Montenegro Adopts Citizenship by Investment Law With EU...

Montenegro's parliament has passed a new citizenship-by-investment law, reopening the program three years after its 2022 closure and setting a minimum investment of EUR 450,000 in government-approved development projects.

The Montenegrin parliament approved the legislation in February 2026, establishing a framework that channels CBI investment specifically into underdeveloped northern regions. The minimum: EUR 450,000 in a government-approved real estate or tourism development project, plus a non-refundable EUR 200,000 contribution to the state. For a family of four, the government fee rises to EUR 250,000. Total outlay for a single applicant sits around EUR 650,000 all-in before legal costs.

That price point puts Montenegro firmly in the upper range of global CBI programs, and well above where the old program sat before its closure. The previous iteration, which ran from 2019 to 2022, required EUR 250,000 invested in development projects in the north or EUR 450,000 in coastal areas, plus a EUR 100,000 government donation. The new law roughly doubles the effective cost.

Why it closed, and why it's back

The original program shut down under EU pressure. Montenegro has been an EU candidate country since 2010, and Brussels made it clear that running a CBI program while pursuing accession was, diplomatically speaking, unwelcome. The EU's position on selling citizenship hasn't softened. The European Commission's 2023 report on CBI programs explicitly flagged the practice as a risk to EU security.

So why reopen? Money. Montenegro's northern regions remain significantly underdeveloped compared to the Adriatic coast. Tourism revenue concentrates in Budva and Kotor while municipalities in the north struggle with depopulation. The government's pitch is that CBI funds will be ringfenced for specific development projects: hotels, resorts, and infrastructure in areas that private capital hasn't reached organically. Whether that works as advertised is another question entirely.

The EU accession question

This is the part that matters most for prospective applicants. Montenegro opened EU accession negotiations in 2012. Progress has been slow, with the European Commission regularly flagging concerns about rule of law, judicial independence, and corruption. Optimistic estimates suggest membership could happen by 2030. Realistic ones push it past 2032.

If Montenegro joins the EU, CBI holders get EU citizenship. That's the implied value proposition, and it's a significant one. An EU passport through Malta's CBI program (the only current EU member offering one) requires EUR 600,000 in contributions plus EUR 700,000 in property investment, held for five years, totaling roughly EUR 1.3 million minimum. Montenegro at EUR 650,000 is half the price for what could eventually become the same thing.

Could. The operative word. EU accession timelines are notoriously unreliable, and there's a real scenario where Brussels conditions membership on shutting down the CBI program again. Applicants are betting on a political outcome they can't control.

Due diligence and the approval process

The new law mandates what the government calls "enhanced" due diligence, though the specifics are still being codified through secondary legislation. What's confirmed: background checks through international databases, source-of-funds verification, in-person interviews for flagged applicants, and a review committee that includes representatives from security services.

Processing time is officially estimated at six months. The old program averaged closer to nine. Applications go through the Ministry of Interior, with a separate investment verification conducted by the Ministry of Finance. Nationals of countries subject to international sanctions are excluded, as are individuals with criminal convictions or pending charges.

The approved project list hasn't been published yet. The government has indicated it will release qualifying developments by mid-2026, and applications won't be accepted until that list exists. So despite the law being passed, the program isn't actually operational today.

How it compares to alternatives

For applicants specifically interested in European options, the landscape is thin. Malta's IIP is the only EU CBI program, and it's expensive, slow (12-14 months minimum residency before citizenship), and accepts fewer than 400 applicants per year. Turkey offers citizenship from $400,000 in real estate, but Turkey isn't in the EU and isn't close to joining. Caribbean programs (St. Kitts, Dominica, Grenada) are cheaper and faster but offer different travel access profiles.

Montenegro's bet is that it occupies a unique middle ground: cheaper than Malta, with a credible (if uncertain) path to EU membership. For applicants with a long time horizon and tolerance for political risk, the math could work. For anyone who needs certainty, it's a speculative play at a price point where speculation should give you pause.

The government expects to begin accepting applications in Q3 2026, once approved development projects are designated and implementing regulations are finalized.