Montenegro Online Gambling Licence 2026: The New Act, the 15% Fee and the 7 November Deadline

What changed, and when

Montenegro’s Parliament adopted a new Law on Games of Chance (Zakon o igrama na sreću) on 31 July 2025. It was published in Službeni list CG 91/2025 on 6 August 2025 and entered into force eight days later, on 14 August 2025 (art. 108). It repealed the 2004 Act and replaced its concession contracts with administrative approvals (odobrenja). Reports that give 1 August 2025 as the start date are using the date the President signed the promulgation decree.

The transition rules are where most published guides are now wrong. As adopted, arts 105 and 106 gave holders of old concessions 270 days to bring their business into line and keep operating. They had to apply for a new approval 90 days before that period ended. After the 270 days every old concession contract “shall be considered terminated”, whatever end date it carried. One year later Parliament changed the number.

Date	Event	Source
31 Jul 2025	Law on Games of Chance adopted	Sl. list CG 91/2025
6 Aug 2025	Published in the Official Gazette	sluzbenilist.me record
14 Aug 2025	In force; the 2004 Act repealed (art. 107)	art. 108
10 Feb 2026	Original deadline to apply for a new approval (270 − 90 days)	art. 105(2), computed
14 Feb 2026	Six-month deadline for implementing rulebooks (art. 103)	computed
11 May 2026	Original end of old concessions (270 days)	art. 106, computed
31 Jul 2026	Amending Act adopted: 270 days becomes 450	Sl. list CG 117/2026, arts 16-17
8 Aug 2026	Amending Act in force, the day after publication	art. 18 of 117/2026
9 Aug 2026	New deadline to apply for an approval (450 − 90 days)	art. 105(2) as amended, computed
7 Nov 2026	Old concessions end (450 days)	art. 106 as amended, computed
1 Jan 2027	50-metre minimum distance between venues applies	art. 22a, art. 16 of 117/2026

Two things in that table are easy to miss. The amendment came into force 89 days after the original 270-day period had already run out, and the amending Act says nothing about the gap between 11 May and 8 August 2026. Its new application deadline also fell one day after the amendment took effect. We read the 450 days from 14 August 2025, the date the Gazette record gives for entry into force. If the day of entry into force is counted differently, the end date moves by a day. As of 20 October 2026, 7 November is 18 days away.

Who can hold an online right

There is no separate online licence in the Act. Article 6(2) says any of the four game types can be offered “via the internet”, and art. 77 gives that right only to companies that already hold an approval for casino games, betting, slot machines or lotteries under art. 6(1). Lotteries are reserved to a company wholly owned by the Government (art. 64), so in practice the base is a casino, betting or slot-club approval.

The applicant itself must be a joint-stock or limited company seated in Montenegro whose core activity is gambling (art. 21). Each type of base approval has its own price:

Base approval	Issued by	One-off fee	Share capital	Bank guarantee (Montenegrin bank)	Term	Premises minimum
Casino	Government, on Ministry of Finance proposal	EUR 2,000,000 per casino	EUR 250,000	EUR 400,000 per casino	15 years	7 tables; risk deposit EUR 150,000
Betting	Uprava za igre na sreću	EUR 1,000 per shop	EUR 200,000	EUR 30,000 + 3,000 per shop	8 years	10 m² per shop
Slot club	Uprava za igre na sreću	EUR 3,000 per club	EUR 200,000	EUR 35,000 + 3,000 per club	8 years	35 m², 10 machines

Sources: arts 32-36 (casino), 44-45 and 50 (betting), 54-56 and 62 (slots). Each guarantee must stay in force for the whole term plus 90 days. Share capital has to be kept at that level for the life of the approval, and holding a second game type means holding the capital for it as well.

With a base approval in hand, the company files for the online decision (art. 78). The file contains its name and tax number, a three-year business plan and the list and rules of the games. The administration decides within 60 days. Before deciding it checks the connection to its own monitoring system, and the operator may not go live until that connection works. Game rules get a separate consent within 30 days (art. 79). Article 78(6) limits each online operator to one starting website, defined as one IP address, website or internet domain.

Everyone else is shut out on purpose. Article 20(1) bans taking part in foreign games of chance where the stake is paid in Montenegro, and collecting stakes in Montenegro for games run abroad. For online play that ban applies to anyone without a Montenegrin online approval (art. 20, last paragraph). Article 80 orders blocking of unlicensed domains, IP addresses and mirror sites, together with the telecoms regulator, and lets the administration ask for payments to unlicensed operators to be blocked. Article 17 bans advertising unlicensed operators in any medium.

