Montenegro’s former economic citizenship programme is approaching its administrative completion, with five of the 1,113 original applications still awaiting final decisions at the end of July 2026, almost four years after the country stopped accepting new applications. By 31 July 2026, the Ministry of Interior had approved 869 applications, while 239 had been rejected. The remaining five were still under consideration by the Prime Minister’s Office and the Ministry of Interior. One additional application that had already received a positive decision was undergoing verification of the related money transfer.
The programme has generated approximately €413.5 million in recorded investments, fees and development contributions, while a further €2.585 million remains in escrow for tourism and innovation-related obligations.
Almost all applications have been decided
The 869 approvals represent approximately 78.1% of all submitted applications, while rejected cases account for around 21.5%. Only 0.45% remain unresolved, meaning approximately 99.6% of the original caseload has been decided. Only one additional application received a positive decision during July. The number of unresolved cases declined from six to five, while approvals increased from 868 to 869. The July application was submitted through Austrian authorised agent Arton Group GmbH. The value of the associated investment was not disclosed.
Montenegro formally closed the programme to new applications on 31 December 2022, although applications submitted before that deadline remained valid and continued through due-diligence, investment-verification and citizenship procedures. The scheme had been introduced in 2019 and was originally limited to 2,000 principal applications.
Investment thresholds increased during the programme
The programme operated through a grant-plus-investment model rather than an outright passport fee. Initially, applicants were required to invest at least €250,000 in approved development projects in northern or less-developed parts of Montenegro, or €450,000 in Podgorica and the coastal region. They also had to make contributions designated for the development of less-developed municipalities and pay administrative fees.
During the final phase, the minimum combined financial commitment for an individual application effectively increased to approximately €465,000 for qualifying northern projects and €665,000 for projects in Podgorica and the coastal region, before certain additional family-related and professional expenses. The increase partly reflected the introduction of an additional contribution to Montenegro’s innovation policy, with related transfers continuing after the application window closed.
During July, the Innovation Fund of Montenegro recorded another €100,000, taking cumulative receipts linked to the programme to €31.4 million. The Investment Agency’s records continued to show €31.3 million. The government attributed the difference to the timing of an independent auditor’s report rather than a disagreement concerning the transaction. Another €500,000 remains in escrow for innovation-policy contributions linked to applications that have not completed the process.
Tourism received most programme-related investment
Tourism attracted by far the largest share of capital generated through the programme. By the end of July, applicants had transferred €251.22 million directly to investors implementing projects on the government’s approved tourism development list. A further €2.085 million remained in applicants’ escrow accounts for tourism investments awaiting completion of the relevant procedures. Agriculture and processing industries received another €500,000. Overall, the programme remained predominantly focused on tourism and hotel development rather than diversified industrial investment.
Approved development projects included Bjelasica 1450 in Kolašin, K16 in Kolašin, Durmitor Hotel and Villas in Žabljak, Boka Place in Tivat, Kolašin Resort & Spa and Montis Hotels & Resorts, alongside other hotel and mixed-use developments.
Kolašin and northern Montenegro became particularly important destinations for programme-related investment because the lower investment threshold was designed to channel capital towards less-developed areas rather than the already more developed coast. Several hotel and condominium developments around the Kolašin ski areas incorporated economic citizenship demand into their financing structures.
Six tourism projects were removed from the approved list
The government removed six tourism projects from the development list in March 2022 after some investors failed to meet investment obligations or provide required bank guarantees. The projects were Bobotov Hotel and Resort in Žabljak, Elite Hotel & Residence in Kolašin, a hotel-and-villas complex in Žabljak, Kolašin Resort & Spa, Kraljičina Plaža in Miločer and Black Pine in Mojkovac. Some projects were subsequently able to reapply after meeting revised requirements. Montenegro subsequently tightened requirements, including the use of irrevocable bank guarantees linked to minimum project investment obligations.
Programme-related financial flows reached €413.5 million
By the end of July, recorded programme-related financial flows comprised approximately €251.22 million in tourism investment, €500,000 in agriculture and processing, €43.58 million in administrative fees, €31.4 million transferred to the Innovation Fund and approximately €86.8 million associated with programmes supporting less-developed municipalities. Together, these flows amounted to roughly €413.5 million.
