A long awaited regulation for the Montenegrin program of citizenship by investment is set to enter into force on 1 January 2019.

The investment threshold for citizenship depends on the region of Montenegro in which the investment is made. It is set at EUR 450,000 for investments in the coastal area or in the capital of Podgorica, and at EUR 250,000 for investments in other parts of the country. On the top of the investment amount, prospective applicant will be obliged to pay a contribution of EUR 100,000 for development of undeveloped municipalities, and the application fees of (i) EUR 15,000 for the applicant himself, (ii) EUR 10,000 for the first four family member and (iii) EUR 50,000 per person for additional family members. Family members eligible for the citizenship, are the applicant’s spouse, children under 18, and dependent children over 18.

In order to qualify for the program, an applicant will have to invest in a pre-approved development project in tourism sector, agriculture or processing industry. The list of approved projects will be issued by the Government. There are strict requirements for a project to qualify as a development project in tourism – it must involve construction of a hotel, or a mixed complex, and satisfy various requirements in terms of category, number of accommodation units, investment value, and planned number of employees. The criteria for development project in agriculture sector and processing industry are to be determined by the ministries of agriculture and economy, respectively.

Marketing agents and due diligence agents that may be involved in the application process must obtain a license from the Government. Marketing agents must have at least three years of relevant experience with citizenship programs in at least three other countries, one of which must be an EU country. Their role is to market the program internationally, collect applications and forward them to the competent authority. License for due diligence agent can be issued to a legal entity with at least three years of experience in international due diligence procedures. Licenses for both marketing agents and due diligence agents will be granted in a public bidding procedure with a one-year validity period and will be extendable. Due diligence agent is subject to no fee, while prospective marketing agents will have to pay an EUR 50,000 annual license fee.

The program is limited to 2,000 passports, and will be effective until 31 December 2021. The process for the licensing of marketing and due diligence agents and preparation of the lists of qualified development projects is expected to take at least a couple of months. The first citizenship applications care therefore expected in Q2 2019.