Montenegro has a new Games of Chance Act, which entered into force on 14 August 2025, bringing significant changes to the gambling sector.

Under the new legal framework, the right to organise games of chance will be granted through licences, replacing the previous concession-based system. Licences for organising casino games of chance will be issued by the government of Montenegro, while licences for other games of chance will be issued by the Games of Chance Administration. Entities currently operating under concession agreements may continue their operations for a maximum of 270 days from the date the new Games of Chance Act entered into force and must reapply for licences within 180 days of its entry into force. Upon the expiration of the 270-day transitional period, all existing concession agreements will be automatically terminated. As was previously the case with concessions, licences can be issued only to companies incorporated in Montenegro, organised in the form of a limited liability company or joint stock company – meaning that in Montenegro, games of chance cannot be organised by other types of companies, foreign companies or entrepreneurs. Once issued, a licence cannot be transferred to third parties.

While the organisation of lottery games was previously permitted in Montenegro, in practice there has been no lottery operator since the end of 2016. The new Games of Chance Act establishes a state-owned lottery, granting the exclusive right to organise lottery games to a company wholly owned by the state of Montenegro.

Online gambling is permitted subject to a licence that can only be given to operators which already hold licences for land-based games of chance. The licence for online games of chance remains valid until the expiry of the associated licence for land-based games of chance. Offshore online operators are not permitted to operate in Montenegro due to a ban on participation in foreign games of chance for which bets are placed within Montenegrin territory. In line with this, the competent authorities are responsible for preventing access to unauthorised online gaming websites. This is enforced through co-operation with an independent regulatory body in the field of electronic communications, which can block access to these sites. The competent authority may initiate the blocking of access through international information exchange and the use of specialised software. Additionally, financial institutions may be requested to block payment transactions and electronic transfers enabling the unauthorised online gambling.

Games of chance are generally divided into two groups:

• lottery games of chance, which encompass games organised by public drawing in which the prize fund is determined in advance; and
• special games of chance, which encompass casino games, betting and games on gaming machines.

There is no differentiation between gambling and gaming.

Recent Changes

With the adoption of the new Games of Chance Act in 2025, significant changes were introduced, including the elimination of the concession model, increased financial obligations for operators, enhanced player protection and underage gambling prevention measures, stricter advertising restrictions, as well as the establishment of a state-owned lottery.

The new legal framework places greater focus on gambling-related social risks, requiring operators to effectively restrict minors from participating in gambling and provide accessible information regarding assistance for gambling-related issues. In this regard, the Games of Chance Act determines when the operators may restrict or temporarily ban players, as well as the cases in which mandatory exclusion applies. Additionally, a self-exclusion mechanism is introduced, allowing players to request exclusion, set loss limits, or restrict maximum bet amounts, either in writing or electronically. Self-exclusion may be temporary or indefinite.

Lottery and other gaming venues must be located at least 150 metres from educational institutions (including primary and secondary schools, schools for artistic education, educational and resource centres, and student dormitories), measured as a straight line from the nearest school building to the nearest entrance of the gaming venue. Previously, a minimum distance of 250 metres was required, but the method of measurement was not specified.

The new Games of Chance Act establishes a stricter regulatory framework for advertising gambling activities. All permitted advertising must include warnings that games of chance can lead to addiction and that individuals under 18 are prohibited from participation. Advertising of social responsibility initiatives by gaming operators is not considered advertising of games of chance, provided such advertisements include the required warnings and information on assistance for gambling-related issues. Operators may display their logo but must refrain from inviting participation in gambling. Advertising prohibitions do not apply to lottery games.

The minimum share capital requirement for betting and gaming machine operators has increased from EUR75,000 to EUR200,000. For casinos, the mandatory share capital has been reduced from EUR300,000 to EUR250,000. The required daily risk deposit for casinos is now set at a minimum of EUR150,000 for up to seven tables, with an additional minimum of EUR30,000 for each subsequent set of five tables. Betting operators must maintain a daily risk deposit of at least EUR300 per betting shop. For gaming machine operators with electronic roulettes, the risk deposit remains unchanged at a minimum of EUR5,000 per electronic roulette machine.

Bank guarantees to secure payment of winnings to players and fulfil obligations to the government have been increased as follows:

• casinos – EUR400,000;
• betting ‒ EUR30,000 plus EUR3,000 for each betting shop; and
• gaming machines – EUR35,000 plus EUR3,000 for each venue.

All operators must install video surveillance at the entrances and exits of gaming venues and retain footage for a minimum of 90 days. Previously, this requirement applied only to casinos.

Social gaming

A game qualifies as a game of chance only if it has all three mandatory features, as follows:

• a consideration is paid;
• the outcome is determined by chance; and
• there is a prize of money, goods or services.

Hence, social gaming is not considered a game of chance and is not regulated, and, despite the growing concern of regulators in many jurisdictions over the potential risks this activity bears, it has not been under the spotlight of the Montenegrin regulator so far.

Esports

The current regulatory regime permits betting on esports, as the definition of betting is open enough to cover any type of uncertain event.

Fantasy sports

Betting on fantasy sports is permitted and is regularly offered in the market. The definition of betting is not restricted to real sports and can cover all sorts of virtual events, such as fantasy sports.

Skill gaming

Skill gaming, as such, is not regulated. When making a distinction between games of chance and games of skill, one should apply the “any chance” test. If the outcome of a game is, to any extent, determined by chance, it will fall within the games-of-chance category, on the condition that the other two elements – consideration and a prize in money, goods or services – are present as well.

Blockchain or cryptocurrency

To date, blockchain technology and cryptocurrencies in general, and their application in the games-of-chance sector, have not been under the scrutiny of the regulator, as the current legislation does not provide for any restrictions related to the underlying technology of online gambling platforms, or to the use of cryptocurrencies. That said, given the lack of regulations, Montenegrin banks are reluctant to co-operate with companies dealing with cryptocurrencies, which may be a practical obstacle for operators intending to include cryptocurrencies in their business model.

