MONTENEGRO Law and Practice Contributed by: Luka Popović and Milana Savović, BDK Advokati
1. Introduction 1.1 Current Outlook and Recent Changes Montenegro has a new Games of Chance Act, which entered into force on 14 August 2025, bringing signifi- cant 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 cur- rently 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 Montene- gro, 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 lot- tery, 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 gam- ing 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 informa- tion 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 meas- ures, 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 gam- bling and provide accessible information regard- ing 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 tem- porary or indefinite. Lottery and other gaming venues must be located at least 150 metres from educational institutions (includ-
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