Published: 25.09.2026. · ISO 14001

Montenegro's new Air Protection Law 2026: what companies should check

Publisher: ConsultHQ

The new Air Protection Law updates emissions permits, monitoring, records and control of stationary sources under a more recent EU framework.

Montenegro has applied the new Air Protection Law (Official Gazette 117/2026) since 15 August 2026. It updates the framework for emissions control, permits, monitoring and records for legal entities and entrepreneurs whose activities affect or may affect air quality, while bringing national rules closer to current EU legislation.

For industrial businesses, this extends beyond the main chimney. Permit status, emissions measurements, stationary-source registers, plant modifications, fuel use and the operation of emission-control equipment may all be affected. Organizations using ISO 14001 should therefore review whether the new law belongs in their register of applicable compliance obligations.

Law 117/2026 has applied since 15 August

The Air Protection Law was published in Official Gazette 117/2026 on 7 August and entered into force on 15 August 2026. It repealed the previous Air Protection Law 25/10 and its amendments, including 43/15.

A correction to the new law was published in Official Gazette 120/2026 on 12 August. Companies should work from the current law and correction, rather than drafts or older texts still available online.

The law reflects a more recent EU air-quality framework

The current law incorporates several EU instruments, including Directive (EU) 2024/2881 on ambient air quality and cleaner air for Europe, Directive 2016/2284 on national emission reductions, and Directive 2015/2193 on medium combustion plants.

When presenting the law, the Government also described updated monitoring methods, modelling, air-quality plans, digital registers, electronic reporting and a revised emissions-permit system. For operators, the immediate question is which of the law's duties apply to their actual activities and sources.

Businesses that may affect air quality have specific duties

Article 45 addresses legal entities and entrepreneurs whose activities affect or may affect air quality. They must provide technical measures to prevent or reduce emissions, account for air-protection costs within investment and production costs, keep records of expenditure and monitor the effect of their activities on air quality, alongside other applicable measures.

Air protection is therefore an operational and investment issue as well as an environmental one. It can shape equipment design, maintenance, budgets, monitoring and decisions on plant changes.

The emissions permit is a central question for relevant sources

Article 45 generally requires covered operators to obtain an emissions permit from the Environmental Protection Agency. The permit is based on emission limit values for stationary sources.

There is an important exception: an operator is not required to obtain this separate emissions permit if other regulations require it to obtain an integrated permit or environmental impact assessment consent. The applicable regime must be checked for the particular installation before submitting an application. The regimes should not be assumed to require duplicate permits.

Stationary sources need records and monitoring

Article 46 sets out duties for owners and users of stationary pollution sources. They must record the source and every modification, ensure regular emissions monitoring and measurement, and retain information on measurement points, results and frequency.

The required records also cover:

• fuel consumed;
• waste generated during combustion;
• operation of emission-reduction equipment.

For an ISO 14001 system, these records should connect to operational controls, monitoring and named responsibilities. A separate spreadsheet created solely for an inspection is less useful than records maintained during routine operation.

A plant modification should trigger a regulatory check

Article 46 expressly requires records of each change or reconstruction of a stationary source. A new furnace, burner or filter, a capacity increase or another technical change can alter an installation's emissions profile.

Investment approval should therefore involve an environmental review before commissioning. The responsible team should assess whether a permit, monitoring programme or other legal duty changes.

Air-quality monitoring may connect to EIA or an integrated permit

For stationary sources subject to environmental impact assessment, or for which an assessment may be required, Article 36 links nearby air-quality monitoring to the EIA documentation or integrated permit. Monitoring data are sent to the Agency and the relevant local authority by 31 March for the previous year; the polluter bears the monitoring costs.

EIA, integrated permitting and air protection should therefore be reviewed together for an affected installation, even though they are separate legal procedures.

Emissions measurements need a controlled method

The law authorizes the Ministry to specify how emissions from stationary sources are monitored, how measurements are taken, how measuring equipment is checked and calibrated, how results are assessed and how data are submitted to the air-quality information system.

Until the new implementing rules are adopted, existing subordinate rules continue to apply where they do not conflict with the new law. The law provides a two-year period for adoption of new subordinate acts. Operators should track both the new statute and the technical rules that remain in use during the transition.

Qualified laboratories matter when proving emissions compliance

Air-quality, stationary-source emissions and fuel-quality monitoring may be carried out by legal entities holding the relevant Agency authorization based on accreditation. A formal emissions measurement is more than a number provided by a maintenance contractor.

