Published: 25.09.2026. · HACCP

Mandatory personal hygiene training in Montenegro in 2026: who needs training and what does it cost?

Publisher: ConsultHQ

The Law on the Protection of the Population from Infectious Diseases requires personal hygiene training for certain employees working in premises subject to sanitary supervision and for employees who handle food. Employers must arrange the training before an employee starts covered work and repeat it every five years. The latest publicly reported price we found is €35 per employee.

For restaurants, hotels, food manufacturers and retailers, this is more than another document to add to a HACCP folder.

It is a separate legal obligation for employers.

In food businesses, it also connects to hygiene, employee competence and the HACCP system.

The current law took effect in January 2026

The legal basis is the Law on the Protection of the Population from Infectious Diseases, published in the Official Gazette of Montenegro, No. 2/2026.

The law was published on 9 January 2026 and entered into force on 17 January 2026. It is currently in force.

For businesses, Article 24 is particularly important because it regulates training in personal hygiene and measures to protect against infectious diseases.

It identifies who must complete the training, when it must take place, who may provide it, who issues the certificate and who pays for it.

Who must complete the training?

The law covers two important groups of employees.

The first comprises employees working in activities carried out in premises subject to sanitary supervision.

The second comprises employees working in premises where food is handled at any stage of production, processing or distribution.

In the food sector, this may include employees in:

• restaurants and other hospitality premises;
• hotels and hotel kitchens;
• food production and processing;
• food retail and distribution;
• food warehouses;
• other premises where employees work directly with food.

The 2022 rulebook also covers a wider range of premises subject to sanitary supervision, so the obligation is not confined to the food sector. The rulebook is still listed as being in force in Montenegro's legal information system.

A company should therefore check its activity and the duties of each role first.

Having a HACCP system is not the only consideration.

Employers must arrange training before work begins

Article 24 sets a clear timetable.

The employer must arrange training before an employee starts the covered work.

Training must then be repeated every five years while the employee works in those roles.

This is particularly important for seasonal employers.

A hotel, restaurant or retailer that hires many new people should not wait until the season starts to check their training status.

The check should be part of employee onboarding.

Certain highly qualified employees are exempt

The law provides specific exemptions.

The obligation does not apply to employees who have completed a level VIII1 educational qualification in the listed fields.

The specified study programmes include:

• medicine;
• pharmacy;
• dentistry;
• sanitary engineering;
• food safety;
• biochemistry;
• food technology;
• nutrition;
• biology;
• biotechnology;
• veterinary medicine.

Employers should therefore not automatically register every employee.

They should first check the role and the employee's relevant qualification.

Training is provided by the Institute of Public Health and eligible health centres

The 2026 law specifies who may provide the training:

• the Institute of Public Health of Montenegro;
• health centres with an organised hygiene and epidemiology service.

A certificate is issued after the training.

The employer must keep the certificate at the business premises where the activity is carried out and make it available to a sanitary inspector on request.

It is therefore inaccurate to say that only the Institute of Public Health can provide the training from 2026 onward.

The law also assigns this role to qualifying health centres.

How much does the training cost?

The law says that the employer pays for the training.

It does not, however, set a fixed training price.

The latest publicly reported amount we found is €35 per employee.

When the 2022 rulebook was introduced, the Chamber of Economy of Montenegro stated that training cost €35 for each employee with a sanitary health booklet, including seasonal workers.

The distinction matters:

€35 is a publicly reported training price, not a fee set by Article 24 of the law.

Before registering a large group, a company should check the current price list of the institution that will provide the training.

As of September 2026, we had not found a newer publicly available official price list confirming a different amount.

A €35 fee can add up for seasonal employers

For a handful of employees, the cost may be modest.

For a hotel, restaurant or retailer with dozens or hundreds of employees, it is a different matter.

For example, if 100 employees need training, the last publicly reported price of €35 would amount to €3,500, before any other costs relating to sanitary documentation and medical examinations.

This is why the Chamber of Economy described the obligation in 2022 as a significant additional cost for companies with large workforces.

Seasonal businesses should prepare a list of employees covered by the obligation in advance.

This also helps avoid registering people who qualify for a legal exemption.

Must documents be certified by a notary?

Precision matters here.

The 2022 rulebook on the training programme sets out a more detailed process and is still listed as being in force.

The application requirements refer to certified copies of certain documents.

The rulebook uses the term “certified copy”.

It does not say that a document must be certified exclusively by a notary.

