Montenegro is preparing a redesigned system for issuing temporary residence and work permits to foreign nationals, with the government moving toward a single administrative procedure linking immigration, employment and other institutional checks through interconnected digital systems.
The initiative comes as the country continues to rely heavily on foreign labour, while authorities seek to address fragmented procedures, duplicated documentation and concerns over the use of company registrations as a basis for residence and employment rights without sufficient evidence of economic activity.
The government has approved the development of a framework that would connect the Ministry of Interior, the Employment Agency of Montenegro and other relevant institutions through interoperable information systems. The reform is intended to simplify applications, improve recruitment procedures and strengthen verification of employers, applicants and the grounds for obtaining residence and work rights. The decision represents the start of the preparation process rather than the introduction of a fully operational digital permit system. Authorities must still establish the necessary legal, organisational and technological framework, including amendments to the Law on Foreigners, secondary regulations, data-exchange rules and new IT infrastructure.
Single procedure to replace fragmented administration
Montenegro already issues a document combining temporary residence and the right to work. The planned reform focuses on changing the process behind that document by replacing separate institutional procedures with a coordinated workflow. The Employment Agency of Montenegro would examine employment-related requirements and whether foreign nationals meet the conditions for access to the domestic labour market.
The final outcome would remain one permit covering both temporary residence and employment. Applicants and employers would no longer be responsible for transferring documents between institutions, as authorities would exchange required information electronically. The reform is linked to Montenegro’s obligations during the European integration process. Directive (EU) 2024/1233 establishes a single application procedure for third-country nationals seeking residence and work rights, alongside employment-related protections.
Foreign workers become essential part of labour market
Foreign labour has become a significant component of Montenegro’s economy. The country issued 40,567 temporary residence and work permits in 2025, an increase of 2,548 permits, or 6.7 per cent, compared with 38,019 permits in 2024. Between 1 January and 1 June 2026, another 14,778 permits were issued. The 2025 figure included 27,689 permits within the annual employment quota and 12,878 permits outside the quota. The quota utilisation rate reached 95.52 per cent.
Regular employment permits used 99.74 per cent of the allocated quota, while seasonal employment permits recorded utilisation of 63.59 per cent. For 2026, the government set an annual quota of 28,988 permits, including 21,668 permits for regular employment and 2,320 permits for seasonal work. An additional 5,000 permits were reserved for later allocation depending on labour-market requirements. Certain categories remain outside the quota system, including company directors, executives, contracted-service providers, highly qualified managers, professional athletes and other groups.
Concerns over company-based residence permits
The scale of outside-quota permits has become a regulatory focus. Of the 12,878 permits issued outside the quota in 2025, 11,826, or almost 92 per cent, were granted to directors and executive directors of registered companies. Contracted-service providers received 625 permits, highly educated managers received 155, professional sports workers received 114, and other categories accounted for 158 permits.
Authorities are examining whether company registration is sometimes being used as the primary basis for residence and work rights without sufficient evidence of real business operations. Company ownership alone does not indicate misuse, as many foreign-owned small businesses operate legitimately in areas such as consulting, information technology, property management, tourism and professional services.
The proposed integrated system could connect Ministry of Interior records with the Central Registry of Business Entities, tax databases, social-insurance records and employment databases to help distinguish active businesses from inactive entities. Potential indicators for assessing genuine activity could include tax registration, submitted returns, contracts, professional qualifications, business expenses, operating premises and consistency between declared activities and actual work.
Construction and tourism drive labour demand
The strongest demand for foreign workers is concentrated in construction, accommodation and food services, and other service activities. These sectors accounted for 71.49 per cent of permits issued within the quota in 2025. Construction received 6,920 in-quota permits, while accommodation and food services accounted for 6,805 permits.
