Crypto License in Montenegro (2026)
The full guide for this jurisdiction is being researched
Read this before you plan an application
Montenegro has no crypto licence. Since March 2025 a crypto-asset service provider based in Montenegro must be entered in the Register of Crypto-Asset Service Providers kept by the Capital Market Authority before it starts, under Articles 40a to 40r of the Law on the Prevention of Money Laundering and Terrorist Financing, inserted by amendments published in Official Gazette 24/2025 on 12 March 2025. Register entry is an anti-money-laundering registration rather than an authorisation: the rulebook that opened the register took effect on 22 December 2025, the application fee is EUR 5,000 under the Authority's fee schedule applying from 1 July 2026, and the first provider, Artenx d.o.o. Podgorica, was entered on 31 July 2026. A standalone crypto-asset law aligned with MiCA has been discussed since 2021; in July 2026 the Ministry of Finance said it is not in the government's 2026 work programme.
Key facts
- Regime
- Registration regime
- Regulator
- Capital Market Authority of Montenegro (Komisija za trziste kapitala Crne Gore, CMA)
- Framework
- Law on the Prevention of Money Laundering and Terrorist Financing, Articles 40a to 40r (crypto-asset services) (2025)
- Application fee
- EUR 5,000 on filing the registration application (CMA fee schedule, Article 14, applying from 1 July 2026)
- Minimum capital
- None set. Article 40b of the Law lists documents to file, not capital
- Annual fee
- No annual or supervision fee for crypto-asset service providers appears in the CMA fee schedule applying from 1 July 2026
- Foreign owners
- Foreign nationals can own and direct a registered provider. Article 40a requires the provider itself to have its seat in Montenegro, or the entrepreneur or natural person to have residence or approved permanent residence there. A provider authorised or registered in an EU member state must also be entered in the Montenegrin register before serving clients in Montenegro. Directors, members and beneficial owners who are not Montenegrin citizens supply their own criminal-record certificates; for Montenegrin citizens the Authority obtains them ex officio (Article 40b).
License classes in Montenegro
| Class | Covers | Fee | Capital |
|---|---|---|---|
| Register entry, provider based in Montenegro | One or more of the ten crypto-asset services in Article 6(1)(70) of the Law: custody and administration, operating a trading platform, exchange for fiat, exchange for other crypto-assets, order execution, placing, reception and transmission of orders, advice, portfolio management, and transfer services. Article 40a(1): seat, residence or approved permanent residence in Montenegro | EUR 5,000 on filing (CMA fee schedule, Article 14) | None set in the Law |
| Register entry, provider authorised in an EU member state | The same services, for a provider authorised or registered by its home supervisor in an EU member state not on the high-risk third-country list, which must still be entered in the Montenegrin register before providing services in Montenegro. Article 40a(2) and 40b(4): home-state confirmation and proof of the registered services replace part of the domestic file | EUR 5,000 on filing (CMA fee schedule, Article 14) | None set in the Law |
What the application requires
- Seat in Montenegro for a company, or residence or approved permanent residence for an entrepreneur or natural person (Article 40a)
- Entry in the Register of Beneficial Owners before a company can be entered in the crypto-asset register (Article 40b)
- An appointed anti-money-laundering officer and deputy under Article 69 of the Law, with proof of the appointment in the file
- A business plan naming the crypto-asset services to be provided and how they will be marketed
- Good repute under Article 40r for every director, member, management body member and beneficial owner: no pending criminal proceedings and no conviction carrying an unconditional prison sentence of one year or more
- Criminal and misdemeanour record extracts not older than three months, and notarised questionnaires and declarations not older than one month, for each of those persons (Rulebook, Article 7)
- Notarised passport copy for foreign nationals among the directors, members and beneficial owners (Rulebook, Article 7)
- Notarised declaration by the responsible person that they know their obligations under the Law (Rulebook, Annex II)
- Data on all directors as required by Article 117(1)(3) of the Law
- EUR 5,000 registration fee paid on filing (CMA fee schedule, Article 14, from 1 July 2026)
- Registration completed before any service is provided, and customer due diligence on every crypto-asset transfer of EUR 1,000 or more once operating
The application process
Determine which services you will register for
Pick from the ten services in Article 6(1)(70); the register records the named services and Article 40e decides when a service counts as provided in Montenegro, including marketing aimed at residents or a .me domain
Incorporate a Montenegrin company and register its beneficial owners
Article 40a requires a seat in Montenegro, and Article 40b bars a company from the crypto-asset register until it is in the Register of Beneficial Owners
Build the application file
Annex I form, business plan, proof of the AML officer appointment, beneficial-owner extract, and the good-repute documents for every director, member and beneficial owner under Article 40r and Rulebook Article 7
File with the Capital Market Authority and pay the fee
The application and supporting documents are delivered physically (Rulebook, Article 8); the EUR 5,000 fee is due on filing under Article 14 of the fee schedule
Assessment and decision
The Authority checks the file, verifies the documents with domestic authorities and through international cooperation channels, and may ask for more; a refusal under Article 40b(8) can be challenged in an administrative dispute
Register entry and supervision
The Authority issues a decision entering the provider in the public register; it can passivate or delete an entry under Article 40d, and services must stop while an entry is passivated
Costs and taxation
The only published official figure is the EUR 5,000 registration fee in Article 14 of the Capital Market Authority's fee schedule applying from 1 July 2026. Article 40b of the Law sets no minimum capital and the schedule sets no annual fee for crypto-asset providers. The file is delivered physically (Rulebook, Article 8) with notarised statements, criminal-record extracts and a beneficial-owner register extract, so budget for notary and translation costs, which no authority publishes.
