The Association of Tourist Agencies of Montenegro has voiced deep concern and dissatisfaction regarding the Ministry of Tourism’s decision to initiate a public debate on the Draft Law on Tourism amidst the peak summer tourist season. They argue that all key stakeholders in the sector, who are the most affected by this law, are fully engaged in tourism operations at this time.

According to the association, this year’s season has faced numerous challenges, ranging from traffic congestion on Montenegrin roads—which hampers tourist movement and tarnishes the destination’s reputation among international partners—to insufficient support in navigating the new challenges arising from the crisis in the Israeli market. They note that Montenegro was expecting around 200,000 tourists from Israel this year, and their absence has significantly impacted many tourism businesses, especially those focused on that market. In such circumstances, they had hoped for a heightened sensitivity and understanding from institutions regarding the sector’s needs.

“This decision, despite prior consultations and clear communication during the development of the draft law, overlooks the industry’s appeal to delay the public debate until after the main season. This would allow for a thorough, quality, and inclusive discussion. As primary representatives of the sector, we have consistently emphasized the necessity for the law to be aligned with the realities of modern tourism and the challenges faced by local tourism companies,” the association stated.

“We find the current draft law to be outdated and misaligned with actual market conditions. Rather than promoting and safeguarding the domestic tourism product and local economic entities, the suggested measures primarily benefit foreign companies and individuals—many of whom may officially operate in Montenegro, but whose profits, revenue, and business operations are largely conducted outside its borders,” they added in a statement.

The association believes this practice directly undermines the sustainability of the domestic tourism economy and contributes to a substantial outflow of funds from the country.

“We estimate that Montenegro loses significant financial resources annually—certainly more than 30 million euros (approximately 10 million of which is legally transferred, while the remainder is generated through unregistered income and illegally moved abroad). This tourism-generated income largely exits Montenegro. We all recognize tourism’s vital importance to our country and its contribution to the overall economy, both directly and indirectly,” they remarked.

“With all due respect, foreigners—who learn about Montenegro solely from brochures—cannot adequately discuss Njegoš on Lovćen, articulate the significance of the Boka Navy, interpret the meaning of the gusal, or explain why local brandy is served to welcome guests. Such experiences are not learned through reading; they are lived. Only local guides can provide visitors with an authentic experience,” the Association of Tourist Agencies asserted.

The association also raised concerns about the section of the draft addressing penal provisions, which they assert are not reflective of real market conditions and place an additional burden on small and medium-sized businesses, without clearly improving service quality or combating unfair competition.

“Furthermore, these penal provisions are inadequate for tackling the shadow economy, leaving significant room for misuse. It would be trivial for someone with malicious intent to, for example, commit fraud or a misdemeanor, subsequently close a travel agency and open a new one,” the statement concluded.

The association is urging the Ministry of Tourism to defer the public debate on the Draft Law until November, when, they claim, conditions will be more favorable for meaningful engagement from all stakeholders.

“This approach can facilitate a legal solution that genuinely advances the sector, rather than a document hastily adopted without dialogue or consideration for those who truly experience tourism in Montenegro. Until then, the tourism industry will have adequate time to prepare proposals and engage with the Ministry, allowing a high-quality, inclusive public debate, to ensure the law is enacted by the end of the year, especially given the need for certain EU accession chapters to be addressed, which would satisfy all parties involved in Montenegrin tourism. We believe a well-structured law could potentially retain nearly 30 million euros annually within Montenegro instead of allowing it to flow out,” they asserted.

“We expect the Ministry of Tourism to demonstrate institutional maturity and readiness for authentic collaboration with the sector that constitutes the backbone of the Montenegrin economy,” the statement concluded.

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