A payment licence in Montenegro is a tool to ensure the legal conduct of activities in the field of payment processing, funds transfer and e-money issuance. The state offers a regulated environment compliant with the requirements of the EU PSD2 directive, with a clear licensing procedure and supervision by the Central Bank of Montenegro (CBCG). Licensed financial institutions can provide payment services domestically and internationally while complying with international standards.
The use of the euro as the national currency reduces currency risks and simplifies settlements in cross-border activities. Montenegro is not part of the European Union, but adheres to EU legal and regulatory standards, including provisions on payment services, protection of personal data and compliance with anti-money laundering measures. This ensures a high degree of compatibility with European financial institutions.
Montenegro provides access to licensing for resident and non-resident companies, including foreign-owned structure. The company registration procedure is simplified and interaction with the regulator is possible through a local representative. Given its low tax burden, moderate operating costs and flexible regulatory policy, the jurisdiction remains in demand among fintech companies targeting the EU, CIS and Middle East markets.
Organisational nuances to consider when obtaining a payment licence in Montenegro
The Central Bank is the main regulatory body in the field of financial services and e-money creation. It is authorised to issue licences to two types of entities: payment institutions and entities generating electronic assets. The activities of these entities are regulated by the CBCG both in terms of obtaining authorisations and in the process of subsequent control of operations.
To obtain a payment licence in Montenegro, the applicant submits a dossier with data on the corporate structure, sources of funding, internal risk management policies, anti-money laundering (AML) compliance measures and customer protection. The regulator considers not only the legal side, but also the operational readiness to provide services, including the availability of office infrastructure and competent staff. If any element is insufficiently addressed, the CBCG has the right to refuse review or request further clarification.
The period for analysing documents averages 60 to 90 calendar days, not including time for processing requests and clarifications. The CBCG internal procedures include both legal expertise and assessment of the technical basis. Once approved and registered, the licensed entity is included in the public register and is obliged to submit regular reports in prescribed formats.
Licensed PIs and EMIs are subject to continuous control, including inspections and monitoring of regulatory compliance. The regulator has the right to suspend a licence in case of non-compliance with the established requirements, as well as to initiate the revocation of a licence in case of systematic non-compliance. These measures are aimed at mitigating systemic risks and protecting the payment ecosystem. A payment licence in Montenegro is issued only on condition of regulatory transparency and compliance with national standards.
The regulator actively cooperates with EU supervisory authorities to ensure that CBCG policies are synchronised with the requirements of the European payment market. This is important for companies aiming at cross-border operations, as well as those attracting foreign capital or co-operating with European settlement institutions.
Legislative basis for obtaining a payment licence in Montenegro
The legal system of the state in the field of financial services is based on the norms harmonised with the European Union directives. The basis is the Law on Payment Transactions and Electronic Money, which incorporates the provisions of EU Directive PSD2 (2015/2366). The current version of the law regulates the licensing of PIs and EMIs, their obligations, reporting format, customer protection system and technological requirements for transaction security.
The law stipulates that all payment organisations must ensure authentication of transactions, control the sources of incoming funds, keep logs of payment activity and guarantee the confidentiality of customers' personal data. There are also provisions for non-discrimination of users, equal access to services and protection against unjustified blocking.
The implementation of PSD2 in Montenegro ensures compatibility with open banking systems and allows for integration with external services upon agreement with the client. This increases the flexibility of fintech platforms and makes the country's market more attractive for cross-border projects. Successful execution of a payment licence in Montenegro requires precise compliance with the specified provisions and readiness to provide full technical and regulatory documentation.
The law also defines requirements for the internal structure of the licensed organisation: a compliance officer, a local manager, independent controls and audit procedures. All employees who have access to confidential information or are involved in transaction processing are subject to a pre-screening and business reputation assessment. This allows the regulator to monitor potential risks and prevent unscrupulous participants from participating in the system.
For companies wishing to obtain a payment licence in Montenegro, it is important to bear in mind that even after its issuance, every transaction, change of structure, launch of a new product or connection to international payment systems is subject to prior notification to the CBCG. Any deviation from the approved model requires separate authorisation.
When submitting an application, the regulator expects a complete dossier, including not only information about the company and its owners, but also a draft business model, a financial stability calculation, a description of the IT environment, and proof of a physical address and staff. Without fulfilling these conditions, it is impossible to obtain a payment licence in Montenegro, even if there is a formal legal basis.
