Montenegro loses around 86 million euros annually due to unregistered private accommodation, due to outdated records, inefficient billing and the lack of a central tourism information system, according to the Information on the analysis of digital flows and tools in tourism in Montenegro based on tourist traffic data from 2024.
The information was adopted by the Government in July and was prepared in cooperation with the United Nations Office for Project Services (UNOPS). The losses of 86 million, as stated, do not include losses from tourist taxes and indirect revenues. Last year, more than 15 million overnight stays were officially recorded, while revenue from tourist taxes amounted to just over 11,6 million euros.
The analysis concludes that Montenegro lacks a central tourism information system that would consolidate all data on applications and turnover, enable the suppression of the grey economy and the collection of this lost revenue. The creation of such a system, as stated, would cost around 1,3 million euros, with an additional 100 to 200 thousand euros in other start-up costs.
The data is not reliable now.
The analysis showed that there are currently several parallel digital systems in tourism that operate without any interconnection. The following were identified: the register of stays up to 90 days (RB-90), which is maintained by the Ministry of the Interior; the central tourist register (CTR) under the jurisdiction of the Ministry of Tourism; local software solutions such as “Primatech”, “Oblak” and “Čikom”; hotel information systems “Opera” and “Diventa”; then statistical systems (Monstat), inspection supervision (JIIS and ROF), and the electronic registry eDMS. However, these systems are not interconnected, which means that institutions do not exchange data in real time.
This, as stated, leads to multiple entries of the same data, outdated records, inconsistent statistics, and poor supervision of accommodation providers, which directly affects the accuracy of data and the efficiency of collection in tourism.
The introduction of the Tourist Information System (TIS) is, as stated, a strategic priority of the Government of Montenegro, in line with the objectives of the 2022-2026 reform agenda and national digital transformation documents.
"As a central digital platform for recording tourists, accommodation facilities, check-in and check-out, as well as managing fees, TIS will enable accurate, up-to-date and accessible data in real time for all relevant institutions. The Government of Montenegro recognizes TIS as one of the key instruments for increasing the efficiency of public administration, combating the shadow economy and strengthening the competitiveness of the tourism sector. Therefore, its urgent implementation is necessary in order to establish a transparent, sustainable and efficient tourism management system," the analysis states.
Introducing TIS leads to higher revenues
It is recommended that TIS consolidate all data on tourists, services and accommodation for better control, planning and combating the grey economy, which are currently in different registers, as well as to improve and simplify the use of this data by the competent inspectorates in the fight against the grey economy in tourism.
"TIS will enable electronic check-in/check-out of tourists, registration of facilities, calculation and collection of taxes, and integration with state and commercial systems. The expected effects of introducing TIS include better data recording and transparency, automation and acceleration of processes, reduction of administration and the grey economy, as well as better planning and increased tax revenues," the analysis states.
They point out that data on tourist registration, applications and payments are collected using different software solutions that are often not connected, which directly affects the quality and accuracy of these statistics, meaning that differences appear in the number of tourists and overnight stays.
"Data is often entered multiple times into different registers, access to information is limited, and exchange between key stakeholders takes place in fragments and without clear technical standards. The absence of high-quality and accurate input data practically prevents the preparation of serious macroeconomic calculations on tourism. Duplication, but also incompleteness of data, i.e. untimely and unreliable exchange of data between authorities (LTO, Ministry of Interior/Border Police, Ministry of Tourism, local authorities for entrepreneurship and economy, inspection authorities) has a direct negative impact on the effects of any attempt to combat the shadow economy, especially in the part of the record of illegal accommodation providers," the analysis states.
It would help the inspectors.
The new system would help the work of inspections by giving them insight into the real state of tourist traffic, which they currently do not have.
“Tourism inspection at the national and local levels faces a serious shortage of staff and limited possibilities to control illegal accommodation and unregistered guests, especially during the season. In addition, legal barriers (soft penalty policy, lack of authority over unregistered entities) further complicate the implementation of inspections. A large number of unregistered facilities and illegal service providers remain outside the control of the system. Many accommodation providers do not register guests, and therefore avoid paying the tourist tax. At the same time, even those who want to register are often unable to do so due to administrative barriers and a procedure predominantly based on paper operations. It has also been noted that hotels are often re-categorized into smaller units in order to avoid higher taxes and the jurisdiction of the Ministry of Tourism,” the analysis states.
TIS makes work easier for legal accommodation providers
TIS would help legal accommodation renters by reducing their administrative obligations because the collection of data, which now has to be submitted to the competent institutions via paper applications, would be carried out through the system ex officio.
"Parallel paper and electronic guest records represent a burden for hotels and accommodation providers, complicate work and require additional resource engagement, which is a type of business barrier. The Ministry of Tourism and local government units currently do not enable electronic submission of applications for registration of accommodation facilities through their portals, while the burden of collecting documentation is largely on the applicants and is carried out almost exclusively in paper form," the analysis states.
The problem of the lack of incentives for the registration of legal accommodation providers, as well as the lack of formal cooperation with online booking platforms, was also pointed out.
"During the season, a large number of tourists have to register in person because their hosts are not registered in the CTR, which creates a bad image of Montenegrin tourism. The lack of consolidated data at the Montenegrin level on the length of stay makes it difficult to monitor tourist flows, while some foreigners practically reside in the country by regularly registering for 90 days in different municipalities. The practice of insecure processing of personal data is also present in the field; in some municipalities, LTOs register tourists based on passport data and images sent via internet communication applications (Viber or WhatsApp)," the analysis states.
Damjanović and Vukčević launched this measure in 2023.
The Document states that the 2022-2026 reform agenda envisages the introduction of a single registry that would unify all current ones and enable real insight into applications, turnover, and full collection of state and local revenues.
The Ministry of Finance, which was then headed by Aleksandar Damjanović, but the Secretary of State Ilija Vukcevic announced in early 2023 that it was preparing a set of new laws and measures that would suppress the gray economy and prevent the withdrawal of tax-free money.
Among these measures was the introduction of the e-visitor system, modeled after Croatia and EU countries, which was supposed to introduce a single tourism registry by 2023, which is now recommended by this analysis. This was followed by a parliamentary blockade, elections in the fall of 2023, and the new leadership of the Ministry then abandoned this plan.
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