Running a small hotel in Montenegro, from linen room to permit file

Early June, a linen room in Bečići. Twenty rooms upstairs, two washing machines that are not going to be enough, and a whiteboard where somebody has started counting.

The count goes like this. A 120-night season from June to September, occupancy of 70 per cent, an average stay of four nights: 20 × 120 × 0.7 ÷ 4 is about 420 full changeovers, plus daily service in between. Each changeover is a set of sheets, four towels, a bathmat and the twenty minutes spent finding the missing pillowcase. Multiply by 420 and you have the real shape of a small coastal hotel: a laundry and a rota with rooms attached. The permit file, the quota, the tourist tax and the VAT rate exist to keep that rota legal.

The demand is not in doubt. MONSTAT's release of 27 August 2026 counted 244,754 arrivals and 1,081,249 overnight stays in collective accommodation (hotels, boarding houses, hostels) in July 2026 alone. The beds are wanted. The question is what the state asks of the person who makes them.

The act that governs the building, and the papers to see before a deposit

Hotels, aparthotels and boarding houses fall under the Zakon o turizmu i ugostiteljstvu, the Tourism and Hospitality Act of 2018. A replacement bill has been circulating for over a year; it is not law. RoNa Legal's note on which tourism act is actually in force, updated 5 September 2026, checks the Official Gazette and finds no replacement published; the 2018 Act (Službeni list CG 2/18, 13/18, 25/19, 76/20 and 130/21) still controls every question below.

The text is on paragraf.me, with one caution: the site stopped updating Montenegrin law on 31 March 2021, so the 130/21 amendment is missing there. Article 90 of the Act obliges the ugostitelj (the hospitality operator, in practice your company) to display the type, category and opening hours, keep the guest book daily, display prices, issue receipts that show the tourist tax as a separate line, and keep a complaints book. Article 84 assigns the star category, one to five, and Article 84(12) issues it for three years.

Before a deposit, ask the seller or the landlord for these:

• The upotrebna dozvola (use permit), or the legalisation file if the building was never permitted (the legalizacija filing deadline is 14 August 2027); without one of these there is no categorisation
• The operating approval under Article 75, which names the operator by name, seat and registration number
• The Central Tourist Registry entry that matches that approval
• The current categorisation decision with its date, so you know how much of the three years is left
• Access to the electronic guest-registration system in the operator's name
• The tourist-tax account with the local tourist organisation, and proof the last remittance was paid
• VAT registration if turnover exceeds €30,000 a year, which twenty rooms on the coast will

Everything after this list is judgement rather than paperwork.

Why a twenty-room house sits outside the condo and mixed models

RoNa's 26 August 2026 analysis of the two statutory hotel-unit models and what the deed covers sets out the rules behind the phrase "condo hotel". Under Article 95 (condo) and Article 96 (mixed) a hotel may sell individual units only if it holds five stars on the coast and in Podgorica, or four stars in the north and centre, operates twelve months a year, keeps the units in commercial letting at least ten months a year, caps the owner's personal use at 15 consecutive days or 10 days a month and, in the condo model, pays the unit owner a 10 per cent floor tied to average rent and occupancy. Article 97 requires three contracts signed together (sale, management and letting) and voids the arrangement if any is missing. Article 72(2) prohibits selling rooms in any hotel outside those two models.

Read that against a ten-to-forty-room house in Bečići or Bijela. Five stars on the coast is a large-hotel standard, and twelve-month operation is exactly what most small coastal houses do not do. The ordinary small hotel is not a condo hotel and cannot become one by calling itself an aparthotel. It is a single business, owned through one company, that sells nights; its exit is the sale of that company or that building, not the sale of room 14 to a buyer in Riyadh.

Buying a running house: the approval follows the operator, not the owner

Many first hotels on this coast are bought, not built, and buying the company that runs the house is a different deal from buying the building.

In a share deal the legal person that holds the operating approval, the categorisation and the employment contracts stays the same; you file an eight-day notification of changed data. In an asset deal the approval does not travel with the walls: the new operator applies afresh, the staff transfer to you under Article 108 of the Labour Act on their existing terms after 15 days' notice from the seller, and you need new contracts with them within five days. RoNa's 31 August 2026 piece on buying the company versus buying the hotel adds the check that matters: the name on the approval must match the Central Tourist Registry entry. If it does not, someone has been trading under an approval that is not theirs, and that becomes your problem on the day you sign.

If a management company runs the house for you, the Act treats the upravljač (the manager) and the brand operator as separate counterparties and prescribes fourteen mandatory heads for the agreement; a contract missing one is void, per RoNa's 26 August 2026 note on management agreements. For twenty rooms the owner is usually the operator; the moment a third party runs the desk for a fee, that contract has to meet the statute.

Housekeepers, a receptionist and the 2,320 seasonal permits

Twenty rooms at 70 per cent occupancy need a morning housekeeping shift of more than one person, a desk covered from breakfast to the late check-in, and a maintenance contact who answers on a Sunday. The seasonal gap is filled from Serbia, Bosnia, Turkey and further away, and that is where the state has a say.

