Record-Keeping, Reporting and Advertising Rules for Games of Chance
During 2026, the Ministry of Finance adopted several subordinate regulations that further regulate the obligations of operators of games of chance. The new rules concern record-keeping, monthly reporting and calculation of fees, as well as the manner of advertising and the external appearance of premises where games of chance are operated.
These obligations should be viewed in the context of the new Law on Games of Chance (“Official Gazette of Montenegro”, No. 091/25 of 6 August 2025), which introduced a new regulatory framework for this area.
New Rulebooks for Different Types of Games of Chance
Five rulebooks were published in the “Official Gazette of Montenegro”, No. 027/26 of 2 March 2026, specifying the manner of keeping records and submitting data for different types of games of chance.
The first rulebook regulates the content and manner of keeping records for cash registers and terminals, as well as the content and manner of submitting the monthly report on the calculation of fees for organizing betting games and proof of payment of the fee.
For gaming machines, a separate rulebook was adopted prescribing in greater detail the content of the monthly report on the calculation of fees and proof of payment of the fee.
Special rules have also been introduced for games of chance conducted via the internet. The rulebook prescribes the form of the monthly record containing the final calculation of business results, as well as proof of payment of the monthly fee for organizing games of chance via the internet.
For casinos, more detailed business record-keeping is prescribed, including data on individual tables, tips and tournaments. Daily records form the basis for the monthly calculation of business results and fees.
Finally, a separate rulebook regulates the method of submission and the form of the monthly record containing the final calculation of business results for organizing games of chance in casinos.
This approach means that operators’ obligations are no longer limited to calculating and paying the prescribed fees, but also include detailed record-keeping that enables control of business results and fee calculations. The Law, for example, stipulates for casinos that the monthly basis for calculating a certain variable component of the fee is determined based on the sum of the daily calculations for all tables for that month.
Special Rules for Advertising and the Appearance of Premises
In addition to the rulebooks published in March, the Ministry of Finance also adopted the Rulebook on the Detailed Manner of Advertising Games of Chance on the External Parts of Premises for Games of Chance and the External Appearance of Premises for Games of Chance (“Official Gazette of Montenegro”, No. 001/26 of 5 January 2026).
The Rulebook further elaborates the rules already established by the Law on Games of Chance. The Law stipulates that advertising games of chance in public places is prohibited, with the exception of advertising on the external parts of premises for games of chance that does not invite persons to play games of chance. The installation of illuminated advertisements, LED displays and other types of screens on the external parts of premises for games of chance is also prohibited.
It is also prescribed that the external appearance of the premises must be arranged in a manner that prevents visibility into the interior of the premises, with the statutory exception for casino premises in five-star hotels.
This means that operators, when arranging or changing the appearance of their business premises, must consider not only technical and spatial requirements, but also the rules concerning external advertising and the visual identity of the premises.
Obligation to Align Business Operations with the New Law
Particular attention should be paid to Article 105 of the Law on Games of Chance, which establishes a transitional period for aligning business operations.
Companies whose principal activity is gambling and betting are required to align their business operations and activities with the provisions of the Law referred to in this Article within 270 days from the date the Law enters into force.
In addition, an important obligation concerning obtaining an authorization is prescribed. Companies to which this provision applies are required to submit an application for authorization to organize games of chance to the competent authority no later than 90 days before the expiry of the 270-day period.
This obligation is particularly important for existing operators, as compliance does not involve merely formal changes to documentation, but also adapting business operations to the new statutory and subordinate regulatory requirements.
What Should Operators Check?
The new regulatory framework requires a systematic approach to compliance. It is particularly important to check:
- whether records are maintained in accordance with the prescribed content and forms;
- whether monthly reports and proof of payment of fees are submitted in the prescribed form and within the prescribed deadlines;
- whether business premises and advertising practices comply with the new rules;
- whether the relevant application for authorization to organize games of chance has been submitted, where required.
The Law also provides for specific obligations for individual types of operators. In betting games, for example, games may be organized only at payment and payout locations in betting shops, i.e. through cash registers and terminals, subject to the prescribed spatial and technical requirements.
In addition, failure to comply with the obligation to submit monthly reports and proof of payments constitutes an offence under the Law.
The adoption of new rulebooks during 2026 has further elaborated the system governing the operation of games of chance operators in Montenegro. The rules now provide more detailed regulation of record-keeping, monthly calculations, reporting, fees, casino operations, betting and online games, as well as advertising and the appearance of premises for games of chance.
For operators, it is therefore particularly important, in addition to the basic obligations prescribed by the Law on Games of Chance, to check compliance with the new subordinate regulations, as these regulations specify in detail how individual statutory obligations are to be implemented in practice.
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