Montenegro’s former economic citizenship programme is approaching its administrative end almost four years after new applications were formally stopped, with only five of the original 1,113 applications still awaiting a final decision at the end of July 2026. The programme has meanwhile generated approximately €413.5mn in recorded investments, fees and development contributions, leaving behind a sizeable tourism and public-finance legacy but also a politically sensitive citizenship file that Montenegro has had to manage carefully as its European Union accession process accelerates.
Data published by the government show that the Ministry of Interior had issued positive citizenship decisions for 869 applications by 31 July 2026, while 239 applications had been rejected. The remaining five were still being considered by the Prime Minister’s Office and the Ministry of Interior. One additional case that had already received a positive decision was undergoing verification of the associated money transfer.
The numbers mean approximately 78.1% of all submitted applications have resulted in approval, while around 21.5% were rejected and only 0.45% remain unresolved. In administrative terms, almost 99.6% of the original caseload has now been decided.
Only one additional application moved to a positive decision during July. The number of unresolved applications fell from six at the beginning of the month to five, while approvals increased from 868 to 869. The case was submitted through Austrian authorised agent Arton Group GmbH, although the value of the associated investment was not disclosed.
The slow finalisation illustrates the long administrative tail created by Montenegro’s Special Investment Programme of Particular Importance for the Business and Economic Interest of the country. The programme stopped accepting applications on 31 December 2022, but applications filed before the deadline remained valid and continued moving through due-diligence, investment-verification and citizenship procedures.
The scheme began in 2019 and was originally capped at 2,000 principal applications. It was designed around a “grant plus investment” model rather than an outright passport fee. Applicants initially had 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, alongside contributions earmarked for development of less-developed municipalities and administrative fees.
The financial conditions became more demanding during the later phase of the programme. By its final year, the minimum combined financial commitment for an individual application had effectively risen to around €465,000 for qualifying northern projects or €665,000 for projects in the coastal region and Podgorica, before some additional family-related and professional costs.
Part of the increase reflected the introduction of an additional contribution towards Montenegro’s innovation policy. That mechanism is still producing transfers years after the application window closed.
During July, the Innovation Fund of Montenegro recorded another €100,000, increasing cumulative receipts linked to the programme to €31.4mn. The Investment Agency’s records continued to show €31.3mn, with the government explaining that the difference reflected the timing of an independent auditor’s report rather than a disagreement over the transaction itself. Another €500,000 remains in escrow for innovation-policy contributions connected with applications that have not yet completed the process.
The tourism sector received by far the largest share of programme-related capital.
By the end of July, applicants had transferred €251.22mn directly to investors implementing projects on the government’s approved tourism development list. Another **€2.085mn remained on applicants’ escrow accounts for tourism investments awaiting completion of the relevant procedures.
A further €500,000 had been invested in agriculture and processing industries, although the programme ultimately remained overwhelmingly a tourism and hotel-development instrument rather than a diversified industrial-investment mechanism.
The concentration is visible in the projects that dominated the approved development lists. Over the programme’s life, qualifying developments included projects such as Bjelasica 1450 in Kolašin, K16 in Kolašin, Durmitor Hotel and Villas in Žabljak, Boka Place in Tivat, Kolašin Resort & Spa, Montis Hotels & Resorts, and a range of other hotel and mixed-use developments.
The programme became particularly important to Kolašin and northern Montenegro, where the lower investment threshold was deliberately intended to channel capital away from the already more developed coast. Several hotel and condominium projects around the Kolašin ski areas used economic citizenship demand as part of their financing structure.
The model was designed to solve a real investment problem. High-end resort construction in northern Montenegro required large amounts of upfront capital in locations where conventional hotel economics were less immediately attractive than on the Adriatic coast. Allowing foreign investors to purchase qualifying units while simultaneously becoming eligible for citizenship created an additional source of financing.
That does not mean every project performed equally well.
The government removed six tourism projects from the development list in March 2022 after some investors failed to meet investment obligations or provide the required bank guarantees. Those projects included 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 satisfying revised requirements.
The episode demonstrated the central weakness of citizenship-linked development programmes: the passport application can create immediate demand for units, but the long-term economic value still depends on whether the underlying hotel is completed, operated professionally and capable of generating tourism activity once the citizenship incentive disappears.
Montenegro attempted to reduce that risk by tightening requirements, including the use of irrevocable bank guarantees linked to minimum project investment obligations.
The financial legacy is nevertheless substantial.
Adding approximately €251.22mn in tourism investment, €500,000 in agriculture and processing, €43.58mn in administrative fees, €31.4mn transferred to the Innovation Fund and approximately €86.8mn connected with programmes for less-developed municipalities produces recorded programme-related flows of roughly €413.5mn by the end of July 2026.
Another €2.585mn remains in escrow for tourism and innovation-related obligations, meaning the ultimate financial total could move somewhat higher as the final applications are resolved.
The €413.5mn figure should not be interpreted as government revenue.
Approximately €251.7mn went directly into development projects in tourism, agriculture and processing rather than into the state budget. Around €161.8mn represents administrative fees, Innovation Fund payments and amounts associated with support for less-developed municipalities.
The distinction is important because citizenship programmes are sometimes presented as generating hundreds of millions of euros directly for government finances when much of the money is actually private capital invested in commercial developments.
Even so, the fiscal contribution was meaningful for a small economy.
