Montenegro’s government has no proposal to revive the country’s former citizenship-by-investment programme and has not discussed a replacement model with the European Commission, effectively closing the door on a policy that generated more than €410mn in recorded investment, contributions and fees but became incompatible with Podgorica’s accelerating European Union accession process.
The Special Investment Programme of Particular Importance for Montenegro’s Economic and Commercial Interest accepted applications between 2019 and December 31, 2022. It offered qualifying non-EU nationals Montenegrin citizenship through a combination of investment in government-approved development projects, non-refundable contributions and administrative fees.
The Ministry of Regional Investment Development and Cooperation with Non-Governmental Organisations, led by Ernad Suljević, says the administration of Prime Minister Milojko Spajić has not developed a new version of the scheme. Nor have formal consultations taken place with Brussels on an alternative.
That position is more definitive than it may initially appear. Montenegro is no longer merely managing European criticism of an existing programme. It is approaching the final stage of accession negotiations at a time when the EU has hardened its legal and political position against the sale of citizenship.
The European Commission has asked Montenegro not only to keep the programme closed, but also to repeal the underlying legal basis that could allow an investor citizenship mechanism to be reintroduced. It regards such schemes as presenting risks related to money laundering, tax evasion, sanctions circumvention, corruption, organised crime and inadequate security screening.
The legal environment became even more restrictive after the Court of Justice of the European Union ruled in April 2025 that Malta’s investor citizenship arrangement breached EU law. The court’s reasoning went beyond deficiencies in due diligence. It concluded that citizenship of an EU member state, and therefore EU citizenship, could not be reduced to a commercial transaction without a genuine connection between the applicant and the country.
Montenegro is not yet an EU member, but it hopes to join as early as 2028, and the Union has begun preparatory work on an accession treaty. Reopening a programme that Brussels has explicitly requested it to dismantle would jeopardise progress under the chapters covering justice, fundamental rights, security and free movement.
The economic record nevertheless explains why the subject continues to return to domestic political debate. Government information covering the programme through July 1, 2026 puts cumulative inflows at more than €410mn. In an economy with annual output of only several billion euros, that is too large a figure to dismiss as a marginal policy experiment.
Yet describing the entire amount as government revenue gives a distorted picture. The largest component, approximately €251.2mn, was directed to investors and developers behind tourism projects included on the official development list. This was private capital committed to qualifying hotel and resort units, rather than unrestricted fiscal income available to finance public spending.
Another €87mn was allocated for less-developed municipalities. Transfers into the central Treasury included €33mn in January 2023, a further €33.3mn during 2023, and about €20.5mn distributed in seven tranches between mid-2024 and mid-2026. The broader total also included government charges, special contributions, innovation funding and other programme-related payments.
The distinction is important for evaluating the scheme’s real impact. The state benefited from direct fiscal receipts, but much of the advertised €410mn represented capital used to purchase stakes or units in approved real-estate developments. Its economic value therefore depends on whether those projects were completed, became operational, created sustainable employment and generated tax receipts after construction.
The programme’s original structure channelled applicants towards two geographic categories. Investors could place €250,000 in approved projects in northern or central Montenegro, excluding Podgorica, or €450,000 in projects in the capital and developed coastal areas. Following changes introduced near the end of the scheme, applicants were also required to make contributions totalling €200,000, divided between development of less-developed municipalities and the country’s Innovation Fund, alongside application and due-diligence fees.
The lower threshold for northern Montenegro was intended to shift investment away from the heavily developed Adriatic coast. It helped finance a pipeline of hotel developments in Kolašin, Žabljak and Mojkovac, linking citizenship demand with the government’s attempt to build a year-round mountain-tourism economy.
Approved developments included projects such as Kolašin Resort & Spa, Hotel Breza, Bjelasica 1450, K16, Montis Mountain Resort, Durmitor Hotel and Villas in Žabljak and coastal developments including Boka Place at Porto Montenegro. The programme therefore became closely associated with the rapid expansion of condominium hotels and branded residences rather than with manufacturing, export industry or technology.