Montenegrin legislation permits online gaming; that is, the provision of games of chance via the internet or via other means of telecommunication. This right is subject to a licence for online gaming. However, this licence can only be issued to an operator that already holds a licence in Montenegro for any type of land-based game of chance. As a result, the online licence serves more as an extension of an existing licence rather than a standalone licence. Furthermore, online gaming providers are allowed to operate only one website.

An online gaming licence allows holders to organise any type of game of chance, irrespective of the underlying type of land-based licence. Therefore, a licence for online gaming issued to a holder of any kind of licence for land-based games entitles its holder to offer betting, virtual casinos and online slot games via the internet. The fixed part of the fee for organising online games of chance, which is paid monthly, amounts to EUR10,000 for online betting games, and EUR10,000 for virtual slots and casinos, plus a monthly variable fee of 15% of the gross gaming revenue.

Social Gaming

Social games are not regulated, as such, and may be freely organised. However, if a social game qualifies as a game of chance (ie, if players pay to participate in the social game, if the outcome of the game depends on chance, and if there is a prize in the form of money, goods or services), that social game would require a licence for online games of chance.

Betting

Betting is permitted in Montenegro, with a few restrictions. Namely, it is not permitted to organise betting on the results of political elections, and owners or shareholders of sports clubs cannot simultaneously be providers of sports betting on the results of the sport their club is playing or on results in the league in which their club is competing. Betting licences are valid for eight years. The operator may apply for a new licence between 120 and 60 days prior to the expiration of the current licence. Operators hold a single licence for betting activities. However, they are required to obtain separate approvals for each individual betting shop they intend to operate. Each approval for individual shops is valid until the expiry of the operator’s eight-year licence, irrespective of when the approval for a particular shop was obtained. All betting shops must be connected over the internet to the regulator’s system.

Poker

Montenegrin law does not regulate poker as a separate type of game of chance, but rather considers it to be a type of casino game; thus, it can be played only in casinos.

Bingo

The new legislation does not regulate bingo as a separate type of game of chance.

Casinos

Casinos are permitted in Montenegro. Operating a casino requires a licence, which is issued by the government of Montenegro. The licence is granted for fifteen years. The operator may apply for the new casino licence between six and three months prior to the expiration of the current licence. A casino licence includes the right to offer gaming machines.

Gaming Machines

It is permitted to offer games of chance on gaming machines, subject to a licence issued by the Games of Chance Administration. However, a separate licence for gaming machines is not required when they are offered in casinos, because the casino licence covers gaming machines as well. The licence is granted for eight years, and a separate approval must be obtained for each slot machine hall. The individual approvals are valid until the expiry of the licence term.

Lotteries

The offering of lottery games is permitted; however, under the new legislation, the exclusive right to organise lottery games is granted to a company wholly owned by the state of Montenegro. The organiser must pay an annual fixed fee of EUR100,000 and a monthly fee equal to 10% of the base amount, calculated as the total value of all tickets, slips, and cards sold, less the value of the prize fund. 

The key piece of legislation that regulates the gambling sector in Montenegro is the Games of Chance Act (Zakon o igrama na sreću, “Official Gazette of Montenegro”, No 091/25).

A game of chance is defined as a game in which the participants have an equal opportunity to win a prize (in money, goods or services) against an indirect or direct payment of consideration, while the result of the game depends on chance or some uncertain event in the game. The notion of games of chance does not encompass:

• quizzes, where the outcome depends on one’s knowledge;
• entertainment games on computers, simulators, video game machines, and pinball and similar machines; or
• billiards, darts and similar games, where the only prize can be one or more free games of the same kind. 

There are no guidelines regarding the extent to which the outcome of a game must depend on chance in order to be considered a game of chance, provided that it also encompasses the other two mandatory elements (the consideration and the prize).

Montenegrin legislation does not provide for a special definition of land-based gambling. The general definition of games of chance applies to any type of game and covers both online and land-based products.

A game of chance provided via the internet or other telecommunication means is defined as one in which the player can participate independently by interacting with the system, without the need for direct involvement from the operator.

The key offences stipulated under the Games of Chance Act are as follows:

• enabling, registering, or permitting the participation of minors under the age of 18 in games of chance;
• collecting stakes in Montenegro for participation in games of chance organised abroad;
• selling, holding, issuing, marketing or otherwise presenting foreign lottery tickets and other foreign tickets for gambling in the territory of Montenegro;
• organising games of chance in free zones;
• organising games where participants pay a certain amount of money to participants who have already joined the game and expect payment of a certain amount of money from participants who will join the game later on (money chain and similar), as well as any other payments and promises of gains contrary to the aleatory nature of games of chance;
• receiving payments at the cash desk, gaming table, self-service terminal, or online by third parties on behalf of the player;
• organising casino games in residential-commercial buildings;
• organising games of chance in contravention of the Games of Chance Act;
• enabling the acceptance of bets for games of chance on behalf of and for the account of the operator, unless otherwise expressly provided by the Games of Chance Act;
• allowing or enabling minors under the age of 18 to enter premises where games of chance are organised;
• allowing minors under the age of 18 to enter casinos, betting shops or gaming-machine shops, or to be registered as players on online gambling platforms;
• organising games of a pyramidal nature (chain letters and similar activities);
• organising prize games involving goods and services in which the prize is paid in cash or other means of payment, or where such cash prize or means of payment constitutes an integral part of the prize;
• the exchange of a prize in goods or a service obtained in games of chance for the monetary equivalent of the goods or service received;
• organising games of chance without obtaining a licence in advance;
• organising games of chance in which the same conditions are not guaranteed to all players;
• having gaming machines or tables for which the Games of Chance Administration has issued an approval, but which have not been put into operation in the premises where special games of chance are organised;
• having equipment for organising betting, or games of chance on gaming machines, in premises where special games of chance are organised, which does not allow for the storage, archiving, and electronic exchange of data with the software solution of the administrative authority, after its commercial use has been permitted by a decision of the competent authority;
• organising betting by an operator who is the owner or co-owner of a sports club on events in which that sports club participates;
• organising games of chance related to the results of parliamentary, local, and presidential elections, for presidents of the member states of the EU, for members of Parliament, for representatives in the EU Parliament, and for members of representative bodies of units of local self-government;
• organising games of chance related to sports events involving teams composed of persons under 18 years of age;
• the sale, possession, commercial transfer, leasing, advertising, and any form of promotion of lottery games of chance organised by business entities without the approval of the competent authority; and
• any advertising of games of chance on sports equipment in all sports categories involving participants under the age of 18.

