Concerns regarding the initiative to postpone the implementation of the Law on Mediation in the Sale and Lease of Real Estate

We remind the public and competent institutions that this law was adopted in August 2025, after many years of work, dialogue and cooperation between representatives of the profession, the Chamber of Commerce of Montenegro and state institutions. The law already provided for a 12-month delayed implementation in order to create conditions for the adoption of by-laws, the formation of a register, the organization of professional exams and the harmonization of the operations of existing intermediaries with new legal solutions.

For us, as legal intermediaries who have been operating in accordance with the law for years, paying taxes, fulfilling all obligations in the field of preventing money laundering and terrorist financing, as well as numerous administrative and financial obligations that are constantly increasing, the adoption of this law represented an important step towards regulating a market that has been exposed to the shadow economy and unfair competition for years.

Of particular concern is the fact that any additional delay in the implementation of the law would directly benefit illegal intermediaries and unregistered entities that have been seriously jeopardizing legal business in Montenegro for many years, causing damage to the state through evasion of tax and other legal obligations, but also undermining the trust of citizens and investors in the real estate market.

We believe that possible technical challenges related to the organization of professional exams or the completion of certain administrative procedures can in no way be a justification for a new one-year postponement of the application of the law. If there is a need for additional time adjustments for certain technical procedures, we believe that a reasonable and justified deadline could only be a shorter transitional period, and not another 12 months of prolongation of a process that has been going on for six years.

We would also like to point out the broader social and economic context in which the real estate sector in Montenegro operates. In the previous period, the market has faced serious challenges caused by changes in several legal solutions, including the Law on Legalization of Illegal Facilities, the Law on Foreigners and the Law on Prevention of Money Laundering and Financing of Terrorism, refusal of banks to open accounts for non-residents, moratoriums on construction and suspension of issuing legalization decisions until the adoption of a management plan in Kotor, Tivat and Herceg Novi, as well as the overall international circumstances that have influenced the decrease in interest of foreign investors in investing in Montenegro. The decline in foreign direct investment and the decrease in investment in the real estate sector are already visible in the first months of 2026.

In such circumstances, Montenegro needs legal certainty, predictability and clearly defined business rules, not additional prolongation of reforms that have already been adopted and which should have represented an important step towards regulating the market.

The Association of Real Estate Agencies of Montenegro expects all competent institutions, parliamentarians and decision-makers to responsibly consider the consequences of any possible delay in the implementation of the law and to protect the interests of legal businessmen, legal certainty and credibility of the institutions that participated in the creation of this legal solution.

Our goal has never been the privileged position of any market participant, but rather the creation of a regulated, transparent and accountable system in which everyone will operate under equal conditions and in accordance with the law.

The Association of Real Estate Agencies of Montenegro remains open to dialogue and cooperation with all institutions in order to ensure full and quality implementation of the Law on Mediation in the Sale and Lease of Real Estate, but at the same time believes that an additional one-year delay in its implementation does not represent a justified or responsible solution.