.

‍Perspective helps. Yes, the legislative situation is fluid. But Montenegro property values remain reasonable by European standards, quality of life along the Bay of Kotor is exceptional, and the country's trajectory toward EU membership hasn't fundamentally changed. These are legitimate reasons to invest regardless of residency considerations.

‍Local knowledge is essential. This isn't the time for overseas consultants operating from afar. Understanding what's actually happening requires relationships with local lawyers, notaries, and government officials who navigate Montenegro's legal system daily.
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The Window Is Closing—But It Hasn't Closed Yet

I began working in Montenegro's property market in 2005, before the country even gained independence. I've seen this nation through its birth as an independent state, through boom times and quiet periods, through citizenship-by-investment programs and their suspensions, through regulatory changes both predictable and surprising.

What's happening now is significant. Montenegro is maturing from a relatively permissive residency regime to something more aligned with EU norms. That maturation benefits the country long-term, even if it creates short-term uncertainty for foreign buyers.

But here's the thing about windows: they close gradually, until suddenly they don't. Greece's golden visa program allowed €250,000 investments for years, then overnight required €500,000 for prime locations. Portugal's welcomed €350,000 investments, then suspended the program entirely pending restructuring.

Montenegro's current proposals—€200,000 property minimum, substantive economic activity requirements—are workable for serious buyers. They're not the end of Montenegro as an accessible European option. They're the evolution of a maturing market.

The time to act is before that evolution completes. Because once these amendments pass—whether in their current form, with the tax contribution alternative, or with some hybrid approach—the rules that exist today will be gone.

And unlike parliamentary debates, that change won't be gradual.
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The information in this article is current as of December 2025 and reflects the author's understanding of proposed legislation that has not yet been formally adopted. Immigration law is subject to change, and readers should consult qualified legal professionals before making property purchase or residency decisions. NT Realty provides real estate advisory services and works with independent legal counsel for residency and immigration matters.

Peter Flynn moved to Montenegro in 2005 and began working in the country's property market as a private speculator, even before independence. He established New Territory DOO in 2006 to formalise his operations after the country gained independence. With two decades of experience guiding international buyers through Montenegro's property market and residency processes, he specialises in the Tivat and Bay of Kotor area. Working alongside business partner Maša Flynn, NT Realty (which takes its name from the New Territory holding company) has helped hundreds of buyers from the US, UK, Australia, and beyond navigate Montenegro's evolving legal and regulatory landscape. Peter maintains close working relationships with local lawyers, notaries, and government officials, providing clients with current, practical guidance rooted in on-the-ground experience since before the country's independence.