Organising games of chance without an approval of the Games of Chance Administration is a criminal offence punishable by a monetary fine or imprisonment for up to three years. In addition, if in such a case the provider of games of chance or the player uses deception, they can be punished by imprisonment for between three months and five years. Furthermore, a monetary fine or a penalty of imprisonment for up to two years can be imposed for the unauthorised sale of gambling tickets or collection of payments for games organised abroad.

Additionally, licensed organisers of games of chance that breach various requirements of the Montenegrin Games of Chance Act can be fined up to EUR20,000 for a misdemeanour.

Furthermore, licences may be revoked in one of the following cases: 

• where the operator ceases to meet the requirements for obtaining the licence;
• where the licence was granted on the basis of incorrect data; 
• where the casino operator did not start operations in the casino after relocation within 90 days of obtaining approval for relocation;
• where the operator breaches the rules of games of chance; 
• where the operator fails to pay duties under the Games of Chance Act or fails to pay winnings to players; 
• where the operator does not allow, or otherwise prevents, supervision to be performed in accordance with the Games of Chance Act, or makes the supervision difficult; 
• where the operator incorrectly reports the realised turnover; 
• where the operator lends money to players; 
• where a minor was found present as a player in a premises where games of chance are organised (betting shop, casino, gaming machine club);
• where the operator violates the provisions of the Act on Prevention of Money Laundering and Financing of Terrorism;
• where bankruptcy or liquidation proceedings have been initiated against the operator pursuant to the law governing bankruptcy and liquidation;
• where the operator does not have a guarantee from a credit institution with a registered office in Montenegro;
• where the merger of commercial entities is carried out in a manner that is not in compliance with the Games of Chance Act; and
• when the supervision process reveals that an operator, previously fined for a violation related to ensuring supervision and compliance with the prescribed technical, IT and other requirements, has repeated the same violation.

If a casino operator holds multiple licences, revocation of one licence results in the revocation of all licences for casino games held by that operator.

The primary regulatory authority for the gambling industry in Montenegro is the Games of Chance Administration, which is under the supervision of the Ministry of Finance. Additionally, the government of Montenegro is the body that issues licences for casino games.

The new legal framework is expected to improve the regulation of the gambling sector in Montenegro by enhancing control over operations, strengthening anti-money laundering measures, providing improved protection for minors, and establishing a stable institutional framework.

The current legislation provides for the following types of licences applicable to the provision of games of chance:

• a licence for TV tombola and tombola;
• a licence for casino games;
• a licence for gaming machines;
• a licence for betting; and
• a licence for online gambling.

It is important to point out that a licence for online gambling can only be issued to an entity that already holds a licence for land-based special games of chance, and cannot be granted as a standalone licence.

The availability of licences depends on the type of licence sought. In this sense, licences for casino games of chance, betting, gaming machines, TV tombola and tombola are available on request. The licence for online gambling is also available on request but can only be granted to holders of a licence for land-based special games of chance. Licences for organising casino games of chance are issued by the government of Montenegro, while licences for other games of chance are issued by the Games of Chance Administration. On the other hand, the right to organise lottery games is granted to a company wholly owned by the state of Montenegro.

Every type of game of chance licence is granted for a fixed time period. The duration of individual licences is as follows:

• TV tombola and tombola – eight years;
• casino games – fifteen years;
• gaming machines – eight years;
• betting – eight years; and
• online gambling – under the Games of Chance Act, no provision is given regarding the duration of the term for online gambling licences.

A general condition for any operator is that it be incorporated in Montenegro in the form of either a limited liability company or a joint stock company. Additional specific requirements – such as the documents that must be provided with the application, the minimum share capital, the amount of the mandatory bank guarantee for the payment of duties and winnings, and staffing requirements – are prescribed separately for each licence type. 

Documents/Information Required

Licences for TV tombola and tombola

Applications for licences for TV tombola and tombola must be submitted to the Games of Chance Administration along with the following documents:

• proof of registration of the company;
• memorandum of association;
• a three-year business plan;
• proof of ownership of, or the right to use, business premises;
• game rules;
• proof that the minimum share capital requirement of EUR75,000 is met; and
• an unconditional guarantee of a credit institution with a registered office in Montenegro of EUR10,000 (as security for the payment of duties and winnings).

