The Government of Montenegro approved a proposed law on 29 June 2026 to implement the European Digital Markets Act (DMA), a significant regulation affecting digital markets within the European Union. This legislation is particularly relevant for Montenegro as it establishes a framework for addressing the influence of global digital platforms that local businesses increasingly rely on.
The bill incorporates Regulation (EU) 2022/1925, which targets large digital platforms classified as “gatekeepers.” This regulation encompasses essential platform services including online search engines, social media, app stores, operating systems, web browsers, virtual assistants, online intermediation services, advertising platforms, and cloud computing services. The approval of this proposal was confirmed during a government telephone session on 29 June.
The DMA focuses on companies with sufficient market power to control access between businesses and consumers. It is unlikely that Montenegro will develop a domestic platform that meets the EU’s gatekeeper criteria. Instead, local firms typically find themselves in a position where they are dependent on these platforms for various business operations, such as app development, advertising, hotel bookings, retail sales, media distribution, payment processing, and other services that require access to broader audiences.
This law is critical for local businesses; for instance, a hotel in Budva may rely heavily on an international booking platform for foreign guests, while a software company in Podgorica might depend on an app store for distributing its products. Retailers can also be affected by the visibility and customer data access provided by search engines or social networks.
The DMA aims to curb practices that allow gatekeepers to exploit their power over dependent businesses. The regulations specifically tackle issues such as self-preferencing of services, mandatory bundling of products, restrictions against directing users to alternative offers, improper use of personal data combinations, and barriers preventing businesses from accessing information generated through their own customers.
In the EU context, enforcement is primarily managed by the European Commission. Therefore, the effectiveness of Montenegro’s implementation law will depend on how well it defines national cooperation and procedural responsibilities without suggesting that a local authority will independently oversee every global platform.
Potential benefits include increased contestability for software developers who may gain more flexibility in reaching users and utilizing alternative payment methods. Advertisers could receive improved insights into campaign performance, while business users might have enhanced access to data and the ability to contest unfair ranking practices or terms.
However, it is important to note that these changes do not guarantee lower commission rates. The DMA serves as an instrument of competition and fairness rather than price regulation. Platforms may adjust fees or introduce new technical requirements under the pretext of privacy and security concerns. Consequently, Montenegrin businesses must develop the capacity to identify potential violations of these rules and gather evidence to support any complaints.
The legislative process has raised concerns regarding public consultation. Although a consultation was conducted in May, the report indicated minimal substantive participation from industry stakeholders. This lack of engagement suggests either limited awareness among businesses or skepticism about the effectiveness of the consultation process in influencing legislation.
Implementation challenges will be localized. Key questions include which authority will handle information from businesses, how to protect sensitive commercial complaints, methods for transferring evidence to the European Commission, and what remedies are available when a platform’s actions threaten a company’s viability before an investigation concludes.
It is crucial not to conflate this proposal with the separate Digital Services Act (DSA), which addresses illegal content and platform accountability more directly. Montenegro is also working on legislation related to the DSA. Together, these two regulatory frameworks will alter interactions among platforms, users, and companies while addressing distinct issues.
For investors, the adoption of the DMA indicates Montenegro’s progress in aligning its regulatory environment with EU single market standards ahead of potential membership. This alignment reduces future legal discrepancies and raises compliance expectations for domestic intermediaries aiming to expand across Europe.
The proposed bill is still subject to parliamentary approval and subsequent implementation processes. Its implications are already evident: access to Montenegro’s digital market will increasingly be accompanied by obligations aligned with European standards, regardless of where the controlling platform is based.
