On March 11th, the Gambling Organizers Group within the Chamber of Commerce of Montenegro sent an official letter to the Prime Minister, warning about the potential long-term consequences of adopting the proposed Gambling Law currently in the parliamentary procedure. According to the group, the law could have a significant impact on the economy, market stability, and the state budget.
Representatives of the Group expressed their readiness for urgent talks with the government to present their arguments for withdrawing the proposed law from parliamentary consideration. They emphasized that despite numerous attempts to engage in dialogue, primarily with the Ministry of Finance, they had faced complete disregard for the well-founded discussions. During the law drafting process, they pointed out violations of legal procedures, including breaches of the State Administration Law and the Regulation on Public Consultation. Moreover, over 70% of public comments during the consultation process were ignored, reducing it to a mere formality.
A major concern is the proposed abolition of the concession system for granting gambling licenses and the introduction of an approval system. This change is seen as undermining transparency and increasing administrative discretion. It also threatens the acquired rights of concessionaires and could send a negative signal to future investors. Instead of creating a stable regulatory framework, the proposed law introduces significant business barriers that endanger the survival of legal operators while encouraging the growth of the gray economy and illegal markets.
If the law passes in its current form, the Group believes it will severely harm the sustainability of the gambling sector, jeopardizing legal businesses and responsible operation standards. It also threatens to drastically reduce fiscal contributions, which are vital for the stability of state finances and the implementation of public activities. They warn that the law could lead to the loss of 40 million euros in projected budget revenues, resulting in the reduction or suspension of funding for essential state obligations.
The proposed law fails to address the need for efficient protection mechanisms for legal operators from the black market, and instead, it imposes new obligations on them while increasing gambling licensing fees by 50%. This, according to the Group, does not solve the sector’s underlying problems but further burdens legitimate businesses, leaving the illegal market untouched. Moreover, they argue that the law undermines basic principles of market economy and legal frameworks, endangering constitutional freedoms related to entrepreneurship and fair market competition.
They also pointed out that the lack of communication and understanding had already led to issues with the implementation of amendments to the Law on Personal Income Tax, which became effective on January 1, 2025, but are not applicable in practice. Similarly, they raised concerns about the Law on Anti-Money Laundering and Terrorism Financing, which imposes obligations contrary to European standards.
The Gambling Organizers Group emphasized that the industry currently employs over 3,000 people, rents nearly 1,000 business premises, and has paid more than 33 million euros in gambling concession fees for 2024, excluding other taxes.
The Group is calling for the Gambling Law to be withdrawn from the parliamentary procedure and returned for further review to ensure the sector’s sustainability and avoid harm to the market and the state budget. They urge policymakers not to ignore the arguments of industry experts and the potential economic consequences of the proposed legal changes.
