On 31 July 2025, the Parliament of Montenegro adopted the new Games of Chance Act, introducing significant reforms to the gambling sector. The Act brings notable changes, including the elimination of the concession model, increased financial obligations for operators, enhanced player protection measures, stricter advertising restrictions, and the establishment of a state-owned lottery. The Act will enter into force on the eighth day following its official publication.
Licensing regime
Under the new legal framework, the right to organize games of chance will be granted exclusively through licenses, replacing the previous concession-based system. Licenses for organizing casino games of chance will be issued by the Government of Montenegro, while licenses for organizing betting and slot machine games of chance will be issued by the Games of Chance Administration.
Entities currently operating under concession agreements may continue to do so for a maximum of 270 days from the date the new Act enters into force and must reapply for licenses under the new regime within 180 days of the Act’s entry into force. After the 270-day transitory period, all concession agreements will be automatically terminated. Casino operators who have paid a one-time concession fee of EUR 2 million are entitled to a proportional refund corresponding to the period from the issuance of the new license until the original expiration date of the concession agreement. It remains unclear whether any remaining balance of the concession fee may be credited towards the new license fee, which is set at EUR 2 million.
Casino licenses are valid for 15 years, while licenses for betting and slot machines are valid for 8 years. Previously, casino licenses were issued for 10 years with a possible 5-year extension, and betting and slot machine concessions were granted for three-year periods.
Share capital requirements and risk deposits
The minimum share capital requirement for betting and slot machine operators has increased from EUR 75,000 to EUR 200,000. For casinos, the mandatory share capital has been reduced from EUR 300,000 to EUR 250,000. The required daily risk deposit for casinos is now set at a minimum of EUR 150,000 for up to seven tables, with an additional minimum of EUR 30,000 for each subsequent set of five tables. Betting operators must maintain a daily risk deposit of at least EUR 300 per betting shop. For slot machine operators with electronic roulettes, the risk deposit remains unchanged at a minimum of EUR 5,000 per electronic roulette machine.
Increased bank guarantee requirements
Bank guarantees to secure payment of winnings to players and fulfill obligations to the government have been increased as follows:
– Casinos: EUR 400,000
– Betting: EUR 30,000 plus EUR 3,000 for each betting shop
– Slot machines: EUR 35,000 plus EUR 3,000 for each venue
Increased monthly license fees
The fixed monthly fee for betting operators has increased from EUR 500 to EUR 750 per betting shop, with a one-off fee of EUR 1,000 payable for each individual betting shop license. For slot machine operators, the fixed monthly fee has increased from EUR 50 to EUR 75 per venue, with a one-off fee of EUR 3,000 for each individual slot machine venue license.
Responsible gambling measures
The new Games of Chance Act places greater emphasis on mitigating the social risks associated with gambling, particularly the protection of minors and the prevention of gambling addiction. Operators are required to:
- effectively prevent minors from participating in gambling;
- provide accessible information regarding assistance for gambling-related problems.
Operators must display a 100 x 80 cm poster near the entrance of each gaming venue, containing:
- warnings about gambling addiction;
- responsible gaming guidelines;
- notice of prohibition of entry for individuals under 18;
- information on the potential harms of gambling;
- contact details for addiction prevention support;
- information on obtaining proof of winnings;
- hours of operation;
- contact information for certified treatment centers.
Brochures containing the same information must be available at each registration counter. All advertisements, including indirect references to games of chance, must include a notice prohibiting participation by minors and an appropriate warning regarding addiction prevention. Gambling rules must expressly prohibit participation by minors.
Operators may restrict or temporarily ban players if there is reasonable suspicion that gambling endangers their well-being or upon request from social service institutions due to harm caused to the player or their family. Mandatory exclusion from participation applies to individuals who:
- are members of households receiving social welfare benefits;
- have been diagnosed with gambling addiction in accordance with the International Classification of Diseases;
- are subject to criminal proceedings for failure to provide support.