What it costs before the first bet

Article 83 sets the online fee in two parts: EUR 10,000 a month fixed, paid by the 15th for the current month, plus 15% of the month’s stakes minus payouts, paid by the 15th for the previous month. Betting is one line. Virtual casino games and virtual slots are a second line with the same EUR 10,000 and 15%. An operator offering both pays the fixed part twice.

The cheapest legal route to online betting is a betting approval with a single shop. In year one, before any revenue:

Item	EUR	Basis
Betting approval, one shop	1,000	art. 44(2)
Shop fixed fee, 12 × 750	9,000	art. 51(2)
Online betting fixed fee, 12 × 10,000	120,000	art. 83(2)
Fixed fees, year one	130,000
Add virtual casino and slots online, 12 × 10,000	120,000	art. 83(5)
Fixed fees with both online lines	250,000
Bank guarantee held, not spent	33,000	art. 44(3)
Share capital held, not spent	200,000	art. 50(1)

The table leaves out the administrative tax with the application (art. 23(4) point 17; we did not find the amount), the cost of the shop itself, the geodetic distance report, translations and notarisation of foreign documents, and the monitoring connection.

The fixed part makes the fee regressive at low volume. Per online line, computed from art. 83:

Stakes minus payouts per month	Fee per month	Effective rate
EUR 20,000	EUR 13,000	65.0%
EUR 50,000	EUR 17,500	35.0%
EUR 66,667	EUR 20,000	30.0%
EUR 100,000	EUR 25,000	25.0%
EUR 250,000	EUR 47,500	19.0%
EUR 1,000,000	EUR 160,000	16.0%

At EUR 66,667 a month the fixed EUR 10,000 equals the 15% part, and the line pays 30% in total. Below EUR 800,000 a year of stakes minus payouts per line, the fixed part is the larger of the two.

Online betting also costs more than the same betting in a shop. A betting shop pays EUR 750 a month and 10% of its daily stakes minus winnings, with negative days counted as zero (art. 51). Online betting pays 15%. Casinos pay EUR 100,000 a year per casino plus 15% (art. 36), and slot machines EUR 75 a month per machine plus 15% (art. 63). Bonuses do not lower any of these bases. Betting-shop bonuses and vouchers are not counted as stakes (art. 51), but online bonus money transferred from the promotional account to the player account may not reduce the art. 83 base (art. 85(7)). The fees go to the state budget and to municipal budgets (art. 4).

What the register shows

Uprava za igre na sreću publishes a list of online operators “active on 2 July 2025”. It is the latest one on its website. We downloaded it on 20 October 2026 and checked each row against the transition rules with a script.

How the transition treats the concession	Operators	Names (website)
Stated expiry already past on the list date	1	Fun Fun (premierbet.me), 19 Mar 2025
Expiry between 14 Aug 2025 and 7 Nov 2026: deemed extended to 7 Nov 2026 (art. 106(2))	7	Meridianbet, Lob Commpany (lobbet.me), Arua (maxbet.me), Alfa-99 Infotech (gamebox9.com), MNA Gaming (admiralbet.me), Soccerbet, Fedora (hatbet.me)
Expiry after 7 Nov 2026: terminated anyway on 7 Nov 2026 (art. 106(3))	5	Sporting Group (ssbet.me), Vezuv (volcanobet.me), Sport Bet (metbet.me), Čibri (zlatnik.me), Luca’s Bet (sansabet.com); cut short by up to seven and a half months

All 13 are local betting brands, and 11 of them use a .me domain. None is an international casino brand. An earlier version of the same list on the government open-data portal, dated 20 December 2024, has the same 13 names, but two rows show older expiry dates. Alfa-99’s concession was renewed from 26 February 2025 to 26 February 2026 and Luca’s Bet’s from 9 December 2024 to 10 December 2026. The regulator has published no list of approvals issued under the 2025 Act.