Casino licences

The conditions that the interested party must meet, the documents that must be provided with the application, and the criteria for the award of the casino licence are prescribed by the Games of Chance Act. The Games of Chance Act prescribes multiple documents/information to be delivered with the application for a casino licence, as follows:

• proof of registration in the Central Registry of Commercial Entities or another appropriate registry in the country where the company, founder, or company member has its registered office or residence;
• tax identification number (TIN), name and seat of the company;
• memorandum of association;
• list of shareholders or stockholders of the company, including full names and residential addresses and/or company names and registered office addresses, information on registration numbers, as well as the total nominal value of shares or stocks and the percentage share in the share capital of the company;

• an excerpt from the registry if the member of the company is a legal entity, or from another public registry if the founder or member of the company is a foreign legal entity, and a list of shareholders or stockholders, including their names and residential addresses and/or company names and registered office addresses, as well as the total nominal amounts of shares or stocks and the percentage of participation in the share capital of the founding legal entity;
• a certified copy of the identification document showing the data on the name, surname, date and place of birth for the director, company members, and members of the management and governing bodies;
• data on the beneficial owner, in accordance with the Act on Prevention of Money Laundering and Financing of Terrorism;
• a notarised statement that the company is not a beneficial owner of an affiliated company with another company that already holds the right to organise casino games;
• a certificate from the authority responsible for maintaining criminal records for the director, authorised/legal representatives, company members, management and executive body members, founders, and the beneficial owners, confirming that no criminal proceedings are pending against the aforementioned individuals nor have they been convicted of offences punishable by an unconditional prison sentence of one year or more, including crimes related to payment transactions, economic operations, life and bodily integrity, freedoms and rights, labour rights, environment and spatial planning, general safety, computer data security, legal transactions, IP, and official duty (for Montenegrin citizens, this information is verified ex officio – if any of these individuals is not a Montenegrin citizen, they must submit a certificate from their country of citizenship, and a certificate from any country where they have resided in the past two years);
• a certificate issued by the authority responsible for maintaining criminal records, evidencing that no criminal proceedings are being conducted against the founder and the beneficial owner of the company, nor has a final and binding conviction been pronounced in connection with the performance of professional activities;
• if the founder or member of the company is a foreign legal or natural person, a certificate, confirmation, or other act issued by the administrative authority competent for the collection of tax revenues, or the competent authority of the country in which the founder and member of the company have their registered office or residence, which must not be older than 30 days as of the date of submission of the application;
• proof of the minimum share capital of EUR250,000;
• a three-year business plan;
• balance sheet and income statement for the previous two years (depending on the date of establishment or commencement of activity), or audit reports of the financial statements of the founder or member of the company (if they are subject to audit), for the previous two years prepared by an authorised auditor, in accordance with the regulations of the country of origin of the member or founder;
• contract regarding the ownership right or the right of lease of the premises in which the operator intends to conduct casino games;
• a report on the distance from educational institutions prepared and certified by a licensed geodetic organisation;
• proof of payment of the administrative fee;
• game rules for each game that will be organised;
• the price of a token or credit point in slot machine games, with a description of the method of recording in the slot machine total registry and the final deadline for payment to participate in the game; and
• data on the type and number of gaming machines and gaming aids, with detailed information for their identification if such are used in the premises for which the licence is being requested.

Betting licences

An application for a betting licence must be submitted to the Games of Chance Administration along with the following documents/information:

• proof of registration in the Central Registry of Commercial Entities or another appropriate registry in the country where the company, founder, or company member has its registered office or residence;
• tax identification number (TIN), name and seat of the company;
• memorandum of association;
• list of shareholders or stockholders of the company, including full names and residential addresses and/or company names and registered office addresses, information on registration numbers, as well as the total nominal value of shares or stocks and the percentage share in the share capital of the company;
• an excerpt from the registry if the company member is a legal entity, or from another public registry if the founder or member of the company is a foreign legal entity, and a list of shareholders or stockholders, including their names and residential addresses and/or company names and registered office addresses, as well as the total nominal amounts of shares or stocks and the percentage of participation in the share capital of the founding legal entity;
• a certified copy of the identification document showing the data on the name, surname, date and place of birth for the director, company members, and members of the management and governing bodies;
• data on the beneficial owner, in accordance with the Act on Prevention of Money Laundering and Financing of Terrorism;
• a notarised statement that the company is not a beneficial owner of an affiliated company with another company that already holds the right to organise casino games;
• a certificate from the authority responsible for maintaining criminal records for the director, authorised/legal representatives, company members, management and executive body members, founders, and the beneficial owners, confirming that no criminal proceedings are pending against the aforementioned individuals nor have they been convicted of offences punishable by an unconditional prison sentence of one year or more, including crimes related to payment transactions, economic operations, life and bodily integrity, freedoms and rights, labour rights, environment and spatial planning, general safety, computer data security, legal transactions, IP, and official duty (for Montenegrin citizens, this information is verified ex officio – if any of these individuals is not a Montenegrin citizen, they must submit a certificate from their country of citizenship, and a certificate from any country where they have resided in the past two years);
• a certificate issued by the authority responsible for maintaining criminal records, evidencing that no criminal proceedings are being conducted against the founder and the beneficial owner of the company, nor has a final and binding conviction been pronounced in connection with the performance of professional activities;
• if the founder or member of the company is a foreign legal or natural person, a certificate, confirmation, or other act issued by the administrative authority competent for the collection of tax revenues, or the competent authority of the country in which the founder and member of the company have their registered office or residence, which must not be older than 30 days as of the date of submission of the application;
• proof of the minimum share capital of EUR200,000;
• a three-year business plan;
• balance sheet and income statement for the previous two years (depending on the date of establishment or commencement of activity), or audit reports of the financial statements of the founder or member of the company (if they are subject to audit), for the previous two years prepared by an authorised auditor, in accordance with the regulations of the country of origin of the member or founder;
• contract regarding the ownership right or the right of lease of the premises in which the operator intends to conduct casino games;
• a report on the distance from educational institutions prepared and certified by a licensed geodetic organisation;
• proof of payment of the administrative fee;
• game rules for each game that will be organised;
• data on the type and number of gaming machines and gaming aids, with detailed information for their identification if such are used in the premises for which the licence is being requested;
• list of locations for receiving payments for betting games;
• proof of payment of a one-time fee in the amount of EUR1,000 per betting shop; and
• an unconditional guarantee of a credit institution with a registered office in Montenegro of EUR30,000 and EUR3,000 for each betting shop (as security for the payment of duties and winnings).

