Montenegro will not adopt a comprehensive law governing crypto-assets during 2026, leaving digital-asset businesses operating primarily under anti-money-laundering registration requirements while the European Union completes its transition to a full licensing and supervisory framework.
The Ministry of Finance confirmed that a dedicated crypto-assets bill is not included in the government’s 2026 work programme. As a result, no legislation is currently scheduled to regulate token issuance, trading platforms, custody services, stablecoins, market conduct, client-asset protection or prudential standards for crypto-asset service providers.
The postponement comes after the European Union’s final transitional period under the Markets in Crypto-Assets Regulation (MiCA) ended on 1 July 2026. Providers that have not secured the required authorisation must discontinue regulated services in EU jurisdictions where grandfathering arrangements have expired. Although Montenegro, as an EU candidate country, is not yet directly subject to MiCA, the regulation will become part of its legal framework upon EU accession.
Registration framework remains in force
Montenegro already regulates crypto-related activities through amendments to the Law on the Prevention of Money Laundering and Terrorist Financing, adopted by parliament on 28 February 2025 and effective from 20 March 2025.
The amendments introduced legal definitions of crypto-assets and crypto-related services while requiring providers to register with the Capital Market Commission of Montenegro, which is also responsible for inspections and supervisory activities.
The framework covers:
- Custody and administration of crypto-assets
- Operation of trading platforms
- Exchange between crypto-assets and fiat currencies
- Exchange between different crypto-assets
- Order execution
- Transfer services
Registered providers must comply with customer identification, transaction monitoring, record-keeping and suspicious transaction reporting obligations. The regime addresses anti-money-laundering and counter-terrorist financing requirements identified by the Financial Action Task Force (FATF) and MONEYVAL, particularly those relating to virtual assets and cross-border fund transfers.
Registration does not constitute a licensing system. The current framework does not establish prudential capital requirements, governance standards, client-asset segregation, insurance requirements, operational resilience or recovery planning comparable with MiCA.
EU licensing regime introduces capital requirements
Under MiCA, crypto-asset service providers must obtain authorisation and comply with requirements covering governance, cybersecurity, outsourcing, complaints handling and customer protection.
Minimum permanent capital depends on the services provided:
- €50,000 for advisory, portfolio management, order reception, execution, placement and transfer services
- €125,000 for custody services and exchanges between crypto-assets and funds
- €150,000 for trading platform operators
Providers must also maintain safeguards equal to the higher of the applicable statutory minimum or one-quarter of the previous year’s fixed overheads. For example, a custody provider with €1 million in annual fixed overheads would require at least €250,000 in safeguards, while a trading platform with €4 million in annual fixed costs would require at least €1 million. MiCA also establishes separate requirements for conventional crypto-assets, asset-referenced tokens and electronic-money tokens, including rules governing white papers, reserve assets, governance, redemption and conflicts of interest.
Gap widens between Montenegro and EU markets
MiCA’s main provisions became applicable across the European Union on 30 December 2024, following the introduction of rules for asset-referenced and electronic-money tokens on 30 June 2024. Existing providers could continue operating under transitional arrangements until 1 July 2026, although individual member states were permitted to shorten or eliminate that period. Following the end of grandfathering, authorised providers can passport services across the European Economic Area, while Montenegrin companies remain limited to domestic registration and must obtain separate authorisation to serve EU clients.
Companies currently registered in Montenegro may eventually need to obtain full licences, increase regulatory capital, revise governance structures and redesign custody arrangements once comprehensive legislation is introduced. The future law will also determine whether existing registered providers receive transitional grandfathering or must immediately satisfy new licensing requirements.
Banking remains a major operational challenge
Analyst Novak Svrkota stated that Montenegro does not yet possess the banking infrastructure required to become a major crypto-industry centre. Crypto exchanges and custodians require operational banking services, payment processing, settlement, safeguarding, liquidity management and access to correspondent banking.
Although Montenegro uses the euro and has joined the Single Euro Payments Area (SEPA), these factors do not guarantee that domestic banks will accept crypto-related clients. Banks continue to assess beneficial ownership, sources of funds, transaction volumes, customer geography, sanctions exposure and anti-money-laundering controls. The absence of a comprehensive licensing regime also leaves uncertainty regarding client-asset segregation, insolvency treatment and supervisory responsibilities.
Tax reporting reforms advance independently
Montenegro is separately expanding tax reporting requirements for digital assets. Proposed amendments to the Law on Tax Administration would establish the legal basis for automatic exchange of information concerning crypto-asset users and transactions with EU member states and other participating jurisdictions.
Crypto service providers would be required to maintain detailed information on individual and corporate customers, including the natural persons exercising ultimate control over legal entities. The measures form part of the EU’s expanded administrative cooperation framework covering crypto-assets. While these reforms increase tax transparency, they do not establish prudential supervision, capital requirements or investor-protection standards for crypto businesses.
Regulatory approach influenced by high-profile crypto case
Montenegro’s approach to crypto regulation has been shaped by the case involving Do Kwon, founder of Terraform Labs. The TerraUSD and Luna ecosystem collapsed in 2022, eliminating approximately $40 billion in market value.
Kwon was arrested at Podgorica Airport in March 2023 while attempting to travel using falsified documents and was extradited to the United States on 31 December 2024. Although the case did not involve a Montenegrin crypto platform or domestic project, it increased international attention on the country’s regulatory environment.
MiCA implementation requires expanded institutional capacity
Preparing legislation aligned with MiCA will require Montenegro to define responsibilities among the Ministry of Finance, Central Bank of Montenegro, Capital Market Commission, Financial Intelligence Unit, Tax Administration and law-enforcement authorities. Supervisory bodies will need expertise covering blockchain technology, custody arrangements, smart contracts, cybersecurity, market abuse and operational resilience.
In July 2026, the European Securities and Markets Authority (ESMA) began a coordinated review of digital operational resilience in crypto custody, examining areas including key management, storage systems, transaction controls, incident response, smart-contract exposure and reliance on third-party providers. Montenegro has yet to establish the licensing framework that would support comparable supervision. The current registration regime continues to provide anti-money-laundering oversight while leaving broader licensing, prudential regulation and market supervision for future legislation.