Additionally, mechanisms have been implemented to ensure compliance with international data exchange requirements. Montenegro participates in mutual administrative assistance agreements and the CBCG co-operates with EU regulators in the exchange of information on risks and irregularities.
Payment institutions admitted to the market are required to make annual contributions to a special fund to cover risks in case of bankruptcy or default to customers. This rule is set by the regulator and reflects an obligation to protect users. Companies that fail to comply with this requirement lose the right to operate, regardless of whether they have a valid licence.
Types of payment licences in Montenegro
A Payment Institution is a legal entity that has obtained a licence from the Central Bank of Montenegro to provide basic payment services. This form of licence is used for companies that process payment transactions without the right to hold funds in customer accounts beyond the time required to complete the transaction. Acceptance of funds, transfer of funds, transfer between payment systems and card transactions are allowed.
To obtain a payment licence in Montenegro in the form of a PI, it is necessary to undergo a registration procedure and submit a set of documents including information on beneficiaries, corporate structure, internal controls, IT environment and risk management policy. A physical office, local staff, and signed agreements with processing and settlement partners are required.
The level of statutory capital limit for PIs is influenced by the scale of transactions and the types of services provided. According to the regulatory classification, the amount can range from EUR 20 thousand to EUR 125 thousand. The capital contribution must be confirmed by a bank report. The CBCG checks not only the origin of the funds, but also the sustainability of the financial model.
After applying for a payment licence in Montenegro, the verification procedure begins, which includes legal, financial and technical assessment. In case of a positive decision, the licence is entered into the public register and the organisation is granted the right to operate. After the commencement of operations, the payment organisation is obliged to submit reports, confirm compliance with customer protection, transaction monitoring and system resilience standards. This is a prerequisite for continuing to operate within the current legislation. The PI licensing procedure is a standard option for startups and medium-sized fintech companies.
An Electronic Money Institution is an organisation that is authorised not only to perform standard payment transactions, but also to issue virtual funds - the digital equivalent of fiat currency. Such companies are authorised to store customer funds in accounts, use them for settlements, and open individual wallets in their infrastructure.
The main difference between EMIs and PIs is the authorisation to issue electronic money and the obligation to redeem it at the first request of the client. This requires compliance with additional regulations: keeping funds in segregated accounts with authorised banks, regular reporting of balances, confirming the technical reliability of the platform and implementing liquidity management policies. Companies that plan to issue a payment licence in Montenegro in the form of an EMI are required to confirm compliance with each of these criteria.
The minimum authorised capital for an EMI is set at EUR 350 thousand. It must be deposited prior to the submission of documents and reflected in the company's bank account. At the same time, higher requirements are imposed on personnel, compliance procedures, data protection, access to API interfaces and backup procedures. All internal policies are subject to legal and technical review prior to authorisation.
To apply for an EMI type payment licence in Montenegro, an application must be submitted to the Central Bank of Montenegro in the form prescribed by law. It is required to attach documents confirming the qualifications of the management, sources of financing, IT architecture and description of the business model. In practice, the review period ranges from 90 to 120 days, depending on the completeness of the information and the amount of interaction with the regulator.
Organisations operating as EMIs are subject to enhanced oversight, including audits of custody policies and review of settlement channels. Violations of regulations lead to sanctions, including suspension of transactions. The CBCG requires full transparency in the handling of client funds and admission of information on the movement of digital money.
The EMI licence is suitable for large-scale payment solutions, international projects and companies planning to integrate with banking and non-banking settlement systems. An additional advantage is the ability to issue its own virtual cards, tokens and integration with crypto-infrastructure, if this is provided for by the business model. EMI status gives a significant expansion of functionality compared to PI, but requires a greater level of organisational maturity and responsibility.
For applicants seeking to obtain a payment licence in Montenegro with full autonomy and legal flexibility, EMI status is the optimal tool to enter the electronic payments market. However, such companies should be prepared for enhanced controls and operational compliance requirements.
Legal form and ownership structure when choosing a payment licence in Montenegro
Registration of a payment institution in Montenegro is allowed only in the form of a legal entity. The legislation requires the establishment of a local company registered according to the norms of the Law on Business Companies. In practice, the form društvo s ograničenom odgovornošću (DOO) is used, which corresponds to the status of an LLC company.
Both residents and non-residents may participate in the company, provided that the ownership structure is fully disclosed. The Central Bank of Montenegro verifies the origin of capital and beneficial owners. If an opaque chain of ownership or affiliation with inadmissible jurisdictions is detected, the application is suspended.