The open-data registers of 20 December 2024 also show the size of the land-based base that online rights must now sit on. We counted 19 betting operators with 926 shops, 24 slot-club operators with 150 clubs and 2,533 machines, and 4 casinos run by 3 companies. One of those casinos, at the Hotel Splendid in Bečići, had a concession ending 20 April 2025. On 25 July 2025, three weeks before the new Act took effect, the Government granted a new ten-year concession for the same casino to a different company under the 2004 Act. That contract falls under art. 106 like the others. The Act gives casino operators who paid a one-off concession fee a proportional refund once they hold a new approval (art. 106(4)).

Player and payment rules that shape the product

These obligations sit in the Act itself. Incumbents had to meet most of them within the transition period; art. 105(1) names arts 5, 14, 15, 22, 27, 28, 61, 82, 84 and 85 among others.

• Registration: ten data points, including a copy of the identity document, a registered mobile number and the player’s transaction account (art. 81). Online registration needs video-electronic identification under the AML law, which may be automated against the photo in an electronic ID (art. 82).
• Every deposit: only by card or another instrument issued by a credit institution, by transfer from the player’s own account, or in a licensed venue (art. 84(1)). At each online deposit the operator compares a fresh digital photo with the registration data and checks that the money comes from the player’s own account (art. 84(5)-(6)).
• Play: no play on credit, an optional double confirmation, and no cancelling a confirmed stake (art. 85(1)-(2)). Bonuses only through a promotional account the player cannot pay into, and promotional winnings cannot be withdrawn until transferred (art. 85).
• Monitoring: real-time records of all stakes, payouts and winnings, sent to the administration at intervals of no more than 10 minutes, with direct electronic access for the administration and the financial intelligence unit, kept for five years (art. 27).
• Who may not play: under-18s, politically exposed persons and self-excluded players (art. 20(1)). Also excluded are members of households on social assistance, people diagnosed with gambling addiction and people facing criminal proceedings for non-payment of maintenance (art. 15). Self-exclusion and limits take effect within 24 hours (art. 14).
• Advertising: no TV or radio adverts for gambling services between 06:00 and 22:00. Bonus advertising only on the operator’s own website and the sites of clubs it sponsors, and in print only on sports pages (art. 17). No betting on elections or on under-18 sports (art. 20(1)).

The AML side follows the Montenegrin AML law, which the Act cites throughout. The general obligations are covered in our AML guide for online gambling operators.

What the July 2026 amendment changed besides the clock

Službeni list CG 117/2026 runs to 18 articles, and most of them concern land-based enforcement:

• Casinos now pay the EUR 100,000 annual fee pro rata in the year of approval, within 30 days of issue (art. 36(4)-(5) new).
• Every new table, machine or self-service betting terminal needs an administration decision before use: 30 days to approve, 15 days to withdraw. The operator then notifies within three days (arts 32, 48, 59).
• Holding machines or tables without approval becomes a separate prohibition (art. 20(1) point 21a). Inspectors can close premises for 90 days and seize equipment, and where no operator can be identified the owner or user of the premises is treated as the operator (arts 91-92).
• A 50-metre minimum distance between gambling venues applies from 1 January 2027, except for venues already approved (art. 22a).
• The closed tombola gets its own regime: EUR 75,000 capital and 10% of ticket sales minus the prize fund (art. 75).

The online articles (77 to 85) were not touched. The rates in art. 83 are the ones adopted in July 2025.

Where Montenegro sits for an international operator

For a group looking for an internationally usable licence, Montenegro is not one. The approval covers players in Montenegro, requires a Montenegrin company with premises and a local bank guarantee, and allows one website. Where it does make sense is for an operator that wants the Montenegrin market itself and already runs, or will buy, a retail betting or slot business there. The arithmetic above is the test. One online line needs about EUR 66,667 a month in stakes minus payouts before the fee drops to 30%. Thirteen local brands already compete for that domestic market.

For licences sold on cost to international operators, see our cost comparison across jurisdictions and the jurisdiction index. For another regime where bonuses do not reduce the taxable base, see the Denmark fee and duty page.

What we could not verify

• Whether Uprava za igre na sreću has issued any approval or online decision under the 2025 Act. Its published list is dated 2 July 2025, before the Act took effect.
• How the 89 days between the end of the original 270-day period (11 May 2026) and the amendment (8 August 2026) are treated for concessions whose contracts had been “considered terminated”.
• The amount of the administrative tax payable with an application (art. 23(4) point 17).
• Corporate income tax, withholding on dividends and tax on players’ winnings. These sit in other statutes we did not read for this page.