Montenegro is preparing coordinated inspections of real estate intermediaries amid estimates that more than 1,000 potentially unregulated agency operations and property-sales profiles are active outside the formal market, raising concerns over tax compliance, licensing and investor protection.
The initiative comes as property transactions continue to attract significant foreign investment, particularly in coastal municipalities and Podgorica. Foreign purchases of real estate reached €319 million in the first eight months of 2026, accounting for just over half of Montenegro’s total gross foreign direct investment during the period.
Industry representatives estimate that approximately 300 agencies comply with existing requirements, while 277 companies regularly submit financial statements. The figure of more than 1,000 potentially unregulated operations is not an official government count of verified illegal businesses. It also covers informal intermediaries and property-sales profiles operating through social media, messaging applications and other channels.
Authorities are preparing closer cooperation between tax officials, market inspectors and police to identify unregistered brokers, examine commission income and strengthen compliance with licensing and anti-money-laundering requirements.
The main enforcement concerns include undeclared brokerage commissions, unpaid taxes and incomplete transaction records. Foreign buyers may also face unclear contractual obligations, misleading property descriptions, insufficient title checks and difficulties recovering funds in the event of disputes.
Budva, Tivat, Kotor, Bar and Podgorica are among the markets particularly exposed to informal brokerage activity, given the concentration of foreign buyers and residential development. Social-media advertising has further expanded the sector by allowing individuals to market apartments and development projects without maintaining registered agency offices, complicating conventional inspection procedures.
New rules governing property intermediation, scheduled to take effect from summer 2027, envisage fines of up to €20,000 for certain violations. Existing legislation already provides for other sanctions against illegal commercial activity.
Enforcement will require authorities to distinguish private owners advertising their own properties from individuals conducting brokerage businesses without registration. Evidence of repeated transactions, commission payments or organised intermediary activity will therefore be important, rather than the mere publication of an online advertisement.
Formal real estate agencies have argued that unregistered competitors gain an advantage by avoiding the costs associated with offices, employees, taxation, accounting, legal compliance and anti-money-laundering procedures. Stronger enforcement could improve competitive conditions and redirect a greater share of transactions towards licensed operators.
Developers could also benefit from more professional brokerage services, particularly as international investment in new-build projects increases. Consistent documentation and knowledge of legal requirements are increasingly important for transactions involving larger investors and lenders.
Banks financing property developments have similar interests in stronger oversight. Presales documentation, buyer records and transaction transparency influence assessments of project cash flow and collateral values, while informal sales channels make these evaluations more difficult.
The initiative also relates to Montenegro’s EU accession process, which involves stronger requirements concerning tax administration, beneficial ownership transparency, anti-money-laundering controls and consumer protection.
With property purchases representing a substantial share of foreign investment, improving market oversight has become an important economic issue. The estimated gap between more than 1,000 potentially unregulated operations or profiles and fewer than 300 agencies operating within the formal reporting framework highlights the scale of the challenge facing regulators.