That concentration was commercially understandable. Hotel-linked real estate allowed developers to divide large capital requirements into units that could be sold to individual applicants. It also gave investors an asset that could potentially be rented, resold or used personally after the required holding period. Construction projects could absorb capital more quickly than industrial ventures, where investors would have faced operating risks, longer development timetables and less predictable exit options.
But the same structure limited the programme’s transformative effect. A hotel apartment can create construction activity and contribute to a resort’s financing, yet it does not necessarily produce the same productivity gains as an export plant, logistics platform, technology business or energy project. The government now acknowledges that a greater share of the proceeds should have been directed towards talent, innovation, productive companies and the real economy.
The economic question is not whether the former scheme brought money into Montenegro. It clearly did. The harder question is whether citizenship was priced appropriately relative to the value granted and whether the resulting capital produced sufficient additional economic activity to justify the legal, reputational and security risks.
Montenegrin citizenship was particularly attractive because applicants were acquiring a passport from a NATO member, a euroised economy and the leading candidate for the EU’s next enlargement. The possibility of future EU membership formed part of the programme’s implicit commercial value, even though no government could guarantee when accession would occur.
That created a fundamental tension. Every step Montenegro took towards EU membership made its passport more valuable to international applicants, but simultaneously made the continuation of investor citizenship less acceptable to Brussels. The programme was therefore most commercially powerful precisely when it became politically unsustainable.
Its legacy also continued well after applications formally closed. The authorities were required to process files submitted before the December 2022 deadline, leading to a substantial number of citizenship decisions during subsequent years. In 2024 alone, 1,282 people received Montenegrin citizenship through pending programme applications, comprising 385 principal applicants and 899 family members.
Among those recipients were 709 Russian citizens, 42 Belarusian citizens and 29 Saudi citizens. The large Russian share attracted particular EU attention following Russia’s invasion of Ukraine and the expansion of European sanctions. Brussels 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 were still being processed when the European Commission prepared its latest detailed assessment. The administrative tail is therefore approaching its end, but due diligence, ownership verification and potential revocation proceedings may remain relevant for years.
A new investor citizenship programme would introduce a disproportionate accession risk relative to the amount of new capital it could realistically attract. The EU has made removal of the programme’s legal foundations part of Montenegro’s alignment obligations. The country would also be attempting to restart the model after the Union’s highest court had rejected the commercial sale of member-state nationality.
For Montenegro’s sovereign risk profile, the cost of confrontation with Brussels would extend far beyond the loss of goodwill. Accession progress influences access to EU grants, concessional financing, infrastructure support and investor perceptions of institutional convergence. Montenegro is already working with European institutions on transport, energy, digitalisation and environmental projects whose combined economic value can exceed the receipts generated by the citizenship scheme.
The Mateševo–Andrijevica motorway section, for example, is expected to use an approximately €500mn financing package involving the European Bank for Reconstruction and Development and the EU. Rail modernisation, electricity-network upgrades, environmental infrastructure and the EU’s Growth Plan for the Western Balkans provide additional sources of lower-cost capital. These flows are slower and more conditional than passport-related investment, but they produce stronger links with the European market and can lower long-term financing risk.
The citizenship programme also needs to be considered against Montenegro’s external imbalances. The country has traditionally relied on tourism receipts, property purchases and foreign capital to finance a large trade deficit. Its current-account deficit widened from 11.4 per cent of GDP in 2023 to 17.1 per cent in 2024, reaching 17.7 per cent in the second quarter of 2025.
In that environment, the loss of a mechanism that mobilised hundreds of millions of euros is noticeable. But the quality and permanence of foreign financing matter as much as the headline amount. Capital used to purchase hotel units supports the balance of payments during construction, while sustainable export businesses, operating resorts and infrastructure investments continue producing revenue after the initial inflow has been spent.
