Company Data Harmonisation in the CRPS: What It Is and How to Meet the 15 June 2026 Deadline
Bringing your company's founding documents into line with Montenegro's new Law on Business Companies
The short version
"Harmonisation" (Montenegrin: usklađivanje) is the mandatory process of bringing your company's founding documents and registered data into line with Montenegro's new Law on Business Companies, which applies from 1 January 2026. You must complete it by 15 June 2026. Until your company is harmonised, the CRPS will not register any change relating to it — in practice, the business is administratively blocked. Missing the deadline triggers fines, "inactive" status, and eventually forced liquidation.
What harmonisation actually means
Usklađivanje translates as "bringing into compliance" or "alignment." In the CRPS context it means one thing: your founding acts (the osnivački akt and statut), your management bodies, and your registered data must be aligned with the new Law on Business Companies — and those changes must be registered with the Central Registry of Business Entities (CRPS).
The point most owners miss: harmonisation is not a checkbox or a notice that you "accept" the new law. It is a set of concrete legal actions: (1) amending or re-adopting your founding documents, and (2) registering those changes in the CRPS.
Where the obligation comes from
In 2025 Montenegro adopted a new Law on Business Companies (Zakon o privrednim društvima, Official Gazette No. 90/2025). It entered into force on 13 August 2025 and applies from 1 January 2026, replacing the previous 2020 law. The reform's purpose is to fully harmonise Montenegrin company law with EU law as part of the EU accession process. Among other things the new law:
- →Introduces a one-tier management system, redefines director responsibilities and term limits;
- →Allows fully electronic incorporation without the founder's physical presence, using a qualified electronic signature;
- →Permits electronic payment of share capital, including to a bank account in an EU member state;
- →Refines the rules on the business name: acceptable language, script, and mandatory elements.
Who must harmonise
The obligation applies to every company and entrepreneur registered in the CRPS before 1 January 2026, whether or not the company is actively trading. A dormant DOO with no turnover must harmonise just the same.
In practice this hits limited liability companies (DOOs) hardest, since they make up the vast majority of entities. But joint-stock companies, entrepreneurs (preduzetnik), and branches of foreign companies are covered too. Companies registered in 2026 under the new law are not affected.
The deadline: why 31 March became 15 June 2026
The law originally allowed three months from the start of application — a deadline of 31 March 2026. Problems with the migration to the Tax Administration's new information system (IRMS) meant registration effectively did not work in the first months of 2026. In March 2026 Parliament adopted amendments that extended the deadline to 15 June 2026. According to the bill's sponsor, this was the maximum extension negotiable with the European Commission.
The same amendments resolved a practical conflict: the CRPS itself now checks the legality of registrations, not notaries — control was logically placed with the body that runs the registration procedure.
Important. 15 June 2026 is a hard deadline. Missing it automatically constitutes a misdemeanour (prekršaj), regardless of the reason for the delay. The law provides no "voluntary" extension after the fact.
What you actually need to synchronise
The scope depends on how far your documents diverge from the new law. For most DOOs, harmonisation involves four areas:
1. Founding act and articles (statut)
Old versions often reference rules that no longer exist. Amendments to the articles are adopted by assembly decision and registered in the CRPS together with a consolidated text.
2. Management bodies and representation
The new law introduces the one-tier model and regulates DOO management more precisely. Check the composition of bodies, appointment procedures, and term limits for directors.
3. Business name (poslovno ime)
Confirm that your name meets the new requirements — it must include the legal-form designation and registered seat, and use an acceptable language and script.
4. Share capital and registered data
Capital, ownership shares, address, and activity codes must all be current and compliant.
| What to check | Typical problem | Action |
|---|---|---|
| Articles / founding act | References to old-law provisions | New version + register in CRPS |
| Management bodies | Old model, expired mandates | Move to one-tier, update appointments |
| Business name | Missing mandatory elements | Adjust and register |
| Capital and shares | Diverges from reality | Bring data up to date |
Step-by-step: harmonising in the CRPS
Step 1 — Document audit
Pull your current osnivački akt and statut, get an up-to-date CRPS extract, and compare them against the new law to see what diverges.
Step 2 — Draft the new versions
Prepare new versions of the founding documents and the corporate resolutions (for example, an assembly decision to amend the articles), in the prescribed form.
Step 3 — Signing
The founding documents are signed by all founders. If you file online, all founders' signatures must be qualified electronic signatures. If you file on paper, the signatures are certified.
