Montenegro Citizenship by Investment

The programme set two different sums, and the gap between them was itself the policy rather than a technicality.

Article 10(3) of the Decision on the criteria, manner and procedure for selecting persons who may acquire Montenegrin citizenship by admission for the realisation of the Special Investment Programme sets the threshold. The Decision is published in Official Gazette nos. 079/18, 012/20, 143/21 and 068/22.

It provides in terms that an applicant may acquire citizenship under the programme if they have deposited into an escrow account at least 450,000 EUR for investment in one of the development projects in the capital Podgorica or the coastal region.

The alternative is at least 250,000 EUR for investment in one of the development projects in the Northern or Central region, excluding the capital Podgorica.

The same passport therefore carried two prices, and the cheaper one, lower by 200,000 EUR, went to those placing money in the less developed part of the country — the threshold was used to steer capital north rather than to the coast.

Two features of the mechanism must be read alongside. First, the money was not paid to the state directly but deposited into an escrow account and only then released to the project, so at the moment of application the sum had left the applicant control without yet entering anyone else.

Second, the transfer had to be confirmed by an independent auditor under the procedure laid down in Article 15(3) of the same Decision, and those audit reports were the basis on which the Investment Agency recorded a payment as made.

Read against its timeframe: this was the threshold while the programme was accepting applications, that is until 31 December 2022

The programme has closed, and it is now possible to say how it closed rather than only that it did. The Government of Montenegro's report on the state of the Special Investment Programme, compiled on figures to 31 January 2025, states plainly that the programme ran until 31 December 2022 — so no new applications exist after that date.

The legal frame is given alongside: the Government Decision of 22 November 2018 setting the selection criteria and procedure for those who may acquire Montenegrin citizenship, published in Official Gazette 79/18 and amended three times at 12/20, 143/21 and 68/22.

On that basis the responsible ministry issued the public call on 26 February 2019.

What repays reading most are the outcome figures, because they show a closed programme whose files were still moving years later. By the date the programme closed, the total number of applications for Montenegrin citizenship was one thousand one hundred and thirteen.

As at 31 January 2025, of those: eight hundred and sixty had received a decision granting citizenship and had been issued passports. Two hundred and thirty-nine were rejected, on a negative opinion from the international due-diligence agent or for failing the criteria in the Decision.

Eleven had been reported by the Investment Agency to the Prime Minister as meeting the criteria under Articles 10 and 13, and await a decision by the Ministry of the Interior.

One was under an independent auditor's control of the transfer of funds and two more were with the auditor.

The report also breaks the applications down by the three authorised intermediary agents, naming each.

One accompanying financial figure shows the scale of the flow: on 13 January 2023, thirty-two million nine hundred and ninety-nine thousand eight hundred and forty-nine euros and eighty cents were transferred from the account for the development of less-developed municipalities to the Central Account of the State Treasury.

The programme had three dates and one ceiling, and all four are stated in the instruments rather than inferred. The Decision was adopted by the Government at its session of 22 November 2018 and published in Official Gazette no. 79/18 of 7 December 2018, providing by its own terms that it applied from 1 January 2019 until 31 December 2021.

The programme began on 1 January 2019, and that initial term was later extended to 31 December 2022.

The quantitative ceiling is the least cited feature but it governed the scale of the whole scheme: throughout the life of the programme, decisions granting citizenship could be issued on no more than 2,000 applications. Set against the actual figures, that ceiling was never reached.

The table of the Montenegro Investment Agency, as at 1 September 2026 — a statistical table without its cut-off date cannot be read.

So the date must travel with the figures — records 1,113 applications submitted in total by the three authorised agents, of which 869 had received a decision granting citizenship from the Ministry of the Interior and 239 were refused.

The table breaks this down by agent, and the three columns each add up: Apex Capital Partners doo Podgorica submitted 287, of which 216 granted and 70 refused;

Henley and Partners Government Services Ltd registered in Jersey submitted 531, of which 431 granted and 97 refused; Arton Group GmbH of Austria submitted 295, of which 222 granted and 72 refused.

One reason is given for all 239 refusals together: a negative opinion from the agent assessing international suitability, or failure to meet the criteria laid down by the Decision.

One change of competence also belongs to this timeline: the 2020 amendment to the Decision transferred all work of implementing the programme to the Montenegro Investment Agency, and that amendment was published in Official Gazette no. 12/20 of 11 March 2020.

Read against its timeframe: the programme stopped accepting new applications after 31 December 2022, while transfers and settlement continued for years afterwards

The decision imposes no residence obligation at all, and reading all eighteen of its articles shows why.

The map of provisions runs from subject and definition of the programme, through the licensing of mediation agents and international due-diligence agents, to the applicant's criteria and development projects.

It continues with the citizenship application, criteria for family members, control of payments, the numerical cap, the sanction for false statements, and entry into force.

There is no article on residence.

What binds the applicant is a different set of duties, and the first is that they may not come alone: under Article 13 the citizenship application must be filed through a licensed mediation agent, for the applicant and their family members alike, on a form the competent authority sets and publishes on its website.