A credible replacement policy therefore has to retain the investment attraction function without linking it to immediate citizenship. The government has indicated that programmes aimed at attracting qualified professionals, entrepreneurs and specialist talent could be considered, but only in cooperation with European partners.
That points towards a residence-based framework rather than another passport programme. Montenegro could offer expedited residence permits to founders, researchers, senior engineers, technology specialists and investors who establish operating businesses, employ local workers and maintain a genuine physical presence. Citizenship would remain available through ordinary naturalisation after an appropriate period, rather than being delivered as the direct consideration for an investment.
Such a model would be more compatible with the direction of EU policy. Several European countries continue to offer residence rights linked to investment, entrepreneurship or employment, although these programmes are also subject to tighter scrutiny. The legal distinction is significant: residence permits remain under national and EU migration rules, while citizenship automatically carries a broader set of political and mobility rights.
For Montenegro, the most useful framework would avoid another passive real-estate route. Eligibility could instead be tied to verified equity investment in operating companies, employment creation, research expenditure, export generation or financing of projects aligned with national development priorities. Renewable energy, digital infrastructure, advanced tourism, food processing, maritime services and environmental technology could all provide qualifying areas.
The authorities would need to define measurable obligations and monitor them over several years. Capital should be deposited through regulated banks, beneficial ownership verified, sources of wealth independently checked and employment or investment commitments confirmed before permanent residence rights are extended. Developers should not receive full access to funds before construction milestones are certified.
A talent-focused route would address one of Montenegro’s most serious structural constraints. The government identifies shortages of qualified personnel across a range of sectors, while the European Commission continues to point to limited administrative and project-delivery capacity. The country needs engineers, construction managers, medical specialists, digital professionals, researchers, tourism executives and experienced industrial operators more urgently than it needs additional owners of passive hotel units.
The policy could also be integrated with Montenegro’s existing investment pipeline. At the EU–Montenegro investment conference held at Luštica in October 2025, companies advanced 14 partnership projects covering renewable energy, transport, agrotourism, digital innovation and low-carbon development. Proposed initiatives included new wind and solar capacity, the decarbonisation of the Port of Bar, a digital innovation campus and projects intended to support the northern municipalities.
These sectors require patient capital and technical expertise. An investor-residence mechanism built around them could complement EU-supported development without creating a conflict over citizenship. It would also help redirect investment from property acquisition towards operating assets and businesses with measurable domestic value added.
The government should still conduct a full economic audit of the closed programme before designing any successor. That assessment needs to separate fiscal receipts from private property purchases, identify how many approved developments reached completion, measure permanent employment and tax revenue, and examine whether promised investments remained in place after citizenship was granted.
Particular attention is needed for condominium-hotel structures. A completed building is not necessarily an operating hotel, while the sale of individual units can create fragmented ownership and complicate professional management. Occupancy, operating income, payroll and municipal revenue offer better indicators of success than construction expenditure alone.
The distribution of the €87mn allocated to less-developed municipalities also deserves transparent reporting. The programme was partly justified as an instrument for narrowing Montenegro’s large regional disparities. Public disclosure of funded projects, procurement procedures, disbursements and completed infrastructure would show whether the contribution created assets with lasting value or merely supplemented general expenditure.
Montenegro is therefore unlikely to develop a “new model” of economic citizenship because the viable policy space has largely disappeared. A relabelled passport scheme, even with higher thresholds and stronger screening, would remain inconsistent with the EU’s central objection that nationality cannot be exchanged directly for money.
The more realistic successor is an EU-compatible investment and talent residence programme, supported by strict due diligence and tied to productive activity. It would generate less immediate marketing appeal than a passport, and probably attract fewer applicants, but the resulting capital would have a better chance of strengthening exports, skills and operating businesses.
The former programme demonstrated that Montenegro can mobilise international investor demand at scale. Its €410mn financial footprint is material, particularly for the northern tourism market. Yet the country’s next investment model will be judged less by the amount entering escrow accounts than by the number of sustainable companies, skilled employees, completed projects and recurring export revenues it leaves behind.
