The Montenegrin government has confirmed that it will not revive its previous citizenship-by-investment program, which generated over €410 million in investment, fees, and contributions. This decision follows a lack of discussions with the European Commission regarding a potential replacement model, marking a significant shift in the country’s approach to investor citizenship as it navigates its European Union accession process.
The Special Investment Programme of Particular Importance for Montenegro’s Economic and Commercial Interest was operational from 2019 until December 31, 2022. It facilitated citizenship for qualifying non-EU nationals through investments in government-sanctioned development projects, alongside non-refundable contributions and administrative fees.
According to the Ministry of Regional Investment Development and Cooperation with Non-Governmental Organizations, under the direction of Ernad Suljević, Prime Minister Milojko Spajić‘s administration has not formulated a new scheme nor engaged in formal consultations with Brussels on alternatives.
This stance reflects a broader context where Montenegro is not merely responding to criticisms but is also nearing the completion of its EU accession negotiations. The European Commission has explicitly requested Montenegro to close the program permanently and eliminate any legal frameworks that could allow for a similar initiative in the future. Such programs have been criticized for their potential links to money laundering, tax evasion, corruption, and inadequate security screenings.
The legal landscape shifted further after the Court of Justice of the European Union ruled in April 2025 that Malta’s investor citizenship scheme violated EU law. The ruling emphasized that citizenship cannot be treated as a commercial transaction without a genuine connection to the country.
While Montenegro aspires to join the EU by 2028, reopening an investor citizenship program would jeopardize its progress in critical areas such as justice and security. The government acknowledges that despite the significant financial inflows generated by the program—over €410 million—the actual fiscal impact is complex. A substantial portion of this amount, approximately €251.2 million, was allocated to private investments in tourism-related projects rather than direct government revenue.
Additionally, funding directed toward less-developed municipalities totaled around €87 million, with specific transfers made to the central Treasury throughout 2023 and into mid-2026. While these figures indicate robust inflows, they also highlight that much of this capital was tied to real estate developments rather than broad-based economic growth.
The program required applicants to invest between €250,000 and €450,000, depending on project location, alongside contributions totaling €200,000. This structure aimed to incentivize investment in less developed regions while linking citizenship demand to governmental objectives for year-round mountain tourism.
However, the focus on hotel and resort developments limited the program’s transformative potential. Although these projects stimulated construction activity, they did not necessarily yield long-term productivity gains comparable to other sectors such as manufacturing or technology.
The attractiveness of Montenegrin citizenship stemmed from its association with NATO membership and potential EU accession. This created a tension where enhanced EU integration increased the passport’s value while simultaneously rendering investor citizenship politically untenable.
The legacy of this program continues as authorities process applications submitted before the December 2022 deadline. In 2024 alone, 1,282 individuals received Montenegrin citizenship through pending applications, including notable numbers from Russia and other countries subject to scrutiny due to geopolitical tensions.
The European Commission has urged Montenegro to conduct thorough security checks on remaining applicants and revoke citizenship where necessary. Currently, only 21 applications remain under review as the administrative process winds down.
A potential new investor citizenship program poses significant risks concerning EU accession relative to expected capital inflows. The EU has made it clear that dismantling existing legal frameworks supporting such programs is part of Montenegro’s obligations for alignment with EU standards.
The government is exploring alternative strategies focused on attracting qualified professionals and entrepreneurs without directly linking investment to citizenship. This approach suggests a shift towards residence-based permits for individuals who contribute actively to the economy through job creation or business establishment.
This proposed framework aligns more closely with EU policies regarding migration and investment while avoiding previous pitfalls associated with direct citizenship sales. Such measures could help redirect investments toward sustainable businesses rather than passive real estate holdings.
Montenegro’s future investment strategy must prioritize sectors that bolster long-term economic resilience, such as renewable energy and digital infrastructure. A comprehensive evaluation of the previous program’s outcomes will be essential for informing any successor initiatives aimed at fostering genuine economic development.
The government recognizes that addressing structural skill shortages is crucial for enhancing productivity across various sectors. As Montenegro continues its path toward EU integration, developing an investment model that promotes sustainable growth over short-term financial inflows will be vital for its economic future.