For entities wishing to obtain a payment licence in Montenegro, it is mandatory to have statutory documents containing provisions on financial activities, management system, rights of participants and decision-making procedures. The articles of association must include a description of the business purpose corresponding to the types of licensed operations.
Capital must be deposited in a corporate bank account prior to application and confirmed by a certificate from a financial institution. No loans, promissory notes, cryptocurrency assets or securities may be used as a source of authorised capital. Funds must be free from liens and restrictions, which is subject to verification by banks and the regulator.
Documentary proof of capital shall be submitted as part of the application and verified as part of the procedure for issuing a payment licence in Montenegro. At the same time, the Central Bank assesses not only the availability of the required amount, but also the financial sustainability of the project as a whole. The calculations include the projected flow of funds, operating costs, as well as cybersecurity, audit and reserve funds.
The company's management team must meet established requirements in terms of experience, qualifications and business reputation. Candidates for key management positions are required to demonstrate relevant education, financial expertise and no disciplinary or criminal record.
The actual presence of the organisation in the territory of the country is a mandatory element of licensing. The applicant is required to have a registered legal address and to rent or own the commercial premises where the main activities will be carried out.
The company must have at least two employees, including a CEO and a compliance officer. Outsourcing of certain functions is allowed if necessary, but critical processes, including risk controls and CBCG interactions, must be performed in-house. These rules are mandatory for any payment licence in Montenegro, regardless of the type of institution.
The Regulation also requires that backup servers, archives with client data and elements of the IT system be located either in Montenegro or in a country with which an agreement on mutual recognition of personal data processing standards has been concluded. This is ensured by a technical audit prior to the launch of operations.
The full list of requirements for the applicant covers legal, human resources, financial and technical aspects. The regulator expects the company to have a high level of organisational readiness, compliance with the regulatory framework and structural transparency. Companies that fail to fulfil at least one of the points are rejected even before the start of the review on the merits. Therefore, a payment licence in Montenegro implies not only legal registration, but also the actual implementation of all elements of internal control.
The CBCG's approach to assessing applicants is based on the principles of proportionality, transparency and reasonableness. This means that each element of the application is checked separately, but in the context of the overall business project. As a result, in order to obtain a payment licence in Montenegro, it is necessary to ensure documentary and factual compliance with a whole set of requirements covering all areas of the organisation's activities.
Internal procedures and compliance when obtaining a payment licence in Montenegro
Financial institutions licensed in Montenegro are required to implement a full-fledged internal control system in the field of anti-money laundering and combating the financing of crimes against public security (AML) and to set up customer identification mechanisms (KYC). The Central Bank of Montenegro requires applicants to implement regulations that comply with the provisions of the Law on Prevention of Money Laundering and international standards, including FATF recommendations.
In practice, the AML system must include a policy of collecting information on customers, their beneficiaries and sources of funds. Verification is performed prior to establishing a business relationship and is updated on a regular basis. The organisation must determine the risk level of each customer based on the origin of capital, jurisdiction, type of transactions and other criteria.
The KYC system is based on the principle of verifying customer identity using documents, databases, electronic means of identification and internal filters. Transactions are continuously monitored to identify suspicious patterns or deviations from expected behaviour. Detected transactions are to be recorded and, if necessary, forwarded to supervisory authorities.
The formation of such a control infrastructure is a prerequisite for all applicants planning to obtain a payment licence in Montenegro. Without a proper AML/KYC system, it is impossible to submit an application, even if other criteria are met. Violations in this part are considered as gross regulatory non-compliance and are subject to administrative sanctions.
Internal audit should be independent from the management level and should be formed as a separate department or an external function. It is responsible for regularly checking compliance with internal regulations, the adequacy of procedures, the fulfilment of duties by key officials and the correctness of reporting data. The results of the audit are recorded in writing and sent to the supervisory authority upon request.
The control structure is documented in the licence application and is accompanied by provisions on auditor independence, audit schedule, and mechanisms for responding to identified irregularities. The Central Bank of Montenegro requires the inclusion of these elements in the corporate governance framework prior to commencement of operations. Their absence prevents the processing of a payment licence in Montenegro from proceeding or results in the suspension of the dossier.
The regulator also verifies the existence of disaster recovery, resilience testing and outsourcing management plans. If necessary, technical protocols, software solutions and internal documentation confirming the operation of the system under stress conditions are requested.
