EGR has partnered with 4H Agency to bring its readers a series of long-form articles on the requirements and key facts and figures for a host of emerging markets throughout the world.
Tapping into 4H’s talent pool of experts, the articles will outline the regulatory framework and entry requirements for interested parties, as well as an insider’s view on how the market could shape up in the coming years.
Here, the series continues with Montenegro, with commentary from 4H partner and head of consulting department, Ivan Kurochkin
Market overview
Montenegro, with a population of 616,177 and a GDP of approximately $7.5bn in 2023, recorded $6.4m in gross gaming revenue for January and February 2025.
Formerly part of Yugoslavia, the country became independent in 2006, and it inherited a tradition of legal gambling dating back to the 1964 Gambling Act. After independence, Montenegro adopted Serbia’s 2004 Law on Games of Chance, which lacked modern online gambling provisions. For years, the sector remained underdeveloped, whereas casino licensing was managed via tenders, advertising was unregulated and online gambling had little presence.
A new law has recently overhauled the outdated system and introduced comprehensive regulation and aligning the market with European standards.
Regulations
Montenegro regulates all major gambling verticals, including land-based casinos and sports betting, slot machine halls, online gambling and lotteries. B2B activities remain unregulated. The national regulatory authority – the Games of Chance Administration under the Ministry of Finance – issues the following types of licences:
- Licence for land-based casinos
- Licence for sports betting
- Licence for slot machine hall
- Licence for online gambling
It is important to note that online gambling licences are granted only as an extension of land-based licences. As a result, any operator wishing to offer online gambling services in Montenegro must first obtain or already hold a relevant land-based licence.
Licence requirements
The general requirement for gambling operations in Montenegro concerns only joint-stock or limited liability companies registered in Montenegro, with gambling as their primary business activity.
To obtain and maintain a licence, the operator must meet the following criteria:
- Possess business, professional, economic and financial capacity;
- Has not been convicted, and neither have its directors, shareholders, beneficial owners or executive officers, for a range of criminal offenses, and no ongoing criminal proceedings or final convictions related to professional activity against the founder or beneficial owner;
- Has no outstanding tax obligations;
- Owns or leases suitable premises and equipment, has a cash register and secure area for money storage;
- Has necessary technical infrastructure and connection to the supervisory authority’s information system, as well as continuous video surveillance connected to the regulator’s system for land-based operations; and
- Provide the regulator with all required documentation
Requirements for land-based casinos
Casinos may operate only in hotels rated five stars or higher and must meet the following minimum standards:
- Gaming area of at least 400 sq m;
- Minimum of seven gaming tables (ball, dice or card games);
- Use of certified casino management system, etc.
Requirements for land-based sports betting
Sports betting may be offered only at physical points of sale or via betting terminals, with the following conditions:
- Each betting shop must be a designated space of at least 10 sq m with entrance video surveillance;
- Betting is prohibited in restaurants, gas stations, educational, healthcare, social, cultural and government institutions;
- All equipment must display official registration stickers, etc.
Requirements for slot machines hall
Slot machine games may be offered in dedicated slot machine halls, subject to:
- Minimum area of 35 sq m and at least 10 installed machines;
- Visible display of game rules and return-to-player percentage;
- Machines must be sealed, technically sound and display manufacturing data;
- Machines may not be used in non-gambling venues (eg, restaurants, gas stations, etc.).
Requirements for online gambling
Only land-based licence holders may apply for an online gambling licence. Online operators must:
- Notify the regulator of each online game and submit corresponding rules;
- Register players through physical or online points;
- Collect and verify player identification data, including name, address, ID, birthdate, email, phone number and bank details;
- Ensure that players have sufficient account balance before accepting payments.
Licence cost and term
Land-based casino licence (15-year term)
- One-time licence fee: ~$2.3m per casino;
- Annual maintenance fee: ~$122,800;
- Monthly slot machine fee: ~$92 per slot machine;
- Unconditional guarantee: ~$454,800;
- Minimum share capital: ~$284,250;
- Daily risk deposit: ~$170,550 for seven tables; an additional ~$34,110 for every five additional tables.
Land-based sports betting licence (eight-year term)
- One-time licence fee: ~$1.2m;
- Monthly maintenance fee: ~$923 per betting shop;
- Unconditional guarantee: ~$34,110 plus ~$3,411 per betting shop;
- Minimum share capital: ~$227,400;
- Daily risk deposit: ~$341 per betting shop.
Slot machine hall licence (eight-year term)
- One-time licence fee: ~$3,696 per slot machines hall;
- Monthly slot machine fee: ~$92 per machine;
- Unconditional guarantee: ~$39,795 plus ~$3,411 per slot machines hall;
- Minimum share capital: ~$227,400;
- Daily risk deposit: ~$5,685 per electronic roulette.
Online gambling licence (term linked to land-based licence)
- Initial fee: Included in the corresponding land-based licence;
- Monthly fee: ~$12,320 for either online sports betting or online casino and slot games.
- Other fees (guarantee, share capital, risk deposit): Included in the corresponding land-based licence.
Taxation
- Slot machines and online gambling: These verticals are taxed at a flat rate of 15% on GGR.
- Sports betting: Taxed at a rate of 10% on GGR.
- Land-based casinos: 15% on the monthly aggregate of daily calculations for table games where players play against the casino; 15% on the portion of stakes withheld by the casino in games where players compete against each other.
- General taxation: Corporate income tax is progressive and ranges from 9% to 15%, depending on the operator’s profit. Additionally, a 15% withholding tax and a 21% VAT apply.