Administrative fees alone generated about €43.58mn for the central Treasury. Payments associated with less-developed municipalities reached roughly €86.8mn, while the Innovation Fund received €31.4mn. These three categories together amount to more than €160mn connected to public institutions or designated development purposes.
The programme’s total recorded financial volume of more than €413mn is equivalent to almost 5% of Montenegro’s expected 2026 GDP, although those flows accumulated over several years and should not be treated as annual economic output.
The more lasting question is what physical assets the programme produced.
Tourism investments can create a stronger economic multiplier than one-off state fees when they result in completed hotels employing staff, purchasing local services and generating accommodation revenue for decades. This was particularly relevant to Montenegro’s northern region, where government policy sought to use tourism investment as an instrument for reducing the development gap with the coast.
Projects around Kolašin have benefited from the simultaneous construction 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 helped create an investment cycle considerably larger than local tourism demand would previously have supported.
The risk is that residential or condominium components can become more economically important than genuine hotel operations.
A property sold to an investor because it qualified for citizenship creates a construction-stage benefit regardless of whether the unit later achieves strong tourist occupancy. The longer-term return to Montenegro is much greater when developments function as successful hotels rather than collections of privately owned apartments with limited commercial utilisation.
That distinction will become more visible now that citizenship-linked demand has disappeared.
Projects completed after the programme must compete for guests and investment capital on conventional tourism economics. Kolašin, Žabljak and other northern destinations will therefore provide a practical test of whether economic citizenship accelerated development that was fundamentally viable or temporarily supported projects that depended heavily on the passport incentive.
The political cost of the programme also needs to be weighed against its financial contribution.
The European Union repeatedly expressed concern about investor citizenship schemes because of potential money-laundering, tax-evasion, organised-crime and security risks, particularly when citizenship of a visa-free country can provide easier access to the Schengen area. Montenegro eventually terminated its programme at the end of 2022, a decision subsequently welcomed by European institutions.
The issue did not disappear immediately with closure because pending applications continued to generate new citizenship decisions.
The European Commission reported in December 2025 that Montenegro’s Ministry of Interior had issued 1,282 citizenship decisions during 2024 to applicants and their family members connected with the former programme, while 29 applications were still being processed as of April 2025. Those figures are not directly comparable with the current 1,113 principal-application count because individual applications could include several family members.
The decline from 29 pending principal cases in April 2025 to only five by July 2026 indicates that the administrative legacy is finally nearing completion.
The EU has become even less tolerant of transactional citizenship structures since Montenegro ended its scheme.
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 return for citizenship. Montenegro is not yet an EU member and the ruling therefore does not retroactively determine the legality of its former national programme, but it materially changes the European legal and political environment surrounding any possible attempt to revive such a model.
The European Commission has also strengthened the connection between investor-citizenship schemes and the Visa Suspension Mechanism, arguing that programmes operated by visa-free third countries can create security risks for the Schengen area. (Migration and Home Affairs)
For Montenegro, that makes reopening the programme increasingly unrealistic as the country moves closer to EU membership.
The European Commission’s June 2026 accession financing communication noted that Montenegro had provisionally closed 16 negotiating chapters, with a possible accession taking place after the beginning of the EU’s 2028–2034 Multiannual Financial Framework, provided the remaining conditions are met. (Enlargement and Eastern Neighbourhood)
At this stage of accession, the value of retaining investor citizenship would be difficult to justify against the potential political cost with Brussels.
EU membership would provide Montenegro with access to a much larger institutional and investment framework than the citizenship programme could ever deliver. European grants, cohesion-type financing, infrastructure funds and increased investor confidence would dwarf the remaining economic benefit of selling an accelerated route to citizenship.
The programme’s closure therefore represents part of Montenegro’s transition from a small non-EU economy using exceptional incentives to attract foreign capital towards a candidate country increasingly required to operate within European regulatory and security standards.
That does not make its financial legacy irrelevant.
More than €250mn flowed into development projects, while more than €160mn was associated with state fees, innovation policy and support for less-developed municipalities. For a country of Montenegro’s size, those are material figures.
The programme also demonstrated the strength of global demand for Montenegrin residency, property and citizenship exposure. Similar capital is continuing to enter the country through conventional real-estate investment even without a passport attached to the transaction.
Foreign investment in property remains one of Montenegro’s largest sources of capital inflow, while new-build housing prices exceeded €2,500 per square metre nationally in 2026 and substantially more in premium coastal developments. This suggests that part of the investment appeal created during the citizenship-programme period has survived its termination.
Montenegro therefore no longer needs to offer citizenship to maintain international property demand at anything resembling previous levels.
The remaining task is administrative rather than strategic.
Five unresolved applications represent only 0.45% of the original 1,113 cases. Once those files and associated escrow transfers are completed, the government will finally be in a position to establish a definitive financial balance for a programme that officially ended on 31 December 2022 but has continued producing citizenship decisions and financial transfers for almost four additional years.
The final numbers are unlikely to differ dramatically from today’s position: roughly €413.5mn already recorded, another €2.585mn held in escrow, 869 approved applications, 239 rejected cases and five decisions still outstanding.
The more consequential legacy will be visible outside the citizenship statistics — in whether the hotels financed through the programme become sustainable tourism businesses, whether money assigned to the Innovation Fund and less-developed municipalities produces measurable economic returns, and whether Montenegro can retain the foreign-investment momentum generated during the scheme without again tying access to citizenship to a predetermined capital contribution.
