Published: 25.09.2026. · ISO 14001

Montenegro's Climate Change Law amendments in 2026: what businesses should know

Publisher: ConsultHQ

Montenegro’s 2026 climate rules clarify the neutrality goal, emissions monitoring and duties applying to certain regulated operators.

Montenegro has applied the amendments to its Climate Change Law, published as 70/2026, since 28 May 2026. They clarify the 2050 climate-neutrality objective and provide more detail on monitoring, reporting and verifying greenhouse-gas emissions from maritime transport. Permits, monitoring and emissions credits under the wider legal framework also matter to certain industrial operators.

The amendments do not automatically require every company to calculate a corporate carbon footprint. Direct legal duties depend on the activity, the installation and whether the business falls within a category regulated by the law.

For companies using ISO 14001, climate change can also be a broader regulatory and business-context issue. It should be assessed within the environmental management system without assuming that every certified company needs an emissions permit.

Law 70/2026 entered into force on 28 May 2026

The Law Amending the Climate Change Law was published in Montenegro's Official Gazette 70/2026 on 20 May and entered into force on 28 May 2026. It amended the principal Climate Change Law 149/2025. The current framework should therefore be cited as the Climate Change Law (Official Gazette of Montenegro, nos. 149/2025 and 70/2026).

Montenegro has clarified its 2050 climate-neutrality objective

The amended Article 3 states that total greenhouse-gas emissions from all sectors should be balanced by removals by 2050 at the latest, achieving net-zero emissions. Measures aimed at negative emissions follow thereafter. The Government linked the clarification to further alignment with EU policy.

This is primarily a national objective. It does not, by itself, require every individual company to reach net zero by 2050.

A company's direct duties depend on its activity

The law covers different categories of activity and entity, including certain stationary installations, regulated entities, aircraft operators and shipping companies. It also addresses verification of emissions reports by accredited verifiers.

It would be inaccurate to tell every ISO 14001 client that it needs a greenhouse-gas emissions permit. The first step is to establish whether its activity falls within the regulatory scope.

Regulation 116/2026 defines covered emitting activities

The new Regulation on activities emitting greenhouse gases for which emissions permits are issued and emissions credits allocated has been in force since 13 August 2026. It was published in Official Gazette 116/2026 and replaced the previous regulation in this area.

For an industrial company operating a covered installation, this regulation is central to assessing its permit and emissions-credit duties. Its annexes identify covered activities; a general description such as “factory” is not enough to decide applicability.

An emissions permit is linked to a monitoring plan

Current regulatory permit forms show that a greenhouse-gas emissions permit is issued to the operator of a stationary installation for a defined activity and location. An approved emissions monitoring plan forms part of that permit.

Compliance therefore extends beyond holding a decision on paper. A covered operator needs a system for monitoring relevant emissions in line with the approved plan.

Emissions monitoring needs reliable data

The monitoring framework calls for complete, consistent, comparable, transparent and accurate data. For covered stationary installations and other regulated entities, monitoring must capture the relevant processes and sources of emissions.

An annual figure alone is insufficient. The operator needs a trail showing how the figure was derived, which activities it covers and which method was used. This connects naturally with ISO 14001 controls over documented information and measurement data.

Reporting and verification provide formal evidence

The law also regulates verification of greenhouse-gas emissions reports. An accredited legal entity verifies a report against the law and related rules. A company's internal climate indicator is therefore different from a formally verified regulatory report.

Where formal verification applies, the operator must follow that separate regulatory process. An internal ISO audit can support data controls, but it is not the accredited verification itself.

Emissions credits are already relevant to covered operators

Montenegro has an emissions-credit system for covered stationary installations. The Government has previously allocated free credits to certain operators and auctioned others. The 2026 law and regulation further govern the system.

For a company within scope, the climate framework may have direct operational and financial effects. Companies outside scope should not be presented as emissions-credit participants merely because they have ISO 14001.

Maritime transport receives a more detailed MRV framework

The 70/2026 amendments are particularly relevant to shipping. The Government describes improvements to monitoring, reporting and verification of greenhouse-gas emissions from ships, including monitoring plans, methods, verification and verifier accreditation.

