Nearly four years after Montenegro closed its Citizenship by Investment Program (CIP) to new applicants, the government has published what amounts to a near-final accounting. Of the 1,113 applications filed before the December 31, 2022, deadline, authorities had approved 869 and rejected 239 as of July 31, 2026, leaving five awaiting decisions and one undergoing a funds-transfer check.
More than €413 million moved through the program in total, according to a government status report dated August 20.
Tourism development projects absorbed €251.2 million of that sum, donations earmarked for less-developed municipalities accumulated to roughly €86.8 million, administrative fees brought the state €43.6 million, and the national Innovation Fund received €31.3 million.
Agriculture and manufacturing attracted €500,000. Another €2.1 million remains in escrow accounts tied to the applications still under review.
The program’s only three licensed marketing agents handled all 1,113 applications. Henley & Partners channeled 531 applications (431 approved, 97 rejected), Arton Group filed 295 (221 approved, 72 rejected), and Apex Capital Partners submitted 287 (216 approved, 70 rejected).
One in Five Applications Rejected
The program rejected 21.5% of all applications filed. Nuri Katz, President of Apex Capital Partners, attributes the elevated refusal count not to any deficiency in the applicant pool, which he considers neither better nor worse than that of competing programs, but to Montenegro’s political churn.
Governments changed hands numerous times during the program’s operational life, he points out, and the resulting turnover among decision-makers was, in his estimation, “a very important factor” behind the high rejection rate.
That reading is consistent with the program’s processing record. A year after the program closed, authorities had approved only 484 of the roughly 1,100 applications received, a backlog that took successive administrations several more years to clear.
Where the Money Went
Of the €251.7 million invested in approved development projects, 99.8% went to tourism. Agriculture and manufacturing received the remaining 0.2%, despite their prominent billing in the program’s founding decision.
Fifteen hotel projects made the government’s approved tourism list, with a combined planned value of €431 million, 2,417 accommodation units, and a projected 1,783 jobs. Nine of those projects are in the north, eight of them in the ski resort town of Kolašin alone, while six larger developments in Tivat, Budva, and Bar account for €311 million of the planned total.
From the licensees’ perspective, delivering on that pipeline was always the underlying objective. Numerous hospitality products were built or are in late stages of construction in northern Montenegro, Katz notes, “which was the whole point of the program.”
Government reviews concede that host municipalities lacked the infrastructure to support the influx. Two nearly completed hotels in Kolašin’s ski zone could not open for want of water supply, while projects elsewhere waited on access roads, sewage systems, and electrical capacity that state and local budgets had to fund after the private capital arrived.
Pending Applications
Why a handful of applications remain undecided 43 months after the program’s closure is a question the government report does not directly answer. The files have outlived several of the governments that were meant to decide them, passing between administrations ever since the program closed.
The remaining group includes, as Katz’s firm understands, a number of clients now in litigation with the government.
The report also acknowledges that the software used to administer the program has no financial accounting module. Balances are instead confirmed retroactively through independent auditor reports, which may explain why discrepancies between institutional financial records are still being reconciled almost four years on.
Legacy and Golden Visa Prospects
Montenegro was one of only two CIP countries in Europe, says Katz, at a much lower price than Malta’s, and that combination drew clients in. Most of them invested, he adds, because they “knew how beautiful a country it is and believed in the future of Montenegro as an integral part of the European continent and Union.”
Many Apex clients who received citizenship “have fallen in love with Montenegro,” Katz observes, purchasing homes and businesses and spending considerable time in the country, a continuing economic contribution he considers “a testament to the success of the program.”
Whether Montenegro follows its defunct CIP with a residence-based offering is a subject of recurring speculation in Podgorica, even as Brussels continues monitoring the program’s unfinished business.
Katz sees the calculus hinging “most of all” on if and when Montenegro joins the Schengen Area, and on whether any golden visa could carry a pathway to citizenship.
Absent that combination, he cautions, the country would struggle to compete with established European residence programs, “and therefore it may not be worth it for the government to create such a program.”