Payment institutions operating in Montenegro are obliged to ensure the protection of personal, payment and identification data of their customers. These measures must comply with the requirements of local legislation and the provisions of the EU General Data Protection Regulation (GDPR), despite the fact that Montenegro is not part of the European Union.
To fulfil the requirements, a Data Protection Officer (DPO) must be appointed, an information handling policy must be established, and a Privacy Impact Assessment (DPIA) must be carried out. The documents should be available for CBCG review and updated in the event of changes to the IT system architecture.
The regulator also requires notification of data breaches and security incidents within a specified timeframe. Breach of this obligation may result in the revocation of the licence or the imposition of administrative sanctions. These measures form the basis of trust on the part of customers and partners in payment infrastructure operators.
The existence of internal controls is not a formal requirement, but an indispensable element of sustainable and legal functioning of a payment institution. Centralised compliance functions, audit and supervision, compliance with information security standards and risk control are the key blocks without which it is impossible to obtain a payment licence in Montenegro in 2025.
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Stages of obtaining a payment licence in Montenegro
The initial stage of obtaining a permit is to register a company in the form of a business entity. In most cases, the DOO (društvo s ograničenom odgovornošću) model is used, which is equivalent to a limited liability company. Registration is done through the Central Register of Commercial Entities (CRPS) under the Ministry of Finance and Social Security of Montenegro.
The applicant provides the articles of association, the decision on establishment, information on the founders and information on the director of the company. Additionally, a legal address is required, which must correspond to the commercial purpose of the object. As an identifier, the company receives a registration number (Matični broj) and a tax identifier (PIB).
A registered firm must include in its articles of association a description of activities subject to the regulation of the Central Bank of Montenegro (CBCG). Without this, admission to licensing is not possible. Once the registration is complete, the entity is entitled to take further steps to apply for a payment licence in Montenegro.
The next step is to deposit the share capital and establish a bank account with a licensed financial institution. The bank account is opened in the name of the registered legal entity. Funds are transferred without the use of borrowed sources, exclusively from confirmed, audited accounts. After the capital has been credited, the bank provides a statement and written confirmation of the crediting.
Documents on the deposit of funds and their origin shall be submitted as part of the licence dossier. The Central Bank assesses both the actual receipt of the capital and its purity from the point of view of the anti-money laundering legislation. Failure to comply with this requirement precludes the possibility of obtaining a payment licence in Montenegro. Capital must be freely available to the company and used to cover operating expenses, including IT infrastructure, compliance, rent and payroll. The regulator checks whether the amount of capital is sufficient taking into account the financial model and the anticipated growth.
The set of documents submitted to the Central Bank of Montenegro is formed taking into account the requirements of the Law on Payment Services and CBCG by-laws. The dossier includes corporate documents, internal regulations, information on founders and management, description of the business model, as well as documents confirming the existence of IT infrastructure and risk management policy.
AML/KYC regulations, documents on protection of personal information, description of the internal control algorithm and incident response system are mandatory. Separately, a business plan with financial calculations, including forecasts of revenues, expenses and break-even point shall be submitted. Documents shall be submitted in Montenegrin or English and certified.
CBCG checks not only the content but also the logical integrity of the documentation. The absence of even one mandatory component stops the review procedure. Companies seeking to apply for a payment licence in Montenegro should carry out an internal check in advance that all components are compliant with the requirements. It is important that the internal documentation reflects real processes and not formally reproduce templates. The regulator analyses the extent to which the operating model protects the interests of customers, avoids conflicts of interest and complies with international standards.
Communication with the regulator is in writing. Companies are required to respond within the established deadlines, and each version of the documentation must be accompanied by an explanation of the changes made. The CBCG expects a high level of elaboration and therefore the same material should not be resubmitted without revision. Upon completion of the review and if there are no objections, the CBCG will make a decision on whether to give the licence. The document is in the form of an official authorisation specifying the activities permitted and includes an entry number in the register. The date of issuance is considered to be the moment when the licence commences.
Banking support in obtaining a payment licence in Montenegro
The authorisation requires a corporate bank account in the jurisdiction of incorporation or in a bank recognised by the regulator. In the case of Montenegro, a company may open an account either with a local bank or with a financial institution registered in the European Union, provided that the latter complies with the CBCG's financial control and anti-money laundering standards.
