As of October 1, 2026, Montenegro’s economic citizenship programme has left approximately €2.235 million in escrow accounts linked to five unresolved applications. This situation arises nearly four years after the programme was closed to new applicants, indicating a lingering financial and administrative complexity.
Under the citizenship-by-investment framework, Montenegro received a total of 1,113 applications. Out of these, 869 applications were approved and 239 were rejected, while five cases remain pending resolution. The funds in escrow include about €1.835 million allocated for tourism investment projects and €400,000 designated for innovation development.
The funds are still associated with individual applicants and cannot be considered available government revenue. While the remaining amount is relatively small compared to the total programme scale, it highlights the administrative challenges involved in concluding a citizenship investment scheme after accepting no further applications.
Government data indicates that the programme generated around €413.85 million throughout its operation. Of this total, approximately €251.47 million was invested in approved tourism projects, while €86.9 million was directed towards less-developed municipalities. Administrative fees contributed around €43.58 million, and the Innovation Fund of Montenegro received about €31.4 million.
The unresolved cases represent a minor fraction of the overall programme value but underscore the ongoing risks related to settlement processes rather than significant macroeconomic consequences. Escrow accounts serve as safeguards for both applicants and the state by holding investment funds until specific conditions are met; however, unresolved applications can lead to prolonged immobilization of capital.
This situation creates opportunity costs and uncertainty for applicants regarding potential refunds or allocation of their investments. For banks managing these escrow accounts, it necessitates ongoing compliance and legal clarity even after the programme has officially concluded.
The outstanding cases also highlight that Montenegro’s citizenship scheme encompassed more than just tourism financing; it integrated immigration policy with hotel development, regional contributions, and public fees within a single investment framework. While this model attracted substantial capital into Montenegro, it also led to a concentration of investments primarily in tourism and real estate.
A critical question remains regarding how much of this capital has been transformed into fully operational hotels that provide sustainable employment and generate recurring tourism revenue. For investors, distinguishing between committed capital and completed assets is vital since projects backed by citizenship investments can only realize their full economic potential once they are operational.
The legacy of this programme will hinge less on the total funds collected and more on the effectiveness of the tourism developments initiated under it. The remaining €2.235 million is not expected to significantly impact Montenegro’s public finances; however, resolving the outstanding cases would enable the government to finalize another chapter of a programme that ended in 2022 yet continues to impose administrative obligations.
This scenario serves as a reminder for Montenegro that investment-attraction schemes require clear exit strategies alongside entry regulations. The conclusion of a programme does not automatically eliminate its financial responsibilities when substantial funds remain in escrow.
