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РусскийSchengen Database Integration at Borders, EU Digital Services Act Enforcement, and New Debt Recovery Standards
InVero editorial team6 min read5 processed actsMontenegro accelerates legal alignment with the European Union: a comprehensive Law on Border Control prepares for integration with the SIS and EES databases, the Digital Services Act is transposed into national law with penalties reaching up to 6% of global turnover, and public bailiffs alongside critical infrastructure operators face rigorous new compliance standards.
Public Safety and Order
Mandatory systematic border checks across national registries and EU databases are introduced for all travelers.
Under Art. 38, all individuals crossing Montenegrin borders are subject to systematic identity and travel document verification against police records, Interpol's Stolen and Lost Travel Documents (SLTD) database, and EU systems. The law enters into force on October 20, 2026. Montenegrin citizens and beneficiaries of EU free movement rights are exempt from in-depth border checks unless a specific security threat arises.
Border police obtain the legal mandate to access the Schengen Information System (SIS), Visa Information System (VIS), and Entry/Exit System (EES).
Pursuant to Art. 44 and Art. 45, border authorities are authorized to create individual files and register biometric data for third-country nationals under the EU Entry/Exit System (EES). Under Art. 93, practical application of these provisions is deferred until Montenegro achieves operational connectivity with the respective EU information systems.
Clear rules and documentation requirements are established for border crossings by minors under 16 years of age.
According to Art. 64, a minor under 16 traveling with one married parent on a valid passport does not require parental consent from the other parent. However, if the minor travels using an ID card, notarized consent from the other parent remains mandatory. Minors over 16 years old are permitted to cross the state border independently without parental consent.
A national framework is enacted for identifying and protecting critical entities and strategic infrastructure.
Under Art. 1, the law establishes uniform criteria for designating strategic operators across the energy, transport, banking, healthcare, and digital infrastructure sectors. The framework aims to bolster national resilience against natural hazards, cyber threats, and supply chain disruptions, entering into force on October 20, 2026.
Designated entities must form resilience teams, notify authorities of incidents, and obtain ISO 31000 and ISO 22301 certifications.
Pursuant to Art. 17, critical infrastructure operators are required to adopt formal resilience plans, appoint dedicated liaisons, and hold certifications under standards MEST ISO/IEC 31000 (risk management) and MEST ISO/IEC 22301 (business continuity). Cross-border EU notification obligations under Art. 50 will apply upon Montenegro's EU accession.
Information Technology
The Agency for Audiovisual Media Services is designated as the national Digital Services Coordinator with supervisory and investigatory powers.
Pursuant to Art. 4, the Agency serves as the single point of contact for the European Commission, the European Board for Digital Services, and other member states under Regulation (EU) 2022/2065 (DSA). Entering into force on October 23, 2026, for institutional and regulatory preparation, the law establishes the administrative framework for overseeing digital intermediary services.
Online platforms and intermediary services face mandatory notice-and-action protocols and enhanced consumer protection obligations.
Articles Art. 14 and Art. 16 obligate digital intermediaries to implement complaint handling systems, enhance recommender system transparency, and take protective measures for minors. Online marketplaces allowing distance contracts must verify third-party merchant identities. In accordance with Art. 24, direct substantive application for businesses begins on the date of Montenegro's accession to the EU.
Fines of up to 6% of annual worldwide turnover are established for non-compliance with digital service requirements.
Under Art. 15, severe penalties apply to intermediary service providers that fail to comply with takedown orders, neglect point-of-contact duties, or obstruct inspections. The calculation methodology for turnover bases is established by the Agency Council. Pursuant to Art. 24, the sanctioning regime applies from Montenegro's EU accession date.
Outdated intermediary liability exemptions for hosting and internet service providers are repealed from the Law on Electronic Commerce.
The legislative amendments repeal Art. 18, Art. 19, Art. 20, and Art. 22, which previously governed intermediary safe harbor provisions. Regulatory oversight of online intermediary liability is shifted to the newly adopted Digital Services Act framework, standardizing national tech regulation with EU single market rules.
Legal Services
Public bailiffs must schedule mandatory daily office hours for receiving clients for at least 4 hours every working day.
Under Art. 7, the working hours of public bailiff offices are synchronized with court working hours across a 40-hour workweek. Daily reception schedules must be prominently displayed at the office entrance and published on the Chamber of Public Bailiffs website. The rulebook takes effect on October 23, 2026.
Standardized protocols are enacted for receiving, recording, and safeguarding funds, bank guarantees, securities, and seized property.
Article Art. 34 regulates the formal handling of monetary deposits and seized assets during business hours through mandatory internal ledgers. Under Art. 56, this act repeals previous rulebooks from 2012 and 2017 as of October 23, 2026, enhancing accountability and transparency in debt collection procedures.