Notarial certification is one common way to obtain a certified copy, but a business article should not claim the law expressly requires a notary when it does not use that wording.

Before submitting documents, check the current instructions of the institution providing the training.

Why the 2022 rulebook still matters

The new law was adopted in 2026, but the existing secondary legislation also governs the detailed training procedure.

The Rulebook on the Training Programme for Acquiring Basic Knowledge of Personal Hygiene and Measures to Protect Against Infectious Diseases and the Manner of Its Implementation was published in the Official Gazette of Montenegro, No. 29/2022.

Montenegro's legal information system currently lists it as being in force.

Companies should therefore look beyond Article 24 of the new law.

They should also follow the secondary rules on how training is carried out and any new rules issued by the Ministry of Health under the 2026 law.

This is not a new HACCP or ISO standard

The training obligation is not an ISO standard.

Nor is it a new “HACCP certificate”.

It is a legal obligation under the rules on protecting the population from infectious diseases.

For food businesses, however, it is closely connected to food hygiene and employee competence.

EU Regulation (EC) No. 852/2004 requires appropriate supervision, instruction and/or training of food handlers for the work they perform.

Montenegro's 2026 Food Hygiene Regulation brings this European hygiene framework into the national system.

The mandatory training under Article 24 and HACCP are therefore separate requirements.

A well-designed system should connect them in practice.

How it connects to HACCP

The training rulebook covers topics directly relevant to food handling.

They include personal hygiene, contamination prevention, cleaning and disinfection, pest control, food hygiene and the HACCP system.

However, the certificate issued after this training does not replace HACCP implementation.

Nor does it replace the specialist training needed by people who develop, maintain or verify a HACCP system when their responsibilities call for deeper knowledge.

Employers should include the mandatory training in their wider employee competence matrix.

How it connects to food safety culture

The modern European hygiene framework goes beyond the formal existence of procedures.

Regulation (EU) 2021/382 explicitly introduced food safety culture requirements.

These focus on employee awareness, clear responsibilities, communication, suitable supervision and management commitment.

For a company, this means the training certificate is not the end goal.

Employees need to understand the rules relevant to their role and apply them in daily work.

This should later be checked through internal HACCP reviews and day-to-day supervision.

A sanitary health booklet and a training certificate are different documents

This distinction is important for employers.

A medical examination and sanitary health booklet are one type of obligation.

Personal hygiene training and the certificate under Article 24 are another.

Neither document should automatically be treated as a substitute for the other.

Employee records should therefore show which requirements apply to each role and whether each one has been met.

Penalties can be much higher than the cost of training

The new law provides for liability for breaches of several duties relating to the prevention of infectious diseases.

These include duties connected with providing and documenting the required training.

The training fee should therefore not be viewed in isolation.

The greater business risk is being unable to show that employees covered by the obligation received the required training.

What employers should check now

Food businesses and organisations operating in premises subject to sanitary supervision should review their workforce.

They need to establish:

• which roles fall under Article 24;
• which employees have a statutory exemption;
• who already holds an appropriate certificate;
• when each certificate was obtained;
• whose five-year interval is approaching;
• whether new employees complete training before starting covered work;
• where certificates are kept;
• whether sanitary health booklets are managed separately where required;
• what documents the training provider currently requires for registration;
• the current training price.

Seasonal employers should make this review part of their preparations before hiring large numbers of staff.

Include the training in an existing HACCP system

A business that already has HACCP does not need to manage this obligation in complete isolation.

Employee training status can be linked to:

• onboarding;
• competence records;
• HACCP training;
• employees' sanitary health status;
• internal checks;
• the annual training plan.

This gives management a single overview instead of several unrelated spreadsheets.

It also reduces the risk of missing a renewal date or allowing a new employee to start without the required training.

ConsultHQ can help review obligations and documentation

The 2026 law covers more than the food sector, while the details depend on the activity and the employee's role.

Before registering a large group, it makes sense to determine who is actually covered.

ConsultHQ can connect the workforce review with an existing HACCP, hygiene and competence management system.

For restaurants, hotels and food manufacturers, we can also review relevant training records, HACCP documentation and preparation for official inspection.

The goal is not to create another layer of administration.

The goal is for employers to know at all times who must be trained, what evidence they need and when training is due again.

Related services: HACCP implementation, employee training and HACCP for restaurants.

Sources: Law, Official Gazette 2/2026; Rulebook, Official Gazette 29/2022; Chamber of Economy: €35 (2022); Food Hygiene Regulation (2026); EU 2021/382.

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