To open an account, the company's articles of association, incorporation documents, information on the beneficial owners, proof of authorised capital and a description of the planned activities will be required. Biographies of the directors and compliance officer, as well as a summary of the business model, are mandatory. Banks additionally request a corporate group structure and a list of counterparties.
Financial institutions conduct a preliminary assessment of the client in terms of operational and regulatory risk. Companies operating as PIs or EMIs are subject to an enhanced due diligence process that includes analysis of transaction channels, transaction controls and compliance with internal regulations. The level of transparency of the corporate structure and projected turnover have a significant impact on the likelihood of opening an account. The most popular banks in Montenegro include CKB Banka, Erste Bank Montenegro, NLB Banka Podgorica and Addiko Bank Montenegro.
Having an open and active account is a prerequisite before applying for a payment licence in Montenegro, as the regulator checks that capitalisation obligations are actually met and that the bank is ready to start operating.
After obtaining a payment licence in Montenegro, the payment institution is entitled to connect to international settlement networks - including SEPA, SWIFT, as well as processing platforms for bank cards. This is possible only in the presence of appropriate technical infrastructure and approved regulations on interaction with external participants of the payment market.
Integration with SEPA requires opening a current account with a SEPA member bank, an IBAN number and connection to a payment gateway using the ISO 20022 standard. For SWIFT, it is necessary to conclude an agreement with the servicing bank, obtain a BIC code and set up MT messaging. For Visa and MasterCard acceptance, integration with a PCI DSS certified processing partner.
CBCG requires licensees to have the described technical protocols as well as agreements with settlement partners. Connection is possible only after obtaining authorisation for transactions. The application must be accompanied by a technical description, IT environment architecture and proof of compliance with security requirements.
Each connection is assessed by the regulator in terms of risk, sustainability and compliance with the data protection policy. Errors in integration design can result in restricted operations. Therefore, even before a company starts processing a payment licence in Montenegro, it is advisable to envisage potential settlement channels and sources of infrastructure support.
Banks working with payment institutions have enhanced disclosure requirements regarding beneficiaries and sources of funds received. This includes providing declarations on sources of capital, legally confirmed ownership structure, biographies and criminal records. Business reputation and experience in the management of financial organisations are also checked.
In order to obtain a payment licence in Montenegro, it is necessary to ensure not only formal compliance with the CBCG requirements, but also the actual performance of all elements of the banking and payment infrastructure. This is particularly important in the case of interaction with non-resident banks, where the level of scrutiny may be higher than in local financial institutions.
Establishing sustainable settlement mechanisms prior to the commencement of operational activities can minimise delays and simplify the licensing procedure. This is one of the key factors that both banks and the regulator focus on when analysing project readiness. A mismatch between the settlement infrastructure and the stated business model significantly reduces the likelihood that a company will be able to obtain a payment licence in Montenegro without additional enquiries and delays.
Completion of bank integration and launch of the settlement platform are mandatory stages in the process of obtaining authorisation for financial activities. The level of readiness to conduct transactions, availability of reliable counterparties and transparency of settlements become determining factors in the CBCG's decision on whether an applicant can obtain a payment licence in Montenegro and start full-fledged activity in the payment services sector. Let us consider the most popular financial institutions in the country in order to decide which institution to cooperate with.
is one of the largest and most stable banks in Montenegro, part of the Hungarian banking group OTP Bank. The bank serves a significant share of both individuals and legal entities in the country, including SMEs and international companies. A high level of digitalisation, English-language support and experience in dealing with non-residents make CKB one of the preferred banks for foreign investors opening a payment licence in Montenegro.
The Bank offers the CKB Project Financing service, which is a specialised form of lending where loan repayment is secured primarily through future cash flows from project implementation. This scheme is used in capital-intensive sectors - energy, infrastructure, telecommunications, real estate - and involves the use of project assets and rights thereto as collateral.
is the Montenegrin division of Erste Group, a large Austrian financial group operating in Central and Eastern Europe. The bank is characterised by a high degree of reliability, conservative financial policy and transparent customer identification procedures. Erste actively works with corporate clients, including foreign entities, offering comprehensive banking services, including multi-currency accounts, credit lines, deposit products and individual consultations on financial planning.
