Digital Payments & Fintech · Montenegro
Fintech & digital payments rules in Montenegro (2026)
Montenegro shaded by its digital payments & fintech status
Montenegro operates a dedicated, in-force licensing regime for payment institutions and electronic money institutions under the Payment System Law, which the CBCG supervises and which is aligned with the EU PSD2. The CBCG licenses and maintains public registers of payment institutions, e-money institutions and their agents, and the PSD2-based amendments (in force 8 October 2023) introduced open banking (payment initiation and account information services) and strong customer authentication. Montenegro joined the SEPA geographical area in November 2024 and began operational use of SEPA schemes in October 2025, with a TIPS-based 24/7 instant-payments platform planned for 2026.
Key points
The Central Bank of Montenegro (CBCG) regulates, oversees and improves the payment system under the Payment System Law, which governs payment services, payment institutions, e-money institutions and payment systems, and maintains the official registers of payment and e-money institutions and their agents.
The Law Amending the Payment System Law transposes the EU PSD2; it was adopted by Parliament on 29 September 2022 and entered into force on 8 October 2023, strengthening payment services competition, transparency and consumer protection.
An electronic money institution must be a legal entity seated in Montenegro holding a CBCG license to issue e-money, with minimum share capital of EUR 350,000; it may also provide payment services and related credit but may not take deposits. The CBCG has issued implementing decisions including on own funds of e-money institutions.
The PSD2-based law introduced two new regulated payment services — payment initiation services and account information services — requiring banks to open their APIs so authorised third-party providers can initiate payments and access account information.
CBCG implementing rules include a Decision on Ensuring Strong Customer Authentication and common, secure open standards for communication, mirroring PSD2 security requirements, alongside decisions on safeguarding payment service users' funds.
Montenegro joined the SEPA geographical scope on 21 November 2024 and began operational use of SEPA schemes from October 2025; the CBCG launched its RTS/X system on 26 May 2025 (online clearing for transactions up to EUR 1,000), with a TIPS-clone platform planned to enable 24/7 instant payments from 2026.
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