When regulated monitoring is required, the operator should check the provider's authorized scope, measurement method and report. The laboratory is a regulatory service provider whose suitability should be verified.

Fuel users may have additional duties

Legal entities and entrepreneurs placing fuel on the market or purchasing it for their own needs must keep fuel-quantity records and submit the data to the Agency by 31 March for the previous year. They must also arrange fuel-quality monitoring and reporting under the relevant implementing rule.

The requirement will not affect every business in the same way. Industrial operators buying substantial quantities of fuel for their own installations should check its application to their operations.

Medium combustion plants fall within a more recent EU framework

The law incorporates Directive 2015/2193 on emissions from medium combustion plants. This may matter for boilers, gas turbines and other combustion installations that fall within the relevant scope.

Air-quality conditions in a particular area may also lead to tighter emission requirements for covered medium plants. Maintenance and energy teams should participate in the regulatory review.

Inspectors may temporarily prohibit operation of a source

Inspectors can order corrective measures and additional measurements if a stationary source operates contrary to the law or exceeds applicable emission limits. The law also provides for temporary prohibition of operation until a problem is resolved.

For a manufacturer, the cost of non-compliance can therefore include production downtime as well as a fine.

Fines for legal entities can reach EUR 40,000

For specified offences, a legal entity can be fined between EUR 2,000 and EUR 40,000. Examples include failing to obtain a required emissions permit, failing to arrange regular emissions measurements, failing to keep required records and failing to submit specified data.

The law also provides fines of EUR 500–4,000 for a responsible individual and EUR 1,000–12,000 for an entrepreneur. The seriousness, duration, consequences, repetition and possible economic benefit of a breach are relevant when assessing a penalty.

ISO 14001 and the Air Protection Law serve different purposes

ISO 14001 provides a management system for environmental aspects, compliance obligations, monitoring and continual improvement. The Air Protection Law imposes specific legal duties. An ISO 14001 certificate does not replace an emissions permit or a required measurement.

A functioning environmental management system can, however, show which permit applies, when to measure, who is responsible, where reports are kept and what happens when a result is outside limits. This is where ISO 14001 becomes useful in daily operations.

The environmental-aspects register should reflect real emission sources

An ISO 14001 organization should know which of its processes release pollutants into the air. Depending on the business, relevant sources may include combustion, process emissions, organic solvents, fuel storage and more than the main production stack.

The environmental-aspects register should connect to the legally required record of stationary sources, so the management system and the statutory register support each other.

Permits belong in the compliance-obligations register

An emissions permit should not be a document known only to one employee. The ISO 14001 system should identify:

• which permit applies and to which source;
• the emission limits it sets;
• the monitoring it requires;
• reporting duties and deadlines;
• the person responsible for each condition.

This makes compliance status auditable through internal review and management processes.

Review air obligations before a process change goes live

A new product, increased capacity, different fuel or changed technology may alter emissions. Industrial change control should include an environmental review before final project approval and commissioning, rather than after the first measurement from an operating installation.

An early review reduces the risk of costly technical changes later.

What companies should check now

Industrial companies should review their position under the law in force since 15 August 2026. A practical review covers:

• every stationary emission source;
• existing emissions permits, integrated permits and applicable EIA conditions;
• source changes and reconstructions;
• the measurement plan, frequency and laboratory authorization;
• measurement results and other required records;
• fuel consumption and operation of emission-control equipment;
• reporting deadlines and ISO 14001 compliance obligations;
• subordinate rules that remain applicable during the transition.

Each company needs an assessment of its real regulatory scope, not the same package of permits.

The law does not automatically require a new environmental system

The new statute does not invalidate a well-functioning ISO 14001 system. Where emissions are already controlled, much of the process can remain in place. A targeted regulatory gap review can identify the affected obligations, permits, records and procedures, then update only what is needed.

ConsultHQ can connect the law with your ISO 14001 system

An organization with a working environmental management system generally needs its permits, monitoring, records and process changes connected to responsibilities already used in daily work, rather than a parallel emissions system.

ConsultHQ can review existing sources and documentation against Law 117/2026, its applicable correction and relevant implementing rules through an ISO 14001 and regulatory gap assessment. The aim is to identify which controls already work, which duties actually apply and where gaps remain before the next audit or inspection.

Related pages: ISO 14001 in Montenegro, ISO standards for factories, gap analysis, integrated permits and environmental impact assessment.

Official sources: Official Gazette: Law 117/2026; Official Gazette: Correction 120/2026.

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