RG and AML regulations
Operators must comply with the following responsible gambling requirements:
- Provide gambling activities in a socially responsible manner, ensuring protection of minors, prevention of gambling addiction and protection of players’ personal data;
- Clearly display a 100 x 80 cm poster near the POS entrance with information on responsible gambling, addiction risks, prohibition of underage participation, help resources, certificate issuance and contact details of certified treatment institutions, as well as brochures with the same information at all registration points;
- Advertise its activities with a warning about addiction and a notice prohibiting participation of minors. Promotion of socially responsible initiatives is allowed and may include the operator’s logo but must not encourage gambling. Such reports must include a ban on minor participation, an addiction warning and contact information.
- Temporarily restrict or prohibit participation if a player’s gambling puts their wellbeing at risk, or if requested by social or child protection services. Players may also self-exclude or request limits on stakes or losses, for a defined or indefinite period. Operators must process such requests within 24 hours and notify the regulator.
- Verify identity via personal documents, maintain internal procedures for exclusion and make them accessible to both players and authorities.
- Keep real-time records of all payments, withdrawals and winnings through an online supervision system. For casinos, this includes tracking cash desk transactions and table drop amounts.
Key obligations of the operators in terms of AML compliance include:
- Player identification must be conducted by collecting personal data from official documents and verifying them against independent or secure sources. Identity verification can be completed through direct inspection of an ID document (with a photo), or through electronic or video-based identification procedures, in line with AML regulations.
- Participation is prohibited for politically exposed persons (PEPs) and for those who have self-excluded or are vulnerable.
- Operators must grant continuous electronic access to their supervision systems to the gambling regulator, the financial intelligence unit (FIU), the police unit responsible for AML enforcement and others.
Marketing
Following the 2025 reform of gambling legislation in Montenegro, advertising of gambling services is now subject to clear restrictions. Previously, only offshore gambling was prohibited, while licensed operators faced no formal advertising limits. The new framework introduces the following key rules:
- Promotion of gambling-related benefits (such as bonuses, jackpots, prizes, free spins) is prohibited, except on the operator’s official website or on the websites of sports clubs and associations sponsored by the operator;
- Gambling advertisements are not allowed on radio or television between 6am and 10pm;
- Advertising in print media is restricted to sports publications only;
- Online advertising is allowed only on platforms that exclusively publish sports content or in the sports sections of daily and weekly publications;
- Gambling promotions must not appear 15 minutes before or after radio and TV programs intended for minors and young people, and must not be published in printed materials aimed at these audiences;
- Advertising is strictly prohibited in all media and at events specifically intended for minors and young people;
- Promotion of offshore and unlicensed gambling services is forbidden.
All permitted gambling advertisements must include a notice prohibiting the participation of minors and a warning on gambling addiction risks. This requirement applies to all advertising formats, including affiliate marketing.
Market specifics for entry
Montenegro strictly regulates the allowed verticals of gambling operation. Unlicensed foreign operators offering online gambling to Montenegrin players are banned, therefore only legal entities holding a valid Montenegrin online gambling licence are permitted to offer services to local players.
The market is more restrictive in its nature, holding several restrictions and limitations applicable for local operators: for example, gambling activities in free zones, pyramid schemes or “money chain” style games, in which new players fund the winnings of earlier participants, sports betting on events involving sports clubs in which operators hold ownership or co-ownership, as well as betting on political election outcomes (national or international) are strictly prohibited.
As of 2025, Montenegro has an established and regulated gambling market with the following active licences:
- Land-based casinos: three;
- Land-based sports betting: 18;
- Slot machine halls: 26;
- Online gambling: 13.
The 4H view
Montenegro’s gambling sector has seen a significant transformation with the adoption of a new regulatory framework in 2025. Previously, the market was governed by outdated and fragmented rules – casinos were licensed through tenders, advertising was largely unregulated and online gambling lacked legal clarity. As a result, the jurisdiction remained low-profile and attracted limited interest from international operators.
The new legislation marked a turning point. It eliminated the tender system for land-based casinos, introduced direct licensing across all verticals and formally regulated online gambling, responsible gaming, AML compliance and advertising. The law also introduced mechanisms for blocking unlicensed operators and strengthened the regulator’s role, which now provides regular market updates and clear licensing guidance.
One of the most notable developments is the rising importance of online gambling. While current rules still require online operators to hold a land-based licence, the momentum is clearly shifting toward online licensing autonomy. With 13 online licences already granted, this vertical is becoming central to the market’s growth strategy.
Montenegro may still be a small market by European standards, but it is becoming a more structured and transparent jurisdiction. The reform signals a clear intention to modernise, attract reputable operators and align with broader regional trends in gambling regulation.
Ivan Kurochkin is one of the founders of 4H Agency, partner and head of the Eastern Europe desk at 4H.
After 10+ years’ experience in consulting every type of clients from the testing laboratories to global operators and B2B providers on a variety of matters related to the gambling operations, Ivan has proven himself to be a business-oriented multi-jurisdictional advisor for entering new markets across the globe.
Ivan’s background helps him to choose the best and most efficient scenarios for expansion to new market or for bringing existing operations of 4H’s clients to a significantly new level. Ivan is also an expert in the field of responsible gambling and frequent author for industry media
The post The 4H View: Everything you need to know about Montenegro first appeared on EGR Intel.
EGR has partnered with 4H Agency to deliver a monthly insight into emerging regulated markets’ key requirements. This month, Montenegro is in the spotlight
The post The 4H View: Everything you need to know about Montenegro first appeared on EGR Intel.