The file must carry certified copies of the passport and identity card, extracts from the birth register, extracts from the marriage register, insurance policies valid in Montenegro covering health insurance, and certificates of freedom from infectious diseases issued under the law of the state of which the applicant is a national.

Family members are defined narrowly: the spouse; the applicant's children over 18 whom the applicant supports; and children under 18, who may acquire citizenship on reaching majority.

Family members must satisfy the due-diligence criterion of Article 10, while the spouse and children over 18 must also satisfy the no-conviction criterion.

The heaviest duty sits after the day of naturalisation, and the text puts no time limit on it.

Under Article 17, it may later be established that the naturalised person gave false data or deliberately concealed facts bearing on the criteria in Articles 10 and 13, or that the international due-diligence agent entered inaccurate data in its report.

In that case the competent authority informs the interior administration so that a decision on loss of Montenegrin citizenship is issued.

And a person who loses it on that ground has no right to recover the sums paid under Article 10.

Family members were not part of the programme from the outset but were added later, and the date of that addition can be established precisely.

The Ministry of the Interior records that the 2020 amendment to the Decision, besides transferring the work to the Investment Agency, also extended acquisition of citizenship under the programme to family members of the applicant who are under 18 years of age.

That amendment was published in Official Gazette of Montenegro no. 12/20 of 11 March 2020.

What follows from this, and what does not, is where care is needed. It follows that before March 2020 the route did not include family members at all, so an application lodged in 2019 stood on a different footing from one lodged from 2020 onward.

It does not follow how spouses were treated: the cited text speaks only of family members under 18, so nothing here establishes the position of a husband or wife, whether unmarried partners had any route, or whether parents could be included.

The full conditions sit in Article 13 of the Decision itself, whose text has not been read.

On the practical weight of the family element there is a set of figures, but where it stands must be said plainly: as at 14 May 2022, 279 proposals corresponded to 279 principal applicants and 655 family members, 934 people in total, an average of roughly 2.35 dependants per application.

That set cannot be read again in the documents this record now holds — none of the four sources contains any of the three figures — so it stands as an older record rather than a figure that can be checked again.

Nor can it be refreshed: the current Investment Agency table, as at 1 September 2026, counts applications only and does not break them down by family member; that document does not mention family at all.

One further limit belongs to the older set itself: the source uses the term family members without breaking it down by relationship, so the figure of 655 does not show how many were children and how many spouses

A person granted citizenship under this programme receives the Montenegro passport, so the figure in this cell is the figure for that passport itself.

According to the Passport Index of Prosperous Intelligence, on data dated 30 September 2026, the Montenegro passport reaches 126 destinations without applying for a consular visa in advance. The figure combines three forms of entry and does not count an e-Visa that must be obtained beforehand:

It is therefore a measure of how easily the holder travels, not a count of visa-free countries in the narrow sense.

For comparison, on the same source and the same method of counting, the Vietnamese passport reaches 44 destinations. The two lists of destinations do not nest inside one another, so the difference is an indication rather than a list of places newly opened.

Prosperous Intelligence dates its data and advises checking with the destination’s official authorities before travelling.

The programme has closed to new applications, and that is the wording of the government itself: the status report on the Special Investment Programme as at 1 September 2026, issued by the Ministry of Regional Development and Investment, states that the programme ran until 31 December 2022.

The application figures in that report:

On money, the report records the following, in EUR:

That report does not mention tax, residence or income: the financial architecture of the programme is described in terms of donations, investment, administrative fees and escrow, not tax.

The founding decision adopted on 22 November 2018 and amended three times likewise mentions none of them.

The exclusion motif lies elsewhere and is unmistakable. Article 8(1)(8) of the Citizenship Law requires an ordinary naturalisation applicant to have settled tax and other statutory obligations then due.

But article 12, the provision on which the investment programme rests, permits exceptional naturalisation in the state, scientific, economic, cultural or sporting interest even where the person does not meet the conditions of article 8.

The clean tax record condition is therefore lifted from precisely this route.

One point of accuracy: the founding decision still carries the status of in force in the official gazette so that pending files can be completed, so writing that the programme has been repealed is wrong; writing that it has closed to new applications and is processing a backlog is right.

Beyond the investment there was a second mandatory payment, and merging the two misstates the total cost. It was a donation of 100,000 EUR per application, earmarked for the development of less developed units of local self-government.

This sum travelled by its own route: money held in the applicant escrow account was transferred to an account the Montenegro Investment Agency holds at CKB bank, and the transfer was made only after the independent auditor engaged to check payments had delivered reports confirming that the funds intended for the donation had been moved.

This was not a paper requirement. The 2024 transfers are recorded tranche by tranche with the matching number of applications, each dividing to exactly 100,000 EUR per application. The four tranches fell on 21 June, 25 July, 30 August and 27 September 2024, in the order of the rows below:

At budget level, the balance held on the Agency account for developing less developed areas was transferred to the central account of the state treasury on 13 January 2023, in the amount of 32,999,849.80 EUR; and during 2023 alone, payments into the Agency donation account at CKB bank totalled 33,300,000 EUR.

Read against its timeframe: the 100,000 EUR obligation belonged to the period while the programme was accepting applications, until 31 December 2022, while the transfers listed above are settlement carried out after it had closed