Self-exclusion mechanism
The Act introduces a self-exclusion mechanism, allowing players to request exclusion, set loss limits, or restrict maximum bet amounts, either in writing or electronically. Self-exclusion may be temporary or indefinite. Operators must implement exclusion requests immediately and notify the Games of Chance Administration within 24 hours. Procedures for managing exclusion and limitation requests must be detailed in internal policies accessible to players and regulatory authorities.
Advertising and location restrictions
The Act establishes a stricter regulatory framework for advertising gambling activities, including the following prohibitions:
- advertising games of chance on radio and television from 6:00 a.m. to 10:00 p.m.;
- advertising in print media, except on pages dedicated to sports;
- advertising on internet publications, except those exclusively dedicated to sports content or the sports sections of other publications;
- advertising in public places.
An exception is made for branding on the exterior of gaming venues or on operators’ vehicles, provided such branding does not constitute an invitation to participate in gaming. The design of gaming venues must prevent visibility of the gaming area from outside.
Advertising of gaming benefits (e.g., bonuses, jackpots, prizes, free spins) is permitted only on the official websites of organizers or the websites of sports clubs and associations sponsored by the organizer. Advertising during radio and television programs intended for minors and youth, including 15 minutes before and after such programs, and in printed materials targeted at minors and youth, is strictly prohibited. These restrictions apply to operators, media founders, publishers, and event organizers.
All permitted advertising must include warnings that:
- games of chance can lead to addiction;
- individuals under 18 are prohibited from participation.
Advertising prohibitions do not apply to lottery games. Advertising of social responsibility initiatives by gaming operators is not considered advertising of games of chance, provided such advertisements include the required warnings and information on assistance for gambling-related issues. Operators may display their logo but must refrain from inviting participation in gambling.
Lottery and other specified gaming venues must be located at least 150 meters from educational institutions (including primary and secondary schools, schools for artistic education, educational and resource centers, and student dormitories), measured as a straight line from the nearest school building to the nearest entrance of the gaming venue. The previous law required a minimum distance of 250 meters but did not specify the method of measurement.
Enhanced player supervision and record-keeping
Operators are required to maintain detailed records of all players who place bets, whether at a counter, game table, or online, including records of winners and payout confirmations. There is no minimum threshold for this obligation, except for betting, where operators must specifically record:
- individuals making payments of EUR 50 or more;
- winners and payouts of EUR 300 or more.
Video surveillance and entry control
All gaming operators must install video surveillance at the entrances and exits of gaming venues and retain footage for a minimum of 90 days. Previously, this requirement applied only to casinos.
Mandatory player registration for slot machines
All slot machines must support player logins via electronic card or biometric data registered by the operator. Players must register prior to participation, and operators must verify identities in accordance with anti-money laundering regulations. Upon registration, players receive an electronic card linked to their account, which is used to access slot machines. Alternatively, with written consent, operators may collect biometric data for account access. For all deposits and withdrawals, operators must verify player identities against registered data.
Establishment of a state-owned lottery monopoly
Although previously permitted, no lottery operator has been active in Montenegro since 2016 due to the absence of new concessions. The new Act establishes a state monopoly, granting the exclusive right to organize lottery games to a company wholly owned by the state of Montenegro. The organizer must pay an annual fixed fee of EUR 100,000 and a monthly fee equal to 10% of the base amount, calculated as the total value of all tickets, slips, and cards sold, less the value of the prize fund.
Tournaments
Organization of tournaments on gaming tables requires prior approval from the Games of Chance Administration. Casino operators must submit a notification and formal request for authorization, together with tournament rules and other required information, no later than 45 days before the scheduled start of the tournament.
Compliance and re-Licensing deadlines
Current operators must comply with the key requirements of the new Act within 270 days of its entry into force. Failure to comply will result in license termination upon expiration of the compliance period.
This summary is intended for informational purposes only and does not constitute legal advice. For specific guidance or compliance assistance, please consult qualified legal counsel.