The institution provides the mBanking service, which gives customers convenient and secure access to banking services via a mobile application. Using the service, it is possible to monitor account balances, make payments, transfers, top up mobile phones, and manage cards around the clock. The application supports modern security standards, including biometric authentication and confirmation of transactions.
is part of Slovenian Nova Ljubljanska Banka and holds a key position in the banking sector in Montenegro. The bank focuses on servicing legal entities, including international companies and investors interested in business development in the region. Within the framework of corporate services NLB Banka offers financing instruments, cash and settlement services, payroll projects, export-import operations, as well as support for investment projects.
The NLB Pay service is a digital wallet that allows customers to make contactless payments and withdraw cash via mobile devices by digitising their NLB Visa and Mastercard payment cards via Google Pay. The app also supports the addition of loyalty cards, providing convenience when shopping. To use the service, an NFC-enabled device with Android operating system version 7.0 or higher is required. The service is ideal for holders of payment licences in Montenegro.
is a universal commercial bank, part of the Addiko Group, an international financial group headquartered in Vienna. In Montenegro, the bank focuses primarily on retail customers and small businesses, offering simple and affordable solutions in cash management, lending, deposit and modern digital platforms. One of the bank's features is a simplified account opening procedure with basic identification requirements, which makes it convenient for entrepreneurs and companies that have obtained a payment licence in Montenegro.
The investment lending service for legal entities from Addiko Bank Montenegro is designed to finance projects aimed at business development and expansion. Loans are granted to companies registered in Montenegro for up to 10 years in euros, with the possibility of granting a grace period, the duration of which depends on the purpose of the loan. Funds can be used for the purchase of equipment, real estate, land, construction or adaptation of commercial premises, as well as for refinancing of existing liabilities
Taxation for holders of payment licence in Montenegro
Licensed organisations are subject to taxation in accordance with the Law on Taxation of Corporate Profits. The corporate tax rate is set on a progressive scale and ranges from 9 to 15% depending on the amount of net profit. Income up to 100 thousand EUR is taxed at the minimum rate of 9%. If the profit is between 100 thousand and 1.5 million EUR, 12% is withheld, while any amounts above that are already subject to the maximum rate.
The tax is calculated on the basis of the annual financial report certified by a licensed auditor. Certain deductions are allowed, including depreciation, operating expenses, staff costs and consulting services. All calculations must be supported by primary documentation and submitted in the prescribed format.
Tax on dividends is 15% and is withheld when profits are distributed to the founders. In the presence of international double taxation treaties, the rate may be reduced if the country of the beneficiary is included in the list of treaties recognised by the Ministry of Finance of Montenegro. Payment of dividend tax is made at the moment of transfer of funds, which is controlled by the tax office. Financial companies planning to obtain a payment licence in Montenegro are obliged to take into account the corporate tax regime when preparing a business plan, especially when calculating the payback and return on investment model.
Under the Value Added Tax Act, most financial and payment transactions are exempt from VAT. The exemption applies to payment processing, transfer of funds, issuance of electronic money, and operations related to the management of client accounts. This provision is in line with European practice and is intended to protect the end user from excessive tax burden.
However, certain auxiliary services, including maintenance of payment platforms, provision of IT infrastructure to third parties, analytics and integration support, may be subject to the standard VAT rate of 21%. The non-taxable nature of the core business does not exempt a company from the obligation to register for VAT if the total income from taxable transactions exceeds the established threshold.
Payment institutions are required to keep separate records of taxable and exempt transactions. Monthly or quarterly returns are also required, depending on the number of transactions. Errors in the qualification of services can lead to penalties and the need for additional tax assessment.
Companies applying for a payment licence in Montenegro should determine in advance the structure of the products offered and check the tax status of each element. This is necessary both for the correct calculation of prices and for building a calculation model when working with partners.
In addition, all companies are required to file regular reports with the Montenegrin Tax Service (Poreska uprava), including corporate tax returns, VAT returns and social security returns. Failure to comply with these obligations results in fines, suspension of activities and revocation of licence.
Financial statements must be prepared in accordance with Generally Accepted Financial Accounting Standards (IFRS) and certified by an auditing company authorised to operate in the country. Annual audit is mandatory for all PIs and EMIs, irrespective of turnover. The auditor provides an opinion not only on the financial position but also on regulatory compliance. Regularity and completeness of reporting are critical factors for companies seeking a payment licence in Montenegro, as CBCG monitors tax discipline when deciding whether to renew a licence or allow additional services.
For businesses dealing with non-resident customers or international payment systems, cross-border data exchange compliance is particularly important. The CBCG and the IRS participate in the automated exchange of information with jurisdictions that are part of tax transparency agreements. This means that companies that intend to obtain a payment licence in Montenegro must ensure transparency of both internal and external reporting from the very beginning of operations.
