Global FinTech Guide
Country Name
Payment services
FinTechs belonging to this category offer alternative payment services which are supposed to provide a faster and cheaper way for national, European, and international payments for private and business customers by using new technologies.

For example, payment service providers hereby offer solutions to easily integrate several payment services in online shops.

Some FinTechs furthermore provide real cash register systems and online-reservation solutions for restaurants and shops providing their own payment services or making use of the payment services of FinTechs described above.


Attitude of the country towards modern payment services

Most of Montenegrin banks offer modern payment services to their clients (such as online banking, mobile banking, etc.) to both citizen as well as corporate clients. The usage of those has increased since the COVID situation begun, with most of the utilities companies offering direct payment via mobile apps, of pre-defined forms that allow payments with only a few clicks. 

In the social context, people have accepted the need to change and transition from standard payment service systems to new modern ways of FinTech. On the other hand, legislation does not keep up with social growth as much as it should, which leads to many institutional to real-life discrepancies in application of the growing FinTech mechanisms.

Legal affairs

Obligations and requirements to provide payment services or ancillary services described above

All payment services, including the ones described herein, are regulated by the Law on Payment Systems, and could be performed only upon obtaining a license issued by the Central Bank of Montenegro (“CBCG”). Payment services could be provided by either banks, payment institutions, institution for electronic money or a branch of foreign loan providing institution, that are incorporated in Montenegro. 

In order to be issued with the license, a payment service provider is required to submit an extensive set of documentation, including incorporation act, business plans, evidence of meeting minimum capital requirements, description of the intended measures for the protection of the clients’ funds, overview of the managing structure, mechanisms of internal control, risk assessment, as well as detailed overview of all managing organs, ownership structure, etc. 

Central Bank of Montenegro prescribes a fixed fee for application for the provision of a payment service license amounting to EUR 5.000. There is a requirement of a minimum capital, depending on the type of payment services provided, e.g. EUR 7.500.000 for a bank, or EUR 20.000/EUR 50.000/EUR 125.000 upon incorporating other payment service providers defined under the Law on Payment System.

Additional comments regarding the legal situation for payment services or what FinTech’s must be aware of in this business area


Economic conditions

Market size for payment services and biggest payment service providers

There are currently 12 banks operating in Montenegro, mostly having foreign majority ownership, with the largest bank being Crnogorska Komercijalna Banka AD Podgorica. Other than banks, there are 3 registered payment service providers, and there are no institutions for electronic money registered in Montenegro.

Additional comments regarding the economic situation for payment services or what FinTech’s must be aware of in this business area




© 2022, Karanovic & Partners in cooperation with local lawyers. All rights reserved by Karanovic & Partners in cooperation with local lawyers as author and the owner of the copyright in this chapter. Karanovic & Partners in cooperation with local lawyers has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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