Montenegro CIP Closeout: €413M Raised, 869 Approvals, and a 21.5% Rejection Rate

Nearly four years after Montenegro closed its Citizenship by Investment Program (CIP) to new applicants, the government has issued what constitutes a near-final accounting. Of the 1,113 applications submitted before the December 31, 2022 deadline, authorities had approved 869 and rejected 239 as of July 31, 2026, with five applications pending decision and one subject to a funds-transfer verification.

According to a government status report dated August 20, the program processed more than €413 million in aggregate. Tourism development projects absorbed €251.2 million; donations designated for less-developed municipalities totaled approximately €86.8 million; administrative fees yielded €43.6 million to the state; and the national Innovation Fund received €31.3 million. Agriculture and manufacturing attracted €500,000, while a further €2.1 million remains held in escrow accounts associated with applications still under review.

The program’s three licensed marketing agents processed all 1,113 applications. Henley & Partners submitted 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 rate not to deficiencies in the applicant pool—which he assesses as neither superior nor inferior to those of competing programs—but to political instability in Montenegro.

He notes that governments changed hands repeatedly during the program’s operational lifespan, resulting in significant turnover among decision-makers, which he characterizes as “a very important factor” contributing to the high rejection rate.

This assessment aligns with the program’s processing history. One year after the program’s closure, authorities had approved only 484 of approximately 1,100 applications received, creating a backlog that successive administrations required several additional years to resolve.

Allocation of Funds

Of the €251.7 million invested in approved development projects, 99.8% was directed to tourism. Agriculture and manufacturing received the remaining 0.2%, notwithstanding their prominent inclusion in the program’s founding decision.

Fifteen hotel projects were included on 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 these projects are located 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 constituted the program’s underlying objective. Numerous hospitality products were constructed or are in advanced stages of construction in northern Montenegro, Katz observes, “which was the whole point of the program.”

Government reviews acknowledge that host municipalities lacked the infrastructure necessary to support the influx. Two nearly completed hotels in Kolašin’s ski zone could not commence operations due to insufficient water supply, while other projects awaited access roads, sewage systems, and electrical capacity that state and local budgets were required to fund following the arrival of private capital.

Pending Applications

The government report does not directly address why a small number of applications remain undecided 43 months after the program’s closure. These files have outlasted several of the governments originally tasked with adjudicating them, passing between successive administrations since the program’s termination.

According to Katz’s firm, the remaining cohort includes a number of clients currently engaged in litigation with the government.

The report further acknowledges that the software employed to administer the program lacked a financial accounting module. Balances are instead verified retroactively through independent auditor reports, which may account for ongoing reconciliation of discrepancies between institutional financial records nearly four years later.

Legacy and Golden Visa Prospects

Montenegro was one of only two CIP jurisdictions in Europe, Katz notes, operating at a significantly lower price point than Malta, a combination that attracted clients. Most 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 obtained 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 regards as “a testament to the success of the program.”

Whether Montenegro will replace its defunct CIP with a residence-based offering remains a subject of recurring speculation in Podgorica, even as Brussels continues to monitor the program’s unfinished business.

Katz considers the calculus to hinge “most of all” on if and when Montenegro accedes to the Schengen Area, and on whether any golden visa could offer 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.”

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