Montenegro’s Government approved a proposed law implementing the European Digital Markets Act on 29 June 2026. The measure concerns one of the EU’s most consequential digital-market regulations, but its significance for Montenegro is easily misunderstood. It is not primarily a law aimed at creating national champions or regulating every domestic technology company. It is a framework for dealing with the global platforms on which Montenegrin companies increasingly depend.
The bill implements Regulation (EU) 2022/1925, which governs large digital platforms designated as “gatekeepers”. The European framework covers core platform services such as online search, social networks, app stores, operating systems, browsers, virtual assistants, online intermediation, advertising and cloud services. The Government formally approved the proposal during its telephone session of 29 June.
The targets are companies whose scale and position allow them to control access between businesses and customers. Montenegro is unlikely to produce a domestic platform meeting the European gatekeeper thresholds. Its companies will usually sit on the other side of the relationship: as app developers, advertisers, hotels, retailers, media outlets, payment providers and business users purchasing access to audiences controlled elsewhere.
That is why the law matters. A hotel in Budva may depend on an international booking platform for most foreign reservations. A software company in Podgorica may depend on an app store for distribution and payments. A retailer may build its customer acquisition around a search engine or social network. In each case, the platform can affect visibility, access to customer data, payment terms and the ability to offer a competing service outside its ecosystem.
The DMA restricts practices that allow a gatekeeper to exploit that dependency. The European rules address self-preferencing, forced bundling, restrictions on directing users to alternative offers, certain combinations of personal data and barriers preventing business users from accessing information generated through their own customers.
Enforcement in the EU remains centred on the European Commission. A Montenegrin implementation law should therefore be judged by how clearly it allocates national cooperation, investigative and procedural responsibilities without pretending that a domestic authority will independently regulate every global platform.
The commercial opportunity lies in better contestability. Software developers may gain more freedom to reach users or use alternative payment channels. Advertisers may obtain better information about campaign performance. Business users may have stronger access to data and greater ability to challenge discriminatory ranking or terms.
None of that guarantees lower commissions. The DMA is a competition and fairness instrument, not price regulation. Platforms can redesign fees, introduce new technical conditions or argue that restrictions are necessary for privacy and security. Montenegrin businesses will need the capacity to identify when a platform practice may breach the rules and to preserve evidence that can support a complaint.
The quality of the legislative process raises a separate concern. The public consultation ran in May, but the published report recorded no substantive participation. For a bill affecting tourism distribution, online retail, media, advertising and application development, the absence of industry comment suggests either limited awareness or a belief that consultation cannot influence the outcome.
That silence matters because implementation questions are local. Which authority receives information from businesses? Can commercially sensitive complaints be protected? How will evidence be transferred to the European Commission? What remedies are available when a platform’s decision threatens a company’s survival before a full investigation can be completed?
The proposal should not be confused with the separate Digital Services Act, which deals more directly with illegal content, platform accountability and user safety. Montenegro has also been preparing legislation in that field. Together, the two regimes will change the relationship between platforms, users and companies, but they solve different problems.
For investors, the DMA law is another sign that Montenegro is beginning to import the regulatory conditions of the EU single market before membership. That reduces future legal divergence. It also raises the compliance standard for domestic intermediaries that hope to grow across Europe.
The bill remains a proposal, and its parliamentary passage and commencement provisions must still be watched. Its larger message is already clear: access to Montenegro’s digital market will increasingly come with European obligations, even when the platform controlling that access is headquartered thousands of kilometres away.