The amount still held in escrow was approximately €2.585 million, covering tourism and innovation-related obligations. The eventual financial total could therefore increase as the remaining applications are completed. The €413.5 million total should not be treated as government revenue. Approximately €251.7 million went directly into development projects in tourism, agriculture and processing, rather than into the state budget. Around €161.8 million represents administrative fees, Innovation Fund payments and amounts connected with support for less-developed municipalities.
Administrative fees generated approximately €43.58 million for the central Treasury, while payments associated with less-developed municipalities reached around €86.8 million and the Innovation Fund received €31.4 million. Together, those three categories amount to more than €160 million associated with public institutions or designated development purposes. The total recorded financial volume of more than €413 million is equivalent to almost 5% of Montenegro’s expected 2026 GDP, although the funds accumulated over several years and do not represent annual economic output.
Northern tourism projects form part of the programme’s legacy
The physical assets created through the programme remain a significant part of its economic legacy. Tourism investments can generate activity through completed hotels, employment, local service purchases and accommodation revenues. This was particularly relevant in northern Montenegro, where tourism investment was used as a means of addressing the development gap with the coast.
Projects around Kolašin benefited from the simultaneous development of ski infrastructure and improved road accessibility following completion of the Smokovac–Mateševo motorway section. The combination of public infrastructure and citizenship-linked hotel financing contributed to an investment cycle larger than previous local tourism demand had supported. The programme also raised a distinction between genuine hotel operations and residential or condominium development. Properties purchased because they qualified for citizenship generated construction-stage activity regardless of subsequent tourism occupancy, while longer-term economic returns depend on developments operating as hotels and generating sustained commercial activity.
With citizenship-linked demand now gone, completed projects must compete for visitors and investment under conventional tourism conditions. Kolašin, Žabljak and other northern destinations will provide an indication of how projects perform without the passport incentive.
European scrutiny shaped the programme’s closure
The economic citizenship model also carried political and regulatory consequences. The European Union repeatedly raised concerns about investor-citizenship schemes because of potential money-laundering, tax-evasion, organised-crime and security risks, particularly where citizenship in a visa-free country could facilitate access to the Schengen area. Montenegro ended its programme at the end of 2022, a decision subsequently welcomed by European institutions.
Administrative processing continued after closure. The European Commission reported in December 2025 that Montenegro’s Ministry of Interior had issued 1,282 citizenship decisions during 2024 involving applicants and their family members connected with the former programme. It also reported that 29 applications remained under processing as of April 2025. Those figures are not directly comparable with the current 1,113 principal-application total because individual applications could include several family members. The number of pending principal cases subsequently declined from 29 in April 2025 to five in July 2026.
EU accession changes the policy environment
The European legal and political environment surrounding investor citizenship has also changed. In April 2025, the Court of Justice of the European Union ruled against Malta’s investor citizenship programme, finding that an EU member state cannot operate a naturalisation system based essentially on predetermined payments or investments in exchange for citizenship. Montenegro is not an EU member, so the ruling does not retroactively determine the legality of its former national programme. It nevertheless changed the European legal and political context surrounding any potential revival of such a model.
The European Commission has also strengthened the relationship between investor-citizenship programmes and the Visa Suspension Mechanism, citing security risks for the Schengen area associated with schemes operated by visa-free third countries. Montenegro is continuing its EU accession process. The European Commission’s June 2026 accession financing communication stated that Montenegro had provisionally closed 16 negotiating chapters, with possible accession following the beginning of the EU’s 2028–2034 Multiannual Financial Framework, provided the remaining conditions are fulfilled.
Property investment continues after programme closure
The end of the citizenship scheme has not eliminated foreign demand for Montenegro’s property market. More than €250 million flowed into development projects through the programme, while more than €160 million was associated with state fees, innovation policy and support for less-developed municipalities. Foreign investment in property remains one of Montenegro’s largest sources of capital inflow. New-build housing prices exceeded €2,500 per square metre nationally in 2026, with substantially higher prices recorded in premium coastal developments. Part of the investment appeal associated with the citizenship-programme period has therefore continued through conventional real-estate investment.
The remaining administrative workload is now limited to five unresolved applications, equal to only 0.45% of the original 1,113 cases. Once those applications and associated escrow transfers have been completed, Montenegro will be able to establish a definitive financial balance for a programme that formally ended on 31 December 2022 but continued generating citizenship decisions and financial transfers for almost four additional years. At the end of July, the recorded figures stood at approximately €413.5 million in programme-related financial flows, €2.585 million in escrow, 869 approved applications, 239 rejected applications and five cases still awaiting final decisions.