Step 4 — Filing via IRMS
From 2026, filing goes through the Tax Administration's IRMS portal (irms.tax.gov.me), which replaced the former e-firma. Two routes:
Electronic route (recommended)
If you hold a qualified electronic certificate on a token, the entire procedure can be done online — with no trip to the CRPS and no notary certification. You need:
- 📌A qualified certificate for electronic signature on a token (eToken / QSCD). In Montenegro it is issued by the Post of Montenegro or CoreIT — roughly €60 for issuance.
- 📌An IRMS portal account, certificate software, and the Chrome browser extension for signing applications electronically.
- 📌Submit the application and signed documents electronically. Official communication runs through an electronic mailbox (e-sanduče) — physical visits are not required.
Practical note. The electronic route requires that everyone who signs (all founders or an authorised representative) holds a token/certificate. If a representative acts for you (accountant, lawyer), authorisations are granted separately within IRMS.
Paper route (alternative)
If you don't have a token, documents are filed in writing — here the notary's role remains, for certifying copies (ovjera prepisa).
Step 5 — Review and registration
The CRPS itself checks the legality of the registration. Once registered, the changes take effect and the consolidated text of the articles is recorded in the registry.
On fees. An administrative fee applies for registering changes. The exact amount depends on the type of change — confirm the current tariff at filing time. For the electronic route, also budget a one-off cost for the certificate/token (~€60, renewable every few years).
What happens if you miss 15 June 2026
Administrative block
This is the most tangible, and it hits at once. Until harmonisation is complete, the CRPS will not register any change for your company — no director change, no address change, no transfer of shares, nothing. The company formally exists, but all registry activity is frozen.
Misdemeanour and fines
Missing the deadline automatically constitutes a prekršaj. The law provides monetary fines for both the company and the responsible person (usually the director). The previous law set fines reaching several thousand euros.
"Inactive" status
Entities that fail to harmonise their data in the CRPS receive neaktivan (inactive) status. The Tax Administration publishes an annual public list of such companies — a reputational risk in dealings with banks and counterparties.
Forced liquidation
For entities that fail to file financial statements for two consecutive years, there is a prinudna likvidacija procedure: the registration body issues a decision and strikes the company from the CRPS within 15 days.
Common mistakes
- ⚠"My company is dormant, so this doesn't apply." It does. The obligation does not depend on having turnover.
- ⚠"I just operate the new way; I won't change the documents." Actual conduct does not count as harmonisation. You need amended acts and their registration.
- ⚠"I'll do it on the last day." June will be peak load at the CRPS. Preparing documents takes time, and a token with a certificate is not issued in five minutes.
- ⚠"I'll wait for another extension." 15 June is already the extension, negotiated with the EC as the maximum. Counting on a further one is risky.
Related reading
Frequently asked questions
Is this the same as annual reporting?
No. Harmonisation is a one-off process of aligning your documents and data with the 2026 law. Annual reporting is a separate, recurring obligation.
Can I do everything online?
Yes. With a qualified certificate on a token, the whole procedure can be done through the IRMS portal — no trip to the CRPS and no notary. Without a token, the paper route remains, with a notary certifying copies.
Do I need a notary?
Only for paper filing, to certify copies. For electronic filing through IRMS, a qualified electronic signature on a token replaces that role.
What if my company was registered in 2026 under the new law?
Then no separate harmonisation is needed — you were incorporated under the current rules from the start. The obligation applies to entities registered before 1 January 2026.
Who checks that it is done correctly?
Under the amendments adopted in March 2026, the CRPS itself reviews the legality of the registration.
How long does the procedure take?
Preparing documents usually takes a few days; registration depends on the registry's workload. Given the June peak load, start as early as possible.
Sources
- Zakon o privrednim društvima Crne Gore, Official Gazette No. 90/2025 — Law on Business Companies of Montenegro
- Amendments of March 2026 — extension of deadline to 15 June; transfer of legality check from notaries to CRPS
- crps.me — Central Registry of Business Entities of Montenegro
- irms.tax.gov.me — IRMS portal through which harmonisation is filed
Not sure whether this applies to your company?
We'll help you make sense of your situation, walk you through the steps, and point you to the right people for the procedure itself.
This material is for information only and does not replace individual legal advice. Confirm deadlines and fees at the time of inquiry.