The labour shortage is linked to Montenegro’s limited working-age population, emigration trends, regional wage competition and seasonal demand, particularly along the coast. Tourism businesses must recruit large numbers of workers before the summer season, often from Serbia, Bosnia and Herzegovina, Albania, Turkey and other labour markets. Delays in permit processing can leave workers unable to begin employment and employers without sufficient staffing at the start of the season.
A faster single-permit process could reduce administrative costs and shorten the period between arrival and legal employment, while also reducing incentives for undeclared work. Authorities also identified the need for clearer documentation requirements, automated checks and case-management systems that allow applicants and employers to track the progress of applications.
Digital system expected to improve oversight and worker protection
The planned system would require defined service standards for the Ministry of Interior, Employment Agency and other institutions involved in processing applications. Authorities would need to distinguish between incomplete applications and delays caused by administrative procedures. Employers could receive access to a portal allowing them to submit applications, upload employment documents, pay fees, monitor progress and respond to requests for additional information.
Foreign workers would also have access to information about applications submitted in their name, including employer details, occupation and employment duration. Such access is intended to reduce risks related to inaccurate job descriptions, unauthorised deductions and employment conditions different from those originally offered. The revised EU framework also addresses workers’ ability to change employers and seek new employment after losing a job. Montenegro will need to determine how these principles will be incorporated into domestic legislation before accession.
Enforcement to focus on employers and labour conditions
The proposed system would also support stronger controls over employers. Authorities could use integrated databases to identify companies whose declared workforce does not correspond with turnover, contracts or workplace conditions. Illegal employment risks include unpaid payroll obligations, undeclared working hours, cash payments and inadequate accommodation conditions.
The system would need to distinguish between deliberate misuse of permits and normal labour mobility. Authorities would retain powers to revoke permits obtained through false documentation or fictitious employment, while workers who lose legitimate employment would require transparent procedures for changing employers.
Coastal municipalities account for majority of permits
Foreign labour is concentrated in several municipalities. In 2025, Podgorica accounted for 13,568 permits, representing 33.45 per cent of the national total.
It was followed by:
- Budva with 10,318 permits
- Herceg Novi with 3,889 permits
- Bar with 3,807 permits
- Tivat with 2,767 permits
- Kotor with 2,102 permits
- Ulcinj with 1,232 permits
Together, these seven municipalities accounted for almost 93 per cent of all permits issued.
The distribution reflects employment demand in construction, tourism, property-related activities and services. It also places greater administrative pressure on immigration offices and inspection services in these locations. Digital processing could reduce workload at local offices, although biometric identification and certain security procedures would continue to require physical attendance.
Turkey, Serbia and Russia among largest sources of workers
Foreign-worker recruitment is becoming increasingly diverse. The largest groups receiving permits in 2025 came from:
- Turkey with 10,346 permits
- Serbia with 8,148 permits
- Russia with 7,429 permits
- Azerbaijan with 2,513 permits
- Albania with 2,098 permits
- Bosnia and Herzegovina with 1,902 permits
Together, these countries accounted for almost 80 per cent of all permits.
Turkish and Azerbaijani workers are associated largely with construction activity, while Serbian, Bosnian and Albanian workers remain important in tourism, retail, services and skilled trades. Russian permit holders include employees as well as company founders, executives and independent professionals who moved business activities to Montenegro after 2022. The broader range of recruitment markets increases the need for multilingual information, document verification and oversight of recruitment intermediaries.
Data protection and implementation challenges remain
The integrated permit system will require compliance with data-protection rules because it would combine immigration, tax, employment, company and security information. Access would need to be limited according to institutional responsibilities, consultations recorded and procedures established for correcting inaccurate records. For employers, the proposed model would create a single compliance process beginning with checking available quotas and occupation categories, followed by one application channel for employment and residence approval.
Authorities would conduct checks in parallel, issue one decision and notify relevant tax, employment and social-insurance systems once employment begins. The government’s current decision represents the beginning of the reform process. The effectiveness of the new framework will depend on the development of connected databases, defined institutional responsibilities and operational digital procedures.
