The Law aims to enhance legal certainty, urban planning, and market transparency, while boosting public revenues. However, its implementation also brings significant challenges — most notably the prohibition of transactions involving unlegalized properties under Article 33, which has led to a partial freeze of the real-estate market.
The Notary Chamber of Montenegro, following the Ministry’s opinion of 28 August 2025, confirmed that this prohibition applies to all unauthorized properties, regardless of when they were built. As a result, notaries are prevented from notarizing such transactions, raising important market and social concerns.
While the Law represents a major step toward a more orderly real-estate system, a phased and balanced application of Article 33 would better align its goals of transparency, stability, and legal certainty.
This analysis (in Montenegrin and English) is provided by Partner Alma Karađuzović Đinđinović from JPM Podgorica office.
