What the closing of chapter 19 means for hotels and restaurants as employers, and what to put in order before the next season
Ljubo Vuljaj and Michael Gehring
Courtesy of Montenegro Experts · Hospitality Consulting
Why this chapter comes first
On 12 October 2026 Montenegro provisionally closed chapter 19, social policy and employment. Of all the chapters that touch hospitality, this one reaches furthest into daily work: every hotel, restaurant and guesthouse is an employer, and many depend on seasonal staff who arrive in May and leave in October.
The chapter brings Montenegrin law in line with a set of EU directives on contracts, working time, fixed-term work and health and safety. Much of this is already written into the Labour Law and the Law on Safety and Health at Work. What changes with accession is the attention: the EU will follow how the rules are applied, and inspections tend to follow the same direction.
The contract on the first day
Under the Labour Law, the employment contract is concluded in writing before the employee starts work. In a busy June, a new waiter or housekeeper sometimes begins on a handshake and the paperwork follows a week later. That gap is exactly what an inspector looks for.
The EU directive on transparent and predictable working conditions (2019/1152) adds a clear standard of content: place of work, duties, start date, pay, working hours, leave, notice and the applicable collective agreement. A one-page template that covers these points, filled in and signed before the first shift, solves most of the problem.
Fixed-term and seasonal work
Fixed-term contracts are meant to be the exception, with a defined end: a date, a task or a season. The EU directive on fixed-term work (1999/70/EC) asks member states to prevent the abuse of successive contracts. Montenegro shortened the maximum duration of fixed-term employment with the same employer from 36 to 24 months in August 2024, with exceptions that include seasonal work.
For a seasonal property, the practical question is simple: does each contract name the season it covers, and does the file show why the work is temporary? Staff who return every year and work most of it are, in substance, permanent employees.
Working time and rest
The EU working time directive (2003/88/EC) sets the frame that Montenegrin law follows:
• an average of no more than 48 hours a week, overtime included
• at least 11 consecutive hours of rest in every 24 hours
• a weekly rest of at least 24 hours, plus the daily rest
• a break when the working day is longer than six hours
• at least four weeks of paid annual leave
The Labour Law sets the regular full-time week at 40 hours and allows working time to be redistributed across a season within these limits.
In hotels the weak point is rarely the contract. It is the roster: a split shift in the restaurant, a late banquet followed by an early breakfast, a receptionist covering a sick colleague for the third night. Without a record of actual hours, nobody can show that the rest periods were kept.
Safety at work is a document and a habit
The Law on Safety and Health at Work requires every employer to have a risk assessment act: a written description of each workplace, its risks and the measures taken against them. The EU framework directive (89/391/EEC) adds the duties around it: information and training for every employee, protective equipment, and consultation with staff.
For a hotel, the risks are well known: hot surfaces and knives in the kitchen, chemicals and heavy lifting in housekeeping, wet floors around the pool, ladders in maintenance, night work at reception. The document exists in many houses. The habit is often missing: a short safety briefing for every new employee on the first day, signed and kept, and a review of the assessment when something changes in the building or the work.
What inspectors and guests will notice
The Labour Inspectorate enforces both laws. Guests from the EU, and the tour operators who send them, increasingly ask how staff are treated. A house that can show contracts, rosters and training records is easier to inspect, easier to insure and easier to recommend.
Checklist
- Check that every employee, including seasonal and part-time staff, signed a written contract before the first day of work.
- Compare your contract template with the content required by directive 2019/1152 and add what is missing.
- Review fixed-term and seasonal contracts: is the reason for the time limit written down, and is the 24-month limit respected?
- Keep a record of actual working hours and check one busy week against the 11-hour daily rest and the 48-hour average.
- Take out your risk assessment act, read it with your heads of department, and update it where the work has changed.
- Introduce a ten-minute safety briefing for every new employee, with a signature on the day.
Next week: clear prices and fair terms in booking, invoicing and cancellation, chapter 28.
Sources
Council of the EU, 29th accession conference with Montenegro, 12 October 2026: consilium.europa.eu. Directive 2003/88/EC on working time; Directive (EU) 2019/1152 on transparent and predictable working conditions; Council Directive 1999/70/EC on fixed-term work; Council Directive 89/391/EEC on safety and health at work: eur-lex.europa.eu. Labour Law of Montenegro, Official Gazette 74/2019 and amendments, including August 2024. Law on Safety and Health at Work, Official Gazette 34/2014 and 44/2018.
Courtesy of Hotelberatung in Montenegro | Montenegro Experts
