Published: 25.09.2026. · ISO 14001

Environmental impact assessment in 2026: changes for investors and industry in Montenegro

Publisher: ConsultHQ

Montenegro updated environmental impact assessment and screening rules for certain projects in 2026, especially renewable-energy projects.

Montenegro amended part of its environmental impact assessment (EIA) framework in 2026. Law 70/2026 makes the exceptions for exclusively defence-related or emergency-response projects more precise. Regulation 85/2026 changes List II and the screening of certain renewable-energy projects, including simplified treatment of some solar installations.

For most companies, this does not create an entirely new EIA process. The core distinction remains: some projects require an assessment, while for others the competent authority decides through an initial screening procedure whether an assessment study is needed. Investors should establish which category their specific project falls into under the updated 2026 rules.

Law 70/2026 entered into force on 28 May

The Law Amending the Environmental Impact Assessment Law was published in Montenegro's Official Gazette 70/2026 and entered into force on 28 May 2026. The amendment itself is narrow.

It changes Article 4(3) to allow the EIA procedure to be disapplied, case by case, to projects or project parts exclusively serving defence purposes or responding to emergencies where an assessment could adversely affect those purposes. This will usually not change the day-to-day obligations of an ordinary industrial or commercial company. The amended project regulation is more relevant to many investors.

Regulation 85/2026 changes screening for certain projects

The Regulation Amending the Regulation on Projects Subject to Environmental Impact Assessment was published in Official Gazette 85/2026 and entered into force on 25 June 2026.

It changes List II, whose projects may require an EIA study following a preliminary screening decision. The Government says the amendment adds renewable-energy generation projects while providing some exemptions and simplifications, especially for solar installations on existing structures. It is part of alignment with EU Directive 2023/2413, known as RED III.

List I and List II serve different purposes

List I contains projects for which an environmental impact assessment is mandatory. List II contains projects for which the competent authority first decides through screening whether an assessment study is required.

Being on List II does not mean that a full study is always necessary. Nor does it allow the investor to decide on its own that no assessment is needed. The prescribed screening procedure provides the decision.

Renewable-energy projects have a more specific EIA framework

The most significant business effect of Regulation 85/2026 concerns the energy transition. Renewable-energy projects were added to List II alongside certain exemptions and simplified treatment. The Government specifically mentioned solar installations on existing structures.

The aim is to speed up lower-impact renewable-energy development while retaining environmental protection where projects may have more significant effects. A project's location and installation method may matter as much as the technology itself.

Rooftop solar and a new solar power plant are not the same case

“Solar project” covers very different investments. Installing panels on an existing structure has a different land-use and environmental profile from building a large energy complex at a new location. The updated framework takes a more differentiated approach. Investors should check the project's exact category rather than assuming that all photovoltaic projects are treated alike.

Check screening before the project is too far advanced

A costly mistake is to examine EIA requirements only after the location and technical solution have effectively been fixed. A screening decision can affect documentation and the development schedule. An early regulatory review should establish:

• which list the project falls under;
• whether screening is needed;
• what documents accompany the application;
• which authority conducts the procedure;
• whether the decision may require an EIA study;
• how EIA fits with other permits and approvals.

This identifies regulatory risk before major investment decisions are locked in.

Screening documentation also changed in 2026

After the legal amendment, a further rulebook amended the requirements for documents submitted with an application for a decision on the need for an EIA study. It was published in Official Gazette 75/2026 and entered into force on 11 June 2026.

Investors and consultants should therefore check the current document list rather than reuse an old checklist. The process should follow the applicable law and secondary legislation.

The Nature Protection Law 117/2026 is an additional framework for projects that may affect species, habitats, protected areas or the ecological network. EIA assesses a wider range of project effects, while specific nature-protection conditions depend on the location. One procedure should not automatically be treated as a substitute for the other.

EIA and ISO 14001 are different mechanisms

EIA is a legal procedure for a particular project. ISO 14001 is an environmental management system for an organisation.

A company can hold ISO 14001 certification and still need an EIA procedure for a new project where the law requires one. Conversely, completing an EIA procedure does not mean the company has an ISO 14001 system.

EIA and an integrated permit are different procedures. EIA assesses the impact of a specific project before it is carried out; an integrated permit governs operation of an installation covered by industrial emissions rules. A project may require a check under both regimes, but one procedure does not replace the other. Regulation 75/2026 specifies the activities and capacities for integrated permits; see our guide to integrated permits for industrial installations.

Article 36 of Air Protection Law 117/2026 connects air-quality monitoring near relevant stationary sources with EIA documentation or an integrated permit. Data are due to the Agency and local authority by 31 March for the previous year. See the Air Protection Law guide.

EIA conditions should feed into ISO 14001

For a company already using ISO 14001, a new project may affect several parts of its environmental management system:

• organisational context;
• compliance obligations;
• environmental aspects;
• risks;
• operational controls;
• monitoring;
• response plans;
• environmental objectives.

Conditions arising from an EIA decision should be reflected in day-to-day management. A permit or approval should not remain an isolated document in the legal archive.

A new production line may require more than ISO change control

An industrial company may first consider a process change in terms of quality or production capacity. A substantial expansion, a new installation or different technology can also have EIA implications. Environmental compliance screening should therefore start early, before a modified process is installed or commissioned.

This is where ISO 14001 change management can connect to the statutory project-screening process.

Conditions in the study and decision must reach operations

An EIA process has limited value if its documents are used only to obtain a decision. Protective measures set out in project documents must reach the people who later manage construction and operations. Depending on the project, controls may concern:

• waste;
• water;
• emissions;
• noise;
• chemicals;
• soil protection;
• biodiversity;
• monitoring of relevant parameters.

The precise measures vary, but responsibility for carrying them out must be clear.

Buying an existing site does not remove environmental due diligence

A company may acquire an existing installation rather than build a new one. It should review the site's regulatory history, including earlier EIA decisions, approvals and conditions that still affect operations. If the new owner plans process changes, it should also check whether those changes alter the project's regulatory status.

What investors should check before a new project

Before finalising a technical and investment plan, review:

• the project's type and scale;
• its location;
• Lists I and II of the current regulation;
• the changes in Regulation 85/2026;
• whether screening is required;
• the current documents under Rulebook 75/2026;
• other environmental permits or approvals;
• effects on an existing ISO 14001 system;
• conditions that may result from an EIA process.

For renewable-energy projects, use the updated 2026 framework. Conclusions based on an older List II may no longer be reliable.

Not every ISO 14001 client needs EIA support

A company maintaining an office or simple service process does not need an EIA review simply because it uses ISO 14001. The issue arises when there is a project that may fall within EIA legislation. EIA should therefore be assessed according to the project and activity, not presented as a standard part of every ISO 14001 engagement.

ConsultHQ connects investment changes with the existing EMS

A company planning a new plant, an expansion or a relevant energy project needs to identify environmental compliance requirements early. Through a regulatory and ISO 14001 gap review, ConsultHQ can help establish how an investment affects existing obligations, environmental aspects and operational controls.

Where an EIA process requires formal project documentation or work reserved to authorised professionals, those tasks should be carried out by appropriately authorised specialists. Our role is to help the company carry the resulting requirements into the management system it uses to run the project and its operations.

Related services: ISO 14001 in Montenegro, ISO standards for factories and gap analysis.

Official sources: Official Gazette: Law amendment 70/2026; Official Gazette: Regulation 85/2026; Official Gazette: Rulebook 75/2026; Government: explanation of the List II changes.

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