Gaming-machine licences

An application for a gaming-machine licence must be submitted to the Games of Chance Administration along with the following documents/information:

• proof of registration in the Central Registry of Commercial Entities or another appropriate registry in the country where the company, founder, or company member has its registered office or residence;
• tax identification number (TIN), name and seat of the company;
• memorandum of association;
• list of shareholders or stockholders of the company, including full names and residential addresses and/or company names and registered office addresses, information on registration numbers, as well as the total nominal value of shares or stocks and the percentage share in the share capital of the company;
• an excerpt from the registry if the member of the company is a legal entity, or from another public registry if the founder or member of the company is a foreign legal entity, and a list of shareholders or stockholders, including their names and residential addresses and/or company names and registered office addresses, as well as the total nominal amounts of shares or stocks and the percentage of participation in the share capital of the founding legal entity;
• a certified copy of the identification document showing the data on the name, surname, date and place of birth for the director, company members, and members of the management and governing bodies;
• data on the beneficial owner, in accordance with the Act on Prevention of Money Laundering and Financing of Terrorism;
• a notarised statement that the company is not a beneficial owner of an affiliated company with another company that already holds the right to organise casino games;
• a certificate from the authority responsible for maintaining criminal records for the director, authorised/legal representatives, company members, management and executive body members, founders, and the beneficial owners, confirming that no criminal proceedings are pending against the aforementioned individuals nor have they been convicted of offences punishable by an unconditional prison sentence of one year or more, including crimes related to payment transactions, economic operations, life and bodily integrity, freedoms and rights, labour rights, environment and spatial planning, general safety, computer data security, legal transactions, IP, and official duty (for Montenegrin citizens, this information is verified ex officio – if any of these individuals is not a Montenegrin citizen, they must submit a certificate from their country of citizenship, and a certificate from any country where they have resided in the past two years);
• a certificate issued by the authority responsible for maintaining criminal records, evidencing that no criminal proceedings are being conducted against the founder and the beneficial owner of the company, nor has a final and binding conviction been pronounced in connection with the performance of professional activities;
• if the founder or member of the company is a foreign legal or natural person, a certificate, confirmation, or other act issued by the administrative authority competent for the collection of tax revenues, or the competent authority of the country in which the founder and member of the company have their registered office or residence, which must not be older than 30 days as of the date of submission of the application;
• proof of the minimum share capital requirement of EUR200,000;
• a three-year business plan;
• balance sheet and income statement for the previous two years (depending on the date of establishment or commencement of activity), or audit reports of the financial statements of the founder or member of the company (if they are subject to audit), for the previous two years prepared by an authorised auditor, in accordance with the regulations of the country of origin of the member or founder;
• contract regarding the ownership right or the right of lease of the premises in which the operator intends to conduct casino games;
• a report on the distance from educational institutions prepared and certified by a licensed geodetic organisation;
• proof of payment of the administrative fee;
• game rules for each game that will be organised;
• data on the type and number of gaming machines and gaming aids, with detailed information for their identification if such are used in the premises for which the licence is being requested;
• list of locations for organising slot machine games;
• proof of payment of a one-time fee in the amount of EUR3,000 per gaming machine club; and
• an unconditional guarantee of a credit institution with a registered office in Montenegro of EUR35,000 and EUR3,000 for each gaming machine club (as security for the payment of duties and winnings).

Online gambling licences

The main requirement for obtaining a licence for online gaming is that the operator already holds a licence for land-based special games of chance. An application for an online gambling licence must be submitted to the Games of Chance Administration along with the following documents/information:

• name, tax identification number and seat of the company;
• a three-year business plan; and
• a list and rules of the games that will be organised.

The administrative decision-making process must be completed within a general deadline of 60 days from submission of the application. Prospective applicants also have to take into account that the preparation of the application may take some time, as they have to engage a licensed company to inspect the premises and confirm that the relevant technical requirements are satisfied.

The Games of Chance Act does not provide for any specific application fees; thus, the applications for licences are subject only to an administrative fee of EUR2, applicable to administrative procedures in general.

The awarded casino operator is obliged to pay a one-off fee of EUR2 million. There is no similar award fee for other types of licences for games of chance.

The regime of ongoing fees for operators is a combination of fixed and variable fees, payable monthly or annually. The fees are different for each licence type, as follows.

• Casino games – there is an annual fixed fee of EUR100,000, and a monthly variable fee of 15% of the gross gaming revenue. For gaming machines in a casino, a fixed concession fee of EUR75 per machine is payable monthly, plus a monthly variable fee of 10% of the gross gaming revenue.
• Lottery games – there is no fixed or monthly variable fee.
• TV tombola and tombola – there is no fixed or monthly variable fee.
• Betting – there is a monthly fixed fee of EUR750 per betting shop, as well as a monthly variable fee of 10% of the gross gaming revenue.
• Gaming machines – there is a monthly fixed fee of EUR75 per gaming machine, as well as a monthly variable fee of 10% of the gross gaming revenue.
• Online gambling – there is a monthly fixed fee of EUR10,000 for online betting, plus another EUR10,000 for online casino games and slots, along with a monthly variable fee of 10% of the gross gaming revenue. These fees are charged separately for betting games, virtual casino games, and virtual slot games.

The new Games of Chance Act does not regulate personal licensing – ie, it does not impose any obligations on the employees of operators relating to professional qualifications.

Premises where games of chance are organised must satisfy various technical and spatial requirements, and compliance with these conditions must be checked by the gaming authority within 30 days from submitting the application. Technical compliance must be maintained for the duration of the licence and regular inspections may be carried out by the gaming authority.

