Montenegro’s Tax Administration is preparing a broad expansion of digital tax reporting that would introduce electronic invoicing and delivery notes and give authorities greater ability to analyse transaction data automatically as the country tightens fiscal controls and aligns its tax infrastructure with the European Union.
Tax Administration Director Sava Laketić said the authority plans to launch a tender for an electronic-invoicing system by the end of 2026, alongside further work on e-delivery notes, central registers of goods and services and automated tax-risk analysis.
The proposed systems have not yet been fully implemented.
Their significance lies in the direction of reform: Montenegro is moving from digital recording of individual transactions toward a tax architecture capable of comparing invoices, fiscal receipts, inventories and declarations across entire supply chains.
That would materially increase the Tax Administration’s visibility over business activity.
The authority already receives large volumes of information through electronic fiscalisation. The next stage is intended to connect that data with the Integrated Revenue Management System, or IRMS, allowing discrepancies to be identified automatically and taxpayers to be ranked according to compliance risk.
For businesses, that could change how tax audits are triggered.
Traditional inspections depend heavily on periodic controls, manual review and information gathered by inspectors. A more integrated digital system can identify anomalies before an inspector enters a company.
Differences between reported sales and purchases, unusual VAT patterns, gaps between invoices and delivery documents or inconsistencies in inventory movements could become visible centrally.
The potential effect is particularly important in sectors where cash transactions, informal trade or under-reporting have historically been harder to monitor.
Montenegro has already intensified inspections of hospitality, tourism, retail and employment activity during the 2026 summer season.
Digitalisation would allow enforcement to continue throughout the year rather than relying mainly on large seasonal campaigns.
Electronic invoicing would be central to that model.
Under a mature e-invoice system, transaction data can be transmitted in a standardised format, allowing tax authorities to cross-check the seller’s declared revenue against the buyer’s reported purchase.
That reduces the scope for mismatched declarations and can make fraudulent invoice chains more difficult to sustain.
The precise legal and technical design of Montenegro’s system has not yet been finalised.
The planned tender will therefore be important in determining how broadly the platform operates, which taxpayers are covered initially and whether implementation is phased.
For larger companies, adaptation may be relatively straightforward because many already use enterprise resource planning systems capable of generating structured electronic documents.
Smaller companies could face a larger adjustment.
Accounting software, internal procedures and relationships with bookkeepers may need to change.
Businesses will also need clarity on accepted formats, digital authentication, archiving requirements and how errors or cancelled invoices are handled.
If designed well, however, electronic invoicing can reduce administrative work as well as increase oversight.
Invoices no longer need to be manually re-entered into accounting systems, and automated reconciliation can reduce errors.
The commercial benefit depends heavily on interoperability.
If businesses must maintain parallel systems because tax software cannot communicate easily with their existing accounting platforms, compliance costs can rise rather than fall.
The government will therefore need to balance enforcement objectives with operational simplicity.
Electronic delivery notes add another layer.
They would allow the authorities to compare the physical movement of goods with invoicing and fiscal records.
That could be particularly relevant for wholesale trade, fuel, construction materials, food distribution and other sectors where goods move between multiple businesses before reaching the final customer.
A central register of goods and services would further standardise reporting.
Common classifications can make it easier to identify unusual pricing, volumes or tax treatment across taxpayers.
For the Tax Administration, the long-term objective appears to be a system in which compliance risks are identified through data rather than mainly through random or reactive inspections.
That would bring Montenegro closer to tax models already used in several EU states.
The reform is also linked directly to accession.
The Tax Administration has launched a separate tender for infrastructure enabling automatic exchange of tax information with EU member states.
That capacity will become increasingly important as Montenegro integrates with European systems governing VAT, income, financial accounts and cross-border tax cooperation.
Cross-border exchange can make it harder for individuals or companies to conceal assets or taxable income outside Montenegro.
For domestic businesses, the broader impact is likely to be a reduction in the advantage enjoyed by companies operating partly outside the formal economy.
Formalisation can improve competitive conditions for compliant companies if authorities are able to identify businesses that avoid taxes or payroll obligations.
The government has repeatedly presented grey-economy reduction as one of the main sources of additional fiscal revenue.
That strategy has limits.
Higher collection cannot indefinitely substitute for underlying economic growth, and aggressive enforcement can create unnecessary burdens if controls are poorly targeted.
Data-driven auditing is intended to address that problem by directing inspectors toward higher-risk cases rather than treating all taxpayers as equally suspicious.
The quality of the underlying data will determine whether that works.
Automated risk systems can be effective only if information is complete, standardised and current.
Poor data can generate large numbers of false alerts and increase the workload for both taxpayers and officials.
Cybersecurity will also become more important as the state centralises sensitive commercial information.
E-invoice systems contain detailed information about customers, suppliers, prices and commercial relationships.
Any large-scale breach could expose confidential business data.
System resilience will be equally important.
If electronic reporting becomes mandatory, temporary outages could prevent companies from issuing valid invoices or completing transactions.
Montenegro will therefore need contingency procedures alongside the digital platform.
The reform could also improve fiscal forecasting.
Real-time or near-real-time information about invoices and sales would allow the government to monitor VAT and other tax bases more accurately during the year.
That can help the Finance Ministry detect revenue weakness earlier and adjust budget management.
Montenegro recorded relatively strong revenue growth through the first seven months of 2026, but the country still faces large spending requirements related to pensions, wages, infrastructure and EU accession.
Improving tax administration is therefore strategically important.
The objective is not simply to collect more from existing compliant taxpayers.
It is to widen the effective tax base and reduce leakage.
The timing also matters for companies preparing for EU membership.
Digital reporting requirements are expanding across Europe, and businesses increasingly need systems capable of exchanging structured tax data with authorities.
Companies that adapt to Montenegro’s domestic reforms will therefore also be better positioned for integration into the single market.
The immediate next milestone is the planned e-invoicing tender by the end of 2026.
Until procurement is completed and the legal framework is finalised, the scope and implementation timetable remain uncertain.
But the policy direction is already clear.
Montenegro’s tax administration is moving away from a model in which authorities mainly see what companies report at the end of an accounting period.
The emerging system is designed to see transactions as they happen and compare them across the economy.
For compliant businesses, that could eventually mean fewer indiscriminate inspections and more automated administration.
For companies dependent on gaps between invoices, stock movements and tax declarations, the room to operate is likely to narrow.