Corporate income tax is progressive under Article 28 of the Law on Corporate Income Tax: 9% on taxable profit up to EUR 100,000, then EUR 9,000 plus 12% on the band from EUR 100,000.01 to EUR 1,500,000, then EUR 177,000 plus 15% on profit above EUR 1,500,000.01.
Who is licensed today
The Register of Crypto-Asset Service Providers is public on the Capital Market Authority's website. As of 6 September 2026 it lists one provider, Artenx d.o.o. Podgorica, entered by decision of the Authority's 195th session on 31 July 2026. Article 40a gives anyone the right to see a provider's name and the crypto-asset services it is registered for. See the official register.
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Frequently asked questions
Do I need a licence to run a crypto exchange in Montenegro?
No licence exists. A provider based in Montenegro must be entered in the Capital Market Authority's Register of Crypto-Asset Service Providers before it starts, under Article 40a of the Law on the Prevention of Money Laundering and Terrorist Financing. Entry is a registration, not an authorisation.
Who regulates crypto in Montenegro?
The Capital Market Authority of Montenegro keeps the register and supervises crypto-asset service providers under the anti-money-laundering law. The Central Bank of Montenegro is not the register-keeper, although it coordinated the working group drafting a standalone crypto-asset law.
How much does crypto registration cost in Montenegro?
EUR 5,000, paid when the registration application is filed, under Article 14 of the Capital Market Authority's fee schedule applying from 1 July 2026. The Law sets no minimum capital and the schedule sets no annual fee for crypto-asset providers.
Is Montenegro covered by MiCA?
No. Montenegro is an EU candidate country, not a member state, so MiCA does not apply there. A Montenegrin register entry is not a MiCA authorisation and cannot be passported into the EU; an EU-authorised provider must separately enter the Montenegrin register before serving clients there.
How many crypto companies are registered in Montenegro?
One, as of 6 September 2026. Artenx d.o.o. Podgorica was entered by decision of the Capital Market Authority's 195th session on 31 July 2026, the first entry since the register rulebook took effect on 22 December 2025.
When will Montenegro pass a crypto-asset law?
Not in 2026. In July 2026 the Ministry of Finance said a draft law is not in the government's 2026 work programme, citing the complexity of MiCA and the fact that not all EU member states have implemented it. Until then the anti-money-laundering registration is the whole regime.
Sources
- Capital Market Authority: first crypto-asset service provider entered in the Register (31 July 2026)
- Capital Market Authority: Rulebook on keeping the Register of Crypto-Asset Service Providers in force from 22 December 2025
- Capital Market Authority: Rulebook on keeping the Register and assessing repute, text with application forms (PDF)
- Capital Market Authority: Law on the Prevention of Money Laundering and Terrorist Financing, consolidated text (PDF)
- Official Gazette of Montenegro 24/2025: Law amending the Law on the Prevention of Money Laundering and Terrorist Financing
- Capital Market Authority: fee schedule applying from 1 July 2026, Article 14 (PDF)
- Capital Market Authority: Register of Crypto-Asset Service Providers
- MONEYVAL: Montenegro, 1st Enhanced Follow-up Report and Technical Compliance Re-Rating, December 2025 (PDF)
- Government of Montenegro: Law on Corporate Income Tax
- CdM, via RTCG, 25 July 2026: Ministry of Finance says the crypto-asset law is not in the 2026 work programme
Buying bitcoin as an individual is a different question entirely: how to buy bitcoin in Montenegro covers exchanges, payment methods and legality for residents, and the crypto license hub compares every jurisdiction we track.
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