Casinos

A casino must be arranged in such a way that both the gaming areas and the guest and casino staff areas are integrated in a single space, where the minimum size of the casino is 400 square metres. In addition, the casino must have at least seven gaming tables. It is prohibited to organise casino games in mixed-use (residential/commercial) buildings. A special label, issued by the Ministry of Finance and displaying the main data on the operator and the concession, must be displayed at the entrance to the casino. Within the casino, there must be a:

• cash register;
• a separate and secured area to store money and other valuables; and
• an exchange office.

There must also be a catering area.

Audio-video surveillance must be installed inside the casino, so that it can cover:

• the entrance and exit;
• the reception;
• any place where gaming chips can be purchased (cash register and exchange office);
• live game tables;
• roulette tables and gaming machines;
• the calculation process – whether it is performed at the table or in a separate calculation room; and
• the movement of money or gaming chips in general.

Video surveillance cameras and monitors must be in colour, and the recordings must always show the date and time of recording. Access to the control room in which the equipment for audio-video surveillance is stored must be strictly guarded, and only authorised security personnel may gain access.

Betting Shops

The minimum permitted size of a betting shop is ten square metres. The premises must be equipped with an IT system for receiving payments that is connected to the central database of the regulatory authority, and there must be a metal safe in the premises for keeping the winning, non-winning and cancelled betting tickets, as well as the fire protection device. Betting rules, the options on offer and the results of the betting must be displayed in a dedicated notice space.

A special label, issued by the Ministry of Finance and indicating the main data on the operator and the licence, must be displayed at the entrance to the betting shop.

Payments for bets can only be made at payment points of betting shops or at betting terminals for which a licence has been granted, while the area dedicated to betting terminals cannot be less than three square metres per terminal. Betting via betting terminals can be organised not only in betting shops, but also in casinos and slot-machine clubs. The premises for receiving bets on betting terminals cannot be less than three square metres.

Gaming-Machine Venues

A gaming-machine venue must have at least ten gaming machines, and the gaming and guest areas must have a total combined area of at least 35 square metres.

A gaming-machine venue must have a cash register and a separate secured area for storing money and other valuables, and it may also have a hospitality section in which drinks and beverages may be served, or a hospitality section for preparing and serving food.

The operator is obliged to have a control IT system in place that allows the gaming machines to be connected to the IT system of the gaming regulator.

Also, a special label, issued by the Ministry of Finance and indicating the main data on the operator and the licence, must be displayed at the entrance to the gaming-machine venue.

The operator is obliged to display the following inside the premises:

• the game rules;
• a warning that gambling is prohibited to persons under the age of 18; and
• the minimum return rate percentage of the gaming machines.

In the case of multi-player gaming machines, the operator is obliged to provide at least three square metres of space per possible player.

Also, the gaming machines must support the SAS (Slot Accounting System) protocol.

Tombola

The premises used for tombola must be organised and must meet certain hygienic-technical conditions. The area must not be under 100 square metres.

The tombola operator must use the following equipment:

• a transparent drum with an automatic ball ejection system;
• an electronic counter of drawn play balls with lights;
• an electronic display with illuminated numbers or a computer system for monitoring the draw, with an appropriate device for displaying results;
• a TV camera with a monitor; and
• an appropriate sound system.

There must be a special label, issued by the Ministry of Finance, indicating the main data on the operator and the licence, displayed at the entrance to the tombola venue.

TV Tombola

The premises (TV studio) inside which TV tombola is being organised cannot have an area of less than 30 square metres, excluding the audience sector.

The organiser of bingo and TV tombola is obliged to ensure the monitoring of the draw of numbers and the entire course of the game through a live TV broadcast.

Any operator holding a land-based gambling licence of any type can apply for an online licence. Due to insufficient regulation in this area, the interpretation is that the online licence, once granted, gives its holder a right to organise any type of gambling online. Practically, that means that the online games provided by the operator are not tied to the types of games for which the operator holds a land-based licence. To illustrate the situation, a company with a licence for land-based gaming machines can obtain a licence for online gambling and offer betting on its website. There is an obligation for the operator to report to the competent authority on all games that they organise online and to submit rules for each online game of chance. The operator can have one initial website (IP (internet protocol) address, website, internet domain) for organising online games of chance.

Business-to-business provision of services in the gambling sector is not a regulated activity in Montenegro. No licence is required for providers of software or services to a licensed operator as long as the provider itself is not offering the games to customers.

The use of affiliates has not been under the spotlight of the regulator and there are no particular statutory rules or restrictions in this respect.

There are no particular licensing or regulatory requirements for white-label providers. The regulator’s approach is generally neutral in this respect, and any type of arrangement for the supply of online gambling platforms or services to operators is permitted.

Under the current legislation, it is forbidden to participate in games of chance organised abroad when the stakes are paid in Montenegro, or to collect stakes in Montenegro for games of chance organised abroad. These restrictions, in the context of online gambling, refer to legal entities that do not have authorisation to organise online games of chance, so the online offering of offshore operators unlicensed in Montenegro is not permitted. The competent authorities have the obligation to prevent access to websites of unauthorised online gaming operators, through technical measures that enable the blocking of all domains, IP addresses, and alternative network pathways, including the use of technologies for the identification of “mirror” or duplicated websites. In the event of circumvention of the blockade, all associated domains and IP addresses may be blocked using geolocation and other network technologies to identify the source. The competent authority, in co-operation with the relevant authorities of other countries, may initiate the blocking of access to illegal operators through international information exchange and the use of specialised software solutions. Additionally, financial and accounting institutions may be requested to block payment transactions and electronic transfers enabling the unauthorised online gambling.

One of the most notable changes introduced by the new Games of Chance Act is the stronger focus placed on reducing the social risks associated with gambling, particularly the protection of minors and the prevention of gambling addiction. Operators are required to effectively prevent minors from participating in gambling and provide accessible information regarding assistance for gambling-related issues.

