Montenegro’s government has confirmed that it has no plans to restore its former citizenship-by-investment programme, which generated more than €410 million in recorded investments, contributions and fees before being closed amid concerns linked to the country’s European Union accession process.
The Special Investment Programme of Particular Importance for Montenegro’s Economic and Commercial Interest accepted applications from 2019 until December 31, 2022, allowing eligible non-EU citizens to obtain Montenegrin citizenship through investment in approved development projects, non-refundable contributions and administrative payments. The Ministry of Regional Investment Development and Cooperation with Non-Governmental Organisations, led by Ernad Suljević, said the government of Prime Minister Milojko Spajić has not prepared a new version of the programme and has not held formal discussions with the European Commission on a replacement model.
EU accession framework limits return of investor citizenship
Montenegro’s position comes as the country approaches the final stage of its EU accession negotiations, with Brussels taking a stricter position against citizenship-by-investment schemes. The European Commission has requested that Montenegro not only keep the programme closed but also remove the legal foundations that could allow a similar mechanism to be introduced in the future.
The Commission considers such schemes to carry risks related to money laundering, tax evasion, sanctions circumvention, corruption, organised crime and insufficient security screening. The legal environment became more restrictive after the Court of Justice of the European Union ruled in April 2025 that Malta’s investor citizenship arrangement violated EU law.
The ruling stated that citizenship of an EU member state, and therefore EU citizenship, cannot be treated as a commercial transaction without a genuine connection between the applicant and the country. Although Montenegro is not yet an EU member, it aims to join the bloc as early as 2028, while the Union has already started preparatory work related to an accession treaty. Reintroducing a programme that Brussels has requested to be dismantled would create risks for progress in areas covering justice, fundamental rights, security and free movement.
Programme generated more than €410 million in inflows
Government data covering the programme until July 1, 2026 shows cumulative inflows exceeding €410 million. The amount includes several categories of investment, contributions and fees, but does not represent direct state revenue in its entirety. The largest portion, approximately €251.2 million, was directed towards investors and developers involved in approved tourism projects.
These funds represented private capital invested into qualifying hotel and resort developments rather than unrestricted government income. A further €87 million was allocated for less-developed municipalities. Transfers received by the state budget included €33 million in January 2023, another €33.3 million during 2023, and approximately €20.5 million distributed through seven tranches between mid-2024 and mid-2026.
The total also included government charges, special contributions, innovation funding and other programme-related payments. The economic effect of the programme depends on whether approved projects were completed, became operational, generated employment and produced long-term tax revenues after construction.
Tourism real estate dominated investment structure
The programme directed applicants towards two main geographic categories.
Investors could place €250,000 into approved projects in northern or central Montenegro, excluding Podgorica, or €450,000 into projects in Podgorica and developed coastal areas. Near the end of the programme, applicants were also required to contribute a total of €200,000, divided between the development of less-developed municipalities and the country’s Innovation Fund, in addition to application and due diligence fees.
The lower investment threshold for northern Montenegro was designed to encourage investment outside the Adriatic coast. It supported a pipeline of tourism projects in Kolašin, Žabljak and Mojkovac, connecting citizenship demand with efforts to develop year-round mountain tourism.
Approved projects included Kolašin Resort & Spa, Hotel Breza, Bjelasica 1450, K16, Montis Mountain Resort, Durmitor Hotel and Villas in Žabljak, as well as coastal developments including Boka Place at Porto Montenegro. The programme became closely linked with condominium hotels and branded residences, rather than manufacturing, export industries or technology businesses.
Economic impact debated after programme closure
The structure of the programme allowed developers to divide large capital requirements into individual units sold to applicants. Investors gained access to assets that could potentially be rented, resold or used personally after the required holding period, while construction projects could absorb capital more quickly than industrial investments. The same structure limited the programme’s broader economic impact.
Hotel apartments can generate construction activity and support resort financing, but they do not necessarily create the same productivity gains as export companies, logistics platforms, technology businesses or energy projects.
The government has acknowledged that future investment policies should place greater emphasis on talent, innovation, productive companies and the real economy. The key economic question is not whether the programme attracted capital, as it clearly did, but whether the value generated was sufficient compared with the legal, reputational and security risks associated with investor citizenship.