Most ordinary service or industrial companies will not have direct shipping duties. Shipping companies and related operators may need a detailed assessment.

Climate law and ISO 14001 have different roles

ISO 14001:2026 is an international environmental management-system standard; the Climate Change Law is legislation. An ISO certificate does not replace an applicable emissions permit, monitoring plan, report or other legal duty.

An ISO 14001 system can, however, connect relevant duties to an organisation's processes through:

• compliance obligations;
• environmental aspects;
• risks and opportunities;
• objectives;
• monitoring and measurement;
• control of documented information;
• internal audits.

Climate change also matters outside the emissions-trading system

A company may have no installation requiring a greenhouse-gas permit and still face climate-related business risks. Examples include:

• high temperatures;
• water shortages;
• supply-chain disruption;
• changing energy costs;
• demands from international customers;
• greater exposure to fires, floods or other extreme events.

ISO 14001:2026 gives climate issues greater prominence when considering the organisation's context. Regulatory compliance and management of climate-related risks should be assessed separately and connected where relevant.

Not every company needs a corporate carbon footprint

Measuring an organisation-wide greenhouse-gas footprint can be useful or required by a customer, group, investor or reporting framework. But the 70/2026 amendment alone does not make a total corporate footprint calculation mandatory for every Montenegrin company.

First establish the company's regulatory status. Then assess any commercial or voluntary measurement needs as a separate question.

Review the ISO 14001 obligations register against the new framework

An organisation using ISO 14001 should periodically review legal developments that may affect it. Law 70/2026 and Regulation 116/2026 belong in the regulatory review for businesses whose activities may fall within their scope. If an activity is outside scope, that conclusion should be documented accurately as well.

The obligations register is not a list of every environmental law in existence. It should identify requirements relevant to the organisation's actual processes.

A production-capacity change can alter regulatory status

An industrial company may remain below a regulatory threshold for years. A change in capacity, technology or activity may change its status. Before a significant expansion, environmental change control should check:

• whether the activity falls within Regulation 116/2026;
• whether an existing permit needs to change;
• whether the monitoring plan needs to change;
• which new records or verification duties may arise.

This review belongs before the modified process starts, not after emissions data have already been generated.

Emissions data need clear ownership

Where emissions monitoring is a legal duty, data should not simply be left to “the environmental officer”. Production, energy management, fuel purchasing and laboratory measurements may all supply inputs. The monitoring system needs defined sources, responsibilities and checks on data quality.

A well-designed ISO system can help reduce the risk of gaps between those teams and the formal report.

Internal audits can check relevant regulatory data processes

An ISO 14001 internal audit is not a substitute for formal verification of an emissions report. It can check the processes that produce the underlying data: whether the current monitoring plan is used, required records exist and responsibilities are clear.

That helps identify system problems before an external regulatory verification takes place.

What companies should check now

First determine whether direct climate-law requirements apply to the company. Industrial and other potentially covered operators should assess:

• the current Climate Change Law, 149/2025 as amended by 70/2026;
• the scope of Regulation 116/2026;
• existing greenhouse-gas emissions permits;
• approved monitoring plans;
• the collection and quality control of emissions data;
• reporting and formal verification;
• emissions-credit duties;
• installation changes that may affect permit status;
• the ISO 14001 compliance-obligations register.

For companies outside the direct regulatory scope, the focus should be on material climate risks and relevant customer or market requirements.

ConsultHQ connects climate requirements with ISO 14001

A company with a functioning environmental management system does not need a parallel “climate folder”. It needs to identify the climate duties that actually apply and connect them with its existing processes.

Through ISO 14001 implementation and a regulatory gap analysis, ConsultHQ can review whether a business falls within the new climate framework and how its permits, monitoring, documents and responsibilities work within its management system. We distinguish legal duties from business climate risks and voluntary ESG or carbon-footprint requests.

Related services and articles: ISO 14001 in Montenegro, the Waste Management Law amendments and gap analysis.

Official sources: Official Gazette: amendments in Law 70/2026; Official Gazette: principal Law 149/2025; Official Gazette: Regulation 116/2026.

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