Foreign hires go through the single permit (jedinstvena dozvola, the combined residence-and-work permit), capped by an annual Government decision. RoNa's explainer on how the annual work-permit quota is allocated by sector gives the 2026 figures: 28,988 permits in total, adopted on 18 December 2025, of which 2,320 are for seasonal work, and accommodation and food service take 1,467 of those. A seasonal application is filed through the Montenegrin diplomatic mission in the worker's home country, not at a counter in Budva, so the June housekeeper is recruited in March. And when a sector's allocation is used up, the counter stops accepting applications for that activity until next year.

Seasonal permits run up to six months, with a hard cap of eight months in a year, according to RoNa's hotel-investment page. Complete files are decided within 15 days; a repeat seasonal worker from last summer is decided in 10 days. The other route is a licensed employment agency (agencija za zapošljavanje), which holds the permit and seconds the worker to you; it costs more per hour, and for a house that only needs extra hands in July and August it is often the honest answer.

What the €600 floor turns into on the payslip

Montenegro's 2026 minimum wage is €600 net for jobs at qualification level V and below, which is where housekeeping sits, and €800 net for level VI and above. RoNa's 3 September 2026 costing of what a foreign worker costs an employer in 2026 gives the planning multipliers: at €1,000 net the total employer cost is roughly €1,190, a factor of about 1.19, rising towards 1.29 at €2,000 net. The same note adds that staff accommodation and meals sit on top of the €600, not inside it. A room you give a seasonal worker is a room you cannot sell, and it does not reduce the wage.

Twelve hours, a guest book and one euro a night

The Foreigners Act puts the duty to register a foreign guest's stay on the accommodation provider, within 12 hours of arrival. The Ministry of the Interior's foreigners page states the split: a foreigner who arranges their own accommodation files their own registration, while providers file for their guests.

Registration is electronic and municipal. Tivat's tourist organisation has moved providers to a mobile application called Lotos Turist; Budva's information points still take registrations in person. The tooling is in the table below. At 420 changeovers a season, "the night receptionist does it in the morning" is not a system. Give the duty to a named person on each shift and check the log weekly.

The tourist tax (boravišna taksa) is collected by you and remitted to the municipality. The Budva tourist organisation's page on the residence tax sets it at up to €1.00 per person per night, with children under 12 exempt, ages 12 to 18 at half rate, and exemptions for stays over 30 consecutive days and for seasonal workers with registered residence, the clause that covers your own staff sleeping on site. The host collects it within 12 hours of arrival and shows it as a separate line on the invoice. RoNa's short-let guide describes remittance within five days after each 15-day period; the cadence is a municipal matter, so confirm it with your own tourist organisation.

The season in numbers, with sources

The plumber's day rate looks small next to a season's revenue until you multiply it by the number of Sundays a twenty-year-old boiler chooses. Glatko's 2026 survey of plumber and electrician prices puts the standard rate at €120 to €180 a day and the call-out at about €25, often waived if the job goes ahead.

A retained tradesperson who has seen your plant room in May is cheaper than any of those numbers in August. If you do not have one yet, describing the job on Glatko sends it to verified tradespeople in your town.

VAT at 15 per cent, and what the older guides still say

Room revenue carried a reduced VAT rate of 7 per cent for years. RoNa's hotel-investment page and its short-let guide both put accommodation at 15 per cent since 1 January 2025. I have not found the amending text online in English, so treat 15 per cent as the working figure and have your accountant confirm it against the current Zakon o PDV (the VAT Act) before you print a price list. On twenty rooms the gap between 7 and 15 per cent is most of the margin on a shoulder-season night.

Profit tax is the gentler line: 9 per cent on profit up to €100,000, then 12 and 15 per cent in the bands above. On the purchase itself, RoNa's page on hotel acquisition for foreign buyers describes a progressive transfer tax of 3, 5 and 6 per cent by value band on resales and 21 per cent VAT on a first transfer from a developer; it also notes that the beach in front of the house is a concession from JP Morsko dobro, never part of the title.

The question to ask before you sign

RoNa Legal is a law firm that advises on Montenegrin and Turkish law from Budva and İzmit; it was founded by lawyers registered with the Kocaeli Bar, and its Budva office opened in 2023. Its hotel material starts where the linen room did: with the operating approval and the name on it.

So the question, put to the seller in writing before the deposit and before the linen order: under which article does this building sell beds? If the answer is Article 95 or 96, ask for the three contracts, the five-star categorisation and the twelve-month operating record, and expect a house this size to have none of them. If the answer is neither, which for a ten-to-forty-room house it will be, you are buying an ordinary hospitality business under Articles 72, 75, 84 and 90, and the papers on the list above are the whole of it. Get the answer on paper, dated, with the categorisation decision stapled to it. Then order the sheets.