Pending applications continued after closure
The programme continued to have administrative effects after applications formally ended. Authorities processed applications submitted before the December 2022 deadline, resulting in a significant number of citizenship decisions in later years. In 2024, a total of 1,282 people received Montenegrin citizenship through pending applications, including 385 principal applicants and 899 family members. Recipients included 709 Russian citizens, 42 Belarusian citizens and 29 Saudi citizens.
The number of Russian recipients attracted additional attention from the EU following Russia’s invasion of Ukraine and the introduction of European sanctions. The European Commission has called on Montenegro to complete security checks on remaining cases and revoke citizenship where recipients are subject to international restrictive measures. Only 21 applications remained under processing when the European Commission prepared its latest detailed assessment. Although the administrative process is nearing completion, due diligence, ownership verification and possible revocation procedures may continue for years.
Government considers investment-focused alternatives
A new citizenship-by-investment programme would create accession risks compared with the amount of capital it could realistically attract. The EU has made removal of the programme’s legal foundations part of Montenegro’s alignment obligations, while the Union’s highest court has rejected the direct sale of member-state nationality. Montenegro’s accession progress affects access to EU grants, concessional financing, infrastructure support and investor confidence.
The country is already working with European institutions on projects in transport, energy, digitalisation and environmental infrastructure, with combined economic value exceeding the previous citizenship programme’s receipts. The Mateševo–Andrijevica motorway section is expected to use an approximately €500 million financing package involving the European Bank for Reconstruction and Development and the EU. Additional sources of development financing include rail modernisation, electricity-network upgrades, environmental infrastructure and the EU Growth Plan for the Western Balkans.
Focus shifts from property purchases to productive investment
Montenegro’s external financing needs remain significant, as the country has traditionally relied on tourism revenues, property purchases and foreign capital to finance a large trade deficit. The current-account deficit increased from 11.4% of GDP in 2023 to 17.1% in 2024, reaching 17.7% in the second quarter of 2025.
In this environment, the loss of a mechanism that attracted hundreds of millions of euros is noticeable, but the quality and long-term effects of investment remain important. Capital used for hotel units supports the balance of payments during construction, while operating companies, export businesses and infrastructure investments continue generating economic activity over longer periods. A potential replacement policy would therefore focus on attracting qualified professionals, entrepreneurs and specialist talent without linking investment directly to citizenship.
A residence-based framework could provide faster permits for founders, researchers, senior engineers, technology specialists and investors who establish operating businesses, employ local workers and maintain genuine economic activity. Citizenship would remain available through standard naturalisation procedures after an appropriate period.
Potential sectors include technology, energy and advanced tourism
A future investment-residence model could focus on areas including renewable energy, digital infrastructure, advanced tourism, food processing, maritime services and environmental technology. Eligibility could be linked to verified equity investment in operating companies, employment creation, research spending, export activity or projects aligned with national development priorities.
Authorities would need to establish measurable obligations, verify beneficial ownership, examine sources of wealth and monitor investment commitments over several years. Funds should be released through regulated channels and development milestones should be confirmed before full access is provided. A talent-focused programme could address Montenegro’s shortage of qualified personnel in sectors requiring engineers, construction managers, medical specialists, digital professionals, researchers, tourism executives and experienced industrial operators.
Future investment policy expected to align with EU standards
Investment projects presented at the EU–Montenegro investment conference in Luštica in October 2025 included 14 partnership projects covering renewable energy, transport, agrotourism, digital innovation and low-carbon development. The proposed initiatives included new wind and solar capacity, decarbonisation of the Port of Bar, a digital innovation campus and projects supporting northern municipalities.
These sectors require long-term capital and technical expertise and could provide a framework for attracting investment without creating conflicts with EU citizenship policies. Before introducing any successor programme, Montenegro would need a detailed economic assessment of the closed scheme, separating public revenues from private property purchases and measuring completed projects, permanent employment and tax contributions.
Particular attention would be required for condominium-hotel developments, as completed buildings do not automatically guarantee operational hotels, professional management or sustained tourism activity. The distribution of the €87 million allocated to less-developed municipalities would also require transparent reporting on funded projects, procurement procedures, disbursements and completed infrastructure. Montenegro is therefore moving away from citizenship-based investment and towards an EU-compatible investment and talent residence model based on productive economic activity, employment creation and long-term business development.