Grounds for refusal and possible risks in obtaining a payment licence in Montenegro
One of the main reasons for the refusal to issue an authorisation is that the submitted dossier does not meet the established requirements. Applicants submitting documents to the Central Bank of Montenegro (CBCG) are required to submit a complete set including legal, corporate, financial, technical and regulatory information. Any deviation from the statutory list may result in the application being returned without substantive consideration.
The most common errors are: lack of signed internal policies, incomplete disclosure of ownership structure, uncoordinated versions of the articles of association and business plan, and submission of outdated documents. Problems also arise when language and translation certification requirements are not met. CBCG accepts dossiers only in Montenegrin or English, with mandatory notarisation of copies.
Failure to trace the ownership structure, lack of beneficiary information and unconfirmed capital details are grounds for automatic rejection. Companies applying for a payment licence in Montenegro should ensure internal due diligence of the entire package prior to submission.
An additional risk relates to technical applications such as IT systems architecture, data security descriptions and backup procedures. Insufficient detail or lack of alignment with internal policies indicate that the project is unprepared. The regulator considers such inconsistencies as an indicator of the lack of a real operational plan.
The applicant's financial model, business plan and operational structure are subject to mandatory review by the CBCG. If the submitted documents do not contain a convincing justification of economic sustainability, this becomes a ground for refusal. Companies seeking a payment licence in Montenegro are required to demonstrate a realistic approach to building a payment infrastructure, including revenue sources, costs and projected profitability.
The business model should take into account the specifics of the payment sector, including the cost of connection to settlement systems, IT infrastructure, marketing and personnel costs. Lack of a balanced budget, unjustifiably understated or overstated indicators, as well as insufficient elaboration of operational risks are perceived by the regulator as signs of unreliability.
The financial part of the project should be supported by detailed information on the target market, competitive environment, transaction volumes and expected number of customers. If the calculations are based on assumptions without evidence, the CBCG may request clarifications, additions or reject the application.
For applicants who expect to apply for a payment licence in Montenegro, it is important to ensure that all elements of the business plan, including the timetable for reaching operational break-even, are credible and justified. Any discrepancies between the described model and the submitted documents are perceived as a breach of good faith.
The Central Bank of Montenegro conducts checks not only on the company itself, but also on all individuals and legal entities that are part of the management, governance and day-to-day control system. Special attention is paid to the biographies of beneficiaries, directors, compliance officers and key employees. Identification of indications of legal irregularities, business malpractice or lack of transparency of ownership are grounds for refusal to issue a licence.
The regulator analyses information from international databases, public sources and documents submitted as part of the dossier. The presence of criminal records, administrative sanctions, bankruptcies or involvement in unregulated projects may be perceived as a critical non-compliance. The CBCG also considers the extent of the applicant's involvement in previous financial projects and the existence of experience in managing payment organisations.
The ownership structure must be fully disclosed. The use of nominees, anonymous trusts or offshore companies without transparent reporting is excluded. In case of doubts about the ultimate beneficiary, the regulator reserves the right to reject the application without the possibility of reconsideration.
In order to obtain a payment licence in Montenegro, it is necessary to carry out an internal check of the team composition, legal connections and sources of funds in advance. Lack of internal compliance or submission of incomplete information is a frequent reason for rejection, especially for companies with a cross-border structure.
Conclusion
Payment licence in Montenegro now retains strategic attractiveness due to a number of objective factors. The use of the euro in the absence of EU membership allows to minimise currency risks without having to comply with all eurozone requirements. The regulatory framework is adapted to PSD2 and provides a high degree of legal certainty. Admission to SEPA, a stable tax policy, the possibility of remote management and access to the European market make the licence a competitive tool for fintech projects with a cross-border orientation.
At the same time, the licence requires significant efforts in the preparation phase. The Central Bank of Montenegro has strict requirements for capital structure, internal controls, team qualifications and documentation compliance. Errors in dossier preparation, non-transparent ownership structure or a formal approach to the business model are the main reasons for refusal. To reduce risks and speed up the procedure, it is recommended to use the services of specialised specialists. Our team of legal advisors supports the process of obtaining a licence at all stages - from choosing a legal model to representing interests in regulatory authorities. This support helps to avoid regulatory errors, improve the quality of the dossier and ensure a sustainable start of operations under the CBCG regime.
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