Operators must display a 100 x 80 cm poster near the entrance of each gaming venue, containing:

• warnings about gambling addiction;
• responsible gaming guidelines;
• notice of prohibition of entry for individuals under 18;
• information on the potential harms of gambling;
• contact details for addiction prevention support;
• information on obtaining proof of winnings;
• hours of operation; and
• contact information for certified treatment centres.

Brochures containing the same information must be available at each registration counter. All advertisements, including indirect references to games of chance, must include a notice prohibiting participation by minors and an appropriate warning regarding addiction prevention. Gambling rules must expressly prohibit participation by minors.

The new Games of Chance Act introduces a self-exclusion mechanism, allowing players to request exclusion, set loss limits, or restrict maximum bet amounts, either in writing or electronically. Self-exclusion may be temporary or indefinite. Operators must implement exclusion requests immediately and notify the Games of Chance Administration within 24 hours. Procedures for managing exclusion and limitation requests must be detailed in internal policies accessible to players and regulatory authorities.

The key AML regulation, which also applies to the gambling sector, is the Act on Prevention of Money Laundering and Financing of Terrorism. Providers of gambling services (gambling operators) are regulated as obliged entities under this piece of legislation and hence are required to have in place policies, controls and procedures for mitigating and effectively managing the risks of money laundering and terrorism financing.

When assessing the risk of money laundering and the financing of terrorism, gambling operators are obliged to observe the list of indicators of suspicious transactions prescribed under the Rulebook on the List of Indicators for Recognition of Suspicious Clients and Transactions (Pravilnik o listi indikatora za prepoznavanje sumnjivih klijenata i transakcija, “Official Gazette of Montenegro”, No 29/24).

Gambling operators (providers of lottery games, special games of chance, online games, etc) are obliged to establish the identity of the customer, upon the collection of winnings or the wagering of a stake in the amount of EUR20 or more, or when carrying out transactions amounting to at least EUR2,000, whether the transaction is carried out in a single operation or in several linked operations. Additionally, the new Games of Chance Act requires organisers of betting games to maintain records of individuals who have made payments in the amount of EUR50 or more, as well as of winners who have been paid EUR300 or more.

The operator must collect information on the name, residential address and date of birth of the customer, among other things, and must verify the customer’s identity on the basis of documents, data or information obtained from a reliable and independent source. This obligation also applies to online gambling operators when opening customers’ accounts, and to casino operators when the customer enters the casino.

The new Games of Chance Act sets out detailed rules governing the advertising of gambling activities. Supervision over the advertising of games of chance in the media is conducted by the ministry responsible for media affairs and the regulatory authority.

The Games of Chance Act distinguishes between the following types of advertising.

• Advertising of games of chance operators is a notification by a specific operator of games of chance with the aim of presenting and drawing attention to the name, brand, logo, or activity of that operator.
• Advertising of games of chance services is the presentation and drawing attention to the games of chance offered by that operator, including invitations to participate in the games, as well as references to the operator’s address, website, or mobile application.
• Advertising of benefits related to games of chance services is any notification by an operator of games of chance intended to promote benefits related to a specific game of chance (such as bonuses, jackpots, prizes, free spins, and similar).

Advertising of games of chance, including indirect references, is conducted with a notice regarding the prohibition of participation of minors in games of chance and an appropriate warning text on the prevention of addiction-related disorders. Operators are required to protect players’ personal data in games of chance in the most effective manner and in accordance with the Games of Chance Act.

General restrictions on advertising imposed under the Consumer Protection Act (Zakon o zaštiti potrošača, “Official Gazette of Montenegro” Nos 02/14, 06/14, 43/15, 70/17, 67/19, 146/21, 84/24) apply to gambling operators as well. In this sense, Article 29(1) prohibits any advertising of products and services that:

• misleads or may mislead the consumer;
• discriminates against consumers on the basis of race, gender or nationality;
• offends dignity, religious or political beliefs; or
• incites violence or behaviour that is detrimental to security and consumer health or the environment.

Article 29(2) prohibits advertising that threatens the health, psychological or moral development of minors. Also, Article 29(3) provides that it is forbidden to use comparative, fraudulent and false propaganda and advertising messages that deceptively promote a product or service, overstating its effects or results.

The Illicit Advertising Act prohibits misleading advertising and sets out conditions under which comparative advertising may be permitted (Article 5).

The Games of Chance Act establishes a stricter regulatory framework for advertising gambling activities, including the following prohibitions:

• advertising the operator or organisation of games of chance services on radio and television programmes intended for minors and youth, including 15 minutes before or after such programmes, and in printed materials intended for minors and youth;
• advertising of games of chance in all media and at events intended for minors and youth ‒ this prohibition applies to operators, media founders, publishers, and event organisers;
• advertising benefits related to games of chance services (bonus, jackpot, prize, free spin, and others), except through the official websites of operators or the websites of sports clubs and associations sponsored by the operator being advertised;
• advertising games of chance on radio and television from 6 am to 10 pm;
• advertising games of chance services in print media, except on pages dedicated to sports; and
• advertising operators and games of chance services through online publications, except through online publications that are entirely dedicated to publishing sports content or sports sections of other online publications.

All permitted advertising must include warnings that games of chance may cause addiction (in the form of an appropriate warning text regarding the prevention of addiction-related disorders) and that minors under the age of 18 are prohibited from participating in games of chance.

Advertising related to games of chance is not allowed to:

• idealise participation in games of chance or present it as desirable and positive;
• encourage excessive participation in games of chance;
• portray daily participation in games of chance as part of everyday life, daily routine, or consumer behaviour such as purchasing food or clothing;
• present participation in games of chance as necessary or harmless entertainment;
• present participation in games of chance as a solution to financial problems, a means of improving financial status, or as an alternative to employment;
• present participation in games of chance as a means of promoting social success or acceptance;
• create false or unrealistic impressions regarding the possibility of winning by excessively emphasising the chances of a large win, or present participation in games of chance as something that does not entail any financial, social, or health consequences;
• exploit the ignorance, inexperience, or gullibility of players with respect to games of chance;
• offer money for participation in games of chance, free participation in games involving money, or participation at a discounted price;
• offer other games of chance or other goods in exchange for winnings obtained;
• offer random prizes in exchange for the possibility of winning included in the purchase/participation in a game of chance;
• promote betting and gambling as a lifestyle, or as values by which life problems are successfully and safely resolved;
• suggest that skill can influence the outcome of the game if that is not the case; or
• through the timing, location, or nature of advertising, exert special pressure to participate in games of chance or belittle non-participation (such as encouraging participants in games of chance to recover losses, and similar).

Advertising operators without a licence for games of chance and their services is prohibited through any type of media. Licensed operators are also banned from advertising on foreign TV programmes available in Montenegro or through other channels in ways that violate the conditions set by the Games of Chance Act.

Advertising games of chance in public places is prohibited, except for branding on gaming venue exteriors or operators’ vehicles, provided it does not invite participation in gambling.

The installation of illuminated advertisements, LED displays, and other types of screens on the exterior parts of premises for games of chance is prohibited and their exterior appearance must prevent visibility into the interior. These rules do not apply to casinos in five-star hotels.

The advertising of games of chance on sports equipment is prohibited in all sports categories involving participants under the age of 18.

Advertising of social responsibility initiatives by gaming operators is not considered advertising of games of chance, provided such advertisements include the required warnings and information on assistance for gambling-related issues. Operators may display their logo but must refrain from inviting participation in gambling. Additionally, advertising prohibitions do not apply to lottery games.

An infringement of advertising restrictions prescribed by the Consumer Protection Act can trigger a fine of between EUR1,500 and EUR20,000, while a breach of the restriction under the Games of Chance Act can trigger a fine of between EUR5,000 and EUR20,000. The Illicit Advertising Act does not prescribe fines for illicit advertising, but rather introduces the possibility of class action lawsuits against infringers.

Disclosure requirements in the case of the acquisition of companies, where applicable, are not sector-specific, in that there are no special requirements applicable to gambling companies only – there are general requirements that apply to any type of business.

However, disclosure is required only in the case of a mandatory or voluntary takeover of joint stock companies (which are subject to capital market and securities regulations), and not in the case of the acquisition of, or change of control in, limited liability companies. A limited liability company is the corporate form of choice for most businesses in Montenegro, and the vehicle type currently utilised by all operators in the games-of-chance sector.

The operator is obliged to notify the Games of Chance Administration of any change relating to a merger or acquisition, within five days from the date the change occurs. In the event of a merger, the right to organise games of chance is lost, unless the operator is the acquiring company in the merger.

If the operator is registered as a joint stock company, the acquisition of direct or indirect control of at least 30% of the shares would trigger the obligation to launch a mandatory takeover bid by the acquirer.

There are no particular passive investor requirements in Montenegro in the case of acquisitions or changes of control of companies in general.

The Games of Chance Administration, as the regulatory body, has broad power to control the compliance of operators with the Games of Chance Act. This is exercised through the regulator’s authorised officers and inspectors, who are entitled, among other things, to:

• enter the premises of operators and perform inspections, issue orders or impose specific measures to cure non-compliance;
• prohibit the disposal of funds at bank accounts;
• temporarily stop the operations; or
• prohibit use of the premises or equipment.

They are also authorised to fine the company and issue a so-called misdemeanour order, which is a decision on a fine that becomes effective only if the fined entity does not challenge it and requests the court’s decision on the misdemeanour. The authorised officers and inspectors can also file a motion for starting misdemeanour proceedings before the competent courts.

Most infringements of the Games of Chance Act are considered to be misdemeanours and trigger monetary fines. The monetary fines are regularly imposed by inspectors, through issuing misdemeanour orders, or by the courts in misdemeanour proceedings. The latter will be the case if the fined company opts to challenge the misdemeanour order and have the case heard before the court, or if the inspector files the motion for starting misdemeanour proceedings instead of issuing the misdemeanour order.

The most severe infringements are penalised with criminal sanctions. Providing games of chance without a proper licence is punishable by a monetary fine or imprisonment for up to three years, while selling betting tickets or accepting payment for games organised abroad can trigger a monetary fine or imprisonment for up to two years.

When a financial penalty is imposed on a company and not paid within the provided deadline, it will be enforced by the competent authority that imposed the fine, which will be the regulatory body or the court.

The primary means of enforcement against companies is blocking their bank accounts and seizing any available funds. If the funds in those bank accounts are not sufficient, the fines will regularly be enforced against other assets of the company, through their seizure and public sale.

The taxation of gambling winnings is introduced in the adopted amendments to the Personal Income Tax Act (Zakon o porezu na dohodak fizičkih lica, “Official Gazette of Montenegro”, Nos br. 065/01, 012/02, 037/04, 029/05, 078/06, 004/07, 086/09, 073/10, 040/11, 014/12, 006/13, 062/13, 060/14, 079/15, 083/16, 067/, 059/21, 146/21, 152/22 and 088/24), which came into effect on 1 January 2025. The tax on income generated from games of chance is calculated and withheld by the operator upon each win and is paid simultaneously with the payout of the winnings. The tax on winnings from games of chance is paid at a rate of 15%. Winnings up to EUR300 are non-taxable. The tax is paid on the amount of the winnings reduced by the amount of the individual stake.

Gambling revenues are taxed through the system of fixed and variable licence fees (see 4.9 Ongoing Annual Fees).